HomeMy WebLinkAboutAQ_F_1900104_20191210_CMPL_InspRpt (4) Yll l"r
NORTH CAROLINA DIVISION OF Raleigh Regional Office
AIR QUALITY 3M Pittsboro- Industrial Mineral Products
NC Facility ID 1900104
Inspection Report County/FIPS: Chatham/037
Date: 12/10/2019
Facility Data Permit Data
3M Pittsboro- Industrial Mineral Products Permit 09006/T06
4191 Highway 87 South Issued 4/6/2016
Moncure,NC 27559 Expires 3/31/2021
Lat:35d 39.6560m Long: 79d 10.0390m Class/Status Title V
SIC: 3295/Minerals,Ground Or Treated Permit Status Active
NAICS: 327992/Ground or Treated Mineral and Earth Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Blake Arnett Blake Arnett Adam Driscoll NSPS: Subpart 000, Subpart UUU
Plant Manager Plant Manager Senior Environmental
(919)642-4011 (919)642-4011 Engineer
(651)737-3622
Compliance Data
Comments: In Compliance
Inspection Date 12/10/2019
Inspector's Name Matthew Mahler
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: (//v �Zp On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2018 101.45 0.1400 22.99 11.41 19.23 60.92 10543.00
2017 97.06 0.1400 22.78 10.76 19.07 74.72 9825.00
2016 86.83 0.1300 21.69 9.70 18.16 66.95 8691.00
*Hi hest HAP Emitted(inpounds)
Five Year Violation History:
Date Letter Tyne Rule Violated Violation Resolution Date
04/23/2018 NOV 2D.0524 New Source Performance Standards 06/05/2018
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
(1)DIRECTIONS: From Raleigh,take US-1 South to US-64 in Cary. Take US-64 West towards Pittsboro. Just
prior to Pittsboro,take exit 386 for US-64 Business and follow 3 miles to traffic circle. Then take US 15-501 South
(merges with NC-87 South)approximately 4 miles, and 3M Industrial Minerals Products will be on the east(left)
side of the highway.
(II)FACILITY DESCRIPTION: At the Moncure plant, 3M Industrial Mineral Products(3M)manufactures
various types of stone granules to sell to the asphalt shingle industry. Luck Stone Corporation operates a stone
crushing operation on the same property and supplies the 3M plant with 4-inch stone. 3M then crushes,dries,
screens,colors and bakes the stone materials to produce the granules. The final product is shipped out in specially
designed bulk trucks. The 3M plant over the past years has had approximately 55 full-time employees.
Historically,the Coloring Plant has operated with three 8-hour shifts(6 am-2 pm,2 pm-10 pm,and 10 pm—6 am).
The Crushing/Screening Plant operates on a 24-hour basis. Both plants typically run Monday through Friday only.
Be prepared to use standard safety items at this facility. Although the facility in the past has provided dust masks,
there is a policy now that dust masks will not be provided unless a visitor is accompanied with a written doctor's
statement authorizing respirator usage. The dust levels can be significant in the facility areas where
crushing/screening occurs.
(IIn INSPECTION SUMMARY: I(Matt Mahler)arrived at the facility on December 10, 2019 to perform a
compliance inspection. There were no remarkable odors, depositions, or visible emissions. Once in the
administrative building,I met with Mr. Stanley B. Carter,Environmental Engineer, as Mr.Blake Arnett,Plant
Manager,Facility Contact and Plant Manager was not onsite. Mr. Carter and I then began the inspection by
reviewing the stipulations of the permit and the record keeping. Overall,the records appeared to be well
maintained. Comments about observations made during the inspection are provided below for the emission
sources and specific conditions listed in the facility's current air permit.
Afterwards,we toured the physical plant. The crushing/screening buildings and the two production lines in the
Coloring Plant were operating on the day of this inspection. The plant appeared to be well maintained and
operating well from an air quality standpoint.
