AQ_F_1900104_20170728_CEM_RptRvwLtr

ROY COOPER
Governor
MICHAEL S. REGAN N.
Set retan,
Air Quality
ENVIRONMENTAL QUALITY MICHAEL A. ABRACZINSKAS
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July 28,2017
Mr.Blake Arnett
Plant Manager
3M Company-Pittsboro
4191 Highway 87 South
Moncure,NC 27559
Subject: Review of First Semester 2016 Continuous Opacity Monitoring Systems(COMS)Excess
Emissions Report(EER) for ID No. ES1415,ESCPPHI &ESCPPH2-40 CFR Part 60,
Subparts A and UUU; Facility ID No.1900104
Dear Mr.Arnett:
The Division of Air Quality(DAQ)has reviewed the subject report,dated July 18, 2017. The
report was reviewed for compliance with the monitoring and reporting requirements as well as
compliance with the emission control standard(opacity limit) set forth in the current Air Quality Permit#
09006T04. The report was also reviewed for compliance with good operation and maintenance(O&M)
practices set forth in 40 CFR Subpart A, Section 60.11(d), 60.13,and Subpart UUU.
When the report was reviewed for compliance with the emission control standard(opacity limit),
no opacity excursion was reported. Therefore,no violations appear to have occurred for any of the units.
When the report was reviewed for compliance with the use of good O&M practices,the following
percent opacity excess emissions(%EE)and percent monitor downtime(%MD)were reported for each
of the units:
UNIT FIRST QUARTER 2017 SECOND QUARTER 2017
C&S Dryer(ES 1415) %EE 0.0% %EE 0.0%
%MD 0.73% %MD 0.85%
COLOR Dryer(ESCPPHI) %EE 0.0% %EE 0.0%
%MD 0.88% %MD 1.37%
COLOR Dryer(ESCPPH2) %EE 0.0% %EE 0.0%
%MD 1.62% %MD 1.10%
DAQ considers sources to have operated with proper O&M if%EE and/or%MD is less than the
target criteria of 6.0% for any single quarter or less than 3.0%for any two consecutive quarters.The data
shown above suggests that the facility and monitoring systems were operated using proper O&M
practices for minimizing emissions in accordance with 40 CFR Subpart A, Section 60.11(d), 60.13,and
Subpart UUU since the target criteria for making this assessment was not exceeded.
The opacity audits were also reviewed with respect to Procedure 3 of 40 CFR Part 60,Appendix
F.Based on the information provided,the quality assurance(QA)test results for the COMS operating at
ESCPPHI,ESCPPH2 and C&S Dryers appear to have met the quarterly specifications.
State of North Carolina I Environmental Quality I Air Quality
1641 Mail Service Center 1 217 W.Jones Street,Suite 4000 1 Raleigh,NC 27609-1641
919 707 8400 T
i.

Mr.Blake Arnett
July 28, 2017
Page 2
If you have any questions regarding this review,please call me at(919)707-8410 or
dennis.i gbokoiu nedenr. gov
Sincerely,
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Dennis U. IX ko,Environm Engineer
Division of Air Quality,NCDENR
CC: Donald R. van der Vaart, Ph.D.,J.D., P.E., Chief- RCO
Patrick Butler—RRO
Adam Driscoll—3M Environmental Operations, 3M Center,Bldg 224-5W—03, St Paul,MN
55144-1000
Central File-Chatham County
IBEAM—Documents— 1900104