AQ_F_1000067_20020607_CEM_RptRvwLtr

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NCDENR
North Carolina Department of Environment and Natural Resources
DIVISION OF AIR QUALITY
Michael F.Easley,Governor William G. Ross,Jr.,Secretary
B. Keith Overcash, P.E., Director
June 7,2002
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, 2001
Relative Accuracy Test Audit (RATA)report for new NOx and CO2 CEMS
Analyzers on Units 1 and 2,2001
Dear Mr. Hickey:
The Division of Air Quality (DAQ)has reviewed the subject reports dated January 17 and
January 31,2001 respectively and submitted by Cogentrix of Southport, Inc. for Units 1 and 2.
The reports were reviewed for compliance with the applicable emission control standards and EPA
Region IV CEM Enforcement Plan (CEP).
When reviewed for compliance with the applicable emission control standards, the report indicated
90 minutes(15 periods) of opacity excursions for Unit 1 and 30 minutes (5 periods) of opacity
excursions for Unit 2. The Unit 1 six-minute opacity excess emission incidents occurred during
heavy rain. The Unit 2 six-minute opacity excess emission incidents occurred during
startup/shutdowns. The report also indicated no excess emissions for NO,on Unit 1. 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 Unit 1
during the quarter ending December 31, 2001. were reported and confirmed as follows:
Units: No. 1 No. 2
NO.,Excess Emission: 0.00% 0.00%
NO,,CMS Downtime: 1.82% 1.81
Opacity Excess Emission: 0.09% 0.03%
Opacity CMS Downtime: 2.94% 3.01%
H:\SimpsonRR\Coc7entrix\Southport\2001\EER4QOlsp.doc
Technical Services Section
1641 Mail Service Center, Raleigh, North Carolina 27699-1641 • 2728 Capital Boulevard, Raleigh,North Carolina 27604
Phone: [phone] , FAX: [phone] - Internet: http://daq.state.nc.us

Mr. Terry Baker
June 7,2002
Page Two
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 and Unit 2 NO,, and opacity CEM
downtime was reported above 2% but below 5%. The data in your report indicated you installed
new monitors and would have been below the CEP threshold levels for Units 1 and 2.
The RATA report indicates that the accuracy values of the new NOx and CO2 monitors were as
follows:
Source Parameter Model and Serial No. % Relative Accuracy
Monitored
Unit 1 NOx TECO 42C 71812-369 5.25% of RM
Unit 1 COl TECO 41CHL 71589-369 NA
Unit 2 NOx TECO 42C 71812-369 4.90% of RM
Unit 2 COl TECO 41CHL 71589-369 NA
All values are within the relative accuracy limits specified in 40 CFR 60, Appendix B, Performance
Specification 2. It appears that the testing was performed correctly and the report indicates
compliance. Therefore, the Division of Air Quality accepts this RATA report.
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
and the CEP. 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
H:\SimpsonRR\Coeentrix\Southport\2001\EER4Q01 sp.doc