AQ_F_1000067_20060523_CEM_RptRvwLtr

a • .
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 23,2006
Mr. Gary Hickey
General Manager
Primary Energy
P.O. Box 10836
Southport,North Carolina 28461
Subject: Excess Emissions Report(EER) for the 1st Quarter, 2006
Relative Accuracy Test Audit(RATA) report for NO,, and CO2 CEMS Analyzers
on Units 1 and 2, 2006
Facility I.D.No. 1000067
Dear Mr. Hickey:
The Division of Air Quality(DAQ)has reviewed the subject reports dated April 25 and March 16,2006 and
submitted by Primary Energy 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.
For Units 1 and 2, compliance with the nitrogen oxide emission standard is detennined 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 6 minutes(1 period)of opacity excursions
for Unit 1 and 188 minutes(3 periods)of opacity excursions for Unit 2. The six-minute opacity excess
emission incidents for Unit 1 occurred due to load swing. The six-minute opacity excess emission incidents
for Unit 2 occurred due to baghouse hoppers high level and RATA test probe interference.
DAQ's review of the Continuous Emissions Monitoring Compliance Report(CEMCR) for NOx, 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, 2006 confirmed the reported results as follows:
Units: No. 1 No. 2
NO,. Excess Emission: 0.00% 0.00%
NOx CMS Downtime: 0.06% 0.00%
Opacity Excess Emission: 0.01% 0.02%
Opacity CMS Downtime: 0.07% 0.00%
Technical Services Section One
1641 Mail Service Center,Raleigh,North Carolina 27699-1641 NorthCarolina
2728 Capital Blvd.,Raleigh, North Carolina 27604
Phone: [phone] FAX [phone] Internet: www.ncair.org Naturally
An Equal Opportunity/Affirmative Action Employer—50%Recycled110%Post Consumer Paper

Mr. Gary Hickey
5/23/06
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. All data in your first 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 NO,, and COZ 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 Model and Serial No. % Relative Accuracy
Monitored
Unit 1 NOX TEI 42C-71812-369 3.8%of RM
Unit 2 NOX TEI 42C-71830-369 4.7% of RM
The next relative accuracy test for Units 1 and 2 are due by March 31,2006.
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 NOX 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 2006.
If you have any questions regarding the issues discussed in this letter,please contact me at
[phone].
Sincerely,
o
0
Richard R. Simpson
Environmental Engineer
cc: �V fie Aldridge
Wayne Cook -WIRO
Central File -Brunswick Co.
Tracy Patterson—Cogentrix
IMPAQ—Documents-1000067
(Filename : SimpsonRR\PrimaryE\2005-06\peEER1Q06sp.doc)