AQ_F_1000067_20040309_CEM_RptRvwLtr

NCDENR
North Carolina Department of Environment and Natural Resources
William G. Ross,Jr., Secretary
Michael F. Easley, Governor Division of Air Quality Y
B. Keith Overcash, P.E., Director
March 9,2004
Mr. Gary Willer
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,2003
Relative Accuracy Test Audit(RATA) report for NO.,and CO2 CEMS Analyzers
on Units 1 and 2, 2004
Facility I.D. No. 1000067
Dear Mr. Willer:
The Division of Air Quality (DAQ)has reviewed the subject reports dated January 9 and January 29,
2004 and submitted by Cogentrix of Southport,Inc. for Units No. 1 and 2. The reports were reviewed
for compliance with the applicable emission standards set forth in 40 CFR Part 60 Subpart Db, the
general provisions of 40 CFR 60.11(d)and 40 CFR 60.13.
For Units 1 and 2, compliance with the nitrogen oxide emission standard is determined through the use
of a 30-day rolling average emission rate in accordance with 40 CFR 60.46b. There were no violations
of the NO,emission standard for Units 1 and 2.
Also, Units 1 and 2 are subject to the opacity standards set forth in 40 CFR 60 Subpart Db. Thus,when
reviewed for compliance with the standards, the report indicated 112 minutes (19 periods) of opacity
excursions for Unit 1 and no opacity excursions for Unit 2. The six-minute opacity excess emission
incidents for Unit 1 occurred due to startup, shutdown,baghouse bypass, and baghouse malfunctions.
DAQ's review of the Continuous Emissions Monitoring Compliance Report(CEMCR)for NO,,the
Excess Emissions Report(EER)for opacity, and Continuous Monitoring System(CMS)downtime
(DT)for Units 1 and 2 during the quarter ending December 31, 2003 confirmed the reported results as
follows:
Units: No. 1 No. 2
NO,,Excess Emission: 0.00% 0.00%
NO,,CMS Downtime: 2.33% 0.44%
Opacity Excess Emission: 0.12% 0.00%
Opacity CMS Downtime: 0.02% 0.03%
One
1641 Mail Service Center,Raleigh,North Carolina 27699-1641 NorthCarohn,,
2728 Capital Blvd.,Raleigh,North Carolina 27604
Phone: [phone] FAX [phone] Intemet: www.ncair.org ;Vaturallff
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Mr. Gary E.Willer
March 9,2004
Page Two
For the purpose of assessing good operation and maintenance(O&M)practices for particulate emission
control devices and all continuous monitoring systems,the DAQ uses, among other things,the EPA
Region 1V CEM Enforcement Plan (CEP). Based on this plan, excess emissions (opacity only) and/or
monitor downtime(all CMS) greater than 2%, 5%for two consecutive quarters or 10%for any one
quarter is followed by appropriate agency response and for enforcement purposes only. However,the
Unit 1 NO,outlet CMS downtime was reported as 2.33%. These values are 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 events in your
report. These explanations and corrective actions are acceptable. All other data in your fourth quarter
report indicated you were below the CEP threshold levels for all of your Units 1 and 2.
The CEM RATA report was reviewed and the NOx and CO2 CEMs monitors on Units 1 and 2 appear
to have been tested in accordance with 40 CFR 60,Appendix B,Performance Specifications 2 and 3
and therefore acceptable. The model/serial numbers and relative accuracy values are as follows:
Source Parameter Monitored Model and Serial No. % Relative Accuracy
Unit 1 NOx TEI 42C-70208-369 9.8% of RM
Unit 1 NOx TEI 42C-71812-369 3.1% of RM
The next relative accuracy test for Unit 1 is due by March 31,2005.
Finally, unless the permit or any applicable rule states otherwise, your future quarterly Continuous
Emission Monitoring Compliance Report and Excess Emission Reports will be reviewed consistent
with the compliance of the emission control standards set forth in 40 CFR 60,Subpart Db,and the CEP
will be used to assess excess opacity emissions and CMS downtime. All violations of the NO,,emission
standard may result in enforcement actions.
If you have any questions regarding the issues discussed in this letter,please contact me at
[phone].
Sincerely,
Richard R. Simpson
Environmental Engineer
cc: ,ivlike Aldridge
Wayne Cook -WIRO
Central File-Brunswick Co.
Tracy Patterson—Cogentrix
IMPAQ—Documents — 1000067 (Filename : SimpsonRR\Cogentrix\2003\cgEER4Q03sp.doc)