(IV)PERMITTED EMISSION SOURCES: At the time of the inspection, 3M's Moncure Plant was operating
under Air Permit No. 9006T06,which became effective on April 6, 2016 and expires on February 31, 2021. The
following table identifies all the emission sources and control devices for which the Title V permit was issued:
Control Control
Emission Source
ID No. Emission Source Description Device ID Device
No. Descri tion
Crushing
ES 123 Plant feed conveyor No. 1 (feed pile to surge bin) CDB 1 Crusher
NSPS 000 baghouse
ES412 Surge bin No. 1
NSPS 000 (6,500 square
ES6NSPS *1 Feed conveyor No. 2(surge bin to C crusher) feet j f filter
area
ES607.2 C crusher
NSPS 000
ES2327A G crusher feed bin No. 1
NSPS 000
ES2426.1 G crusher feed conveyor No. 8A(G crusher feed
NSPS 000 bin No. 1 to G crusher No. 1)
Emission Source Control Control
ID No. Emission Source Description Device ID Device
No. Descri tion
Crushing and Screening Plant
ES2426.2 G crusher No. 1
NSPS 000
ES3031 M feed transfer bin
NSPS 000
ES3941 L crusher bin No. 1
NSPS 000
ES4347.1 L crusher feed conveyor No. 16A(L crusher feed
NSPS 000 bin to L crusher)
ES4347.2 L crusher
NSPS 000
ESC3 Product conveyor No. 3 (C crusher to D screen bin
NSPS 000 No. 1)
ESC23A.1 Conveyor No. 23A(baghouse hopper screw
NSPS 000 conveyor to dust conveyor No. 23C)
ES 16-A Dryer and G crusher conveyor No. 9(G crusher to
NSPS 000 screens No.2 and No. 3 feed bin)
ES32.1 L crusher product conveyor No. 17,two pickups
NSPS 000 (M feed transfer bin and L crusher No. 1 to M
screen feed bin)
ES32A L crusher product conveyor No. 17 (L crushers to
NSPS 000 conveyor No. 18A)
ES32B Conveyor No. 18A(L crusher product conveyor
NSPS 000 No. 17 to live M screens feed bin)
ES340-A Live M screens feed bin,two pickups
NSPS 000
ES 1721 A Screen
NSPS 000 D screen bin No. 2 baghouse No.
ES1721B CDB2 1 (11,750
NSPS 000 D screen No. 2 feeder square feet of
ES 1721 C filter area)
NSPS 000 D screen No. 2
ES 1721 D G crusher bin feed conveyor No.5 (D screen No.2
NSPS 000 to G crusher bins)
ES1721E L circuit new feed conveyor No. 13 (D screen No.
NSPS 000 2 to M transfer bin)
ES3537A M screen No. 1
NSPS 000
ES3537B
NSPS 000 M screen No. 2
ES3537C M screen No. 3
NSPS 000
Emission Source Control Control
ID No. Emission Source Description Device ID Device
No. Descri tion
Crushing and Screening Plant
ES3537D L crusher feed bin conveyor No. 14,three pickups
NSPS 000 (M screens to L crusher bins)
ES3537E Grade collecting conveyor No. 19,three pickups
NSPS 000 (M screens Nos. 1,2,and 3 to M screens Nos.4,5,
and 6)
ES3537F Waste conveyor No. 21,three pickup points(M
NSPS 000 screens to waste bin)
ES8913A D screen bin No. 1
NSPS 000
ES8913B D screen No. 1 feeder
NSPS 000
ES8913C D screen No. 1
NSPS 000
ES8913D Undersize conveyor No. 3 (D screen No. 1 to dryer
NSPS 000 feed conveyor No. 7)
ES8913E C bin feed conveyor No. 4(D screen No. 1 to C
NSPS 000 crusher bin)
ES8913F Dryer feed conveyor No. 7(undersize conveyor
NSPS 000 No. 3 to dryer)
Dryer
ESC23A.2 Conveyor No. 22 (baghouse hopper screw baghouse
NSPS 000 conveyor to clust conveyor No.
feet of filter
area
CDC1 Dryer cyclone
(eight feet in
diameter) in
CD133 series with
NSPS 5 One natural gas-fired dryer Dryer
er
baghouse
(12,300 square
feet of filter
area)
Crushing and Screening Plant(continued)
ES16-B Dryer and G crusher product conveyor No. 9 (G
NSPS 000 crusher to screens No.2 feed bin
ES33A Conveyor No. 18A(conveyor No. 17 to conveyor
NSPS 000 No. 18B
ES33B Conveyor No. 18B (conveyor No. 18A to live M
NSPS 000 feed bin)
ES340-B Screen
NSPS 000 Live M feed bin,two pickups baghouse No.
