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HomeMy WebLinkAboutAQ_F_1900104_20221017_CMPL_InspRpt NORTH CAROLINA DIVISION OF Raleigh Regional Office k17W AIR QUALITY 3M Pittsboro-Industrial Mineral Products Inspection Report NC Facility ID 1900104 Date: 10/17/2022 County/FIPS:Chatham/037 Facility Data Permit Data 3M Pittsboro-Industrial Mineral Products Permit 09006/T08 4191 Highway 87 South Issued 1/13/2022 Moncure,NC 27559 Expires 8/31/2026 Lat: 35d 39.6560m Long: 79d 10.0390m Class/Status Title V SIC: 3295/Minerals,Ground Or Treated Permit Status Active NAICS: 327992/Ground or Treated Mineral and Earth Manufacturing Current Permit Application(s)TV-Minor,TV- Minor,TV-Renewal Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact P/Title V Blake Arnett Blake Arnett Ryan Navis SIP PS: Subpart 000, Subpart UUU Plant Director Plant Director Advanced Environmental (919)642-4011 (919)642-4011 Engineer (651)230-4776 Compliance Data Comments: In compliance. Inspection Date 09/22/2022 Inspector's Name Abdul Kadir Inspector's Signature:Adal/raaiw Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: 10/17/2022 Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2020 92.03 0.1600 24.56 11.12 20.54 68.73 9831.47 2019 91.08 0.1520 24.77 11.15 20.75 52.15 9608.00 2018 101.45 0.1400 22.99 11.41 19.23 60.92 10543.00 *Highest HAP Emitted inpounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 08/12/2021 NOV NCGS 143-215.108 Control of sources of air pollution; 02/15/2022 permits required. 12/11/2020 NOV Part 60-NSPS Subpart 000 Nonmetallic Mineral 01/20/2021 Processing Plants 12/11/2020 NOV NCGS 143-215.108 Control of sources of air pollution; 01/20/2021 permits required. 04/23/2018 NOV 2D .0524 New Source Performance Standards 06/05/2018 Performed Stack Tests since last FCE: Date Test Results Test Method(s) Source(s)Tested 11/11/2021 Compliance Method 9 F6771,F72 06/02/2021 Compliance Method 9 (I)DIRECTIONS: From Raleigh,take US-1 South to US-64 in Cary. Take US-64 West towards Pittsboro. Just prior to Pittsboro,take exit 386 for US-64 Business and follow 3 miles to traffic circle. Then take US 15- 501 South(merges with NC-87 South) approximately 4 miles, and 3M Industrial Minerals Products will be on the east(left)side of the highway. (II)FACILITY DESCRIPTION: At the Moncure plant, 3M Industrial Mineral Products(3M)manufactures various types of stone granules to sell to the asphalt shingle industry. Luck Stone Corporation operates a stone crushing operation on the same property and supplies the 3M plant with 4-inch stone. 3M then crushes,dries, screens,colors and bakes the stone materials to produce the granules. The final product is shipped out in specially designed bulk trucks. The 3M plant over the past years has had approximately 55 full-time employees. Historically,the Coloring Plant has operated with three 8-hour shifts(6 am-2 pm,2 pm-10 pm, and 10 pm—6 am). The Crushing/Screening Plant operates on a 24-hour basis. Both plants typically run Monday through Friday only. Be prepared to use standard safety items at this facility and a fit tested respirator. Although the facility in the past has provided dust masks,there is a policy now that dust masks will not be provided unless a visitor is accompanied with a written doctor's statement authorizing respirator usage. The dust levels can be significant in the facility areas where crushing/screening occurs. (II1)INSPECTION SUMMARY: on September 22,2022 I(Abdul Kadir)arrived at the facility to perform a compliance inspection. There were no remarkable odors, depositions, or visible emissions. Once in the administrative building, I met with Mr.Andrew Miller,EHS Supervisor. We could not do the record review since the facility contact,Ms. Della Hardy,was not available. However,I communicated with Ms. Hardy and decided that we would go through the record review process on another day when we both are available. However,Mr.Miller and I toured the whole facility and observed almost all the emission