AQ_F_0400056_20130521_ST_STO-Rpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Piedmont Natural Gas-Wadesboro Compressor
Station
Stack Test Observation Report NC Facility ID 0400056
Date: 05/22/2013 County/FIPS: Anson/007
Facility Data - Compliance Data
Piedmont Natural Gas-Wadesboro Compressor Station Observation Date 05/21/2013
259 Pleasant Grove Church Road Observer's Name Gregory Reeves
Wadesboro,NC 28170 Operating Status Operating
Lat: 35d 1.4834m Long: 80d 1.6830m Action Code 23/STACK TEST
SIC: 4922/Natural Gas Transmission OBSERVED
NAICS: 48621 /Pipeline Transportation.of Natural Gas
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
(704) 731-4I18 Engineering/Operations [phone] Classification Title V
Services Permit Status Active
[phone]
Inspe^Siganature:
Comments:
4 Source Test Tracking Number
Datel2 MI-3 0{ 2013-071ST
1. LOCATION:
Piedmont Natural Gas-Wadesboro Compressor Station,259 Pleasant Grove Church Road, Wadesboro,NC,
Anson County.
2. DIRECTIONS:
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 other vehicles. At the time of this stack test,the facility was not yet operating. The operations are currently
being tested to assure proper operation.
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 in Wilmington,but the power station has not

Piedmont Natural Gas—Wadesboro Compressor Station
Stack Test Observation Report
05/21/2013
Page 2 of 4
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.
S. TEST CHRONOLOGY:
04/10/13 FRO received a letter from the company with testing protocols and stack test notifications for
both the Wadesboro and Lumberton facilities. Stack testing was proposed for only the
emergency generator engines at each of these locations. The proposed date for the test at the
Wadesboro facility was May 15,2013.
05/06/13 Mitch Revels of FRO received an email from Gil Vinzani of Piedmont Natural Gas
confirming that the testing of the emergency generator engine at Wadesboro was still
scheduled for 05115.
05/07/13 DAQ SSCB reviewed the testing protocol and deemed it acceptable. Testing is for the initial
- _ performance testing required under NSPS Subpart JJJJ.
05/15/13 Stack testing was proposed, but failure of an analyzer resulted in the testing to be postponed
until May 21,2013.
05/21/13 Testing was conducted on the engine.
6. PURPOSE OF STACK TEST:
The purpose of this test is to demonstrate compliance for the initial performance test for the emergency
generator natural gas-fired reciprocating internal combustion engine as required under NSPS Subpart JJJJ. This
engine is not a "certified" engine, and thus a stack test is required to demonstrate compliance with the NOx,
CO,and VOC emission standards under the NSPS regulation.
The engine being tested is a Waukesha 880 HP natural gas-fired engine, driving a 600 KW electrical generator.
Under NSPS Subpart JJJJ,the emission limits for this engine are as follows: [40 CFR 60, Subpart JJJJ,Table 1]
Note that the owner or operator can choose to comply with either the emission limit in g/hp-hr OR the emission
limit in ppmvd% 15%Oz.
Emissipn LimitErrissAOA »it
�Pollutanf�' v.
/11` 6ir ; , invil 1' 02"".,
NOx 2.0 160
CO 4.0 540
VOC 1.0 86
g/hp-hr=grams per horsepower—hour
ppmvd=parts per million by volume,dry basis,corrected to 15%Oz content