ES1822A CDB4 2(9,000 square
NSPS 000 D screen bin No. 3 feet of filter
area)
ES 1822B D screen feeder No. 3
NSPS 000
ES1822C D screen No. 3
NSPS 000
ES1822D Feed conveyor No. 5,two pickups (D screens
NSPS 000 Nos. 2 and 3 to G crusher bin)
ES2327B Feed conveyor No. 6(D screens to G crusher bins)
NSPS 000
ES3537G M screen No. 4
NSPS 000
ES3537H M screen No. 5
NSPS 000
ES3537I M screen No. 6
NSPS 000
ES3537J L crusher feed bin conveyor No. 14,three pickups
NSPS 000 (M screens to L crusher)
ES3537K Grade collecting conveyor No. 19,three pickup
NSPS 000 points (M screens to grade silos)
ES3537L Waste conveyor No.21,three pickups (M screen
NSPS 000 to waste bin)
ESC23C 24"Dust conveyor No. 23C(baghouse hopper to
NSPS 000 dust elevator)
ES 16-C Dryer and G crusher product conveyor No. 9 (G
NSPS 000 crusher to screens No. 2 feed bin)
ES32.2 L crusher product conveyor No. 17(L crushers
NSPS 000 and M feed transfer bin to M screen feed bin)
ES38 Conveyor No. 14 (M screens to conveyor No. Crusher
NSPS 000 14A) baghouse No.
ES39 Conveyor No. 14A(conveyor No. 14 to L crusher CDB5 2(5,250 square
NSPS 000 feed bins)
327 feet of filter
ES2
NS 3 7 G crusher bin No. 2 area)
ES2729.1 G crusher feed conveyor No. 8B(G crusher bin to
NSPS 000 G crusher)
ES2729.2 G crusher No. 2
NSPS 000
Crushing and Screening Plant(continued)
ES4042 Feed conveyor No. 14A to L crusher bin No. 2
NSPS 000
ES4043 L crusher bin No.2
NSPS 000
ES4044 Feed conveyor No. 16B to L crusher No.2
NSPS 000
ES4448.1 L crusher feed conveyor No. 16B
NSPS 000
ES4448.2 L crusher No. 2
NSPS 000
ES49A Grade collection conveyor No. 19 (M screens to
NSPS 000 grade bucket elevator)
ES49B Grade bucket elevator No. 1,two pickups(grade Crusher
NSPS 000 collecting conveyor No. 19 to grade transfer CDB5 baghouse No.
conveyor No. 20) (continued 2(5,250 square
ES50 Grade transfer conveyor No. 20,two pickups feet of filter
NSPS 000 ( ade bucket elevator to grade silos) area)
ES57 Grade silo conveyor No. 26, three pickups(grade
NSPS 000 silos to bin discharge bucket elevator)
ES58 Grade transfer conveyor No. 27 (bin discharge
NSPS 000 elevator to coloring plant)
ES59 Bin discharge bucket elevator No. 4,two pickups
NSPS 000
ES5155A silo No. 1
NSPS 000
ES5155B silo No. 2
NSPS 000
ES5155C Grade silo No. 3
NSPS 000
ES23C Dust conveyor No.23C(baghouse hopper loadout
NSPS 000 to dust elevator)
ES63A Dust conveyor No. 23C (hoppers for screens,
ES63B Dust elevator No. 3,two pickups
NSPS 000
Waste
ES68A Waste conveyor No.21 handling
NSPS 000 g
ES68B CDB7 baghouse
NSPS 000 Waste elevator No. 2,two pickups (2,750 square
ES6466 feet of filter
NSPS 000 Dust bin area)
ES6466SC Dust bin screw conveyor(waste handling
NSPS 000 baghouse hopper to pugmill)
ES6970 Waste bin
NSPS 000
Crushing and Screening Plant(continued)
ESAI
NSPS 000 D screen No. 4 assembly(includes the vibrator)
ESAS
NSPS 000 Load-in to conveyor No. 18C Screen
ESA6 baghouse No.
