AQ_F_1900104_20210916_CMPL_Fac-Ltr

3M Environment, 3M Center 0224-05-W-03
Health,and Safety St. Paul, MN 55144
September 16, 2021
Certified Mail 7020 3160 00013479 2609
Will Wike, Compliance Supervisor
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
Re: Notice of Violation—Unpermitted Emission Source;40 CFR 60 NSPS 000
Emission Testing Requirements;
3M Pittsboro—Industrial Mineral Products
Air Permit ID No. 1900104
Dear Mr.Wike:
3M Company(3M) is in receipt of the North Carolina Department of Environmental Quality's
Division of Air Quality(DAQ) Notice of Violation (NOV) issued on August 12, 2021.A written
response was requested by September 3, 2021; however, on August 31, 2021, an extension was
granted via email from the DAQ to September 17, 2021.
Prior to the issuance of the recent NOV,3M Pittsboro was issued a prior NOV on December 11,
2020.Since then, 3M has initiated facility changes, completed internal reviews of its operations,
equipment, and permit, and has completed a DAQ inspection held on May 28, 2021.Within this
letter,3M Pittbsoro would like to take the opportunity to review all the related compliance
matters associated with these actions to provide a clear understanding of the events taken
place, and provide the DAQ its plan of action moving forwardwith respect to these NOVs.
1. New Pugmill Notice of Violation (12/11/2020)
On December 11, 2020, 3M Pittsboro received an NOV alleging that the facility was in violation
of North Carolina General Statute 143-215.108, as well as 40 CFR 60.8, NSPS Performance Tests
and 40 CFR 60.675, NSPS Subpart 000, Test Methods and Procedures for the installation of an
additional pugmill system.On Thursday January 14, 2021, 3M conducted a meeting with Ms.
Judy Lee, Mr. Booker Pullen, and Mr. Matthew Mahler of the DEQ. During that time 3M
contended it was not in violation of said regulations because it was 3M's interpretation that 3M
Pittsboro complied with state permitting regulations in accordance to 15A NCAC 02Q.0503(8)
and 15A NCAC 02Q.0102(h)(5),and,additionally was not in violation of 40 CFR Part 60,Subpart
000—Standards of Performance for Nonmettallic Mineral Process Plants because pugmills are
not subject to the regulations.After this meeting,31VI provided a follow-up written response to
the DAQ received on January 26, 2021. 3M had not received any additional correspondence on
this matter until requesting follow-up from the DAQ on July 1, 2021 during a call un-related to
this NOV.The DAQ communicated they would prepare a follow-up letter,which was received on
July 28, 2021.The DAQ's response had not changed and the NOV would not be rescinded.

While 3M still holds it's position that the pugmills are not subject to 40 CFR Part 60,Subpart
000 and did comply with state permitting regulations, 3M wishes to resolve the violation and
respects the DAQ's position;therefore, 3M will conduct initial performance testing on the new
pugmill unit(future ID No. F6772) in accordance to 40 CFR 60.8, NSPS Performance Tests and 40
CFR 60.675, NSPS Subpart 000, Test Methods and Procedures. 3M will submit an NSPS 000
"after the fact" notification of construction and start-up for the newly added pugmill by October
1, 2021,and will schedule NSPS 000 initial performance testing to demonstrate compliance
with applicable NSPS 000 limits by December 1, 2021, pending test company availability.
2. Baghouse Total Filter Surface Area Notice of Violation (8/12/2021)
In reference to the recently issued NOV,3M Pittsboro is in violation of Section 3, General
Condition G, Permit Modifications of its Title V permit for not sumitting a minor modification
application prior to replacing the Seneca bagfilters to BHA Parker bagfilters.
In April 2021,31VI Pittsboro submitted a minor modification application to add two exhaust
pickups at existing transfer points between Conveyors#22 and#23A,and Conveyors#23A and
#23C.The pickups were to be routed to the Dryer Baghouse (CDB3) and Grade Silo Baghouse
(CDB6) respectively.Within the application, 31VI provided control equipment forms (Form Cl)for
each affected baghouse and provided the total filter surface area. Notably,the surface areas
provided in the application did not match the areas stated within the permit.The information
was confirmed to be out of date due to the utilization of a new bag manufacturer with slightly
varying filter cloth areas.
Since the application was submitted,3M Pittsboro has verifieid the total surface areas of all its
baghouses and confirmed the actual surface areas of all its baghouses do not reflect the surface
areas listed in its Title V permit because of the utilization of the BHA Parker bagfilters. 3M is in
process of preparing an additional minor modification application and intends to add these
changes within the contents of this application. Updated C1 Forms will be provided as well as a
Professional Enginering(PE) certification included as necessary for any baghouse with an
exhaust flow rate greater than 10,000 ACFM. 3M expects to have this application submitted by
October 31, 2021. 31VI understands a minor modification will be required if any of its baghouse's
total filter surface areas change in the future.
3. Unpermitted Equipment Notice of Violation(8/12/2021)
In reference to the recently issued NOV,31VI Pittsboro is in violation North Carolina General
Statute 143-215.108,as well as 40 CFR 60.8,NSPS Performance Tests and 40 CFR 60.675, NSPS
Subpart 000, Test Methods and Procedures for installing, operating and failing to perform initial
performance tests on two unpermitted emission sources, including a portable backup conveyor
(future ID No. IS-32) and Waste Stacker Conveyor#25A. In a 2003 application,the portable
backup conveyor was submitted as IA5 and was identified as an insignificant unit not subject to
15A NCAC 02Q.0102(b)(2)(E)(i) and.0503(7). IS-32 is not currently listed in the Title V permit.
Conveyor 25 (F72) is an encosed permitted conveyor and is further controlled by wet
suppression and feeds Conveyor 25A which transfer waste material to the outside waste piles.
IS-32 and Conveyor 25A are required to be permitted due to being subject to 40 CFR Part 60,
Subpart 000. In July 2021, 3M prepared and submitted the appropriate minor modification
application to the DAQ.The DAQ deemed the application (Appplication No. 1900104.21B)