Piedmont Natural Gas—Wadesboro Compressor Station
Stack Test Observation Report
05/21/2013
Page 3 of 4
The approved test methods are as follows:
Ta`g9t Proposed Test ;
Number' ,Test Number of
+ f of Test Run Samplutg Comments"
Poll ; IGlethodr - w
+r guns Duration Po nts
CO EPA Method 10 3 60 min
OZ EPA Method 3A 3 60 min 1-3 No of sampling points is per WE
NOx EPA Method 7E 3 60 min stratification test
VOC EPA Method 25A 3 60 min
Moisture EPA Method 4 3 60 min 1-3 For moisture calculations,correction
to dry standard
CH4 EPA Method 18 3 60 1-3 Correction of THC to report NMHC
THC—total hydrocarbon
NMHC—non-methane hydrocarbon
Testing is to be conducted at full load+ 10%. Proposed testing rate was 770 HP.
7. STACK TEST OBSERVATIONS:
On May 15, 2013, I, Greg Reeves of the Fayetteville Regional Office, arrived at the Piedmont Natural Gas —
Wadesboro Compressor Station site to observe stack testing of the emergency generator engine. I met with Gil
Vinzani, Environmental Engineer (919-899-6081 office, 919-623-5701 cell), Mike Golombowski, Manager,
Gas Control (704-731-4647 office, 704-618-1286 cell), and Tony Jabon, consultant with Trinity Consultants in
Charlotte, NC (704-553-4474 office, 214-274-7980 cell). Air-Tech Environmental, LLC was performing the
source test for Piedmont. The technician for Air-Tech was Darrel Doerle (919-302-6627 office, 919-544-6338
cell).
l,. The test technician informed me that one of the stack gas analyzers had not been operating properly, and a
backup unit had been sent for and would arrive later in the day. This is a new facility and has not yet formally
commenced operation. The facility personnel conducted me on a tour of the plant. Pictures are available on the
FRO LAN G: drive. The facility currently consists of four large natural gas compressors driven by 4,273 HP
Natural Gas-fired engines. The facility is permitted for eight of these compressor engines. The facility also
includes a 600 KW emergency generator driven by an 880 HP natural gas-fired engine. Facility personnel
indicated that full load for the generator in the event of a power outage should not exceed 500 KW.
Since the testing was not going to resume until early afternoon, I left the facility to conduct other business.
Testing was to commence when the new analyzer arrived.
UPDATE 05/16/13:
Greg Reeves received an email from Tony Jabon stating that the testing had been postponed, and would
commence on Tuesday May 21 2013. Difficulties with the testing equipment had been corrected,but the
equipment manufacturer's representative on site had noted some difficulties with engine tuning and gas pressure
problems that were also corrected prior to the testing.
UPDATE 05/21/13:
I arrived back at the site at approximately 8:45 AM on Tuesday 05/21/13. The generator engine had been
started up, and the generator was connected to a heat sink load that would allow full load operation. The
generator was operating at a load of approximately 550 KW. The first stack test run commenced at
approximately 8:55 AM, and finished at approximately 9:55 AM. The load during the test run was very steady
at 550-551 KW. Typical field data and field calculations for the run were as follows(Further analysis will be
done prior to the final report):

Piedmont Natural Gas—Wadesboro Compressor Station
Stack Test Observation Report
05/21/2013
Page 4 of 4
Park eter. Uncorrected Reading Corrected Reading -hr
02 7.26% ------ ------
COz 7.37% ------ ------
NOx 231 ppm 105 ppm 1.90
CO 385 ppm 169 ppm 1.87
THC** 775 ppm ------ ------
CH4 743 ppm ------ ------
NMHC 1 32 ppm I ----- ------
includes methane,which will be subtracted to obtain NMHC results.
A gas sample taken during the testing showed a methane content of approximately 743 ppm when analyzed on a
gas chromatograph. Therefore,the uncorrected NMHC appears to be approximately 32 ppm.
I departed the site at 10:30 after the first test run had concluded, and before the second test run had commenced.
8. COMPLIANCE STATEMENT:
It appeared that the stack testing during the first test run was conducted in accordance with the requirements of
the EPA methods specified. Field results on the analysis of the stack gases and preliminary emission
calculations based on field measurements of power generation would appear to indicate compliance with the
emission limits set forth in NSPS Subpart JJJJ. However,these were only preliminary field calculations. Final
results will be submitted by the company.
gwr
cc: FRO Facility Files