NSPS 000 Line 3 live M feed bin CDB16 3(9,000 square
ESA7 feet of filter
NSPS 000 Line 3 M screen assemblies area)
ESAl 1
NSPS 000 Screen baghouse No. 3 ash loadout
ESA2 G bin feed conveyor No. 6 loadout to bin feed
NSPS 000 conveyor No. 6A
ESA3 G feed bin No. 3
NSPS 000
ESA4 Crusher
NSPS 000 G crusher No. 3 baghouse No.
ESA8 CDB17 3(6,500 square
NSPS 000 Feed bin No. 3 feet of filter
ESA9 area)
NSPS 000 L crusher No. 3
ESAl2
NSPS 000 Crusher baghouse No. 3 ash loadout
F61 Enclosed dust conveyor No. 23C(dust conveyor N/A N/A
NSPS 000 No. 23A to transfer conveyor No. 23C)
F72 Enclosed waste stacker conveyor No. 25 with N/A N/A
NSPS 000 wet suppression(puginill to outside storage)
F6771 Enclosed pugmill with wet suppression(dust N/A N/A
NSPS 000 and waste processing)
FWP Waste pile N/A N/A
Coloring Plant
ESCP1012A Headlap bin
ESCP 1012B Transfer conveyor No.27(grade silos to headlap
and raw granule bins) Raw granule
ESCP1012C Raw granule bin No. 1 baghouse
ESCP1012D Raw granule bin No. 2 CDB8 (5,750 squarefeet of filter
ESCPPFCI Line 1 dryer feed conveyor,two pickups(line 1 area)
raw granule and rerun bins to dryer)
ESCPPFC2 Line 2 dryer feed conveyor,two pickups(line 2
raw granule and rerun bins to dryer)
Line I dryer
ESCPPHI baghouse
NSPS UUU One natural gas-fired dryer, line 1 CDB9 (7,111 square
feet of filter
area)
Coloring Plant(continued)
Line 2 dryer
ESCPPH2 baghouse
NSPS UUU One natural gas-fired dryer,line 2 CDB10 (7,111 square
feet of filter
area
Line 1 mixer
ESCPMI baghouse
CAM Mixer,line 1 CDB11 (2,889 square
feet of filter
area)
Line 2 mixer
ESCPM2 baghouse
CAM Mixer,line 2 CDB12 (2,889 square
feet of filter
area)
Line 1 kiln
ESCPKI baghouse
CAM One natural gas-fired kiln, line 1 CDB13 (11,111 square
feet of filter
area)
Line 2 kiln
ESCPK2 baghouse
CAM One natural gas-fired kiln, line 2 CDB14 (11,111 square
feet of filter
area)
ESCPLI-280A Blend bin No. lA
ESCPLI-280B Product/blend bin No. 1B
ESCPLI-280C Product bin No. 1 C
ESCPL2-280A Blend bin No. 2A
ESCPL2-280B Product/blend bin No.2B Finished
ESCPL2-280C Product bin No. 2C baghouse
CDB 15 ESCPLI-600 R screen No. 1 (6,111 square
feet of filter
ESCPL2-600 R screen No. 2 area)
ESCPL3-600 R screen No. 3
ESCP900 Waste bin
ESCPA9 Line 3 product elevator No. 9,product and blend
bins
ESCPAI0 R screen for line 3 (ROT4)
Coloring Plant(continued)
ESCPCC Line 1 rerun conveyor(consolidation conveyor CDB15
to rerun elevator No. 1) (continued)
Line 3 dryer
ESCPPH3 baghouse
NSPS UUU One natural gas-fired dryer,line 3 CDB18 (7,111 square
feet of filter
area)
Line 3 mixer
ESCPM3 baghouse
CAM Mixer, line 3 CDB19 (2,889 square
feet of filter
area)
ESCPA6 Kiln feed elevator No. 3 (KFE3) Line 3 kiln
baghouse
C �PK3 CDB20 (11,111 square
C One natural gas-fired kiln,line 3 feet of filter
area)
ESCPCI Cooler,line 1 N/A N/A
ESCPC2 Cooler, line 2 N/A N/A
ESCPC3 Cooler, line 3 N/A N/A
FCP44A Truck loading with dust suppression N/A N/A
FCP44B Truck loading with dust suppression N/A N/A
FCP363940 Finished product storage bins N/A N/A
FCPA11 Product conveyor No. 1 and No. 2 loadouts to N/A N/A
railcars
During the facility walkthrough,some of the listed sources were observed. Line 1 and Line 2 of the Coloring Plant
were operating during the inspection. The Crushing and Screening Plant was operating normally during the time
of the inspection. All the equipment that is listed as being associated with the proposed Line 3 has not been
installed and there is no projected date for construction. Mr. Carter indicated that there are plans of crushing side
of the plant in the next couple of years. Of the emission sources observed in operation,no significant visible
emissions were noted.
