OMB No. 2010-0032 Expiration Date 01/10/2010

Performance Track Membership Renewal Application 2007 3M ESPE 3M Company Member since 2001 A090016

		Baseline	Future
4a	Please provide information for these calendar years.	2006	2009
4b	What units are you using to quantify this indicator?	Pounds
4c	List the baseline annual quantity of the indicator and the annual quantity you are commited to achieve by the future year.	4,462	2,677

5	Does the quantity presented in the future quantity column represent an absolute goal or a normalized goal?	Normalized goal (i.e. indexed to level of business in        baseline year)
6	Whether your goal is absolute or normalized, in your annual performance reports you will need to provide normalizing factors and normalized quantities of your annual data. In the textbox to the right, please briefly describe your basis for normalizing. Examples of potential normalizing bases include:      -gallons of paint produced -square feet of circuit boards sold -number of patients seen -dollars of sales adjusted for inflation -number of employees (for R&D and administrative sites only)	The goal is normalized based upon production (pounds) of dried, intermediate filler materials where the acetic acid emissions occur.
7a	Are you subject to Federal, State, Tribal, or local regulatory requirements for this indicator?	No
7b	If yes, please list those requirements, including the quantitative limits and compliance deadlines that apply to you. Explain how your commitment exceeds requirements.

Commitment 3

1a	What category have you selected from the Environmental Performance Table?	Waste
1b	What indicator have you selected from the Environmental Performance Table?	Hazardous waste generation
1c	Does your commitment include everything covered by the indicator (e.g., all VOCs, all non-hazardous waste), or a specific substance or component (e.g., ethane, cardboard)?All measurements should represent the performance level for the indicator across the entire facility. For many indicators, however, you may choose to focus your commitment on a specific subset of the indicator, e.g. a specific material, a specific group of toxic air emissions, a particular waste component, a specific VOC, etc.	Specific
	If your commitment is to a specific substance or component, please provide additional detail on your indicator (e.g., specific chemical to be reduced, specific waste component).	3M ESPE commits to a reduction of 20 percent in ethanol-containing hazardous waste generated during the production of dental adhesive materials produced through a (proprietary) solvent-exchange process. The metric for this goal is facility-wide ethanol waste generation.
1d	What activities or process changes do you plan to undertake at your facility to accomplish your commitment e.g., technology changes in a particular process line, employee training?	The facility has not yet decided upon a specific strategy. Possible strategies include process change, on-site beneficial reuse of the ethanol waste material, and replacement of a solvent recovery system with a regenerative thermal oxidizer. Presently, condensed solvents are collected as a hazardous waste. The waste is, ultimately, incinerated to recover the energy content of the material. By replacing the condensor with a thermal oxidizer, solvent vapors will not be condensed and hazardous waste will not be generated. In a regenerative oxidizer, the heat content is also recovered and used to heat the oxidizer bed.
2	Are you proposing this as a Challenge Commitment?	No
3a	Does this commitment address a significant aspect in your EMS?	Yes
3b	If no, please explain why you believe this indicator should be included as a performance commitment.

In the table below, please enter your facility's amount of hazardous waste, broken down by waste management method. Please enter both the amounts that you manage currently and that you intend to manage in 2009. Include all hazardous waste that is treated on-site or sent off-site.

Is the goal of your hazardous waste commitment to reduce hazardous waste, to improve methods of waste management, or a combination of both?		Reduce Hazardous Waste
4a	Please provide information for these calendar years.	Baseline: 2006	Future: 2009
4b	Method of Waste Management	How much of your hazardous waste is handled using each management method?
		Baseline	Future	Units
Incineration		13,905	11,124	Pounds
Total Hazardous Solid Waste		6.95	5.56	Tons

