AQ_F_1900104_20050623_CEM_RptRvwLtr

®A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
June 23, 2005
Mr. William S.Bond
Environmental,Health&Safety Manger
3M Environmental Technology and Safety Services
P.O. Box 33331
St.Paul,MN 55133-3331
Subject: Second Semester 2004 Continuous Opacity Monitoring Systems (COMS) Report for ID
No. CD1 - 40 CFR Part 60, Subparts A and UUU.
Facility ID No.1900104
Dear Mr. Bond:
The Division of Air Quality(DAQ)has reviewed your second semester 2004(July 1, 2004 through
December 31, 2004)opacity emission report. The report was reviewed for compliance with the monitoring
and reporting requirements of the emission control standard(opacity limit) set forth in current Air Quality
Permit#09006R00 in accordance with EPA's High Priority Violations (HPVs) guidance. The report was
also reviewed for compliance with good operation and maintenance practices set forth in 40 CFR Part 60,
Subparts A and UUU and implemented in the EPA Region 1V CEM Enforcement Plan(CEP).
Based on the review,during the second semester 2004, nine incidents[nine 6-minute periods] of
opacity exceedance due to"Unknown Problems"were reported from"CL 2 Preheater"and no incident was
reported from both "CL 1 Preheater"and"C&S Dryer". The opacity excursions from"CL 2 Preheater"did
not result in an HPV guidance exceedance.
However, when the report was reviewed for compliance with good operation and maintenance
practices as implemented in 40 CFR Part 60, Subparts A and UUU and/or CEP,the opacity monitor
downtimes from the"C&S Dryer", "CL 1 Preheater" and"CL 2 Preheater"for the second semester 2004
were reported at 0.42%, 18.9%and 15.7%respectively. Because the monitor downtimes from CL 1
Preheater and CL 2 Preheater are greater than 10%of the operating time in the quarter,the DAQ is
requesting 3M Environmental Technology and Safety Services to submit specific and details of the all the
incidents of monitor downtime that occurred during the second semester 2004. Please include the date/time
of each incident, a description of each monitor problem, when the problem was resolved and whether or not
a corrective action plan was implemented to prevent similar problem from recurring. Please submit this
information no later than July 30, 2005.
Please note that excess emissions and/or monitor downtime greater than 5%in any two consecutive
quarters or greater than 10% in any quarter may result in the issuance a Notice of Violation(NOV) for
failure to maintain the opacity monitor and/or failure to properly operate and maintain your facility
including the monitoring system.
Technical Services Section
1641 Mail Service Center,Raleigh,North Carolina 27699-1641 One
2728 Capital Blvd.,Raleigh,North Carolina 27604 NorthCarohna
Phone: [phone]/FAX [phone]/Internet: www.ncair.org ;VatumlAn Equal Opportunity/Affirmative Action Employer—30%Post Consumer Recycled Paper

Mr. William S. Bond
Page Two
June 23, 2005
If you have any questions regarding this review,please call me at(919)733-1467.
Sincerely,
Dennis U. Igboko
Environmental Engineer
CC: Michael Aldridge
Ernie Fuller—RRO
IMPAQ—Documents - 1900104
Dianne Dejolsvay—3M
Central File-Chatham County