(V)APPLICABLE AIR QUALITY REGULATIONS:As is the case with all Title V permits, Air Permit No.
9006T06 lists all of the air quality regulations that apply to each of the permitted emission sources. To avoid
redundancy in this report,the applicable air quality regulations are discussed individually, and all of the permitted
emission sources that are subject to a specific regulation are noted.
(1)15A NCAC 2D.0510:PAR TIC ULA TES FROM SAND, GRAVEL, OR CRUSHED STONE OPERATIONS-The
following emission sources are subject to 2D.0510:All permitted emission sources except for the four, natural
gas-fired dryers(ID Nos.ES 1415,ES-CPPHI,ES-CPPH2,and ES-CPPH3), the three natural gas-fired kilns(ID
Nos.ES-CPK1,ES CPK2, and ES-CPK3), the three roofgranule mixing units(ID Nos.ES-CPM1,ES-CPM2, and
ES CPM3), and the three coolers (ID Nos. ES CPCI,ES-CPC2, and ES-CPC3).
IN COMPLIANCE-To comply with 15A NCAC 2D .0510,the facility must not cause,allow, or permit any
material to be produced,handled,transported or stockpiled without taking measures to reduce to a minimum any
particulate matter from becoming airborne. The facility has installed enclosures,bagfilters and associated
ductwork to locations throughout the plant that would be likely to produce particulates. These devices are effective
controls and would significantly reduce particulate emissions. The permit defers to the monitoring,record
keeping, and reporting requirements under the 40 CFR 60 (NSPS), Subpart 000 and 15A NCAC 2D .0521
sections of the permit to ensure compliance with 15A NCAC 2D .0510. Compliance is expected.
(2) 15A NCAC 2D.0 515:PAR TIC UL-A TES FR OM MISCELLANEO US INDUSTRIAL PROCESSES- Th
following emission sources are subject to 2D.0515: The three natural gas-fired kilns(ID Nos. ES-CPKI,
ES-CPK2, and ES-CPK3), the three, roofgranule mixing tin its(ID Nos.ES-CPMI,ES-CPM2, and ES-CPM3)and
the three coolers (ID Nos. ES-CPCI, ES-CPC2, and ES-CPC3).
IN COMPLIANCE-The particulate emission limit for each of the subject emission sources is determined based
on the individual process weight rates for each source. The facility has installed enclosures,bagfilters and
associated ductwork to locations throughout the plant that would be likely to produce particulates. These devices
are effective controls and would significantly reduce particulate emissions.
The permit does not require any particulate emission testing. However,the facility is required to conduct annual
inspections on the granule mixing units' bagfilters,to maintain production records on the coolers,and to submit a
summary report every six months documenting any deviations to permit requirements. Upon request, 3M
personnel were able to produce the required records. Additionally,all recent compliance reports have been
submitted on time. Compliance is expected.
(3) 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMB USTION SO URCES- The following
emission sources are subject to 2D.0516: The four, natural gas-fired dryers (ID Nos. ES-1415, ES-CPPHI,
ES-CPPH2, and ES-CPPH3) and the three, natural gas-fired kilns(ID Nos.ES-CPKI, ES-CPK2, and ES-CPK3)
IN COMPLIANCE-The sulfur dioxide emission limit for each of the subject emission sources is 2.3 pounds per
million Btu heat input. Since the facility burns only natural gas and#2 fuel oil in its combustion equipment,the
15A NCAC 2D .0516 sulfur dioxide emissions standard should be achieved during normal operating conditions.