5	Does the quantity presented in the future quantity column represent an absolute goal or a normalized goal?	Normalized goal (i.e. indexed to level of business in        baseline year)
6	Whether your goal is absolute or normalized, in your annual performance reports you will need to provide normalizing factors and normalized quantities of your annual data. In the textbox to the right, please briefly describe your basis for normalizing. Examples of potential normalizing bases include:      -gallons of paint produced -square feet of circuit boards sold -number of patients seen -dollars of sales adjusted for inflation -number of employees (for R&D and administrative sites only)	This goal is normalized based upon production (pounds) of dental adhesives produced utilizing the above process.
7a	Are you subject to Federal, State, Tribal, or local regulatory requirements for this indicator?	No
7b	If yes, please list those requirements, including the quantitative limits and compliance deadlines that apply to you. Explain how your commitment exceeds requirements.

Commitment 4

1a	What category have you selected from the Environmental Performance Table?	Energy Use
1b	What indicator have you selected from the Environmental Performance Table?	Total (non-transportation) energy use
1c	Does your commitment include everything covered by the indicator (e.g., all VOCs, all non-hazardous waste), or a specific substance or component (e.g., ethane, cardboard)?	All
1d	What activities or process changes do you plan to undertake at your facility to accomplish your commitment e.g., technology changes in a particular process line, employee training?	Installation of more energy-efficient new and replacement production equipment; other improvements in process yields and energy efficiency; improvements in lighting, heating, and cooling efficiencies. (See Commitment No. 1 for a further description of the normalization basis for this goal.)
2	Are you proposing this as a Challenge Commitment?	No
3a	Does this commitment address a significant aspect in your EMS?	Yes
3b	If no, please explain why you believe this indicator should be included as a performance commitment.

4a	Is the goal of your energy use commitment to reduce total energy use, to use or invest in renewable energy fuel sources, or a combination of both?	Reduce Total Energy Use
4b	Please provide information for these calendar years.	Baseline: 2006	Future: 2009

4c	How much energy does your facility obtain from off-site sources?
Electricity Purchased		Baseline: 2006	Future: 2009	Units
	Electricity from Grid/Utility	6,150,918	5,843,372	Kwh
	Electricity from Off-Grid Renewable Sources	0	0
	Total Electricity Purchased	20,986.93	19,937.59	MMBtus
	If your facility purchases electricity from the grid, please identify your facility's electricity geographic region.	WECC California
Steam
Total Energy Generated Off-Site		20,986.93	19,937.59	MMBtus

4d	How much energy of each type does your facility generate on-site?	Baseline: 2006	Future: 2009	Units
Coal
Natural Gas		956	956	MMBtus
Crude Oil
Fuel Oil
Diesel
Propane/LPG
Gasoline
Hydrogen Powered Fuel Cells
Natural Gas / Methane Powered Fuel Cells
Biomass
Biodiesel
Solar
Wind
Landfill Gas
Geothermal
Hydroelectric
Tire Derived Fuel
Other Fuel or Source Specify:
Total Energy Generated On-Site		956.00	956.00	MMBtus

4e	Total Energy Use and Associated Greenhouse Gas Emissions
Total Renewable Energy Use		5,307.60	5,042.22	MMBtus
Total Non-Renewable Energy Use		16,635.34	15,851.37	MMBtus
Total Energy Use		21,942.93	20,893.59	MMBtus
Metric Tons of CO2 Equivalents		2,295.66	2,183.41	MTCO2E
Metric Tons of CO2 Equivalents Offset due to Investments in Green Energy, e.g. green tags				MTCO2E
Net Metric Tons of CO2 Equivalents		2,295.66	2,183.41	MTCO2E

5	Does the quantity presented in the future quantity column represent an absolute goal or a normalized goal?	Normalized goal (i.e. indexed to level of business in        baseline year)
6	Whether your goal is absolute or normalized, in your annual performance reports you will need to provide normalizing factors and normalized quantities of your annual data. In the textbox to the right, please briefly describe your basis for normalizing. Examples of potential normalizing bases include:      -gallons of paint produced -square feet of circuit boards sold -number of patients seen -dollars of sales adjusted for inflation -number of employees (for R&D and administrative sites only)	The goal is normalized based upon inflation-adjusted, facility-wide production expressed as sales value of production.
7a	Are you subject to Federal, State, Tribal, or local regulatory requirements for this indicator?	No
7b	If yes, please list those requirements, including the quantitative limits and compliance deadlines that apply to you. Explain how your commitment exceeds requirements.