complete on July 28, 2021. 3M will continue to work with the DAQ if there are any additional
questions throughout the application process.
NSPS 000 initial performance testing of the portable back-up conveyor was completed on June
2,2021. Please note that in the August 12, 2021 NOV, DAQ incorrectly states that Conveyor 25A
had initial performance testing conducted on June 2,2021. 31VI will conduct initial performance
testing on Conveyor 25A(future ID No. IS-32) in accordance to 40 CFR 60.8, NSPS Performance
Tests and 40 CFR 60.675, NSPS Subpart 000, Test Methods and Procedures, prior to December
1, 2021, pending test company availability.
4. Title V Permit#.09006T06, General Condition F. Circumvention Deviation (7/30/2021)
On July 30, 2021, 3M Pittsboro disclosed a deviation in in its Semiannual Deviation Report in
accordance to General Condition F, Circumvention of its Title V permit regarding its permitted
Megatex Screens.3M discussed this deviation in depth on Wednesday September 15, 2021 with
DAQ personnel including: Ms.Taylor Hartsfield, Ms.Judy Lee, Ms. Heather Sands, Mr. Booker
Pullen,and Mr. Mark Ciulla. During the call, 3M discussed its commitment to rectifying this non-
compliance event and communicated it's in process of considering a number of viable options—
specifically installing an inner liner hose within each of the ducts. Knowing the duct lines are not
adding exhaust load in comparison to the duct's original design, 3M Corporate Environmental
believes 31VI Pittsboro can begin this work immediately and qualify as actions and changes
considered to be exempt from permit requirements in accordance to 15A NCAC
02Q.0102(g)(1)(a):
maintenance,structural changes, and repairs activities that do not increase the capacity
of such process and do not cause any change in the quality or nature or an increase in
quantity of an emission of any regulated air pollutant.
3M requests guidance from the DAQ on its position that these changes can begin immediately
as an exemption from permitting requirements.Additionally, 3M and the DAQ has agreed that
3M will follow-up with an additional disclosure letter identifying additional information for the
DAQ to provide proper guidance on the next steps. 3M continues to evaluate its processes and
operations and continues to strive in achieving a world class EHS program. 3M thanks the DEQ
again for its time to meet and discuss both Notice of Violations and deviation.We look forward
to any future discussions as needed. Please contact myself or Ryan Navis at [e-mail]
or at 651-230-4776 if there are any additional questions or information needed.
Sincerely,
Blake Arnett
Plant Director
([e-mail])

cc(electronically)
Judy Lee, Division of Air Quality Permitting Section ([e-mail])
Booker Pullen, Division of Air Quality Permitting Section ([e-mail])
Taylor Hartsfield, Division of Air Quality([e-mail])
Heather Sands, Division of Air Quality([e-mail])
Mark Cuilla, Division of Air Quality Permitting Section ([e-mail])
Ryan Navis,Advanced Environmental Engineer([e-mail])
Andrew Miller, EHS Supervisor([e-mail])
Della Hasan, Environmental Engineer([e-mail])
Connor Doede, EHS Engineer, ([e-mail])
Andrea Russell,Senior Environmental Scientist([e-mail])
Troy Jordan,Air Quality Compliance Manager([e-mail])