sources. The plant appeared to be well maintained and operating well from an air quality standpoint. On October 13,2022,Ms. Hardy emailed me two months of record keeping documents upon my request. These records appeared to be well maintained as per the permit requirements. (IV)PERMITTED EMISSION SOURCES: At the time of the inspection, 3M's Moncure Plant was operating under Air Permit No. 09006T08,which became effective on January 13,2022 and expires on August 31,2026. The following table identifies all the emission sources and control devices for which the Title V permit was issued: Emission Control Control Device Source ID No. Emission Source Description Device ID Description No. Crushing and Screening Plant ES 123 Plant feed conveyor No. 1 (feed pile to surge CDB I Crusher baghouse NSPS 000 bin) No. 1 (6,500 square ES412 Surge bin feet of filter area) NSPS 000 ES607.1 Feed conveyor No. 2 (surge bin to C crusher) NSPS 000 Emission Control Control Device Source ID No. Emission Source Description Device ID Description No. ES607.2 C crusher NSPS 000 ES2327A G crusher feed bin No. 1 NSPS 000 ES2426.1 G crusher feed conveyor No. 8A(G crusher NSPS 000 feed bin No. 1 to G crusher No. 1 ES2426.2 G crusher No. 1 NSPS 000 ES3031 M feed transfer bin NSPS 000 ES3941 L crusher bin No. 1 NSPS 000 ES4347.1 L crusher feed conveyor No. 16A(L crusher NSPS 000 feed bin to L crusher ES4347.2 L crusher NSPS 000 ESC3 Product conveyor No. 3 (C crusher to D NSPS 000 screen bin No. 1 ESC22.1 Conveyor No. 22(crushing baghouse hopper NSPS 000 screw conveyor loading to dust conveyor No. 22 ES16-A Dryer and G crusher conveyor No. 9(G CD132 Screen baghouse No. NSPS 000 crusher to screens No. 2 and No. 3 feed bin) 1 (11,750 square feet ES32.1 L crusher product conveyor No. 17,two of filter area) NSPS 000 pickups(M feed transfer bin and L crusher No. 1 to M screen feed bin ES32A L crusher product conveyor No. 17 (L NSPS 000 crushers to conveyor No. 18A) ES32B Conveyor No. 18A(L crusher product NSPS 000 conveyor No. 17 to live M screens feed bin ES340-A Live M screens feed bin,two pickups NSPS 000 ES1721A D screen bin No. 2 NSPS 000 ES1721B D screen No. 2 feeder NSPS 000 ES 1721 C D screen No. 2 CDB2 Screen baghouse No. NSPS 000 (continued) 1 (11,750 square feet ES1721D G crusher bin feed conveyor No. 5 (D screen of filter area) NSPS 000 No. 2 to G crusher bins ES1721E L circuit new feed conveyor No. 13 (D NSPS 000 screen No. 2 to M transfer bin ES3537A M screen No. 1 NSPS 000 ES3537B M screen No. 2 NSPS 000 Emission Control Control Device Source ID No. Emission Source Description Device ID Description No. ES3537C M screen No. 3 NSPS 000 ES3537D L crusher feed bin conveyor No. 14,three NSPS 000 pickups M screens to L crusher bins ES3537E Grade collecting conveyor No. 19,three NSPS 000 pickups(M screens Nos. 1,2, and 3 to M screens Nos. 4, 5,and 6 ES3537F Waste conveyor No. 21,three pickup points NSPS 000 M screens to waste bin ES8913A D screen bin No. 1 NSPS 000 ES8913B D screen No. I feeder NSPS 000 ES8913C D screen No. I NSPS 000 ES8913D Undersize conveyor No. 3 (D screen No. 1 to NSPS 000 dryer feed conveyor No. 7 ES8913E C bin feed conveyor No. 4(D screen No. 1 NSPS 000 to C crusher bin ES8913F Dryer feed conveyor No. 7 (undersize NSPS 000 conveyor No. 3 todryer) ESC22.2** Conveyor No. 22(crushing 1 and 2 CD133 Dryer baghouse NSPS 000 baghouse, dryer A and B baghouse and (12,002 square feet cyclone hopper screw conveyor)to dust of filter area) conveyor No. 23A ES 1415 One natural gas-fired dryer CDC I Dryer cyclone(eight NSPS UUU feet in diameter)in series with CD133 Dryer baghouse (12,002 square feet of filter area ES 16-B Dryer and G crusher product conveyor No. 9 CD134 Screen baghouse No. NSPS 000 G crusher to screens No. 2 feed bin 2(9,000 square feet ES33A Conveyor No. 18A(conveyor No. 17 to of filter area) NSPS 000 conveyor No. 18B ES33B Conveyor No. 18B (conveyor No. 18A to NSPS 000 live M feed bin ES340-B Live M feed bin,two pickups CDB4 Screen baghouse No. NSPS 