Section C Attachments (if applicable):

Section E: Self-Certification of Continued Program Participation On behalf of 3M ESPE, I certify that: I have read and agree to the terms and conditions for Membership Renewal and Participation in the National Environmental Performance Track, as specified in the National Environmental Performance Track Program Guide and in the Renewal Application Instructions; I have personally examined and am familiar with the information contained in this Renewal Application. The information contained in this Renewal Application is, to the best of my knowledge and based on reasonable inquiry, true, accurate, and complete, and I have no reason to believe the facility would not meet all program requirements; My facility has an environmental management system (EMS), as defined in the Performance Track EMS requirements, including systems to maintain compliance with all applicable Federal, State, tribal, and local environmental requirements in place at the facility, and the EMS will be maintained for the duration of the facility's participation in the program My facility has conducted an objective assessment of its compliance with all Federal, State, tribal, and local environmental requirements, and the facility has corrected all identified instances of potential or actual noncompliance; Based on the foregoing compliance assessment and subsequent corrective actions (if any were necessary), my facility is, to the best of my knowledge and based on reasonable inquiry, currently in compliance with applicable Federal, State, tribal, and local environmental requirements. I agree that EPA's decision whether to accept participants into or remove them from the National Environmental Performance Track is wholly discretionary, and I waive any right that may exist under any law to challenge EPA's acceptance or removal decision. I am the senior facility manager and fully authorized to execute this statement on behalf of the corporation or other legal entity whose facility is applying to this program.

Signature/Date:	______________________________________________________
Name:	Mr.  Ed Cardenas
Title:	Plant Manager
Phone Number:	(949) 863-1360
E-Mail Address:	ecardenas@mmm.com
Facility Name:	3M ESPE
Facility Street Address:	2111 McGaw Ave Irvine, CA 92614
Mailing Address:
Address cont:
City, State Zip:	,
Member ID#:	A090016

