3M Company (Board decision, February 7, 2022)
In re 3M Company (EAB CAA 22-01C): self-disclosed air-pollution violations settled
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This is citable Board precedent from 2022, and it may have been appealed since. Ezel checks how it stands today and answers your situation, with citations.
Plain-English summary
3M Company conducted a corporate audit of environmental compliance at its manufacturing facilities and voluntarily disclosed violations involving notification, reporting, recordkeeping, inspection, performance testing, monitoring, work practices, and emission standards. The agreement says the disclosures covered New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants at facilities in multiple states. The penalty in this proceeding was based on alleged violations of the miscellaneous coating manufacturing requirements at 3M's Nevada, Missouri facility, involving two process vessels and conduct described as occurring between December 16, 2011, and December 16, 2016. The EAB ratified the settlement and approved a $170,000 civil penalty, while the agreement states that the Audit Policy eliminated the gravity-based component of the penalty. 3M admitted EPA's jurisdiction, consented to the penalty, and waived its right to contest the alleged violations and appeal the order.
Decision snapshot
- Cited authorities: 40 C.F.R. §§ 22.4, 22.13, 22.18, 60, 63.8000, and 63.8005; 42 U.S.C. §§ 7411, 7412, and 7413
- Outcome: The Consent Agreement and Final Order were ratified, and a $170,000 civil penalty was approved.
- Key point: EPA's Audit Policy can reduce a self-disclosed enforcement settlement's gravity-based penalty component when its conditions are satisfied, while the settlement can still require payment of the economic benefit attributed to the violations.
Full text (EPA EAB public release)
F I L E D
Feb 07, 2022
Clerk, Environmental Appeals Board
ENVIRONMENTAL APPEALS BOARD INITIALS ________________________
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
In re: )
) Docket No. CAA-HQ-2022-8420
3M Company )
)
)
)
FINAL ORDER
Pursuant to 40 C.F.R. § 22.18(b)-(c) of EPA’s Consolidated Rules of Practice, the
attached Consent Agreement resolving this matter is incorporated by reference into this Final Order and is hereby ratified.
The Respondent is ORDERED to comply with all terms of the Consent Agreement,
effective immediately.
So ordered. 1
ENVIRONMENTAL APPEALS BOARD
Dated: ____
Feb 07, 2022 ______
Aaron P. Avila
Environmental Appeals Judge
1
The three-member panel ratifying this matter is composed of Environmental Appeals
Judges Aaron P. Avila, Mary Kay Lynch, and Kathie A. Stein.
BEFORE THE ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
In the Matter of:
3M Company, Docket No. CAA-HQ-2022-8420
Respondent.
CONSENT AGREEMENT
A. PRELIMINARY STATEMENT
1. This is an administrative penalty assessment proceeding brought under Section 113(d)
), 42 U.S.C. § 7413(d), and Sections 22.13
and 22.18 of the Consolidated Rules of Practice Governing the Administrative
Assessment of Civil Penalties and the Revocation/Termination or Suspension of
C.F.R. Part 22.
2. Complainant is the United States Environmental Protection Agency
behalf, Mary E. Greene, Director, Air Enforcement Division, is delegated the
authority to settle civil administrative penalty proceedings under Section 113(d) of
the Act.
3. Respondent is a Delaware corporation headquartered in Saint
Paul, Minnesota. as defined in Section 302(e) of the Act,
42 U.S.C. § 7602(e).
4. Complainant and Respondent , having agreed that settlement
of this action is in the public interest, consent to the entry of this consent agreement
agrees to comply with the terms of this Consent Agreement and Final Order.
B. JURISDICTION
5. This Consent Agreement is entered into under Section 113(d) of the Act, as amended,
42 U.S.C. § 7413(d), and the Consolidated Rules, 40 C.F.R. Part 22.
6. The EPA and the United States Department of Justice jointly determined that this
matter, although it involves alleged violations that occurred more than one year
before the initiation of this proceeding, is appropriate for an administrative penalty
assessment. 42 U.S.C. § 7413(d).
