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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS February 9, 2021
Director
Mr. Blake Arnett
Plant Manager
3M Company—Pittsboro
4191 Highway 87 South
Moncure,North Carolina 27559
Subject: Review of 2020 Semiannual COMS Report, Second Half
3M Pittsboro—Industrial Mineral Products
Moncure, Chatham County,North Carolina
Air Quality Permit No. 09006T06
Facility ID: 1900104
Dear Mr. Arnett:
Thank you for the timely submittal of the subject report,dated January 26,2021.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 2020. Specifically, COMS
data for the following natural gas-fired dryers were reviewed: C&S Dryer(ID No.ES 1415),Line 1
Coloring Dryer(ESCPPHI), 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.
NORTH CAROHNAD_E Q
Depart—t of Environmental Duality
North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707.8400

Mr. Blake Arnett
February 9, 2021
Page 2
Unit Quarter %EE %MD
C&S Dryer 3rd 0.0 0.63
4th 0.0 0.44
Line 1 Coloring Dryer 3rd 0.0 0.83
4th 0.0 0.65
Line 2 Coloring Dryer 3rd 0.0 1.21
4th 0.0 0.80
3. The 2020 third and fourth quarter audits of the COMS units were reviewed in accordance
with Procedure 3 of 40 CFR Part 60, Appendix F - Quality Assurance Procedures. The
quality assurance (QA)test results for the COMS (which were performed on both the
AirVision and Wonderware data collection software) appear to have met the quarterly
specifications and are acceptable.
Due to the COVID-19 restrictions on DAQ staff and our office operations, the mailing of
this letter may be delayed. In the meantime, 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)
Andrew Miller, 3M (e-copy)
Will Wike, DAQ RRO (e-copy)
Dena Pittman, DAQ RRO (e-copy)
Gary Saunders, DAQ SSCB (e-copy)
IBEAM Documents, 1900104 (e-copy)
Central File, Chatham County