AQ_F_1900104_20210728_CMPL_CmplDetLtr

STAIZ
ROY COOPER
Governor
ELIZABETH S.BISER
Secretary
MICHAELABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
July 28, 2021
CERTIFIED MAIL 7020 3160 0000 2219 1507
RETURN RECEIPT REQUESTED
Blake Arnett, Plant Manager
3M Pittsboro - Industrial Mineral Products
4191 Highway 87 South
Moncure,NC 27559
SUBJECT: DAQ Response to Notice of Violation Rescission Request
3M Pittsboro -Industrial Mineral Products
Moncure, Chatham County,North Carolina
Air Permit No. 09006T06
Facility ID No. 1900104
Fee Class: Title V
Dear Mr. Arnett:
On January 26, 2021, this office received a response to the Notice of Violation(NOV) issued to
the subject facility on December 11, 2020. The response requested that the Division of Air Quality
(DAQ) rescind the NOV. After carefully reviewing the information provided, the DAQ will not be
rescinding the NOV. The fact remains that 3M Pittsboro - Industrial Mineral Products was in violation
of North Carolina General Statute 143-215.108, 40 CFR 60.8, Standards of Performance for New
Stationary Sources (NSPS), Performance Tests, and 40 CFR 60.675, Subpart 000-Standards of
Performance for Nonmetallic Mineral Processing Plants, Test Methods and Procedures regarding the
newly added pugmill system(future ID No. F6772).
The permit applicability evaluation conducted by Raleigh Central Office (RCO) staff had
determined that the operation of the newly added pugmill system without prior inclusion in your air
quality permit is in violation of North Carolina General Statute 143-215.108. Secondly, the failure to
conduct an initial performance test within 180 days of initial startup of the newly added pugmill system
is in violation of 40 CFR 60.8,NSPS, Performance Tests and 40 CFR 60.675,NSPS Subpart 000. No
company response was required for the NOV concerning the existing unpermitted emission source,
pugmill (ID No. F6771), since the violation cited was being resolved through the permit renewal process
subsequent to Application No. 1900104.20A.
In support of these violations, the evaluation by RCO staff cited that the newly added pugmill
system has an 11.2% greater capacity than the existing pugmill (ID No. F6771), and the worse-case
uncontrolled potential PM emissions are greater than 5 tons per year. Thus, the source is not considered
an insignificant activity. For the existing pugmill,the 2003 and 2009 permit applications have both
provided uncontrolled emission factors with a primary control description of"total enclosure with wet
North Carolina Department of Environmental Quality I Division of Air Quality
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh,North Carolina 27609
NORTH CAROLINA _
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3M Pittsboro - Industrial Mineral Products
July 28, 2021
Page 2
suppression." Additionally, 3M Pittsboro's permit has been renewed twice (Permit Nos. 09006T03 and
09006T06) and had no change in operating or control scenarios for the existing pugmill.
Regarding the applicability of NSPS 000, the newly added pugmill system is an affected facility
that is subject to NSPS Subpart 000 per §60.670(a) and(e). NSPS Subpart 000 §60.670 (a)(1) states
that except as provided in paragraphs (a)(2), (b), (c), and(d) of this section, the provisions of this
subpart are applicable to the following affected facilities in fixed or portable nonmetallic mineral
processing plants: each crusher, grinding mill, screening operation,bucket elevator, belt conveyor,
bagging operation, storage bin, enclosed truck or railcar loading station. Furthermore,NSPS Subpart
000 §60.670 (e) states that an affected facility commencing construction after August 31, 1983, is
subject to NSPS Subpart 000. Based on the emission factor used in each application(i.e., 2003 and
2009) and industry data, a pugmill is similar to a screening operation with wet suppression per AP-42
Table 11.19.2-2,Emission Factors for Crushed Stone Processing. Thus, the newly added pugmill
system is not a wet material processing operation and is an affected facility under NSPS 000.
You are encouraged to thoroughly review your air permit and ensure that you understand what is
required. Strict adherence is expected with the terms and conditions of your air permit. If you have any
questions concerning this matter, please contact Matthew Mahler, Environmental Engineer, or Will
Wike, Compliance Supervisor, at(919) 791-4200.
Sincerely,
--J 74q-b"
Taylor Hartsfield, EIT, CPM
Raleigh Regional Supervisor
Division of Air Quality,NC DEQ
cc: RRO Files
�CLINAI
North Carolina Department of Environmental Quality I Division of Air Quality
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh,North Carolina 27609
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