AQ_F_0400056_20130515_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Piedmont Natural Gas-Wadesboro Compressor
Station
Inspection Report NC Facility ID 0400056
Date: 05/16/2013 County/FIPS: Anson/007
Facility Data Compliance Data
Piedmont Natural Gas-Wadesboro Compressor Station Inspection Date 05/15/2013
259 Pleasant Grove Church Road Inspector's Name Gregory Reeves
Wadesboro,NC 28170 Operating Status Operating
Lat: 35d 1.4834m Long: 80d 1.6830m Compliance Code Compliance- inspection
SIC: 4922/Natural Gas Transmission Action Code FCE
NAILS: 48621 /Pipeline Transportation of Natural Gas On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 10097/R00
Alicia Mooney Rodney Myers Alicia Mooney Issued 3/28/2011
Environmental Engineer VP of Environmental Engineer Expires 2/28/2016
_ [phone] Engineering/Operations [phone] Classification Title V
Services Permit Status Active
[phone]
Inspector's Signature: 169 f, Comments:
Of,
Date of Signature:
1. MACT/GACT Review:
This facility currently has four 4,735 HP natural gas-fired engines driving compressors, and one 880 HP natural
gas-fired engine driving an emergency generator. The facility is permitted to operate eight of the compressors
and the emergency generator. All of these engines are subject to 40 CFR 63 Subpart ZZZZ and NSPS Subpart
_ JJJJ. There are no other current NESHAP or NSPS regulations that apply to the facility. None of the engines
are certified to achieve the NSPS emission limitations, so will have to be stack tested to verify compliance with
emission limits.
2. DIRECTIONS TO SITE:
From FRO,take US Hwy 401 South through Raeford and Wagram. Just outside 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.
3. 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 yet operating. The operations are currently being
tested to assure proper operation.

Piedmont Natural Gas—Wadesboro Compressor Station
Compliance Inspection Report
05/15/2013
Page 2 of 6
4. FACILITY DESCRIPTION:
The facility is a large natural gas pipeline compressor station. The facility accepts natural gas from the
Piedmont 30 inch diameter distribution pipeline at 500-800 psig pressure, and compresses this gas to 800-1,000
psig for injection back into the 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 eight(8)permitted natural gas-fired
4,735 HP compressors,plus a 770 HP natural gas-fired emergency generator. The facility has not yet started
operation,and is in the midst of performing stack tests to demonstrate compliance with NSPS Subpart JJJJ
requirements for the engines.
5. FACILITY INSPECTION SUMMARY:
On 05/15/2013 I, Greg Reeves,visited the Piedmont Natural Gas—Wadesboro Compressor Station plant site in
Wadesboro. I met with Gil Vinzani,Environmental Engineer,Michael Golombowski,Manager, Gas Control,
and Tony Jabon, Principal Consultant. Mr. Jabon is the facility consultant and works for Trinity Consultants in
Charlotte,NC. The primary purpose of the visit was to witness the stack testing of the emergency generator
engine to determine compliance with NSPS Subpart JJJJ emission limits. While at the facility, I also conducted
a facility compliance inspection. The company has installed four of the eight permitted large 4,735 HP natural
gas-fired compressor units and has also installed the natural gas-fired emergency generator, The compressors
will be taking natural gas from the main pipeline at 500-800 psi pressure, and re-compressing it to 800-1,000 psi
in order to transport it further down the pipeline. The gas from this installation is slated to be transported to the
Progress Energy facility, but the Progress facility is not yet ready to receive the gas. Therefore,the compressor
station has not become fully operational,and is in the process of testing of the operations. Installation of
additional compressors will be done as needed to add capacity in the future.
NOTE: The emergency generator that was installed at the facility is an 880 HP unit,not the 770 HP unit
that was permitted. At the next permit revision,the higher horsepower engine should be evaluated and
the description should be changed.
See pictures in the facility file on the G drive.
6. PERMITTED EQUIPMENT:
Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
COMP01 One four-stroke lean burn natural gas- COMP01 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- 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

Piedmont Natural Gas—Wadesboro Compressor Station
Compliance Inspection Report
05/15/2013
Page 3 of 6
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 1 One four-stroke lean burn natural gas-
MACT fired emergency generator(770 hp N/A N/A
maximum rating)
NOT OPERATING
7. SPECIFIC PERMIT CONDITIONS:
A. Eight 4,735 Four Stroke Lean Burn Natural Gas-fired Compressor Engines(ID Nos. COMPOI through
COMPO8)
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 Ib/mmBtu. As long as the engines only combust natural gas,they should not exceed
the limitation. The engines were not operating during the inspection and have not yet been formally
started up.
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 and have not yet been formally started up.

Piedmont Natural Gas—Wadesboro Compressor Station
Compliance Inspection Report
05/15/2013
Page 4 of 6
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 and
have not yet been formally started up.
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 Ib/mmBtu. As long as this engine only
_ combusts natural gas, it should easily meet this limitation. The engine was not operating during the
inspection and has not yet been formally started up.
_ 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 and has not yet been formally started up.
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."
APPEARS IN COMPLIANCE—The engines will demonstrate compliance by complying with the
requirements of NSPS Subpart JJJJ. The engines were not operating during the inspection and have
not yet been formally started up.

Piedmont Natural Gas—Wadesboro Compressor Station
Compliance Inspection Report
05/15/2013
Page 5 of 6
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.
APPEARS INCOMPLIANCE—Stack testing will be performed to demonstrate compliance. This
stack testing has not yet been completed. The engines were not operating during the inspection,and
have not yet been formally started up.
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.
- APPEARS IN COMPLIANCE—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 have not yet been
formally started up.
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,and have not yet been
formally started up.
v. CLEAN AIR ACT,SECTION 112(r)REQUIREMENTS
APPEARSIN 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).

Piedmont Natural Gas—Wadesboro Compressor Station
Compliance Inspection Report
05/15/2013
Page 6 of 6
8. CONCLUSIONS/RECOMMENDATIONS:
The facility appeared to be IN COMPLIANCE during my visit. The facility has not yet commenced full
operation, and is just starting to conduct stack testing on the engines at this time. It is anticipated that full
operations may commence sometime in December 2013.
Stack testing will be required to be conducted for the compressor engines after startup. I recommend that a
compliance inspection be conducted in conjunction with the stack testing observation when these engines are
tested for compliance with NSPS Subpart JJJJ.
Note also that the Emergency Generator engine(ID No.EG01)was supplied as an 880 HP engine,not the 770
HP engine that was submitted to be permitted. At the next permit revision,this HP description should be
changed. It was recommended that the facility representative or their consultant contact Kevin Godwin at RCO
to discuss the engine horsepower and see whether the permit might be modified administratively to incorporate
the correct horsepower in the emission source chart.
Note that a full Title V permit application must be submitted within 12 months of initial startup of the first
compressor unit.