7. The Environmental Appeals Board is authorized to ratify this Consent Agreement,
which memorializes a settlement between Complainant and Respondent. 40 C.F.R.
§§ 22.4(a) and 22.18(b).
8. The issuance of this Consent Agreement and attached Final Order simultaneously
commences and concludes this proceeding. 40 C.F.R. § 22.13(b).
C. GOVERNING LAW
9. As discussed in further detail in Section D, this matter concerns several different
regulations promulgated by the EPA. However, the penalty at issue in this Consent
Agreement is only based on alleged violations of 40 C.F.R. Part 63, Subpart HHHHH
- National Emissions Standards for Hazardous Air Pollutants: Miscellaneous Coating
Manufacturing.
CAA NSPS 40 C.F.R. Part 60
10. Section 111(b)(1)(A) of the CAA, 42 U.S.C. § 7411(b)(1)(A), requires the
Administrator to publish a list of categories of stationary sources that cause or
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 2 of 18 contribute significantly to air pollution that may reasonably be anticipated to
endanger the public health or welfare and promulgate standards of performance for
new sources within those categories.
11. These standards, commonly known as the New Source Performance Standards
( NSPS ), are codified at 40 C.F.R. Part 60.
12. Section 111(e) of the CAA, 42 U.S.C. § 7411(e), prohibits an owner or operator from
operating any new source in violation of an NSPS after the effective date of the NSPS
applicable to such source.
13. Pursuant to Section 111(b) of the CAA, the Administrator promulgated the following
NSPSs, which are relevant to this matter:
(a) Subpart RR - Standards of Performance for Pressure Sensitive Tape and Label
Surface Coating Operations, codified at 40 C.F.R. §§ 60.440-60.447;
(b) Subpart UUU - Standards of Performance for Calciners and Dryers in Mineral
Industries, codified at 40 C.F.R. §§ 60.730-60.737;
(c) Subpart VVV - Standards of Performance for Polymeric Coating of Supporting
Substrates Facilities, codified at 40 C.F.R. §§ 60.740-60.748; and
(d) Subpart IIII - Standards of Performance for Stationary Compression Ignition
Internal Combustion Engines, codified at 40 C.F.R. §§ 60.4200-60.4219.
CAA NESHAP 40 C.F.R. Part 63
14. Section 112 of the CAA, 42 U.S.C. § 7412, ational
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 3 of 18 15. Pursuant to Sections 112(c) and (d) of the CAA, 42 U.S.C. §§ 7412(c), (d), the
Administrator has listed categories and subcategories of major sources of HAPs and
promulgated regulations establishing emissions standards and/or work practices
applicable to major sources of HAPs in each such category or subcategory, which are
codified at 40 C.F.R. Parts 61 and 63.
16. Section 112(i)(3) of the CAA, 42 U.S.C. § 7412(i)(3), provides that after the effective
date of any emissions standard, limitation, or regulation promulgated pursuant to
Section 112, no person may operate a source in violation of an applicable NESHAP
regulation.
17. Pursuant to Section 112 of the CAA, 42 U.S.C. § 7412, the Administrator
promulgated the following NESHAPs, which are relevant to this matter:
(a) Subpart JJJJ - National Emission Standards for Hazardous Air Pollutants: Paper
and Other Web Coating, codified at 40 C.F.R. §§ 63.3280-63.3420;
(b) Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for
Major Sources: Industrial, Commercial & Institutional Boilers and Process
Heaters codified at 40 C.F.R. §§ 63.7480-63.7575;
(c) Subpart HHHHH - National Emission Standards for Hazardous Air Pollutants:
Miscellaneous Coating Manufacturing, codified at 40 C.F.R. §§ 63.7980-63.8105;
and
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 4 of 18 (d) Subpart VVVVVV - National Emission Standards for Hazardous Air Pollutants
for Chemical Manufacturing Area Sources, codified at 40 C.F.R. §§ 63.11494-
63.11503.
CAA NESHAP 40 C.F.R. Part 63, Subpart HHHHH National Emission Standards for Hazardous Air Pollutants: Miscellaneous Coating Manufacturing
18. As relevant to the penalty at issue in this matter, the Administrator promulgated
requirements regarding the emission limits and work practice requirements for new
and existing miscellaneous coating manufacturing operations on December 11, 2003.
