AQ_F_1000067_20070828_CEM_RptRvwLtr

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
August 28, 2007
Mr. Paul Stubbs
Operations Manager
Primary Energy
P.O. Box 10836
Southport,North Carolina 28461
Subject: Semi Annual Excess Emissions Report(EER) for the 1 S' Half,2007
Facility I.D. No. 1000067
Dear Mr. Stubbs:
The Division of Air Quality(DAQ)has reviewed the subject reports dated July 26, 2007 and submitted by
Primary Energy of Southport, Inc. for Units No. I 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 12 minutes (2 periods) opacity excursions
for Unit 1 and no opacity excursions for Unit 2. The six-minute opacity excess emission incidents for Unit
I occurred due to control equipment problems and startup.
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 semi annual period ending June 30, 2007 confirmed the reported results as follows:
Units: No. 1 No. 2
NO,Excess Emission: 0.00% 0.00%
NO,CMS Downtime: 1.18% 1.66%
Opacity Excess Emission: 0.01% 0.00%
Opacity CMS Downtime: 0.28% 0.25%
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Mr. Paul Stubbs
8/2 8/67
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 2 NOa
CEMs downtime was reported above 2%. 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 first half semi annual report indicated you were below
the CEP threshold levels for all of your Units I and 2. Also, the facility should separate the quarters in
the semi annual report for excess emissions and/or monitor downtime to be consistent with the
monitor performance assessment in 40 CFR Part 60 Appendix F and the EPA Region IV CEM
Enforcement Plan (CEP).
The CD results, after the excessive monitor downtimes, indicate that the calibration drift values of your
CEM systems are within the specifications given in 40 CFR 60 Appendix F, and therefore demonstrate
compliance.
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 2007.
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.
IMPAQ=Documents-1000067