Piedmont
011
Natural Gas
April 9, 2013
Ms. Shannon Vogel
North Carolina Division of Air Quality APR 10 2011
1641 Mail Service Center
Raleigh, NC 27699-1641
FAYEMILLEREOIONALOFFICL
RE: Stack Test Notifications.and Protocols
Lumberton and Wadesboro Sites- NSPS Subpart JJJJ
DAQ Permit Nos. 10094R01 (Lumberton)and 10097R00(Wadesboro)
Ms. Vogel:
Piedmont Natural Gas (Piedmont) is submitting protocols and stack test notifications for two
sites: the Lumberton Facility located at 3012 Singletary Church Rd., Lumberton, North Carolina
and the Wadesboro Compressor Station located 259 Pleasant Grove Church Rd.,Wadesboro,
North Carolina.
Piedmont operates a natural gas-fired generator at each location subject to New Source
Performance Standard(NSPS)Subpart JJJJ. As required by40 CFR 60.8, Piedmont must
complete performance testing on these units within 60 days of achieving maximum production.
The Wadesboro unit began operation on March 22, 2013 and the Lumberton unit has yet to
begin operation. Piedmont is requesting approval to test both units prior to May 22 In order to
meet this requirement.
We have contracted with Air-Tech Environmental to conduct testing based on NSPS required
test methods. Two protocols and DAQ requested items are included with this letter. If you have
any questions or comments with regard to this submittal, please contact me at(919) 899-6081.
Sincerely,
��C
Gil Vinzani
Attachments: DAQ Stack Test Protocols
cc: Tony Jabon,Trinity Consultants, Inc.
150 Fayetteville Street, Suite 2810
Raleigh, North Carolina 27601
piedmontng.com

1
�® pq� PROTOCOL ,SUBAUTTAL FORM(Rev.2010a)
s "®EN" DrmioN OF STIR QUALITY PAGE 1 OF 2
Purpose: The goals of the Protocol Submittal Form are to initiate communication between representatives of the permitted facility,
the testing consultants,and the DAQ as well as to identify and resolve any specific testing concerns prior to testing.
Instructions: Use Guidance Document to fill out this form. Submit all forms and additional information to the DAD Regional
Supervisor at least 45 days prior to testing. Complete one form for each sampling location. If this form does not supply
sufficient space to completely answer all questions or if additional relevant information is necessary, attach additional
documentation and/or information to the original form Questions and/or comments should be directed to the appropriate
Regional Supervisor.
This form and its Guidance Document are available from the DAQ website(http://daq.StAte.ne-us/enf/Soureetestl)
Specify Appropriate Regional Office:(check one)
❑Asheville ®Fayetteville ❑Mooresville ❑Raleigh ❑Washington ❑Wilmington ❑Winston-Salem
FacilityName:Piedmont Natural Gas-Wedesboro Testing Company:Air-Tech Environmental,LLC
Compressor Station
Facility ID No;0400056
_ Facility Contact Person/mailing address&email: Testing Company Contact Person'/mailing address&email:
Gil Vlnzani, P.E. Michael W.HartmaaorDarrell H.Doerle
Environmental Engineer Air-Tech Environmental,LLC
Piedmont Natural Gas P.0.Box 12353
150 Fayetteville St., Suite 2810 Research Triangle Park,NC 27709-2353
Raleigh,NC 27601
Email Address:giLTfimni®piedmontag.com Email Address:answersopass.net
Phone:[phone] Fax: Phone:[phone] Pax:919-572-2203
5701 Mobile No.:919-623- Mobile No.:919-270-1810
Air PermitNumber&Revislam 10097R00 Permitted Source Name and ID No.:One four-stroke lean bum natural
gas-fired emergency generator EGO
Permitted Maximum Process Rate: MaximurallormdOperationProcessRate: TargetProcess Rate for Testing:
770 BF N/A 770 BF
1.1)What is the sproffic purpose for the proposed testing?(permit condition,NSPS,NESBAP,etc,see guidance doe):To demonstrate
compliance with 40 CFR Part 60,Subpart JJJ
Is this an initial performance test? ©Yes or ®No
1.2)List all state and federal regulations that apply to the proposed testing(see guidance doe):NSPS Subpart JJJJ,15 NCAC 20.0524
13)Will the test results be used for other regulatory purposes(e.g.,emission inventories,penult application,etc.)beyond that stated above?
❑Yes or ®No If yes,explain.
1.4)How will production/process&control device data be documented during testing(list specific control equipment,process parameters,
instrumentation that will be used,frequency of data collection,collected by computadmanually,etc.)?TEST WILL NOT BE
ACCEPTED Wf£HOUT APPROPRIATE PRODUCTION/PROCESS&CONTROL DEVICE OPERATION DATA.
Engine load will be calculated from parameters recorded electronically during testing(e.g„firing rate,timing,rpm).
1.5)Provide a brief description of the source(including control equipment)and attach source or process flow diagram from source through
stack exit One 4-stroke lean burn natural gas-fired emergency generator without emission control devices.
1.6)Provide a brief description of the sampling location,attach schematic of sampling location,and indicate whether concurrent testing will
be conducted at other sampling locations(Approval of protocol without this data will not exempt you from Method I criteria):
Samples will be collected from the unit exhaust stack. No sketch is available at this time. The pretest stratification traverse will be used
to demonstrate acceptability of the sampling location for gaseous pollutants.