See 68 Fed. Reg. 69,185. These requirements are found at 40 C.F.R. Part 63, Subpart
HHHHH - National Emissions Standards for Hazardous Air Pollutants:
Miscellaneous Coating Manufacturing.
19. Among other requirements, 40 C.F.R. § 63.8000 requires owners and operators of
miscellaneous coating manufacturing operations to comply with the emission limits
and work practice standards set forth in Tables 1 through 5 of Subpart HHHHH at all
times, except during periods of startup, shutdown, and malfunction. In addition,
40 C.F.R. § 63.8005 sets forth specific requirements for process vessels.
D. STIPULATED FACTS
20. Respondent 3M is a manufacturer of industrial, safety, and consumer products and is
incorporated under the laws of the State of Delaware. Respondent has its headquarters
in Saint Paul, Minnesota.
21. On May 2, 2012, the 2 proposal to enter
into a voluntary Corporate Audit Agreement to audit all 3M manufacturing facilities
for compliance with the Act under the Incentives for Self-
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 5 of 18 Policing: Discovery, Disclosure, Correction and Prevention of Violations, 65 Fed.
22. The scope of the audit covered each NSPS and NESHAP rule not identified prior to
the Corporate Audit Agreement as an applicable rule of a 3M manufacturing facility;
each NSPS and NESHAP rule which was a known applicable rule prior to the
Corporate Audit Agreement, but for which one or more applicable equipment items
were omitted from the corresponding NSPS affected facility or NESHAP affected
source; and each applicable emissions standard, monitoring, recordkeeping, and
reporting requirement associated with each NSPS and NESHAP rule discovered as
noted above.
23. Pursuant to agreement by the Parties, Respondent was granted a one-year extension to
complete the assessment of compliance with applicable NSPSs and NESHAPs at its
manufacturing facilities by January 1, 2015. The Parties also agreed that the final
report would be due the earlier of either 60 days of completion of all facility
assessments or March 2, 2015. Subsequently, the Parties agreed to extend the date for
completion of the work and submission of the final report to November 20, 2015.
24. Respondent provided the EPA with periodic progress reports throughout the time
period during which it conducted its as
submitted as letters dated September 28, 2012; January 31, 2013; June 1, 2013;
October 1, 2013; January 31, 2014; May 31, 2014; September 30, 2014; January 30,
2015; and May 31, 2015.
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 6 of 18 25. On November 20, 2015, Respondent provided its final audit report. Respondent
subsequently submitted additional information through several addenda, with the first
and last addenda dated May 17, 2016 and April 23, 2020, respectively.
26. w evaluated the applicability of thirty-one different NSPSs
and eighty-one different NESHAPs for thousands of manufacturing operations,
processes, and individual items of equipment across approximately one hundred 3M
manufacturing facilities in over thirty different states.
27. With the exception of the violations referenced in Paragraph 28 and identified in
Attachment A, all -disclosed violations returned to compliance
more than five years before the date of this Consent Agreement. Accordingly, those
violations are outside the five-year statute of limitations for actions to enforce a
penalty found in 28 U.S.C. § 2462 and are not relevant to this matter.
28. The self-disclosed violations that are within the five-year statute of limitations for
actions to enforce a penalty under 28 U.S.C. § 2462 are identified in Attachment A,
hereby incorporated by reference, and are the subject of this Agreement.
29. As relevant to this matter, Respondent voluntarily disclosed violations of:
(a) NSPS 40 C.F.R. Part 60, Subparts RR, UUU, VVV, IIII; and
(b) NESHAP 40 C.F.R. Part 63, Subparts JJJJ, DDDDD, HHHHH, VVVVVV.
30.
additional information submitted to the EPA, summarized steps taken to prevent
recurrence of any violations at the facilities at which they were identified after they
had been disclosed.
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 7 of 18 31. -disclosed violations fall within the following three categories:
(a) notification, reporting, and recordkeeping issues; (b) inspection, performance
testing, and monitoring issues; and (c) work practice and emission standards issues.