000 (continued) 2 (9,000 square feet ES1822A D screen bin No. 3 of filter area) NSPS 000 ES1822B D screen feeder No. 3 NSPS 000 Emission Control Control Device Source ID No. Emission Source Description Device ID Description No. ES 1822C D screen No. 3 NSPS 000 ES 1822D Feed conveyor No. 5,two pickups(D NSPS 000 screens Nos. 2 and 3 to G crusher bin ES2327B Feed conveyor No. 6(D screens to G crusher NSPS 000 bins ES3537G M screen No. 4 NSPS 000 ES3537H M screen No. 5 NSPS 000 ES3537I M screen No. 6 NSPS 000 ES3537J L crusher feed bin conveyor No. 14,three NSPS 000 pickups M screens to L crusher ES3537K Grade collecting conveyor No. 19,three NSPS 000 pickup points M screens to grade silos ES3537L Waste conveyor No. 21,three pickups(M NSPS 000 screen to waste bin ESC23C 24"Dust conveyor No. 23C(baghouse NSPS 000 hopper to dust elevator ES 16-C Dryer and G crusher product conveyor No. 9 CDB5 Crusher baghouse NSPS 000 G crusher to screens No. 2 feed bin No. 2(5,250 square ES32.2 L crusher product conveyor No. 17 (L feet of filter area) NSPS 000 crushers and M feed transfer bin to M screen feed bin ES38 Conveyor No. 14(M screens to conveyor NSPS 000 No. 14A ES39 Conveyor No. 14A(conveyor No. 14 to L NSPS 000 crusher feed bins ES2327 G crusher bin No. 2 NSPS 000 ES2729.1 G crusher feed conveyor No. 8B (G crusher NSPS 000 bin to G crusher ES2729.2 G crusher No. 2 NSPS 000 ES4042 Feed conveyor No. 14A to L crusher bin No. NSPS 000 2 ES4043 L crusher bin No. 2 NSPS 000 ES4044 Feed conveyor No. 16B to L crusher No. 2 NSPS 000 Emission Control Control Device Source ID No. Emission Source Description Device ID Description No. ES4448.1 L crusher feed conveyor No. 16B NSPS 000 ES4448.2 L crusher No. 2 CDB5 Crusher baghouse NSPS 000 (continued) No. 2(5,250 square feet of filter area ES49A Grade collection conveyor No. 19 (M CDB6 Grade silo baghouse NSPS 000 screens to grade bucket elevator) (4,942 square feet of ES49B Grade bucket elevator No. 1,two pickups filter area) NSPS 000 (grade collecting conveyor No. 19 to grade transfer conveyor No. 20 ES50 Grade transfer conveyor No. 20,two pickups NSPS 000 (grade bucket elevator to grade silos ES57 Grade silo conveyor No. 26,three pickups NSPS 000 (grade silos to bin discharge bucket elevator ES58 Grade transfer conveyor No. 27 (bin NSPS 000 discharge elevator to coloring plant) ES59 Bin discharge bucket elevator No. 4,two NSPS 000 pickups ES5155A Grade silo No. 1 NSPS 000 ES5155B Grade silo No. 2 NSPS 000 ES5155C Grade silo No. 3 NSPS 000 ESC23A.1** Conveyor No. 23A(crushing and dryer NSPS 000 baghouse hopper screw conveyor)to dust conveyor No. 23C transfer point [baghouse dust from conveyor No. 22 conveyed onto conveyor No. 23A then onto 23C] ES23C Dust conveyor No. 23C(baghouse hopper CDB7 Waste handling NSPS 000 loadout to dust elevator) baghouse(2,750 ES63A Dust conveyor No. 23C(hoppers for screens, square feet of filter NSPS 000 grade silo,and waste baghouses to dust area) elevator ES63B Dust elevator No. 3,two pickups NSPS 000 ES68A Waste conveyor No. 21 NSPS 000 ES68B Waste elevator No. 2,two pickups NSPS 000 ES6466 Dust bin NSPS 000 ES6466SC Dust bin screw conveyor(waste handling NSPS 000 baghouse hopper to a mill ES6970 Waste bin NSPS 000 Emission Control Control Device Source ID No. Emission Source Description Device ID Description No. ESA1 D screen No. 4 assembly(includes the CDB16 Screen baghouse No. NSPS 000 vibrator) 3 (9,000 square feet of filter area) ESA5 Load-in to conveyor No. 18C CDB 16 Screen baghouse No. NSPS 000 (continued) 3 (9,000 square feet ESA6 Line 3 live M feed bin of filter area) NSPS 000 ESA7 Line 3 M screen assemblies NSPS 000 ESAl l Screen baghouse No. 3 ash loadout NSPS 000 ESA2 G bin feed conveyor No. 6 loadout to bin CDB 17 Crusher baghouse NSPS 000 feed conveyor No. 6A No. 3 (6,500 square ESA3 G feed bin No. 3 feet of filter area) NSPS 000 ESA4 G crusher No. 3 NSPS 000 ESA8 Feed bin No. 3 NSPS 000 ESA9 L crusher No. 3 NSPS 000 ESA12 Crusher baghouse No. 3 ash loadout NSPS 