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Home My WebLink AboutAQ_F_0400056_20150121_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Piedmont Natural Gas-Wadesboro Compressor Station Inspection Report NC Facility ID 0400056 Date: O1/23/2015 County/FIPS:Anson/007 Facility Data Permit Data Piedmont Natural Gas-Wadesboro Compressor Station Permit 10097/TO 259 Pleasant Grove Church Road Issued 9/15/2014 Wadesboro,NC 28170 Expires 8/31/2019 Lat: 35d 1.4834m Long: 80d 1.6830m Classification Title V SIC: 4922/Natural Gas Transmission Permit Status Active NAICS: 48621/Pipeline Transportation of Natural Gas Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V _ Gil Vinzani Martin Petchul Gil Vinzani MACT Part 63: Subpart ZZZZ Environmental Engineer Managing Dir. of Eng. Environmental Engineer NSPS: Subpart-JJJJ (919)899-6081 and Tech. Svcs. (919)899-6081 (704)731-4457 Compliance Data Comments: Inspection Date 01/21/2015 / Inspector's Name Gregory Reeves Inspector's Signature: ( � Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: O✓A,6*11— On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PM10 *HAP 2013 0.0800 --- 1.0000 0.3900 0.1100 0.0800 985.82 2012 --- --- -- --- --- 2011 --- --- --- --- * --- Highest HAP Emitted(in pounds) Five Year Violation History:None Date Letter Type. Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested Piedmont Natural Gas—Wadesboro Compressor Station Compliance Inspection Report Page 2 of 6 . 1. DIRECTIONS TO SITE: From FRO,take US Hwy 401 South through Raeford and Wagram. Just past Wagram,turn right onto Old Wire Road(NC 144). Follow Old Wire Road across US 15/501 and through Laurel Hill to US 74. Turn right onto US 74. Follow US 74 35 miles to Wadesboro,then turn right onto N.Greene St/NC Hwy 109. Drive 4.9 miles, then turn left onto Pleasant Grove Church Road. The Piedmont facility is located approximately 0.3 miles on the left side of the road. 2. SAFETY CONSIDERATIONS: The usual FRO safety gear is required,including hard hat,safety shoes,safety glasses,and hearing protection. There may be numerous pieces of equipment operating on site,including forklifts,personnel lifts,trucks,cars, and others. At the time of this inspection,the facility was not operating. 3. FACILITY DESCRIPTION: The facility is a large natural gas pipeline compressor station. The facility accepts natural gas from the Trans- Continental distribution pipeline at 500-800 psig pressure, and compresses this gas to 800-1,000 psig for injection into the Piedmont pipeline to transport it to its destination. The Piedmont facility consists of four(4) permitted natural gas-fired 4,735 HP compressors(8 are permitted at the facility),plus a 770 HP natural gas- fired emergency generator. All the engines are fueled by natural gas from the transmission pipeline. The facility operates only as needed to supply the gas demand downstream of the compressor station. 4. FACILITY INSPECTION SUMMARY: On 01/22/2015 I,Greg Reeves,visited the Piedmont Natural Gas—Wadesboro Compressor Station plant site in Wadesboro. The facility was not in operation,but facility personnel were on site conducting maintenance and a security inspection. The facility is generally un-manned unless gas demand spikes,generally due to colder weather I met with Mr.Alan Henderson,Manager,Compression and Controls(910-419-7207 office, 910-334-9035 cell). I explained that I was at the site to conduct a compliance inspection. Mr.Henderson verified that the FacFinder information was correct for the facility contacts. Records for operating hours and operating loads on the engines is kept on the computerized control system. The operator was able to show me the records on operating hours for each of the permitted engines. Piedmont Natural Gas—Wadesboro Compressor Station Compliance Inspection Report Page 3 of 6 5. PERMITTED EQUIPMENT: Emission Emission Source Description Control Control Device Description Source Device ID No. ID No. COMPOI One four-stroke lean bum natural gas- COMPOl C Catalytic oxidizer(24.0 cubic NSPS fired reciprocating internal feet of oxidation catalyst) MACT combustion engine(4,735 horsepower rating)powering a compressor NOT OPERATING COMP02 One four-stroke lean burn natural gas- COM002C Catalytic oxidizer(24.0 cubic NSPS fired reciprocating internal feet of oxidation catalyst) MACT combustion engine(4,735 horsepower rating)powering a compressor NOT OPERATING COMP03 One four-stroke lean burn natural gas- COMP03C Catalytic oxidizer(24.0 cubic NSPS fired reciprocating internal feet of oxidation catalyst) MACT combustion engine(4,735 horsepower _ rating)powering a compressor NOT OPERATING COMP04 One four-stroke lean burn natural gas- COMP04C Catalytic oxidizer(24.0 cubic NSPS fired reciprocating internal feet of oxidation catalyst) MACT combustion engine(4,735 