AQ_F_1000067_20010503_CEM_RptRvwLtr

North Carolina
Department of Environment and Natural Resources 1 •
Division of Air Quality
Technical Services Section
Michael F.Easley, Governor NCDENR
William G.Ross,Jr.,Secretary
Alan W.Klimek,P.E.,Director
May 3, 2001
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 4th Quarter, 2000
Calibration Drift(CD)Test Results for the 4th Quarter, 2000
Dear Mr. Carter:
The Division of Air Quality(DAQ) has reviewed the subject reports dated January 18, 2001 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 Violations (HPV) guidance and EPA Region IV CEM Enforcement Plan (CEP).
When reviewed for compliance with the applicable emission control standards,the report indicated no
opacity excursions for Units 1 and 2. The report also indicated no excess emissions for NO, 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 December 31, 2000 were reported and confirmed as follows:
Units: No. 1 No. 2
NOX Excess Emission: 0.00% 0.00%
NO,,CMS Downtime: 1.7% 1.98%
Opacity Excess Emission: 0.00% 0.00%
Opacity CMS Downtime: 2.21% 1.13%
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
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
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Mr. Terry Baker
May 3, 2001
Page Two
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 60.11(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 1 opacity COM downtime was reported as 2.21%.
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 January 18, 2001 letter. All other data in your 4th quarter report
indicated you were below the CEP threshold levels for all of your Units 1 and 2.
The CD results indicate that the calibration drift values of your NO,,/Oz 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_, �)
Richard R. Simpson
Environmental Engineer
cc: Mike Aldridge
Wayne Cook-WIRO
Central File-Brunswick Co.
Tracy Patterson -Cogentrix