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NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor Division of Air Quality William G. Ross,Jr., Secretary
B, Keith Overcash, P.E., Director
June 23, 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 1st Quarter,2004
Facility I.D.No. 1000067
Dear Mr. Willer:
The Division of Air Quality(DAQ)has reviewed the subject report dated April 23,2004 and submitted
by Cogentrix of Southport,Inc. for Units No. 1 and 2. The report was 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 54 minutes (9 periods)of opacity
excursions for Unit 1 and 270 minutes (45 periods)of opacity excursions for Unit 2. The six-minute
opacity excess emission incidents for Unit 1 occurred due to startup and baghouse air control
equipment problems. The six-minute opacity excess emission incident for Unit 2 occurred during
boiler startup,broken baghouse bag,frozen baghouse air line and other control equipment problems.
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 March 31,2004 confirmed the reported results as
follows:
Units: No. 1 No. 2
NO,,Excess Emission: 0.00% 0.00%
NO,,CMS Downtime: 0.11% 0.00%
Opacity Excess Emission: 0.05% 0.28%
Opacity CMS Downtime: 0.35% 0.14%
One
1641 Mail Service Center,Raleigh,North Carolina 27699-1641 NofthCaroli
2728 Capital Blvd.,Raleigh,North Carolina 27604 /
Phone: [phone] l FAX [phone] Internet www.ncair.org aturall,

Mr. Gary E. Willer
June 23,2004
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 IV 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. All data in your
first quarter report indicated you were below the CEP threshold levels for all of your Units 1 and 2.
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: - ike Aldridge
Wayne Cook-WIRO
Central File-Brunswick Co.
Tracy Patterson—Cogentrix
IMPAQ—Documents— 1000067 (Filename: SimpsonRR\Cogentrix\2003\cgEER1Q04sp.doe)