horsepower rating)powering a compressor NOT OPERATING COMP05 One four-stroke lean burn natural gas- COMP05C Catalytic oxidizer(24.0 cubic NSPS fired reciprocating internal feet of oxidation catalyst) MACT combustion engine(4,735 horsepower rating)powering a compressor NOT OPERATING COMP06 One four-stroke lean burn natural gas- COMP06C Catalytic oxidizer(24.0 cubic NSPS fired reciprocating internal feet of oxidation catalyst) MACT combustion engine(4,735 horsepower rating)powering a compressor NOT OPERATING COMP07 One four-stroke lean burn natural gas- COMP07C Catalytic oxidizer(24.0 cubic NSPS fired reciprocating internal feet of oxidation catalyst) MACT combustion engine(4,735 horsepower rating)powering a compressor NOT OPERATING COMP08 One four-stroke lean bum natural gas- COMP08C Catalytic oxidizer(24.0 cubic NSPS fired reciprocating internal feet of oxidation catalyst) MACT combustion engine(4,735 horsepower rating)powering a compressor NOT OPERATING EGO I One four-stroke lean burn natural gas- MACT fired emergency generator(770 hp N/A N/A maximum rating) NOT OPERATING Piedmont Natural Gas—Wadesboro Compressor Station Compliance Inspection Report Page 4 of 6 6. SPECIFIC PERMIT CONDITIONS: A. Eight 4,735 Four Stroke Lean Burn Natural Gas-fired Compressor Engines(ID Nos. COMPOI,through COMP08) i. 15A NCAC 2D.0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES— Emissions of sulfur dioxide from the eight 4,735 HP compressor engines shall not exceed 2.3 pounds per million Btu heat input. APPEARS IN COMPLIANCE—The engines use only natural gas,with an EPA AP-42 emission factor of 0.001 lb/mml3m. As long as the engines only combust natural gas,they should not exceed the limitation. The engines were not operating during the inspection. Only 4 of the permitted engines have been installed. ii. 15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from the eight compressor engines shall not exceed 20 percent opacity when averaged over a 6-minute period. 6- minute averaging periods may exceed 20 percent opacity no more than once in any hour and not more than four times in any 24-hour period. In no event shall the 6-minute average exceed 87 percent opacity. APPEARS IN COMPLIANCE—The typical opacities for these engine exhausts are zero. The facility should have no difficulty complying with these limits. The engines were not operating during the inspection. iii. 15A NCAC 2D.1423 LARGE INTERNAL COMBUSTION ENGINES—The Permittee shall not cause to be emitted into the atmosphere nitrogen oxides (NOx)in excess of 125 ppm, corrected to 15 percent by volume stack gas oxygen on a dry basis,averaged over a rolling 30-day period. This limit may be adjusted basis the engine efficiencies. Compliance with the limits will be demonstrated by conducting stack testing at the engine exhausts. A report is required by October 31 of each year, documenting the total nitrogen oxide emissions during the period Mayl through September 30 of each year,beginning with the year of the first ozone season that the engines operate. Records are required to be maintained for each engine for ID and location of each engine;number of hours of operation of each engine each day, including startups,shutdowns,and malfunctions,and the type and duration of maintenance and repairs;date and results of any emissions corrective maintenance taken;results of compliance testing. Emission standards do not apply during periods of start-up and shutdown and periods of malfunctions,not to exceed 36 consecutive hours,or regularly scheduled maintenance activities. APPEARS INCOMPLIANCE—The facility will maintain all records electronically through the DCS control system,which maintains hours of operation and other data. Some paper records may also be maintained for the maintenance operations. The engines were not operating during the inspection. The last ozone season report was received at FRO on 10/30/14. B. 880 HP Four Stroke Lean Burn Natural Gas-fired Emergency Generator(ID No.EGO1) i. 15A NCAC 2D.0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES— Emissions of sulfur dioxide from the emergency generator engine shall not exceed 2.3 pounds per million Btu heat input. APPEARS INCOMPLLANCE—The engine combusts only natural gas. The EPA AP-42 emission factor for sulfur dioxide for natural gas combustion is 0.001 lb/mmBtu. As long as this engine only combusts natural gas,it should easily meet this limitation. The engine was not operating during the inspection. Piedmont Natural Gas—Wadesboro Compressor Station Compliance Inspection Report Page 5 of 6 ii. 15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS-Visible emissions from the emergency generator engine shall not exceed 20 percent opacity when averaged over a 6-minute period. 