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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Qualify
Michael F Easley, Governor William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
November 25,2008
Mr. Paul E. Stubbs
General Manager
EPCOR
P.O. Box 10836
Southport,North Carolina 28461
Subject: Semi Annual Excess Emissions Report(EER)for the I"Half, 2008
Relative Accuracy Test Audit(RATA) report for NO,, and COZ CEMS Analyzers
on Units 1 and 2, 2008
Facility I.D.No. 1000067
Dear Mr. Stubbs:
The Division of Air Quality(DAQ) has reviewed the reports submitted by EPCOR of Southport, Inc. for
Units No. 1 and 2, dated July 28 and March 26, 2008. These reports were reviewed for compliance with the
applicable emission standards set forth in 40 CFR Part 60 Subpart Db and the general provisions of 40 CFR
60.11(d) and 40 CFR 60.13. For the purpose of assessing good operation and maintenance(O&M)
practices pursuant to 40 CFR 60.11(d) (including associated particulate emission control devices
and all continuous monitoring systems), the DAQ also uses the NC CEM Enforcement Plan
(NCCEP). Based on this plan, excess emissions and/or monitor downtime in excess of 3% for two
consecutive quarters or 6% for any one quarter may result in the issuance of a Notice of Violation
(NOV). The NOV may also be followed by enforcement actions including assessment of civil
penalties.
Review of Compliance with NO Emissions Limits and Monitoring Requirements
Compliance with the nitrogen oxide emission standard for Units 1 and 2 is determined through the use of a
30-day rolling average emission rate in accordance with 40 CFR 60.46b. Based upon the information
submitted, there were no violations of the NO,, emission standard for Units 1 and 2.
The DAQ also reviewed the Continuous Emissions Monitoring Compliance Report(CEMCR) for NO,,and
Continuous Monitoring System(CMS) downtime (DT) for Units 1 and 2 during the semi annual period
ending June 30, 2008. The review confirmed the reported results as follows:
First Quarter
Units: No. 1 No. 2
NOX Excess Emission: 0.00% 0.00%
NO,, CMS Downtime: 0.41% 4.80%
Second Quarter
NO, Excess Emission: 0.00% 0.00%
NOX CMS Downtime: 0.20% 0.34%
Technical Services Section One
1641 Mail Service Center,Raleigh,North Carolina 27699-1641 North Carolina
2728 Capital Blvd., Raleigh, North Carolina 27604 Phone: [phone] FAX [phone]/Intemet: www.ncair.org Nalutally
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Mr. Paul E. Stubbs
11/25/08
Page 2
The review of the first quarter data for the Unit 2 NO, CEMs indicate that downtime was reported above
3%, but below the trigger levels suggested for further action. Please ensure that monitor downtime is
minimized below 3%at all times.
The CEM RATA report was reviewed and the NO,and CO2 CEMs on Units 1 and 2 appear to have been
tested in accordance with 40 CFR 60,Appendix B,Performance Specifications 2 and 3. Based upon the
review of the submitted test data the RATA appears 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 4.7%of RM
Unit 2 NOX TEI 42C-71830-369 8.0%of RM
The next relative accuracy test for Units 1 and 2 are due by March 31, 2009.
The calibration drift(CD)results indicate that the monitors are within the specifications given in 40 CFR 60
Appendix F, and therefore demonstrate compliance.
Review of Compliance with Opacity Limits and Monitoring Requirements
Units 1 and 2 are subject to the opacity standards set forth in 40 CFR 60 Subpart Db. The first quarter
report for Unit 1 indicated 90 minutes (15 periods)of opacity exceedances in excess of the opacity limit of
20% and the second quarter report indicated 12 minutes(2 periods)of opacity excursions. For Unit 1,
there were seventeen(17)6-minute exceedances of the 20% opacity limit that were attributed to
`Control Equipment Problems' due to baghouse control system during the first semi-annual report
for 2008 listed in Table 1 attached.
The first quarter report for Unit 2 indicated 3 84 minutes(64 periods) of opacity excursions and the second
quarter report indicated 18 minutes(3 periods)of opacity excursions. For Unit 2,there were forty-nine
(49) 6-minute exceedances of the 20% opacity limit that were attributed to `Control Equipment
Problems' due to bag failure during the first semi-annual report for 2008 listed in Table 2 attached.
According to 40 CFR Part 60 Subpart Db Section 60.43b(f), `... no owner or operator of an affected facility
that combust coal,oil,wood, or mixtures of these fuels with any other fuels shall cause to be discharged
into the atmosphere any gases that exhibit greater than 20 percent opacity(6-minute average), except for
one 6-minute period per hour of not mare than 27 percent opacity.'
The higher than normal excursions from Unit 2 were discussed by EPCOR in the semi-annual report
received by our office on July 28, 2008 (see attachment). The letter asserted that `the excess emissions
were the result of equipment malfunctions in the form of multiple bag failure events in the three baghouses
that exhaust to the common stack.' The definition of malfunction in 40 CFR Part 60, Subpart A—General
Provisions, Section 60.2 reads, `Malfunction means any sudden, infrequent,and not reasonably preventable
failure of the air pollution control equipment, process equipment,or a process to operate in a normal or
usual manner. Failures that are caused in part by poor maintenance or careless operation are not
malfunctions.' Based upon the information provided to date, the DAQ believes the seventeen (17)6-
minute exceedances due to baghouse control system from Unit 1 and the forty-nine(49)6-minute
exceedances due to bag failures from Unit 2 do not meet the definition of a malfunction and are,
therefore,violations of 15A NCAC 2D .0524 and Permit Condition 2.1.A.2.d. We conclude that the