000 F61 Enclosed dust conveyor No. 23C(dust N/A N/A NSPS 000 conveyor No. 23A to transfer conveyor No. 23C F72 Enclosed waste stacker conveyor No. 25 CDF72 Wet suppression NSPS 000 (pugmill to outside storage) consisting of water sprays ES25A*** Waste stacker conveyor No. 25A(to waste CD25A Wet suppression NSPS 000 pile,ID No. FAT) consisting of water Bras F6771 Enclosed pugmill with wet suppression(dust N/A N/A NSPS 000 and wasteprocessing) FWP Waste pile N/A N/A Coloring Plant ESCP1012A Headlap bin CDB8 Raw granule baghouse(5,750 ESCP 1012B Transfer conveyor No. 27 (grade silos to square feet of filter headla and raw granule bins) area) ESCP1012C Raw granule bin No. 1 ESCP1012D Raw granule bin No. 2 ESCPPFCI Line 1 dryer feed conveyor,two pickups line 1 raw granule and rerun bins to dryer) Emission Control Control Device Source ID No. Emission Source Description Device ID Description No. ESCPPFC2 Line 2 dryer feed conveyor,two pickups line 2 rawgranule and rerun bins todryer) ESCPPHI One natural gas-fired dryer,line 1 CDB9 Line 1 dryer NSPS UUU baghouse(7,111 square feet of filter area) ESCPPH2 One natural gas-fired dryer,line 2 CDB 10 Line 2 dryer NSPS UUU baghouse(7,111 square feet of filter area ESCPMI Mixer,line I CDBI I Line I mixer CAM baghouse(2,889 square feet of filter area ESCPM2 Mixer,line 2 CDB 12 Line 2 mixer CAM baghouse(2,889 square feet of filter area ESCPKI One natural gas-fired kiln, line 1 CDB 13 Line 1 kiln baghouse CAM (11,111 square feet of filter area ESCPK2 One natural gas-fired kiln, line 2 CDB 14 Line 2 kiln baghouse CAM (11,111 square feet of filter area ESCPLI- Blend bin No. IA CDB15 Finished granule 280A baghouse(6,111 ESCPLI-280B Product/blend bin No. 1B square feet of filter ESCPLI-280C Product bin No. 1C area) ESCPL2- Blend bin No. 2A 280A ESCPL2-280B Product/blend bin No. 2B ESCPL2-280C Product bin No. 2C ESCPLI-600 R screen No. 1 ESCPL2-600 R screen No. 2 ESCPL3-600 R screen No. 3 ESCP900 Waste bin ESCPA9 Line 3 product elevator No. 9,product and blend bins ESCPA10 R screen for line 3 (ROT4) ESCPCC Line 1 rerun conveyor(consolidation conveyor to rerun elevator No. 1 Emission Control Control Device Source ID No. Emission Source Description Device ID Description No. ESCPPH3 One natural gas-fired dryer,line 3 CDB 18 Line 3 dryer NSPS UUU baghouse(7,111 square feet of filter area ESCPM3 Mixer,line 3 CDB 19 Line 3 mixer CAM baghouse(2,889 square feet of filter area ESCPA6 Kiln feed elevator No. 3 (KFE3) CDB20 Line 3 kiln baghouse (11,111 square feet ESCPK3 One natural gas-fired kiln, line 3 of filter area) CAM ESCPCI Cooler,line I N/A N/A ESCPC2 Cooler, line 2 N/A N/A ESCPC3 Cooler,line 3 N/A N/A FCP44A Truck loading with dust suppression N/A N/A FCP44B Truck loading with dust suppression N/A N/A FCP363940 Finished product storage bins N/A N/A FCPA11 Product conveyor No. 1 and No. 2 loadouts N/A N/A to railcars (V)APPLICABLE AIR QUALITY REGULATIONS: As is the case with all Title V permits,Air Permit No. 09006T08 lists all of the air quality regulations that apply to each of the permitted emission sources. To avoid redundancy in this report,the applicable air quality regulations are discussed individually,and all of the permitted emission sources that are subject to a specific regulation are noted. (1) 15A NCAC 2D.0510:PARTICULATES FROM SAND, GRAVEL, OR CR USHED STONE OPERATIONS- The following emission sources are subject to 2D.0510:All permitted emission sources except for the four, natural gas-fired dryers (ID Nos. ES-1415, ES-CPPHI, ES-CPPH2, and ES-CPPH3), the three natural gas- fared kilns (ID Nos. ES-CPKI, ES-CPK2, and ES-CPK3), the three roof granule mixing units (ID Nos. ES- CPMI, ES-CPM2, and ES-CPM3), and the three coolers (ID Nos. ES-CPCI, ES-CPC2, and ES-CPC3). IN COMPLIANCE-To comply with 15A NCAC 21) .0510,the facility must not cause, allow, or permit any material to be produced,handled,transported or stockpiled without taking measures to reduce to a minimum any particulate matter from becoming