AQ_F_1900104_20061013_CEM_RptRvwLtr

NCDEN
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
October 13, 2006
Mr. William S. Bond
Environmental, Health & Safety Manger
3M Environmental Technology and Safety Services
P.O. Box 33331
St. Paul,MN 55133-3331
Subject: First & Second Semesters 2005 and First Semester 2006 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 first semester 2005 (January 1-June 2005),
second semester 2005 (July 1, 2005 through December 31, 2005)and first semester 2006(January 1-June
2006)opacity emission reports. The reports were reviewed for compliance with the monitoring and
reporting requirements of the emission control standard(opacity limit) set forth in current Air Quality
Permit 4 09006R00. The reports were 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 IV CEM
Enforcement Plan (CEP) and in accordance with EPA's High Priority Violations (HPVs) guidance.
Based on the review, the opacity excess emissions and monitor downtime for the periods were
reported and confirmed as follows:
UNIT 1ST SEMESTER 2005 2ND SEMESTER 2005 1ST SEMESTER 2006
C&S Dryer EE 0.04% 0% 0%
MDT 23.9% 17.49% 0.58%
CL1Preheater EE 0% 0% 0%
MDT 0.45% 3.57% 0.79%
CL2 Pre heater EE 0% 0% 0%
MDT 0.95% 3.83% 0.76%
When the reports are reviewed with respect to the emission control standard(opacity limit)no opacity
exceedances were noted. However,when the reports were 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"were reported at 23.9% and 17.49% for the first and
second semesters 2005 respectively. Most of the monitor downtimes appear to be due to malfunction. You
indicated that method 9 tests were conducted during the malfunction events in which no opacity
exceedances were recorded. Please note that the DAQ considers any monitor downtime greater than 10%in
a quarter-or greater than 5% in two consecutive quarters evidence of bad operation and maintenance (O&M)
Technical Services Section One
1641 Mail Service Center,Raleigh,North Carolina 27699-1641
2728 Capital Blvd.,Raleigh,North Carolina 27604 NOrthCarofina
Phone: [phone] FAX [phone]/Internet: www.ncair.org Ydurally
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Mr. William S. Bond
Page Two
October 13, 2006
practice pursuant to 40 CFR Part 60, Subpart A as implemented in CEP. Unless you submit additional
information to explain the reasons for the excessive monitor downtime, the DAQ will have no other choice
than to issue 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. Please provide any additional
information no later than October 31,2006.
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