AQ_F_1900104_20150216_CEM_RptRvwLtr

irCSFEINR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
February 16, 2015
Mr.Blake Arnett
Plant Manager
3M Company-Pittsboro
4191 Highway 87 South
Moncure,NC 27559
Subject: Review of Second Semester 2014 Continuous Opacity Monitoring Systems (COMS)
Excess Emissions Report(EER)for ID No.ES 1415,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 21,2014.
Additional information was provided upon request by Stanley Carter of your staff on February 13, 2015.
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.
Based on the review,the opacity excess emissions and monitor downtime for the period were
reported and confirmed as follows:
UNIT THIRD QUARTER 2014 FOURTH QUARTER 2014
C&S Dryer(ES 1415) Excess Emissions 0.0% Excess Emissions 0.0%
Monitor Downtime 1.13% Monitor Downtime 1.39%
COLOR Dryer(ESCPPHI) Excess Emissions 0.0% Excess Emissions 0.0%
Monitor Downtime 1.50% Monitor Downtime 1.64%
COLOR Dryer(ESCPPH2) Excess Emissions 0.0% Excess Emissions 0.0%
Monitor Downtime 2.20% Monitor Downtime 3.33%
When the reports were reviewed for compliance with the emission control standard(opacity
limit),no opacity excursion was reported.Therefore,no further action is required.
Also,when the reports are reviewed for compliance with good O&M practices,no excess
emission appeared to have occurred. However,when the monitor downtimes are compared to the total
operating time of the Dryers(ES 1415,ESCPPHI and ESCPPH2),percent monitor downtimes(%MD)
were reported and confirm as shown in above table.Although,the monitor downtimes for C&S Dryer(ES
1415)and(ESCPPHI)were below 3.0%target criteria,the downtime for unit ESCPPH2 was reported at
3.33%which is above the target criteria. Please note that 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
1601 Mail Service Center,Raleigh,North Carolina 27699-1601
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Mr. Blake Arnett
February 16, 2015
Page 2
than 3.0%for any two consecutive quarters.Thus,your first quarter 2015 COMS report would be
reviewed to determine if the monitor downtime is above 3.0%of the operating time in the quarter and,if
further action is necessary.
As a reminder,please note that EPA released a new QA/QC rule(40CFR Part 60,Appendix F,
Procedure 3) for continuous opacity monitoring system(COMS) subject to NSPS regulation.The new
rule became effective November 12,2014.A copy of the federal register notice(79 FR 28439)can be
found online.Essentially,the new federal rule establishes requirements for daily instrument zero and
upscale drift checks, daily status indicator checks,quarterly performance audits and annual zero
alignments. It also requires that source owners and operators have a corrective action program in place
for a malfunctioning COMS.The requirements contained in the new rule were modeled after
manufacturers' maintenance recommendations.Please include all quarterly and annual audit results with
your COMS excess emissions reports. [If your COMS unit is subject to SIP regulations,you will be
expected to comply with the current version of 2D .0613 until it is revised to include 40 CFR Part 60,
Appendix F,Procedure 3.]
If you have any questions regarding this review,please call me at(919)707-8410 or
dennis.i bg oko agncdenngov
Sincerely,
Dennis U.Igboko,Environmrtal Engineer
DAQ,NCDENR
CC: Mike Pjetraj
Patrick Butler RRO
IBEAM—Documents- 1900104
Chris Nelson—3M Environmental Operations, 3M Center,Bldg 224-5W—03, St Paul,MN
55144-1000
Central File-Chatham County