AQ_F_1900104_20180911_CEM_RptRvwLtr

ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretory
MICHAEL ABRACZINSKAS
Director September 11, 2018
Mr. Blake Arnett
Plant Manager
3M Company—Pittsboro
4191 Highway 87 South
Moncure,North Carolina 27559
Subject: Review of 2018 Semiannual COMS Report, First 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 July 24, 2018. The
excess emissions report(EER)provided information about the continuous opacity monitoring
systems (COMS) operating at 3M's Pittsboro facility during the first half of 2018.
Specifically, COMS data for the following natural gas-fired dryers were reviewed: C&S
Dryer(ID No. ES1415), Line 1 Coloring Dryer(ESCPPHI), and Line 2 Coloring Dryer
(ESCPPH2). The Division of Air Quality(DAQ)has completed its review of the submittals
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/or%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,percent excess emissions(%EE) and
D.P1M eM of bWk0MmntW MWb
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. Thomas Hanes
September 11,2018
Page 2
percent monitor downtime(%MD) as shown in the table below were below the
actionable threshold of 6%for any single calendar quarter and less than 3% for two
consecutive quarters:
Unit Quarter %EE %MD
C&S Dryer 1st 0.0 0.76
2nd 0.0 2.15
Line 1 Coloring Dryer 1 st 0.0 1.07
2nd 0.0 0.88
Line 2 Coloring Dryer 1 st 0.0 1.14
2nd 0.0 1.67
Therefore, during the first and second quarter of 2018,the dryers and associated COMS
units appear to have used good O&M practices for minimizing emissions.
3. The 2018 first and second quarter audits of the COMS units were reviewed in accordance
with Procedure 3 of 40 CFR Part 60, Appendix F - Quality Assurance Procedures. The
QA test results for the COMS appear to have met the quarterly specifications, and are
acceptable.
If you should have any questions regarding this review,please contact me at(919) 707-
8410 or [e-mail].
Sincerely,
Dennis U. Igboko, Environmental Engineer
Division of Air Quality,NCDEQ
c: Adam Driscoll, 3M
Ray Stewart, DAQ RRO
Gary Saunders, DAQ RCO
IBEAM Documents, 1900104
Central File, Chatham County