AQ_F_1900104_20220215_ST_RvwLtr

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ROY COOPER =_
Governor
ELIZABETH S.BISER
Secretary
MICHAELABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
February 15, 2022
Blake Arnett, Plant Director
3M Pittsboro—Industrial Mineral Products
4191 Highway 87 South
Moncure,NC 27559
Subject: Method 9 Testing of Dual Pugmill, 25 Conveyor, & 25A Conveyor Transfer Points
3M Pittsboro—Industrial Mineral Products
Moncure, Chatham County,North Carolina
Facility ID: 1900104; Permit No.: 09006T08
Testing Conducted: November 11, 2021 and December 1, 2021
Tracking No.: 2021-304ST
Dear Mr. Arnett:
On January 18, 2022, this office received the results from the EPA Method 9 tests performed November
11, 2021 and December 1, 2021 at the subject facility. Because the December 1 test was conducted at
higher throughput rate, the November 11 results will not be evaluated in this review. The EPA Method
9 test results were reviewed and demonstrated that visible emissions at the tested material throughput
rate were in compliance with the applicable standards during the testing period. However, the testing
took place with a material throughput rate that was significantly lower than the potential throughput
used when this equipment was added to the air permit. Because compliance testing was conducted at
this lower throughput, compliance cannot be determined for the potential throughput. Accordingly,
DAQ will modify your air permit with a lower potential throughput as part of the current renewal
application that is in process.
Additionally, in an email dated January 25, 2022, it was clarified that there is not any wet suppression
directly applied at the 25 Conveyor and 25A Conveyor. Instead, both conveyors rely on water carryover
from upstream water sprays at the Dual Pugmill to control fugitive emissions. As such, periodic
inspections for these conveyors shall occur at the upstream water sprays at the Dual Pugmill. This
change to source descriptions in the air permit will be addressed as part of the current renewal
application that is in process.
The Dual Pugmill, 25 Conveyor, and 25A Conveyor Transfer Points are subject to 40 CFR 60 New
Source Performance Standards Subpart 000. As required by 40 CFR 60 Subpart 000, including
Subpart A "General Provisions," for affected facilities constructed, modified, or reconstructed on or
after April 22, 2008, the emission limit for fugitive emissions from conveyor belts, screening operations,
and other affected facilities is 7% opacity. The test results indicate that the highest six-minute average
during the testing period was 0% opacity.
D E Q�� North Carolina Department of Environmental Quality I Division of Air Quality
Raleigh Regional Office 13800 Barrett Drive I Raleigh,North Carolina 27609
NORTH CAROLANA
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3M Pittsboro—Industrial Mineral Products
February 15, 2022
Page 2
As a reminder, 40 CFR 60 Subpart 000 contains specific directions for the scheduling of future visible
emissions tests for conveyors, screens, and crushers. Additionally,please read your permit closely for
the language associated with the emission source throughput limits and testing requirements. If you
have any questions concerning this matter, please contact Dawn Reddix, Environmental Engineer, or me
at [phone].
Sincerely,
William T. Wike, Jr., Compliance Supervisor
Division of Air Quality, Raleigh Regional Office
cc: RRO Files