AQ_F_1900104_20220208_CEM_RptRvwLtr

Etc STATE
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ROY COOPER
Governor
ELIZABETH S.BISERf,z�M
Secretary
MICHAEL ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
February 8, 2022
Mr. Blake Arnett
Plant Director
3M Company—Pittsboro
4191 Highway 87 South
Moncure,North Carolina 27559
Subject: Review of 2021 Semiannual COMS Report, Second Half
3M Pittsboro—Industrial Mineral Products
Moncure, Chatham County,North Carolina
Air Quality Permit No. 09006T08
Facility ID: 1900104
Dear Mr. Arnett:
Thank you for the timely submittal of the subject report, dated January 28, 2022, and
received February 2, 2022. The excess emissions report(EER)provided information about the
continuous opacity monitoring systems (COMS) operating at 3M's Pittsboro facility during the
second half of 2021. Specifically, COMS data for the following natural gas-fired dryers were
reviewed: C&S Dryer(ID No. ES1415), Line 1 Coloring Dryer(ESCPPH1), and Line 2
Coloring Dryer(ESCPPH2). The Division of Air Quality(DAQ) has completed its review of the
submittal and has the following comments:
1. The natural gas-fired dryers were reviewed for compliance with the underlying opacity
standard set forth at NCAC 2D .0524 (40 CFR Part 60, Subpart UUU -Standards of
Performance for Calciners and Dryers in Mineral Industries) and Air Permit No. 09006,
Specific Conditions 2.1.B.2 and 2.1.D.2. The EER indicated there were no excess emissions
and consequently no violations of the applicable standard.
2. A review was also conducted for compliance with good operation and maintenance (O&M)
practices pursuant to NCAC 2D .0524 (NSPS UUU, including Subpart A - General
Provisions), 40 CFR 60.11(d), and 40 CFR 60.13. Unless otherwise specified in regulation,
DAQ considers sources to have operated with good O&M if the percent excess emissions
(%EE) and percent monitor downtime (%MD) are less than the target criteria of 6% for any
single quarter and less than 3% for two consecutive quarters. When compared to the total
operating time of the dryers, %EE and%MD were reported as shown in the table below and
appear to indicate the use of good O&M practices for minimizing emissions.
D Q2177 North Carolina Department of Environmental Quality I Division of Air QualityE West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
NORTH CAROLINA
oePanment of Environmental Uwi\ /� 919.707.8400

Mr. Blake Arnett
February 8, 2022
Page 2
Unit Quarter %EE %MD
C&S Dryer 3rd 0.0 1.01
4th 0.0 0.84
Line 1 Coloring Dryer 3rd 0.0 4.14
4th 0.0 0.98
Line 2 Coloring Dryer 3rd 0.0 4.04
4th 0.0 1.59
3. The 2021 third and fourth quarter audits of the COMS units were reviewed in accordance
with 40 CFR Part 60, Appendix F, Procedure 3 - Quality Assurance Requirements for
Continuous Opacity Monitoring Systems at Stationary Sources. The quality assurance (QA)
test results for the COMS appear to have met the quarterly specifications and are acceptable.
In addition to the mailing of this letter, an electronic copy(e-copy) is being provided for
your records. If you should have any questions regarding this review, please contact me at (919)
707-8410 or [e-mail].
Sincerely,
ennis U. Igb6ko, Environmental ngineer
Division of Air Quality,NCDEQ
c: Blake Arnett, 3M (e-copy)
Della Hardy, 3M (e-copy)
Taylor Hartsfield, DAQ RRO (e-copy)
Gary Saunders, DAQ SSCB (e-copy)
IBEAM Documents, 1900104 (e-copy)
Central File, Chatham County