No sulfur dioxide emission testing is required by the facility's air permit. Additionally,no monitoring/record
keeping/reporting is required for sulfur dioxide emissions from the firing of natural gas in the combustion units.
Compliance is expected.
(4) 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS- The following emission sources are subject to
2D.0521: Those emission sources in the table in Section IV above that are not marked as subject to NSPS
Subparts 000 or UUU.
IN COMPLIANCE-The visible emission limit for each of the subject emission sources is 20 percent opacity.
During the inspection,all of the emission sources observed in operation were well below the 20 percent opacity
standard. The facility has installed enclosures,bagfilters and associated ductwork to locations throughout the
plant that would be likely to produce particulates. These devices would be expected to significantly reduce the
opacity of the exhaust streams. No visible emission testing is required for any of these sources by the facility's air
permit. The permit does require the facility to perform monthly visible emissions observations on each of the
subject emission sources,to record the results of the monthly observations in a logbook,and to submit a summary
report of all visible emission observations on a semiannual basis. Upon request, 3M personnel were able to
produce the required records. All recent compliance reports have been submitted on time. Compliance is
expected.
(5) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart 000) - The
following emission sources are subject to NSPS, Subpart 000:All the emission sources in the table in Section IV
above that are marked as subject to NSPS, Subpart 000.
IN COMPLIANCE-To comply with the requirements of 40 CFR 60, Subpart 000 - Standards of Performance
for Nonmetallic Mineral Processing Plants,the facility must maintain particulate and visible emissions below the
source specific limits defined in the permit. The facility completed the initial NSPS performance test/initial
compliance demonstration in August 2002 for the equipment originally installed at the plant. The permit requires
the facility to evaluate the visible emissions from each of the affected sources on a monthly basis,to record the
results of the monthly observations in a logbook, and to submit a summary report of all visible emission
observations on a semiannual basis. Upon request, 3M personnel were able to produce examples of required
records. Additionally, all recent compliance reports have been submitted on time. Compliance is expected.
(6) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart UUU) - The
following emission sources are subject to NSPS, Subpart UUU: The four natural gas-fired dryers (ID Nos.
ES-1415,ES CPPHI, ES-CPPH2, and ES-CPPH3).
IN COMPLIANCE-To comply with the requirements of 40 CFR 60, Subpart UUU-New Source Performance
Standards for Calciners and Dryers in Mineral Industries,the facility must maintain particulate emissions below
0.057 grams per dry standard cubic meter and visible emissions below 10 percent opacity. The facility completed
the initial NSPS performance test/initial compliance demonstration in August 2002 for the equipment originally
installed at the plant. The facility is required to install,calibrate,maintain, and operate a continuous opacity
monitoring system(COMS)on each of the dryers. The permit also requires the facility to conduct annual
inspections on the dryers'bagfilters,to record the results of the inspections in a logbook,and to submit a summary
report of all inspection and maintenance activities on a semiannual basis. Upon request, 3M personnel were able
to produce the required records,which indicated that the facility is meeting their various NSPS requirements.
Additionally, all recent compliance reports have been submitted on time. Compliance is expected.
(7) 15A NCAC 2D.0540:PARTICULATES FROM FUGITIVE NON-PROCESS D UST EMISSION SOURCES -
The following emission sources are subject to 2D.0540:All permitted emission sources except for the four natural
gas-fired dryers(ID Nos.ES-1415,ES-CPPHI,ES-CPPH2, and ES-CPPH3), the three natural gas-fired kilns(ID
Nos.ES-CPKI,ES-CPK2,and ES-CPK3), the three roofgranule mixing units(ID Nos.ES-CPM1,ES-CPM2, and
ES-CPM3), and the three coolers (ID Nos. ES-CPCI, ES-CPC2, and ES-CPC3).
IN COMPLIANCE-To comply with 15A NCAC 2D .0540,the facility shall not cause or allow fugitive
non-process dust emissions to cause or contribute to substantive complaints.According to the Raleigh Regional
Office's complaint database,there have been no fugitive dust complaints against the facility. Based on
observations made during the inspection,the facility appears to be meeting the requirements of 15A NCAC 2D
.0540. Compliance is expected.