6-minute averaging periods may exceed 20 percent opacity no more than once in any hour and not more than four times in any 24-hour period. In no event shall the 6-minute average exceed 87 percent opacity. APPEARS IN COMPLIANCE—Typical visible emissions for this engine are zero. The facility should have no difficulty complying with this limitation. The engine was not operating during the inspection. C. Compressor Engines(COMPOI through COMP04)and Emergency Generator Engine(EGO1) i. 40 CFR 63,Subpart ZZZZ STATIONARY RECIPROCATING INTERNAL COMBUSTION ENGINES—The engines meet the requirements of Subpart ZZZZ by meeting all the requirements of NSPS Subpart JJJJ"Stationary Spark Ignition Internal Combustion Engines." APPEARS IN COMPLLANCE—The engines will demonstrate compliance by complying with the requirements of NSPS Subpart JJJJ. The engines were not operating during the inspection. ii. 40 CFR 60,Subpart JJJJ STATIONARY SPARK IGNITION INTERNAL COMBUSTION ENGINES—The compressor engines must meet the following emission limits: NOx—1.0 g/HP-hr and 82 ppmvd @ 15%oxygen;CO 2.0 gW-hr and 270 ppmvd @ 15%oxygen;VOC 0.7 g/AP-hr and 60 ppmvd @ 15%oxygen. The emergency engine must meet the following emission limits: NOx— 2.0 g/HP-hr and 160 ppmvd @ 15%oxygen;CO 4.0 g/IIP-hr and 540 ppmvd @ 15%oxygen;VOC— 1.0 g/HP-hr and 86 ppmvd @ 15%oxygen. VOCs do not include formaldehyde. The nine engines are not certified engines,and therefore the facility must conduct initial stack testing to demonstrate initial compliance on each engine. Records of maintenance plans and records of conducted maintenance must be maintained,as well as records of the stack testing. Subsequent stack testing must be conducted every 8,760 hours or 3 years,whichever comes first. Results of stack testing must be submitted within 60 days after the testing is performed. APPEARS IN COMPLLANCE—Stack testing was performed on the emergency generator engine on 05/21/13. Results of the test demonstrated compliance with the emission limits. Stack testing for the four compressor engines was conducted on 02/25—02/27/14. The stack testing results indicated compliance with the emission limits. The engines were not operating during the inspection. The operating hours of the four compressor engines were as noted in the table below. The emergency engine is seldom run except for operational checks,and will be due for stack testing in May 2016. The facility is preparing for the 1,000 hour maintenance for each of these engines. zmss, T3a fttaF1s tlxat StE�r t tIougsatflat i z l'f � gU� COMPOI 02/25/14 197 909 712 COMP02 02/26/14 185 920 735 COMP03 02/26/14 179 897 718 COMP04 02/27/14 178 892 714 Piedmont Natural Gas—Wadesboro Compressor Station Compliance Inspection Report Page 6 of 6 iii. 15A NCAC 2Q.0317 AVOIDANCE CONDITION FOR 40 CFR 63 SUBPART ZZZZ(HAP MAJOR CLASSIFICATION AVOIDANCE)—The facility has accepted an emission limit of no more than 10 tons of formaldehyde per consecutive 12-month period to avoid the Major Source rules for this Subpart. This requirement is met by conducting the required monitoring,recordkeeping,and reporting of emissions of CO based on stack testing. APPEARS INCOMPLIANCE—The review of the potential controlled emissions during the permit review process showed that this limit should not be exceeded. Proper operation and maintenance of the catalytic oxidizers on the engines is required to comply with this limit. The stack testing results indicated compliance with the emission limits. The engines were not operating during the inspection. iv. 15A NCAC 2D.1100 TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REQUIREMENT—Potential emissions of Acrolein,Butadiene,Benzene, and Formaldehyde exceeded the TPERs. The facility submitted a dispersion modeling analysis for these four pollutants with the permit application. Limits for the four pollutants were included in the permit for each emission source. (Note that Benzene was not included in the modeling for the emergency generator engine.) APPEARS IN COMPLLANCE—Since the maximum potential emissions were modeled and shown to not exceed these limits,the facility should meet the limitations as long as the engines are operated as originally permitted. The engines were not operating during the inspection. v. CLEAN AIR ACT,SECTION 112(r)REQUIREMENTS APPEARS IN COMPLLANCE—The facility does not store any of the listed 112(r)chemicals in amounts that exceed the threshold quantities. Therefore,the facility is not required to maintain a written Risk Management Plan(RMP). 7. COMPLIANCE HISTORY: There have been no negative compliance instances since the permit was initially issued in 2011. S. FACILITY PINK SHEET REVIEW: There were no pink sheet items to be included in the facility inspection. 9. CONCLUSIONS/RECOMMENDATIONS: The facility appeared to be INCOMPLLANCE during my visit. The facility was not operating during this visit.