32. The EPA is seeking a civil penalty only
Subpart HHHHH - National Emissions Standards for Hazardous Air Pollutants:
Miscellaneous Coating Manufacturing at its Nevada, Missouri facility.
33. The Parties have engaged in cooperative and good faith efforts to resolve
-disclosed violations.
34. The disclosures listed in Attachment A have been determined by the EPA to satisfy
all nine of the conditions set forth in the Audit Policy and therefore qualify for a
35. Pursuant to the warrants as true
for all the violations listed in Attachment A, the following facts upon which this
Agreement is based:
(a) The violations were discovered through an audit;
(b) The violations were discovered voluntarily;
(c) The violations were promptly disclosed to the EPA in writing;
(d) The violations were disclosed prior to commencement of an agency inspection or
investigation, notice of citizen suit, filing of a complaint by a third party,
ry
by a regulatory agency;
(e) The violations have been corrected;
(f) Appropriate steps have been taken to prevent a recurrence of the violations.
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 8 of 18 (g) The specific violations, identified in Attachment A, have not occurred within
three years of the dates of disclosure referenced in the reports identified in Section
D, Paragraph 25 above, at the same facilities that are the subject of this
Agreement, and have not occurred within five years of the dates of disclosure
referenced in the reports identified in Section D, Paragraph 25 above, as part of a
pattern at multiple facilities owned or operated by Respondent. For the purposes
of Subparagraph (g), a violation is:
i. Any violation of federal, state, or local environmental law identified in a
judicial or administrative order, consent agreement or order, complaint, or
notice of violation, conviction or plea agreement; or
ii. Any act or omission for which the regulated entity has previously received
penalty mitigation from the EPA or a state or local agency;
(h) The violations have not resulted in serious actual harm nor presented an imminent
and substantial endangerment to human health or the environment and they did
not violate the specific terms of any judicial or administrative final order or
agreement; and
(i) Respondent has cooperated as requested by the EPA.
E. ALLEGED VIOLATIONS OF LAW
36. Respondent failed to meet notification, reporting, and recordkeeping requirements;
inspection, performance testing, and monitoring requirements; and/or work practice
and emission standards imposed under the foregoing NSPS, 40 C.F.R. Part 60, and
NESHAP, 40 C.F.R. Part 62, rules, identified in Section C of this Agreement.
37. Specifically, and relevant to the penalty at issue in this matter, Respondent failed to
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 9 of 18 comply with the emission and work practice standards under 40 C.F.R. Part 63,
Subpart HHHHH - National Emissions Standards for Hazardous Air Pollutants:
Miscellaneous Coating Manufacturing, at its Nevada, Missouri facility.
38. Respondent is the owner and operator of two process vessels a
Missouri ,
therefore violating Section 112 of the Act, 42 U.S.C. § 7412; 40 C.F.R. § 63.8000;
and C.F.R. § 63.8005.
39. The EPA hereby states and alleges that, based on the information supplied by
and work practice standards, as required by 40 C.F.R. §§ 63.8000, 63.8005, for two
process vessels at its Nevada, Missouri facility between December 16, 2011, and
December 16, 2016.
F. TERMS OF CONSENT AGREEMENT
40. For the purpose of this proceeding, as required by 40 C.F.R. § 22.18(b)(2),
Respondent:
(a) admits that the EPA has jurisdiction over the subject matter alleged in this
Agreement;
(b) admits to the stipulated facts stated above;
(c) consents to the assessment of a civil penalty as stated below;
(d) waives any right to contest the alleged violations of law set forth in Section E of
this Consent Agreement; and
(e) waives its rights to appeal the Order accompanying this Agreement.
