AQ_F_1900104_20160823_CEM_RptRvwLtr (4)

PAT MCCRORY
i•�a Governor
DONALD R. VAN DER VAART
Secretary
Alr Quality SHEILA C. HOLMAN
ENVIRONMENTALENTALQUALITY
Director
August 23, 2016
Mr.Blake Arnett
Plant Manager
3M Company-Pittsboro
4191 Highway 87 South
Moncure,NC 27559
Subject: AMENDED 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
ULM;Facility ID No.1900104
Dear Mr.Arnett:
The Division of Air Quality(DAQ)has reviewed the subject report, dated July 19,2016. 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 FIItST QUARTER 2016 SECOND-QUARTER 2016
C&S Dryer(ES 14.15) %EE 0.0% %EE 0.0%
%MD 0.83% %MD 0.74%
COLOR Dryer(ESCPPHI) %EE 0.0% %EE 0.0%
%MD 1.30% %MD 1.02%
COLOR Dryer(ESCPPH2) %EE 0.0% %EE 0.0%
%MD 1.67% %MD 1.66%
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.In my letter to you dated August 15,2016 on the same subject,I inadvertently used the word "improper"
O&M instead of"proper"O&M to characterize the compliance status of the Dryers. Therefore,this letter seeks to
correct the error, and supersedes my letter of August 15,2016.
State of North Carolina I Environmental Quality I Air Quality
1641 Mail Service Center 1 217 W.Jones Street,Suite 4000 1 Raleigh,NC 27699-1641
919 707 8400 T

Blake Arnett
August 23, 2016
Page 2
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 and ESCPPH2 appear to
have met the quarterly specifications.
If you have any questions regarding this review,please call me at(919)707-8410 or dennis igbokogncdenr.gov
Sincerely,
Dennis U.Igboko,Environmental Engin er
Division of Air Quality,NCDENR
CC: `� Mike Pjetraj, RCO
Patrick Butler—RRO
ions, 3M Center,Bldg 224-SW—03, St Paul,MN 55144-1000
Tricia Shearen—3M Environmental Operat
Central File-Chatham County
IBEAM—Documents— 1900104