AQ_F_1900104_20170207_CEM_RptRvwLtr

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
Air Quality SHEILA C. HOLMAN
Y Director
ENVIRONMENTAL QUALITY
February 7, 2017
Mr. Blake Arnett
Plant Manager
3M Company- Pittsboro
4191 Highway 87 South
Moncure,NC 27559
Subject: Review of Second 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 January 17, 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 (0&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 0&M practices,the
following percent opacity excess emissions (%EE) and percent monitor downtime (% MD)were
reported for each of the units:
UNIT THIRD QUARTER 2016 FOURTH QUARTER 2016
C&S Dryer(ES 1415) % EE 0.0% % EE 0.0%
% MD 0.96% % MD 1.31%
COLOR Dryer(ESCPPHI) % EE 0.0% % EE 0.0%
% MD 1.38% %MD 1.76%
COLOR Dryer(ESCPPH2) % EE 0.0% %EE 0.0%
%MD 2.15% % MD 2.74%
DAQ considers sources to have operated with proper 0&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
State of North Carolina I Environmental Quality I Air Quality
217 West Jones Street 1 1641 Mail Service Center I Melgh,North Carolina 27699-1641
919 707 8400

Mr. Blake Arnett
February 7, 2017
Page 2
proper 0&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.
If you have any questions regarding this review,please call me at(919) 707-8410 or
dennis.i bg oko.,,'&ncdenr.gov
Sincerely, n
Dennis U. Igboko,Environmental Engineer
Division of Air Quality, NCDENR
CC: Mike Pjetraj, 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