airborne. The facility has installed enclosures,bagfilters and associated ductwork to locations throughout the plant that would be likely to produce particulates. These devices are effective controls and would significantly reduce particulate emissions. The permit defers to the monitoring, record keeping, and reporting requirements under the 40 CFR 60(NSPS), Subpart 000 and 15A NCAC 2D .0521 sections of the permit to ensure compliance with 15A NCAC 21) .0510. Compliance is expected. (2) 15A NCAC 2D.0515:PARTICULATES FR OM MISCELLANEO US INDUSTRIAL PROCESSES- The following emission sources are subject to 2D.0515: The three natural gas-fired kilns (ID Nos. ES-CPKI, ES- CPK2, and ES-CPK3), the three, roof granule mixing units (ID Nos. ES-CPMI, ES-CPM2, and ES CPM3) and the three coolers (ID Nos. ES-CPCI, ES-CPC2, and ES-CPC3). IN COMPLIANCE-The particulate emission limit for each of the subject emission sources is determined based on the individual process weight rates for each source. The facility has installed enclosures,bagfilters and associated ductwork to locations throughout the plant that would be likely to produce particulates. These devices are effective controls and would significantly reduce particulate emissions. The permit does not require any particulate emission testing. However,the facility is required to conduct annual inspections on the granule mixing units' bagfilters,to maintain production records on the coolers,and to submit a summary report every six months documenting any deviations to permit requirements. Upon request, 3M personnel were able to produce the required records. Additionally, all recent compliance reports have been submitted on time. Compliance is expected. (3) 15A NCAC 2D.0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES- The following emission sources are subject to 2D.0516: The four, natural gas-fired dryers (ID Nos. ES-141 S, ES-CPPHI, ES- CPPH2, and ES-CPPH3)and the three, natural gas-fired kilns (ID Nos. ES-CPKI, ES-CPK2, and ES-CPK3) IN COMPLIANCE-The sulfur dioxide emission limit for each of the subject emission sources is 2.3 pounds per million Btu heat input. Since the facility burns only natural gas and#2 fuel oil in its combustion equipment,the 15A NCAC 2D .0516 sulfur dioxide emissions standard should be achieved during normal operating conditions. No sulfur dioxide emission testing is required by the facility's air permit. Additionally,no monitoring/record keeping/reporting is required for sulfur dioxide emissions from the firing of natural gas in the combustion units. Compliance is expected. (4) 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS- The following emission sources are subject to 2D.0521: Those emission sources in the table in Section IV above that are not marked as subject to NSPS Subparts 000 or UUU. IN COMPLIANCE-The visible emission limit for each of the subject emission sources is 20 percent opacity. During the inspection, all of the emission sources observed in operation were well below the 20 percent opacity standard. The facility has installed enclosures,bagfilters and associated ductwork to locations throughout the plant that would be likely to produce particulates. These devices would be expected to significantly reduce the opacity of the exhaust streams. No visible emission testing is required for any of these sources by the facility's air permit. The permit does require the facility to perform monthly visible emissions observations on each of the subject emission sources,to record the results of the monthly observations in a logbook, and to submit a summary report of all visible emission observations on a semiannual basis. Upon request, 3M personnel were able to produce the required records. All recent compliance reports have been submitted on time. Compliance is expected. (5) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart 000) - The following emission sources are subject to NSPS, Subpart 000:All the emission sources in the table in Section IV above that