Environmental Requirements Checklist

Facility Identification Information
1.	Do you have a RCRA identification number? (A RCRA number is used in the RCRAInfo database for Resource Conservation and Recovery Act (RCRA) programs).
	Yes
	RCRA ID: CAD084160407
2.	Do you have a TRI identification number? (A TRI number is used in the Toxics Release Inventory (TRI) for Emergency Planning and Community Right-to-Know Act).
	No
	TRI ID:
3.	Do you have an AFS identification number? (An AFS number is used in the AIRS Facility Subsystem of the Aerometric Information Retrieval System (AIRS) for Clean Air Act programs).
	No
	AFS ID:
4.	Do you have a PCS/NPDES identification number? (A PCS/NPDES number is used in the Permit Compliance System (PCS) for Clean Water Act programs monitoring National Pollutant Discharge Elimination System (NPDES) permits).
	No
	PCS/NPDES ID:
5.	Do you have a FIFRA identification number? (A FIFRA number is given to facilities regulated by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)).
	No
	FIFRA ID:
Air Characteristics
1.	Is your facility a State Air Permit Holder?
	Yes
2.	Is your facility a Clean Air Act Major Source?
	No
3.	Is your facility a Clean Air Act Synthetic Minor Source?
	No
4.	Is your facility a Clean Air Act Minor Source?
	Yes
5.	Is your facility subject to New Source Performance Standards (NSPS)?
	No
	If so, which NSPS are you subject to?
6.	Is your facility subject to National Emissions Standards for Hazardous Air Pollutants (NESHAPS)?
	No
7.	Is your facility subject to Section 112/Maximum Achievable Control Technology (MACT) standards?
	No
	If so, which MACT standard(s) are you subject to?
8.	Is your facility subject to SIP (State Implementation Plan) requirements (including Reasonably Available Control Technology (RACT))?
	Yes
	If so, which SIP requirement(s) are you subject to?minor-source NSR, BACT
9.	Is your facility a Title V permit holder?
	No
10.	Is your facility subject to Section 129 combustion requirements?
	No
11.	Is your facility subject to National Ambient Air Quality Standards (NAAQS)?
	No
	If so, which NAAQS are you subject to?
12.	List relevant state/local/tribal/other air requirements: (If none, please enter "n/a".)
	South Coast Air Quality Management District (SCAQMD) rules and regulations
Water Characteristics
1.	Is your facility a State Water Permit Holder?
	No
2.	Is your facility Required to Pretreat?
	No
3.	Is your facility a National Pollutant Discharge Elimination System (NPDES) Permit Holder?
	No
4.	Is your facility subject to Phase I of the NPDES Storm Water Program?
	No
5.	Is your facility subject to Phase II of the NPDES Storm Water Program?
	No
6.	Is your facility subject to the Spill Prevention Control and Counter Measure (SPCC) requirements of the Clean Water Act?
	No
7.	Is your facility subject to industry specific effluent guidelines and standards?
	No
	If so, which guidelines and standards are you subject to?
8.	List relevant state/local/tribal/other water requirements: (If none, please enter "n/a".)
	California (state)/City of Irvine stormwater general permit requirements; Orange County (Sanitation District) discharge ordinances ("non-significant" discharger); categorical process "zero discharge" certification requirements.
Hazardous Waste Characteristics
1.	Is your facility a Large Quantity Generator?
	Yes
2.	Is your facility a Small Quantity Generator?
	No
3.	Is your facility a Conditionally Exempt Small Quantity Generator?
	No
4.	Is your facility a Treatment, Storage, or Disposal (TSD) Facility?
	No
5.	List relevant state/local/tribal/other hazardous waste requirements: (If none, please enter "n/a".)
	California Health & Safety Code regulations pertaining to waste identification/characterization, accumulation and management.
Environmental Clean-Up, Restoration, and Corrective Action Characteristics
1.	Is your facility a Potentially Responsible Party under CERCLA or Superfund for onsite clean-up?
	No
	If so, please provide Record of Decision date:
2.	Is your facility a Potentially Responsible Party under CERCLA or Superfund for offsite clean-up?
	No
	If so, please provide Record of Decision date:
3.	Is your facility a Potentially Responsible Party in a federal or state clean-up of hazardous waste and/or oil?
	No
4.	Is your facility Engaged in RCRA corrective action?
	No
5.	List other relevant federal/state/tribal/local environmental clean-up, restoration, or corrective actions not listed above. Please include date(s) of any remedy decisions. (If none, please enter "n/a".)
	N/A
Other Environmental Characteristics
1.	Is your facility a Toxic Release Inventory (TRI) Reporter?
	No
2.	Is your facility regulated under the Safe Drinking Water Act?
	No
3.	Is your facility subject to Underground Storage Tank (UST) Regulations?
	No
4.	Is your facility regulated under Toxic Substances Control Act (TSCA)?
	No
5.	Is your facility subject to Worker Right-to-Know Regulations?
	Yes
6.	Is your facility required to file an emergency management plan under the Emergency Planning and Community Right-to-Know Act (EPCRA)?
	Yes
7.	Is your facility regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)?
	No
8.	List relevant state/local/tribal/other requirements: (If none, please enter "n/a".)
	The facility manufactures dental products that are regulated by FDA and generally exempted from TSCA regulations. Potential TCSA applicability is limited to only a small number of non-production incidential chemical usages. The facility is required to submit hazardous materials disclosure and a California Hazardous Material "Business Plan" to comply with EPCRA Sections 311 and 312.