41. For the purpose of this proceeding, Respondent:
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 10 of 18 (a) agrees that this Agreement states a claim upon which relief may be granted
against Respondent;
(b) acknowledges that this Agreement constitutes an enforcement action for purposes
of considering
actions related to the Nevada, Missouri facility;
(c) waives any and all remedies, claims for relief and otherwise available rights to
judicial or administrative review that Respondent may have with respect to any
issue of fact or law set forth in this Order, including any right of judicial review
under Section 307(b)(1) of the Clean Air Act, 42 U.S.C. § 7607(b)(1);
(d) consents to personal jurisdiction in any action to enforce this Agreement or Order,
or both, in the United States District Court for the District of Minnesota; and
(e) waives any rights it may possess at law or in equity to challenge the authority of
the EPA to bring a civil action in a United States District Court to compel
compliance with the Agreement or Order, or both, and to seek an additional
penalty for noncompliance with the Agreement or Order, and agrees that federal
law shall govern in any such civil action.
42. Civil Penalty. The EPA:
(a) alleges that the gravity component is potentially assessable against Respondent
for these violations.
(b) agrees, based upon the facts and information submitted by Respondent and upon
Respondent has satisfied all of the conditions set forth in the Audit Policy and
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 11 of 18 thereby qualifies for a 100% reduction of the gravity component of the civil
penalty that otherwise would apply to the violations listed in Attachment A.
(c) pursuant to the Audit Policy, will waive 100% of the gravity-based penalties
assessed for the violations listed in Attachment A.
(d) has discretion, under the Audit Policy, to assess a penalty equivalent to the
economic benefit Respondent gained as a result of its noncompliance.
(e) has determined, based on information provided by Respondent and use of the
Economic Benefit ( BEN ) computer model, that Respondent obtained an
economic benefit of $170,000 as a result of its noncompliance in this matter for
the violations listed in Attachment A.
43. Penalty Payment. The civil penalty agreed upon by the Parties for settlement
purposes is $170,000. Respondent agrees to:
(a) pay the civil penalty of $170,000
Effective Date of this Agreement.
(b) pay the EPA Penalty using any method, or combination of methods, provided on
the website http://www2.epa.gov/financial/additional-instructions-making-
payments-epa Docket No. CAA-
HQ-2022-8420.
(c) within 24 hours of payment of the EPA Penalty, send proof of payment via
electronic mail to Jennifer Lee at [email protected] and to the Clerk of the
Environmental Appeals Board at [email protected]. P
means, as applicable, a copy of the check, confirmation of credit card or debit
card payment, confirmation of wire or automated clearinghouse transfer, and any
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 12 of 18 other information required to demonstrate that payment has been made according
to the EPA requirements, in the
CAA-HQ-2022-8420.
44. If Respondent fails to timely pay any portion of the penalty assessed under this
Agreement, the EPA may:
(a) request the Attorney General to bring a civil action in an appropriate district court
to recover: the amount assessed; interest at rates established pursuant to 26 U.S.C.
§
nonpayment penalty, 42 U.S.C. § 7413(d)(5);
(b) refer the debt to a credit reporting agency or a collection agency, 42 U.S.C.
§ 7413(d)(5), 40 C.F.R. §§ 13.13, 13.14, and 13.33;
(c) collect the debt by administrative offset (i.e., the withholding of money payable
by the United States to, or held by the United States for, a person to satisfy the
debt the person owes the Government), which includes, but is not limited to,
referral to the Internal Revenue Service for offset against income tax refunds,
40 C.F.R. Part 13, Subparts C and H; and
(d) (1) s licenses or other privileges, or (2) suspend or
disqualify Respondent from doing business with the EPA or engaging in
programs the EPA sponsors or funds, 40 C.F.R. § 13.17.
45. By signing this Agreement, Respondent acknowledges that this Agreement and Order
will be available to the public and agrees that this Agreement does not contain any
confidential business information or personally identifiable information.
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 13 of 18 46. By signing this Agreement, the undersigned representative of Complainant and the
undersigned representative of Respondent each certify that he or she is fully
authorized to execute and enter into the terms and conditions of this Agreement and
has the legal capacity to bind the party he or she represents to this Agreement.
47. By signing this Agreement, Respondent certifies that the information it has supplied
concerning this matter was at the time of submission true, accurate, and complete for
each such submission, response, and statement. Respondent acknowledges that there
are significant penalties for submitting false or misleading information, including the
possibility of fines and imprisonment for knowing submission of such information,
under 18 U.S.C. § 1001.