are marked as subject to NSPS, Subpart 000. IN COMPLIANCE-To comply with the requirements of 40 CFR 60, Subpart 000 - Standards of Performance for Nonmetallic Mineral Processing Plants,the facility must maintain particulate and visible emissions below the source specific limits defined in the permit. The facility completed the initial NSPS performance test/initial compliance demonstration in August 2002 for the equipment originally installed at the plant. The permit requires the facility to evaluate the visible emissions from each of the affected sources on a monthly basis,to record the results of the monthly observations in a logbook, and to submit a summary report of all visible emission observations on a semiannual basis. Upon request, 3M personnel were able to produce examples of required records. Additionally, all recent compliance reports have been submitted on time. Compliance is expected. (6) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart UUU) - The following emission sources are subject to NSPS, Subpart UUU: The four natural gas-fired dryers (ID Nos. ES- 1415, ES-CPPHI, ES-CPPH2, and ES-CPPH3). IN COMPLIANCE-To comply with the requirements of 40 CFR 60, Subpart UUU-New Source Performance Standards for Calciners and Dryers in Mineral Industries,the facility must maintain particulate emissions below 0.057 grams per dry standard cubic meter and visible emissions below 10 percent opacity. The facility completed the initial NSPS performance test/initial compliance demonstration in August 2002 for the equipment originally installed at the plant. The facility is required to install, calibrate,maintain, and operate a continuous opacity monitoring system(COMS) on each of the dryers. The permit also requires the facility to conduct annual inspections on the dryers' bagfilters,to record the results of the inspections in a logbook, and to submit a summary report of all inspection and maintenance activities on a semiannual basis. Upon request, 3M personnel were able to produce the required records,which indicated that the facility is meeting their various NSPS requirements. Additionally, all recent compliance reports have been submitted on time. Compliance is expected. (7) 15A NCAC 2D.0540:PARTICULATES FROM FUGITIVE NON-PROCESS DUST EMISSION SOURCES - The following emission sources are subject to 2D.0540:All permitted emission sources except for the four natural gas-fired dryers (ID Nos. ES-1415, ES-CPPHI, ES-CPPH2, and ES-CPPH3), the three natural gas- fired kilns (ID Nos. ES-CPKI, ES-CPK2, and ES-CPK3), the three roof granule mixing units (ID Nos. ES- CPMI, ES-CPM2, and ES-CPM3), and the three coolers (ID Nos. ES-CPCI, ES-CPC2, and ES-CPC3). IN COMPLIANCE-To comply with 15A NCAC 2D .0540,the facility shall not cause or allow fugitive non- process dust emissions to cause or contribute to substantive complaints. According to the Raleigh Regional Office's complaint database,there have been no fugitive dust complaints against the facility. Based on observations made during the inspection,the facility appears to be meeting the requirements of 15A NCAC 2D .0540. Compliance is expected. (8) 15A NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING(40 CFR 64) - The following emission sources are subject to 2D.0614: The three natural gas fired kilns (ID Nos. ES-CPKI, ES-CPK2, and ES-CPK3) and the three roof granule mixing units (ID Nos. ES-CPM], ES-CPM2, and ES-CPM3). IN COMPLIANCE-To comply with compliance assurance monitoring(CAM)requirements and ensure that particulate and visible emissions from the subject emission sources do not exceed the applicable emission limits during normal operation,the facility is first required to monitor the pressure drop across each of the bagfilters serving the affected emission sources during periods of operation. Second,the facility must conduct an EPA Reference Method 22 visible emission evaluation once per month on each of the affected emission sources. If the CAM monitoring procedures indicate a potential