AQ_F_1900104_20190319_CEM_RptRvwLtr

c,: �.srn7pQ
ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS
Director
March 19, 2019
Mr. Blake Arnett
Plant Manager
3M Company—Pittsboro
4191 Highway 87 South
Moncure, North Carolina 27559
Subject: Review of 2018 Semiannual COMS Report, Second Half
3M Pittsboro—Industrial Mineral Products
Moncure, Chatham County,North Carolina
Air Quality Permit No. 09006T06
Facility ID: 1900104
Dear Mr. Arnett:
Thank you for the timely submittal of the subject report, dated March 4, 2019. The
excess emissions report(EER)provided information about the continuous opacity monitoring
systems (COMS) operating at 3M's Pittsboro facility during the second half of 2018.
Specifically, COMS data for the following natural gas-fired dryers were reviewed: C&S
Dryer(ID No. ES1415), Line 1 Coloring Dryer(ESCPPH1), and Line 2 Coloring Dryer
(ESCPPH2). The Division of Air Quality(DAQ)has completed its review of the submittal
and has the following comments:
1. The natural gas-fired dryers were reviewed for compliance with the underlying opacity
standard set forth at NCAC 2D .0524 (40 CFR Part 60, Subpart UUU-Standards of
Performance for Calciners and Dryers in Mineral Industries) and Air Permit No. 09006,
Specific Conditions 2.1.13.2 and 2.1.D.2. The EER indicated there were no excess
emissions and consequently no violations of the applicable standard.
A review was also conducted for compliance with good operation and maintenance
(0&M) practices pursuant to NCAC 2D .0524 (NSPS UUU,including Subpart A-
General Provisions),40 CFR 60.11(d), and 40 CFR 60.13.Unless otherwise specified
in regulation, DAQ considers sources to have operated with good 0&M if the percent
excess emissions (%EE) and percent monitor downtime (%MD) are less than the
target criteria of 6% for any single quarter and less than 3% for two consecutive
quarters.When compared to the total operating time of the dryers, %EE and%MD
NORrH cvwou�����
omemauro� r
North Carolina Department of Environmental)Quality 1 Division of Air Quality
217 West]ones Street 11641 Mail Service Center 1 Raleigh,North Carolina 27699-1641
919.707.8400

Mr. Blake Arnett
March 19, 2019
Page 2
were reported as shown in the table below and appear to indicate the use of good
O&M practices for minimizing emissions.
Unit Quarter %EE %MD
C&S Dryer 3rd 0.0 0.89
4th 0.0 0.87
Line 1 Coloring Dryer 3rd 0.0 1.11
4th 0.0 1.20
Line 2 Coloring Dryer 3rd 0.0 1.64
4th 0.0 1.61
2. The 2018 third and fourth quarter audits of the COMS units were reviewed in accordance
with Procedure 3 of 40 CFR Part 60, Appendix F - Quality Assurance Procedures. The
QA test results for the COMS appear to have met the quarterly specifications and are
acceptable.
If you should have any questions regarding this review,please contact me at(919) 707-
8410 or [e-mail].
Sincerely,
Dennis U. Igboko, Environmental Engineer
Division of Air Quality, NCDEQ
c: Adam Driscoll, 3M
Ray Stewart, DAQ RRO
Gary Saunders, DAQ RCO
IBEAM Documents, 1900104
Central File, Chatham County