(8) 15A NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING(40 CFR 64) - The following emission
sources are subject to 2D.0614: The three natural gas-fired kilns (ID Nos. ES-CPKI, ES-CPK2, and ES-CPK3)
and the three roofgranule mixing units (ID Nos. ES-CPM1, ES-CPM2, and ES-CPM3).
IN COMPLIANCE-To comply with compliance assurance monitoring(CAM)requirements and ensure that
particulate and visible emissions from the subject emission sources do not exceed the applicable emission limits
during normal operation,the facility is first required to monitor the pressure drop across each of the bagfilters
serving the affected emission sources during periods of operation. Second,the facility must conduct an EPA
Reference Method 22 visible emission evaluation once per month on each of the affected emission sources. If the
CAM monitoring procedures indicate a potential problem with the operation of the affected units or control
devices,the facility must take corrective action to fix the problem within the time frames specified in the permit.
Based on record reviews and observations made during the inspection,the facility appears to be meeting the CAM
requirements of 15A NCAC 2D .0614. Compliance is expected.
(9) 15A NCAC 2Q.0711: TOXIC AIR POLLUTANT REQUIREMENTS-All of the permitted emission sources are
subject to 2Q.0711.
IN COMPLIANCE-To comply with 15A NCAC 2Q .0711,the facility must ensure that emissions of specified
toxic air pollutants(TAPS)do not exceed the toxic permit emission rates(TPERs)specified in the permit. If any of
the TPERs are exceeded,the facility must obtain a permit to emit TAPs and demonstrate compliance with state
acceptable ambient levels(AALs). In the 2011 15'semiannual report,the facility indicated that it was discovered
during an internal audit that the estimated 12-month emission rate of arsenic over the past years had been over the
TPER. A review of database records indicated that the estimated arsenic emission rate from the facility has
exceeded the TPER for at least the past 8 years. A modeling analysis was presented to the DAQ modeling staff on
November 21, 2011, addressing arsenic and cadmium emissions(see Subsection 12 below). The analysis,based
on an increased production rate,was reviewed and found acceptable according to an October 1,2012 memo. Also,
the arsenic annual limit has been increased. Compliance is demonstrated.
(10) 15A NCAC 2D.0958: WORK PRA CTICES FOR SOURCES OF VOLATILE ORGANIC COMPOUNDS
(VOCs) (40 CFR 64)-All of the permitted emission sources are subject to 2D.0958.
IN COMPLIANCE-To comply with the work standards to minimize the release of volatile organic compound,the
facility is required to implement eleven basic operational practices.These practices were discussed with Mr.
Carter. The facility appears to be meeting all the applicable standards. The facility does not store or utilize
significant volumes of VOC sources. Compliance is expected.
(11) 15A NCAC 2Q.0317 AVOIDANCE CONDITIONS— TO AVOID 15A NCAC 2Q.1111 MAXIMUM
ACHIEVABLE CONTROL TECHNOLOGY (MACT) -All the emission sources in the table in Section IV that are
included in the Coloring Plant, the four natural gas-fired dryers(ID Nos. ES-1415,ES-CPPH1, ES-CPPH2, and
ES-CPPH3), the three natural gas-fired kilns(ID Nos.ES-CPKI,ES-CPK2, and ES CPK3), the three roofgranule
mixing units (ID Nos. ES CPMI, ES-CPM2, and ES-CPM3)and the three coolers(ID Nos. ES-CPC1, ES-CPC2,
and ES-CPC3).
IN COMPLIANCE-To assure avoidance of the MACT regulatory requirements,the facility is required to record
the total HAP emissions on a monthly basis. The facility 12-month total HAP emission must not exceed 10 tons
per year for an individual HAP and 25 tons per year for all HAPs. According to the 2018 Emission Inventory,the
largest contributor of HAP emissions was methanol. The methanol emissions were estimated to be approximately
5.27 tons for 2018. The other HAP cmissions were relatively smaller and the total annual HAP emission rate was
approximately 6.37 tons for 2018. Records reviewed indicated that the total annual HAPs emitted in 2018 were
well below the 25 tpy limit. Compliance is expected.
(12) 15A NCAC 2Q.1100: TOXIC AIR POLL UTANT EMISSIONLIMITATION-All of the permitted emission
sources are subject to 2Q.1100.