problem with the operation of the affected units or control devices,the facility must take corrective action to fix the problem within the time frames specified in the permit. Based on record reviews and observations made during the inspection,the facility appears to be meeting the CAM requirements of 15A NCAC 2D .0614. Compliance is expected. (9) 15A NCAC 2Q.0711: TOXIC AIR POLL UTANT REQUIREMENTS-All of the permitted emission sources are subject to 2Q.0711. IN COMPLIANCE-To comply with 15A NCAC 2Q .0711,the facility must ensure that emissions of specified toxic air pollutants(TAPS)do not exceed the toxic permit emission rates(TPERs) specified in the permit. If any of the TPERs are exceeded,the facility must obtain a permit to emit TAPS and demonstrate compliance with state acceptable ambient levels(AALs). In the 2011 1S1 semiannual report,the facility indicated that it was discovered during an internal audit that the estimated 12-month emission rate of arsenic over the past years had been over the TPER. A review of database records indicated that the estimated arsenic emission rate from the facility has exceeded the TPER for at least the past 8 years. A modeling analysis was presented to the DAQ modeling staff on November 21,2011, addressing arsenic and cadmium emissions(see Subsection 12 below). The analysis,based on an increased production rate,was reviewed and found acceptable according to an October 1,2012 memo. Also,the arsenic annual limit has been increased. Compliance is demonstrated. (10) 15A NCAC 2Q.0317 AVOIDANCE CONDITIONS—TO AVOID 15A NCAC 2Q.1111 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) -All the emission sources in the table in Section IV that are included in the Coloring Plant, the four natural gas-fired dryers (ID Nos. ES-141 S, ES-CPPHI, ES-CPPH2, and ES-CPPH3), the three natural gas-fared kilns (ID Nos. ES-CPKI, ES-CPK2, and ES-CPK3), the three roof granule mixing units (ID Nos. ES-CPMI, ES-CPM2, and ES-CPM3) and the three coolers (ID Nos. ES-CPCI, ES-CPC2, and ES-CPC3). IN COMPLIANCE-To assure avoidance of the MACT regulatory requirements,the facility is required to record the total HAP emissions on a monthly basis. The facility 12-month total HAP emission must not exceed 10 tons per year for an individual HAP and 25 tons per year for all HAPs. According to the 2020 Emission Inventory,the largest contributor of HAP emissions was methanol. The methanol emissions were estimated to be approximately 4.9 tons for 2020. The other HAP emissions were relatively smaller and the total annual HAP emission rate was approximately 5.98 tons for 2020. Records reviewed indicated that the total annual HAPs emitted in 2020 were well below the 25 tpy limit. Compliance is expected. (11) 15A NCAC 2Q.I 100: TOXIC AIR POLLUTANT EMISSION LIMITA TION-All of the permitted emission sources are subject to 2Q.I100. IN COMPLIANCE-To comply with 15A NCAC 2Q .1100,the facility must ensure that emissions of specified toxic air pollutants (TAPS)do not exceed the limits listed in the permit which are based on air modeling performed. The modeling exercise involving arsenic and cadmium emissions was approved on October 1,2012. The 2020 emission inventory indicated that the annual releases of both of these toxic metals were well within the permit limits of 0.1 lb/yr of arsenic and 0.55 lb/yr of cadmium. (12) 15A NCAC 2D.18 06 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-All of the permitted emission sources are subject to 2D.1806. IN COMPLIANCE—The facility is required to manage and/or use control devices so to prevent objectionable odors from reaching their boundary. There were no remarkable odors detected during the inspection and there are no records of odor complaints that have been lodged against the facility. Compliance is expected. Additional Regulatory Conditions 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY(40 CFR 63, Subpart ZZZZ) -The following emission source is subject to 2D .I 111: Diesel-powered emergency fire