AIR&
a PROTOCOL SUBMITTAL FORM(Rev.moa)
NCDENR DrMION OF AIR QUALITY PAGr 2 oF2
2.1)Provide the following information for each test parameter.
Tgeget Proposed Number of Test Run #of Sampling Comments
Pollutant Test Method Test Runs Duration Points
Sampling points will be based on results of
NOx EPA7E 3 1 1-3 pre-test stratification characterization. VOC
will.be determinated as total hydrocarbons
(M25A less methane l8
CO EPA 10 3 1 1-3
VOC EPA25A/16 3 1 1-3
021CO2 EPA 3A 3 1 1-3
Moisture EPA 4 3 1 1-3
22) Will all testing be conducted in strict accordance with the applicable test methods? If answer is no,attach ®Yes No
complete documentation of all modifications and/or deviations to the applicable test methods.
23) Does the proposed sampling location meet the minimum EPA Method 1 criteria for acceptable measurement sites? ®Yes []No
Attach supporting docmmmenmtioa.
2.4) Has cyclonic flow been documented at this source(EPA Method 1 Section 11.4)?
ABSENCE OF CYCLONIC FLOW MUST BE VERIFIED DURING CURRENT TESTING. El as No
2.5) Will the oxygen concentration be determined by 0 EPA Method 3 via Orsat or®strict EPA Method 3A(specify) ®Yes El No
If answer is no,see Question 2.2 above.(Fyritcs am NOT allowed per 15A NCAC 2D.2606)
2.6) Do any of the proposed test methods require analysis of EPA audit samples? If yes,notify Regional Office ��� No
a minimum of 45 days prior to testing to allow for audit sample preparation and shipment.
2.7) Has all testing equipment been calibrated within the past year? If answer is no,explain. ®Yes ❑No
2.8a)Have all calibration gases been certified by EPA Protocol I procedures?(Answer only as applicable) 0 Yes r]No
2.8b)Is a dilution system(via EPA Method 205)proposed?(Answer only as applicable) 0 Yes Z No
2.8c)Attach a summary of expected calibration gas concentrations for all proposed instrumental test methods.
2.9) What is proposed test schedule?DAO Regional Supervisor must be notified a minimum of 15 days prior to the actual test datefsh
THIS FORM DOES NOT CONSTITUTE 15 DAY REGIONAL OFFICE NOTIFICATION
May 15,2013
Additional Comments:
Signatures: Representatives from the permitted facility end the contracted testing company must provide signatures below certifying
that the information provided.on.this form and any attached information is accurate and complete.
/'w
Z F `
"wAo'v� /
Permitte.dFacifity pre/sentaEive ate -Testing Company Representative Date
Name' Gt ' I/ i Vi 2 Ce t71 Name: Darrell II.Docile
Title: t�nVtVGh yHeit�� JJc' plYl�Gt Title: Senior Staff Scientist
Compsny: Pedpli o4 Ala—//Und Gas Company: Air-Tech Environmental,LLC