Mr. Paul E. Stubbs
11/25/08
Page 3
referenced excess emissions in Tables 1 and 2 are not excused pursuant to 40 CFR 60, Subpart A and
Subpart Db. These excesses may prevent you from certifying continuous compliance in your Annual
Compliance Certification (ACC)for the calendar year 2008.
Further, the DAQ is requesting that the facility address each excursion highlighted with shading in
Tables 1 and 2 by separating them into individual 6-minute blocks and identify steps the facility
took to minimize the duration of each exceedance. Please include any appropriate notes or
narratives that you believe would be of use to the Director in deciding whether the opacity
exceedances associated with the control equipment problems (in these cases, baghouses) were
malfunctions. We request your response to this inquiry within thirty (30) days following the
receipt of this letter.
The DAQ also reviewed the Excess Emissions Report(EER)for opacity, and the Continuous Monitoring
System (CMS) downtime (DT)for Units 1 and 2 during the semi annual period ending June 30, 2008 and
confirmed the reported results as follows:
First Quarter
Units: No. 1 No. 2
Opacity Excess Emission: 0.07% 0.30%
Opacity CMS Downtime: 0.53% 2.71%
Second Quarter
Opacity Excess Emission: 0.01% 0.01%
Opacity CMS Downtime: 0.11% 0.10%
Based upon the review of the data,the overall percentages of time for excess emissions and monitor
downtown were less than the thresholds set forth in the NCCEP.
Please note that unless the permit or any applicable rule states otherwise,your future quarterly Continuous
Emission Monitoring Compliance Report and Excess Emission Reports will be reviewed for compliance
consistent with the emission control standards set forth in 40 CFR 60, Subpart Db. The general provisions
of 40 CFR 60.1 l(d) and 40 CFR 60.13 as expressed in the NCCEP will be used to assess good O&M
practices for all your facilities and monitoring systems. Any violations of the underlying control emission
standards and/ or good O&M practices 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 w/attachment:
Mike Aldridge
Wayne Cook- WIRO
Central File-Brunswick Co.
IMPAQ—Documents-1000067

Mr. Paul E. Stubbs
11/25/08
Page 4
Table 1
Unit 1
lst Semi-annual 2008 Excess Emissions Report for
Opacity Due to Baghouse Control System
Recorded Start Date End Date Duration Average Emission
Incident No. Periods Readings
1st Quarter
1 1/4/08, 15:48:36 1/4/08, 15:53:36 1 29
2 1110108, 1 ;48t3 13f .. ., 1 36
3 1128%08, 'Ofi3$ 128I $, 8 S 68
4 2120108, 4:3 %20fQ8; 3058 2 53
5 1, 124 ,8�3; 2�` 9 2 21 0 .° .t k ,$ 5 42
2" Quarter
1 625Q8 4= G, / 5`0` ,� 4 v j8 215
Table 2
Unit 2
1St Semi-annual 2008 Excess Emissions Report for
Opacity Due to Bag Failure
Recorded Start Date End Date Duration Average Emission
Incident No. Periods Readings
1 I151 6a31 j 1 2
2 1/5/08, 14:54:37 1/5/08, 14:59:37 1 22
3 ( 1/5/08, 15:06:37 I/5/08, 15:11:37 1 26
4 1/5/08, 15:36:37 1/5/08, 15:41:37 1 22
5 1/5/08, 15:54:37 1/5/08, 15:59:37 1 23
'6 ( 1/16 08;�3.(I
$ Il/16 os3�1 ;a °6 x s " . . + 27
� � � • . 2 30
Flo 23
°1111�6108�201236; 1b$ i4 ,.0ti3t 4 31
12 1/16/08, 22:36:40 1/16/08, 22:41:40 1 21.
13 1/16/08, 22:48:38 1/16/08, 22:53:38 1 21
14 1/17/08, 16:24:39 1/17/08, 16:29:39 1 21
15 1/17/®8 23 18 38 1 17108. .53 6 48
16 1/18/08, 00:00:38 1/18/08, 00:05:38 1 33
17' 1L18/,,08, OQ 4238; 1118/F08 Ql.OS8 4 35

Mr. Paul E. Stubbs
11/25/08
Page 5
1'$ 1/�510,$, 08,.48 3Gl18/i8 '0, . SA35 28
19 1 /18J0,8;09`48.:36 27
20 11/18l08, Oi12;36 1180 �0.41• 5 25
32 3/610$, 2Q,:3i36 %6/O 2047.3.E 2 33
2° Quarter
1 6/2 23-: 6, 6/2/0$;' 23; ;'36 2 30
10' 24 3 2 6/24/08, 09:06:37 6/24/08, 09:11:37 1 29