AQ_F_1900104_20210812_CMPL_NOV (4)

STATE 4
ROY COOPER _
Governor
ELIZABETH S.BISER
Secretary
MICHAELABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
August 12, 2021
CERTIFIED MAIL 7020 3160 0000 2219 0760
RETURN RECEIPT REQUESTED
Blake Arnett, Plant Manager
3M Pittsboro - Industrial Mineral Products
4191 Highway 87 South
Moncure,NC 27559
SUBJECT: Notice of Violation—Failure to Obtain a Minor Modification Permit; Air Permit
Section 3, General Condition G,Permit Modifications
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 April 7, 2021, the Division of Air Quality(DAQ) received a minor modification permit
application for the 3M Pittsboro -Industrial Mineral Products (3M) facility located in Moncure,
Chatham County,North Carolina. The application (No. 1900104.21A) included the submission of
Form C1, which listed the total filter surface area of the Dryer Baghouse (Control Device ID No.
CDB3) as 12,002 square feet, while the current Air Permit No. 09006T06 lists 12,300 square feet.
During an inspection of the facility on May 28, 2021, Andrew Miller of 3M informed Matt Mahler,
DAQ inspector, that the CDB3 bagfilters were originally manufactured by Seneca. Seneca had gone
out-of-business many years ago, at which time 3M began installing replacement bagfilters for CDB3
with those manufactured by BHA Parker. 3M had not submitted the minor modification permit
application prior to the transition from Seneca bagfilters to BHA Parker bagfilters and thus is in
violation of Section 3, General Condition G,Permit Modifications.
Additionally, as an addendum to the Notice of Violation(NOV) issued on December 11, 2020,
the facility is being cited for two additional violations for operating unpermitted emission sources.
First, the facility's May 13, 2021 notification letter indicated that 3M operates a portable backup
conveyor(draft ID No. IS-32)that was installed around 2002. Second, Mr. Mahler observed an
existing Waste Stacker Conveyor 25A during his May 28, 2021 inspection. IS-32 and Conveyor 25A
are subject to New Source Performance Standards (NSPS) 40 CFR 60, Subpart 000, Standards of
Performance for Nonmetallic Mineral Processing Plants, and have been operating prior to obtaining
the proper air permit. The operation of IS-32 and Conveyor 25A without prior inclusion in your air
quality permit is in violation of North Carolina General Statute (NCGS) 143-215.108. Additionally,
the failure to conduct an initial performance test within 180 days of initial startup of the two conveyors
e-�M E Q�� 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
August 12, 2021
Page 2
is in violation of 40 CFR 60.8,NSPS, Performance Tests and 40 CFR 60.675 Subpart 000, Test
Methods and Procedures. It should be noted that the visible emissions test for Conveyor 25A was
conducted on June 2, 2021, and the test report is under review by the DAQ Stationary Source
Compliance Branch (SSCB).
The violation of NCGS 143-215.108 is explained as follows. Under the provisions of NCGS
143-215.108 - Control of sources of air pollution;permits required, paragraph(a) states, "Except as
provided in subsections (al) and(a2) of this section, no person shall do any of the following things or
carry out any of the following activities that contravene or will be likely to contravene standards
established pursuant to G.S. 143-215.107 or set out in G.S. 143-215.107D unless that person has
obtained a permit for the activity from the Commission and has complied with any conditions of the
permit:
(1) Establish or operate any air contaminant source, except as provided in G.S. 143-
215.108A.
(2) Build, erect,use, or operate any equipment that may result in the emission of an air
contaminant or that is likely to cause air pollution, except as provided in G.S. 143-
215.108A.
(3) Alter or change the construction or method of operation of any equipment or process
from which air contaminants are or may be emitted..."
In addition to the above violation, 40 CFR 60.8,NSPS, Performance Tests requires that within
60 days after achieving the maximum production rate at which the affected facility will be operated,
but not later than 180 days after initial startup of such facility, the facility shall conduct an initial
performance test according to 40 CFR 60.675 Subpart 000, Test Methods and Procedures. The
failure to conduct an initial performance test within 180 days of initial startup of both the portable
backup conveyor(draft ID No. IS-32) and Waste Stacker Conveyor 25A is in violation of 40 CFR 60.8
and 40 CFR 60.675.
These violations and/or any future violations are subject to the assessment of civil penalties as per
the authority of NCGS 143-215.114. This office recommends that you or a designated representative
conduct a complete inventory of all air emission sources and/or air cleaning devices at your facility and
assure that all sources are permitted that are required to be. If you have questions concerning specific
processes,please contact the DAQ Raleigh Central Office, Permitting Section.
To resolve this issue, please submit a written response to this office by September 3, 2021. As
an additional reminder, the three violations and any other permit deviations that occurred in
calendar year 2021 are required to be referenced in your facility's Annual Compliance
Certification (ACC),in accordance with Section 3, General Condition P of your Title V permit.
Your CY2021 ACC is due by March 1, 2022.
�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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919.791.4200 T 1919.881.2261 F

3M Pittsboro - Industrial Mineral Products
August 12, 2021
Page 3
Your cooperation in this matter is appreciated. If you have any questions regarding compliance
issues, please call Matthew Mahler, Environmental Engineer, or Will Wike, Compliance Supervisor, at
[phone].
Sincerely,
'��J� 74�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
NOFTiH G
0..rM_'n'&.1—W.QWnry
919.791.4200 T 1919.881.2261 F