48. Except as qualified by Paragraph 44(a),
costs, and disbursements incurred in this proceeding.
G. EFFECT OF CONSENT AGREEMENT AND ATTACHED FINAL ORDER
49. In accordance with 40 C.F.R. § 22.18(c), completion of the terms of this Consent
Agreement and Final
penalties for the violations listed in Attachment A.
50. Penalties paid pursuant to this Agreement shall not be deductible for purposes of
federal taxes.
51. This Agreement constitutes the entire agreement and understanding of the Parties and
supersedes any prior agreements or understandings, whether written or oral, among
the Parties with respect to the subject matter hereof.
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 14 of 18 52. The terms, conditions, and compliance requirements of this Agreement may not be
modified or amended except upon the written agreement of both parties, and approval
of the Environmental Appeals Board.
53. Any violation of this Order may result in a civil judicial action for an injunction or
civil penalties of up to $102,638 per day per violation, or both, as provided in Section
113(b)(2) of the Act, 42 U.S.C. § 7413(b)(2), as well as criminal sanctions as
provided in Section 113(c) of the Act, 42 U.S.C. § 7413(c). The EPA may use any
information submitted under this Order in an administrative, civil judicial, or criminal
action.
54. Nothing in this Agreement shall relieve Respondent of the duty to comply with all
applicable provisions of the Act and other federal, state, or local laws or statutes, nor
regulations, nor shall it be construed to be a ruling on, or determination of, any issue
related to any federal, state, or local permit.
55. Nothing herein shall be construed to limit the power of the EPA to undertake any
action against Respondent or any person in response to conditions that may present an
imminent and substantial endangerment to the public health, welfare, or the
environment.
56. The EPA reserves the right to revoke this Agreement and settlement penalty if and to
the extent that the EPA finds, after signing this Agreement, that any information
provided by Respondent was materially false or inaccurate at the time such
information was provided to the EPA, and the EPA reserves the right to assess and
collect any and all civil penalties for any violation described herein. The EPA shall
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 15 of 18 give Respondent notice of its intent to revoke, which shall not be effective until
received by Respondent in writing.
H. EFFECTIVE DATE
57. Respondent and Complainant agree to issuance of the attached Final Order. Upon
filing, the EPA will transmit a copy of the filed Consent Agreement to the
Respondent. This Consent Agreement and attached Final Order shall become
effective after execution of the Final Order by the Environmental Appeals Board, on
the date of filing with the Hearing Clerk.
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 16 of 18 The foregoing Consent Agreement In the Matter of 3M Company, Docket No. CAA-HQ-2022- 8420, is Hereby Stipulated, Agreed, and Approved for Entry.
FOR RESPONDENT:
______ November 29, 2021
_________
Signature Date
James R. Kotsmith
Printed Name: _________
Title: Vice President, Corporate Environment
_________
Address: 3M Center, Bldg. 224-5W-17, St. Paul, MN 55144
_________
Federal Tax Identification Number: 41-0417775
___________________________
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 17 of The foregoing Consent Agreement In the Matter of 3M Company, Docket No. CAA-HQ-2022- 8420, is Hereby Stipulated, Agreed, and Approved for Entry.
FOR COMPLAINANT:
__ ____ Date Mary E. Greene
Director, Air Enforcement Division
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
Consent Agreement and Final Order, Docket CAA-HQ-2022-8420 Page 18 of 18 CERTIFICATE OF SERVICE
I certify that copies of the foregoing “Consent Agreement” and “Final Order,” in the
matter of 3M Company, Docket No. CAA-HQ-2022-8420, were sent to the following persons in the manner indicated:
By Electronic Mail:
Adam Kushner
Counsel for Respondent 3M Company
Hogan Lovells US LLP
555 Thirteenth Street, NW
Washington, DC 20004
e-mail: [email protected]
Jennifer Lee
Office of Civil Enforcement
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
e-mail: [email protected]
Feb 07, 2022
Dated: ____ ______
Emilio Cortes
Clerk of the Board
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