Loading...
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.