IN COMPLIANCE-To comply with 15A NCAC 2Q .1100,the facility must ensure that emissions of specified
toxic air pollutants (TAPS)do not exceed the limits listed in the permit which are based on air modeling
performed. The modeling exercise involving arsenic and cadmium emissions was approved on October 1, 2012.
The 2018 emission inventory indicated that the annual releases of both of these toxic metals were well within the
permit limits of 0.691b/yr of arsenic and 3.79 lb/yr of cadmium.
(13) 15A NCAC 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-All of the permitted
emission sources are subject to 2D.1806.
IN COMPLIANCE—The facility is required to manage and/or use control devices so to prevent objectionable
odors from reaching their boundary. There were no remarkable odors detected during the inspection and there are
no records of odor complaints that have been lodged against the facility. Compliance is expected.
Additional Regulatory Conditions
15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY(40 CFR 63, Subpart ZZZZ) -
The following emission source is subject to 2D .1111: Diesel-powered emergency fire pump.
IN COMPLIANCE—There is a diesel-powered emergency fire pump that is presently sitting on the facility
grounds disconnected from any water or electrical source. The facility has installed the pump in a more ideal
location since the last inspection. The hour meter on the pump indicated 310.8 hours during the February 2017
inspection,341 hours during the June 2018 inspection, 356.7 hours during the January 2019 inspection, and 376.8
hours during this inspection. According to information gathered during the last inspection,annual maintenance on
the unit was performed by Gregory Poole Power Systems on November 11, 2019.
(VI)EXEMPT EMISSION SOURCES: Three fuel storage tanks were observed during the site tour that should
be added to the insignificant activities list. Two of the tanks contain gasoline and diesel and are 280 gallons in size.
This fuel is used to service onsite vehicles. The third 550-gallon tank contains diesel and services the fire pump
engine.
(VH)CLEAN AIR ACT SECTION 112(r) REQUIREMENTS: Pursuant to 15A NCAC 2D .2100 "Risk
Management Program," if the Permittee is required to develop and register a risk management plan pursuant
to Section 112(r) of the Federal Clean Air Act, then the Permittee is required to register this plan with the
USEPA in accordance with 40 CFR Part 68.
IN COMPLIANCE—3M Pittsboro is subject to the 112(r)program general duty clause,but does not maintain
regulated chemicals onsite above the threshold quantities, which would require a risk management plan.
(VIII)ENFORCEMENT HISTORY: 3M's Moncure plant has been issued four Notices of Violation(NOVs).
On April 23, 2018,the facility was issued an NOV for failing to conduct daily calibrations on its COMS unit,
which services the dryers. The facility was issued an NOV on March 10, 2010 for failing to notify the Regional
Office about permit deviations related to missing visible emissions observations. On June 6,2007,the company
was issued an NOV for failure to submit a complete annual compliance certification for calendar year 2006 by the
January 30,2007 due date. Also, on October 3, 2006,the company was issued an NOV for failure to submit a
summary report of monitoring and record keeping activities for the first half of 2006. 3M has not been assessed
any civil penalties related to air quality issues.
(IX)STACK TEST HISTORY: The most recent stack test performed at this facility was on August 8,2007. The
testing was performed to satisfy NSPS Subpart 000 requirements. The tests appeared to demonstrate compliance
to particulate and visible emissions standards.
(X)EMISSION INVENTORY EMISSION CHANGES—There were no changes in the emission rates in the
past two years that affect the fee status of this facility or potentially approach an emission limitation. The
following summary describes emission changes between 2017 and 2018 and was taken from the 2018 inventory's
review/comment section of IBEAM.
"PM 10 and PM2.5 emissions decreased due to the revised emission factors of dryers and kilns material throughput
within operating scenario OS-35. Toluene emissions increased due to the increased use of adhesion promoters in
the Coolers. These material usages increased due to the hours of operation increasing by 5%."
(XI)CONCLUSIONS/RECOMMENDATIONS: Based on observations made during the December 10, 2019
inspection, 3M Industrial Mineral Products appeared to be in compliance with the requirements of the current air
permit. It is recommended that the facility be inspected again in one year.