AQ_F_1000067_20060522_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
May 22, 2006
Mr. Gary Hickey
General Manager
Primary Energy
P.O. Box 10836
Southport,North Carolina 28461
Subject: Excess Emissions Report(EER) for the 4th Quarter,2005
Facility I.D.No. 1000067
Dear Mr. Hickey:
The Division of Air Quality (DAQ) has reviewed the subject report dated January 20, 2006 and
submitted by Primary Energy 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 246 minutes (41 periods) of
opacity excursions for Unit 1 and 348 minutes (58 periods) of opacity excursions for Unit 2. The
six-minute opacity excess emission incidents for Unit 1 occurred due to broken bags, load swing,
damper sticking, startup and shutdown. The six-minute opacity excess emission incidents for Unit
2 occurred due to broken feeder chains, unstable leveling bars, dampers not properly closing,
baghouse control system malfunctions, startups, and shutdown.
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, 2005 confirmed the
reported results as follows:
Units: No. 1 No. 2
NO, Excess Emission: 0.00% 0.00%
NO, CMS Downtime: 1.25% 0.06%
Opacity Excess Emission: 0.21% 0.35%
Opacity CMS Downtime: 2.87% 0.08%
Technical Services Section One
1641 Mail Service Center, Raleigh,North Carolina 27699-1641 NorthCarohna
2728 Capital Blvd.,Raleigh, North Carolina 27604
Phone: [phone] FAX [phone] Internet: www,ncair.org Naturallff
An Equal Opportunity/Affirmative Action Employer—50%Recycled110%Post Consumer Paper

Mr. Gary Hickey
5/22/06
Page 2
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. However, the Unit 1 opacity COMB downtime was reported as
2.87%. 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.
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.
Based on this review and any other information you have submitted,we conclude that the
referenced excess emissions are excused pursuant to 40 CFR 60, Subpart A and Subpart Db. These
excused excesses do not prevent you from certifying compliance in your Annual Compliance
Certification (ACC) for the calendar year 2005.
If you have any questions regarding the issues discussed in this letter, please contact me at
[phone].
Sincerely,
Aa 114V11T.
Richard R. Simpson
Environmental Engineer
cc: ike Aldridge
Wayne Cook - WIRO
Central File - Brunswick Co.
Tracy Patterson—Cogentrix
IMPAQ—Documents-1000067
(Filename : SimpsonRR\PrimaryE\2005-06\peEER4Q05sp.doc)