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Home My WebLink AboutAQ_F_0400056_20140422_CMPL_InspRpt Piedmont Natural Gas—Wadesboro Compressor Station Compliance Inspection Report Page 1 of 6 NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Piedmont Natural Gas-Wadesboro Compressor Station Inspection Report NC Facility ID 0400056 Date: 04/23/2014 County/FIPS: Anson/007 Facility Data Permit Data Piedmont Natural Gas-Wadesboro Compressor Station Permit 10097/ROO 259 Pleasant Grove Church Road Issued 3/29/2011 Wadesboro,NC 28170 Expires 2/28/2016 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)TV-1st Time Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP 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 04/22/2014 Inspector's Name Gregory Reeves Inspector's Signature: Operating Status Operating Compliance Code Compliance- inspection Action Code FCE Date of Signature: m�l�l2B�5� On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PM10 HAP No emissions inventory on record.The emissions inventory is due June 30th of every year. * Highest HAP Emitted(in pounds) Five Year Violation History:None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE: Date Test Results Test Method(s) Source(s)Tested 05/21/2013 Compliance Method 10,Method 18,Method 25A,Method 7E EGO 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 151501 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. Piedmont Natural Gas—Wadesboro Compressor Station Compliance Inspection Report Page 2 of 6 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. This facility was installed to be able to supply natural gas to a Progress Energy electrical power station,but the power station has not yet made the switch to natural gas for the facility. 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. 4. FACILITY INSPECTION SUMMARY: On 04/22/2013 I,Greg Reeves, visited the Piedmont Natural Gas—Wadesboro Compressor Station plant site in Wadesboro. The facility was not in operation,and no personnel were on site. I called Gil Vinzani, Environmental Engineer, to discuss the operation. Mr.Vinzani informed me that the facility is generally un- manned unless gas demand spikes,generally due to colder weather Mr. Vinzani verified that the FacFinder information was correct for the facility contacts. During a recent visit to the facility on 02/25/14 during the stack testing for the four compressor engines, Heather Carter of FRO and I observed some of the facility records for operation of the engines. It appeared at that time that the facility had extensive records of operational hours,NOx emissions quantities, and other relevant information,although no formal inspection was conducted during that site visit. -- It is recommended that the next facility inspection be conducted during the cold weather months (January—February),when the facility will more likely be operating. I would further recommend a call to the facility representative prior to departing for the inspection to verify that the facility is operating that day. 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 burn natural gas- COMPOIC 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- COMP02C 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 burn 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 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. COMPO 1 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/mmBtu. 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 IN COMPLIANCE—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. Records were not inspected during this visit to the facility. B. 770 HP Four Stroke Lean Burn Natural Gas-fired Emergency Generator(ID No.EGO1) NOTE: The actual horsepower of this unit is 880,not 770. At the next permit revision,this engine should be evaluated at the actual horsepower and the description should be changed. _ 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 IN COMPLIANCE—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 Piedmont Natural Gas—Wadesboro Compressor Station Compliance Inspection Report Page 5 of 6 combusts natural gas, it should easily meet this limitation. The engine was not operating during the inspection. 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 and Emergency Generator Engine 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." APPEARSIN COMPLIANCE—The engines will demonstrate compliance by complying with the requirements ofNSPS 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 g/HP-hr and 270 ppmvd @ 15%oxygen; VOC 0.7 g/HP-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/HP-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. An initial notification is required,and results of stack testing must be submitted within 60 days after the testing is performed. APPEARSIN COMPLIANCE—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 02/25/14. The stack testing report has not yet been submitted to DAQ for review. The engines were not operating during the inspection, and records were not reviewed during this visit. iii. 15A NCAC 2Q.0317 AVOIDANCE CONDITION FOR 40 CFR 63 SUBPART ZZZZ(HAP MAJOR CLASSIFICATION AVOIDANCE)—The facility is accepting 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. COMPLIANCE STA TUS NOT DETERMINED—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. This will be verified with the stack testing results. The engines were not operating during the inspection, and the stack testing results have not yet been submitted for the four compressor engines. Stack test results from the testing on the emergency generator engine demonstrated compliance with emissions limits. Piedmont Natural Gas—Wadesboro Compressor Station Compliance Inspection Report Page 6 of 6 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 COMPLIANCE—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 COMPLIANCE—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. CONCLUSIONS/RECOMMENDATIONS: The facility appeared to be INCOMPLIANCE during my visit. The facility was not operating during this visit. The facility is required to submit a full Title V permit application within 12 months of startup of any of the sources. A first time Title V application was received by DAQ on 12/06/13. It is recommended that the next facility inspection be conducted during the cold weather months (January—February),when the facility will more likely be operating. I would further recommend a call to the facility representative prior to departing for the inspection to verify that the facility is operating that day.