AQ_F_1900104_20221024_CMPL_NOV-NRE

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Governor 3�,
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ELIZABE.TH S. BISER '' •��„ r ~
Secretor
MICHAEL ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
October 24, 2022
CERTIFIED MAIL 7020 3160 0000 2219 1200
RETURN RECEIPT REQUESTED
Blake Arnett, Plant Director
3M Pittsboro - Industrial Mineral Products
4191 Highway 87 South
Moncure, NC 27559
SUBJECT: Notice of Violation/Notice of Recommendation for Enforcement
40 CFR 60 NSPS 000
3M Pittsboro - Industrial Mineral Products
Moncure, Chatham County, North Carolina
Air Permit No. 09006RT08
Facility ID No. 1900104
Fee Class: Title V
Dear Mr. Arnett:
On March 4, 2022, the 3M Pittsboro facility started operation of two already permitted emission
sources, ID Nos. ES3537B and ES3537H (M Screens 2 and 5, respectively). According to your Title V
Air Permit No. 09006T08, these sources are subject to New Source Performance Standards (NSPS)
Subpart 000 (Standards of Performance for Nonmetallic Mineral Processing Plants). This rule
requires the facility to submit a start-up notification withing 15 days and conduct initial performance
testing withing 180 days of starting the operation of those emission sources. However, 3M Pittsboro did
not notify DAQ of start-up of ES3537B and ES3537H within 15 days. This is a deviation from 40 CFR
60.675 and permit condition 2.1.A.2. Furthermore, 3M Pittsboro facility did not conduct an initial
performance testing for ES3537B and ES3537H within 180 days. This is also a deviation from 40 CFR
60.8 and permit condition 2.1.A.2.
As indicated in the "subject" above, this letter represents not only a Notice of Violation for failure
to submit NSPS Subpart 000-required start up notification and initial performance testing, but also puts
3M Pittsboro on notice that an enforcement report is being prepared by this office addressing the
violations. Please submit a written response to this office by November 14, 2022 explaining any
actions taken to bring about compliance and any additional information or description of any
mitigating circumstances that you believe should affect the outcome of the enforcement
evaluation. After this date, in lieu of any mitigating circumstances brought to our attention, this office
will submit the enforcement report to the Director of the Division of Air Quality and make
recommendations for the assessment of appropriate civil penalties.
This is the fourth occurrence of an NSPS-related violation which this office has documented
against the subject facility in the last five years. Most recently a Notice of Violation was issued August
inI�— North Carolina Department of Environmental Quality Division of Air Quality
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Raleigh Regional Office 8800 Barrett Drive Raleigh,North Carolina 1 T60't

3M Pittsboro - Industrial Mineral Products
October 24, 2022
Page 2
12, 2021 for the NSPS Subpart 000 non like-for-like replacement of Dryer Baghouse (ID No. CDB3)
and failure to permit prior to installation of portable backup conveyor (draft ID No. IS-32) and Waste
Stacker Conveyor 25A. A Notice of Violation was issued December 11, 2020 for NSPS Subpart 000-
related addition of a pugmill system (ID No. F6772) prior to it being added to the air permit and failure
to perform initial performance testing. Finally, a Notice of Violation was issued April 23, 2018 for the
NSPS Subpart UUU (Standards of Performance for Calciners and Dryers in Mineral Industries) for
failure to conduct daily calibrations.
Your cooperation and concern for the environment are appreciated. If you have any questions
concerning this matter, please contact Abdul Kadir, Environmental Engineer, Will Wike, Compliance
Supervisor, or me, at [phone].
Sincerely,
f _7
Dawn L. Reddix
Acting Raleigh Regional Supervisor
Division of Air Quality, NC DEQ
cc: RRO Files
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