AQ_F_1000067_20010214_CEM_RptRvwLtr

North Carolina Department of
Environment and Natural Resources MC.11A
Division of Air Quality a
'Technical Services Section �,a&4j
Michael F.Easley,Governor NCDENR
William G.Ross,Jr.,Secretary
Alan W.Klimek,P.E.,Director
February 14, 2001
AMENDED
Mr. Terry Baker
The Plant Manager
Cogentrix of North Carolina,Inc.
P.O. Box 10836
Southport,North Carolina 28461-0836
Subject: Excess Emissions Report(EER) for the 3rd Quarter, 2000
Calibration Drift(CD)Test Results for the 3rd Quarter, 2000
Relative Accuracy Test Audit(RATA)Results for 3rd Quarter, 2000
Dear Mr. Carter:
This letter amends the previous letter dated January 24, 2001 based on the same subject.
The Division of Air Quality(DAQ)has reviewed the subject reports dated October 11, 2000 and
submitted by Cogentrix of Southport, Inc. for Units No. 1 and 2. The report was reviewed for
compliance with the applicable emission control standards and conformance with the EPA's High
Priority Violator(HPV)guidance and EPA Region IV CEM Enforcement Plan (CEP).
When reviewed for compliance with the applicable emission control standards, the report indicated 12
minutes (2 periods) of opacity excursions for Unit 2. All the six-minute opacity excess emission
incidents occurred during restart of baghouse controls. The report also indicated no excess emissions
for NOx on Units 1 and 2. Please note that each exceedance of the emission control standard, unless
excused by the applicable regulation, can be credible evidence of a violation consistent with 40 CFR
60.11(g).
The Excess Emissions (EE) and Continuous Monitoring System(CMS)downtime(DT)for Units 1
and 2 during the quarter ending September 30, 2000 were reported and confirmed as follows:
Units: No. 1 No. 2
NOX Excess Emission: 0.0% 0.0%
NOx CMS Downtime: 0.0% 2.6%
Opacity Excess Emission: 0.0% 0.01%
Opacity CMS Downtime: 0.52% 0.43%
The EPA's High Priority Violator(HPV) guidance recommends enforcement action based on the
degree and frequency of exceedance. The HPV guidance recommends enforcement for excursions of
NO,emissions that are 15% above the emission control standard and occurring more than 5% of the
1641 Mail Service Center, Raleigh,North Carolina 27699-1641
2728 Capital Blvd., Suite 166,Raleigh,NC 27604
Phone: [phone]\FAX: 919-73'M 812\ Internet: http://daa.state.nc.us/
AN EQUAL OPPORTUNITY\AFFIRMATIVE ACTION EMPLOYER—50%RECYCLED/ 10%POST CONSUMER PAPER

Mr. Terry Baker
February 14, 2001
Page Two
reporting period or any exceedance of the reference limit greater than 50% of the operating time in the
quarter. The HPV guidance also recommends enforcement for excursions of opacity emissions that are
5% above the emission control standard and occurring more than 5% of the operating time in the
quarter. The data in your third quarter report indicates you are below these thresholds.
For the purpose of assessing good operation and maintenance (O&M)practices on control devices and
monitoring systems, as required by 40 CFR 60.1 l(d),the DAQ uses, among other things, the EPA
Region IV CEM Enforcement Plan (CEP). Based on this plan,excess emissions and/or monitor
downtime greater than 2%, 5% for two consecutive quarters or 10% for any one-quarter is followed by
appropriate agency response. However,the Unit 2 NO,CEM downtime was reported as 2.6%. This
value is considered high and efforts should be made to minimize monitor downtime values below 2%
at all times. Your facility has submitted the required explanation and corrective action for the monitor
downtime event in your October 11, 2000 letter. All other data in your 3rd quarter report indicated you
were below the CEP threshold levels for all of your Units 1 and 2.
The RATA and CD results indicate that the relative accuracy and calibration drift values of your
NO,/02 CEM systems are within the specifications given in 40 CFR 60 Appendix F, and therefore
demonstrate compliance.
Finally,unless the permit or any applicable rule states otherwise, your future quarterly excess emission
reports will be reviewed consistent with the compliance of the emission control standard, the CEP, and
the HPV guidance. Any potential enforcement action will also be processed consistent with the same
guidance.
If you have any questions regarding the issues discussed in this letter,please contact me at
[phone].
Sincerely,
�X.Jl�
Richard R. Simpson
Environmental Engineer
cc: Mike Aldridge
Ernie Fuller-RRO
Central File -Edgecombe Co.
Tracy Patterson -Cogentrix