pump. IN COMPLIANCE—There is a diesel-powered emergency fire pump that is presently sitting on the facility grounds disconnected from any water or electrical source. The facility has installed the pump in a more ideal location since the last inspection. The hour meter on the pump indicated 310.8 hours during the February 2017 inspection, 341 hours during the June 2018 inspection, 356.7 hours during the January 2019 inspection, 376.8 hours during the December 2019 inspection and 414.5 hours on May 1,2021. According to information gathered during the last inspection, annual maintenance on the unit was performed by Gregory Poole Power Systems on May 1,2021. Hour meter was not checked during this inspection. (VI)EXEMPT EMISSION SOURCES: No new emission source is observed which should be added to the insignificant list. (VII) CLEAN AIR ACT SECTION 112(r)REQUIREMENTS: Pursuant to 15A NCAC 2D .2100 "Risk Management Program," if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part 68. IN COMPLIANCE—3M Pittsboro is subject to the 112(r)program general duty clause,but does not maintain regulated chemicals onsite above the threshold quantities,which would require a risk management plan. (VIII)ENFORCEMENT HISTORY: 3M's Moncure plant has been issued five Notices of Violation(NOVs). On August 12,2021,the facility was issued an NOV for non like-for-like replacement of Dryer Baghouse CD No. CDB3). Also, failure to permit prior to installation of NSPS Subpart 000 portable backup conveyor(draft ID No. IS-32) and Waste Stacker Conveyor 25A. On December 11,2020,the facility was issued an NOV for failing to permit a redundant enclosed pugmill with wet suppression(draft ESID No. 6772),which is listed in the draft T07 permit. This pugmill was also subject to NSPS 000. On April 23,2018,the facility was issued an NOV for failing to conduct daily calibrations on its COMS unit,which services the dryers. The facility was issued an NOV on March 10, 2010 for failing to notify the Regional Office about permit deviations related to missing visible emissions observations. On June 6,2007,the company was issued an NOV for failure to submit a complete annual compliance certification for calendar year 2006 by the January 30, 2007 due date. Also,on October 3,2006,the company was issued an NOV for failure to submit a summary report of monitoring and record keeping activities for the first half of 2006. 3M has not been assessed any civil penalties related to air quality issues. (IX) STACK TEST HISTORY: The most recent stack test was a Method 9 test for VE performed on November 11, 2021. The testing was performed in response to a NOV. A testing was performed at this facility on June 2, 2021 for the backup feed conveyor that is being added to the permitted equipment list. The testing was performed to satisfy NSPS Subpart 000 requirements and the test report results are being reviewed by SSCB. A stack test was performed at this facility on August 8,2007. The testing was performed to satisfy NSPS Subpart 000 requirements. The tests appeared to demonstrate compliance to particulate and visible emissions standards. (X)EMISSION INVENTORY EMISSION CHANGES—There were no changes in the emission rates in the past two years that affect the fee status of this facility or potentially approach an emission limitation. The following summary describes emission changes between 2019 and 2020 and is an excerpt from the 2020 inventory's review/comment section of IBEAM. "PM10 and PM2.5 emissions increase were due to Hours of Operation increase in Crushing and Screening Plant and in Coloring Plant. Chromium emission decrease was due to the change of emission factor.." (XI) CONCLUSIONS/RECOMMENDATIONS: Based on observations made during the September 22,2022 inspection and review of the records sent via email on October 13, 2022, 3M Industrial Mineral Products appeared to be in compliance with the requirements of the current air permit. It is recommended that the facility be inspected again in one year.