Natural Gas
May 6, 2013
Mr. Mitchell Revels
NC Division of Air Quality
225 Green.Street, Suite 714
Fayetteville, NC 28301-5043
Subject: Stack Testing Notifications and Protocols
Lumberton and Wadesboro Sites
Dear Mr. Revels:
In response to your inquiry this afternoon, I am confirming that the subject testing will occur on
May 21 for Lumberton and on May 15 for Wadesboro. This is in agreement with the notice and
testing protocols that were submitted on April 9, 2013 to Ms. Shannon Vogel and also to your
office (see attached). This formal notification is in addition to the E-mail notification which you
were sent earlier today.
Should you have any questions, please contact me at [phone], w
MAY 08 2013
Sincerely' FAYETTEViLLE REGIONAL OFFICE
Gil Vinzani, P. E.
Environmental Engineer
Attachment:
April 9, 2013 Cover Letter with Protocol Submittal Forms
150 Fayetteville Street, Suite 2810
Raleigh, North Carolina 27601
piedmontng.com

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Pat McCrory Sheila C. Holmah John E. Skvarla, III
Governor Director Secretary
May 7, 2013 Anson County
Mr.Gil Vinzani
Piedmont Natural Gas, Ino
150 Fayetteville Street, Suite 2810
Raleigh,North Carolina 27601
Subject: Piedmont Natural Gas,Wadesboro MAY 13 2013.
_ = Air Permit No.10097R00,Facility ED 0400056 OENR
Proposed Initial Performance Test for ID EG-01,NG-fired engmeAY EVILLE REGIONAL OFFICE
Proposed Test Date:May 15, 2013
DAQ Tracking No. 2013-071 ST
Dear Mr.VinzaniY
North Carolina Division of Air Quality(DAQ)has reviewed the protocol submittal form(PSF)for the
subject testing and deemed it acceptable. The source is a 4-stroke lean burn natural gas engine emergency
generator rated at 770 horsepower(hp). The proposed testing is the initial performance testing required by
applicable regulations for new sources.
Applicable regulations:
40 CFR 63 Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines(RICE NESHAP)
• Permit including Section 3.0 General Conditions Section JJ General Emissions Testing and
Reporting Requirements
• 15A NCAC 2D .2600 Source Testing
40 CFR 60 Subpart7JJ7,Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
The primary purpose for testing is to demonstrate compliance with 40 CFR 60 Subpart JJJJ. Compliance
with 40 CFR 63 Subpart,ZZZZ is met by complying with the emission limits in 40 CFR 60 Subpart JJJJ.
1641 Mail Service Center,Raleigh,North Carolina 27699-1641
217 West Jones Street,Raleigh,North Carolina 27603
_ Phone:[phone] Fax:[phone]
Internet:www.ncair.oro

Mr. Gil Vinzani May 7, 2013
Page 2
The following emission standards apply to new spark ignition,lean burn burn gas-fired engines
constructed after July 1,2010.
Table 1: NSPS,40 CFR Part 60, Subpart JJJJ Standards for 4-stroke lean bum natural gas-fired
emergency engines> 130 h
Pollutant . Emtsswn"Standard 7rr ,,:=ar .,Emisstoil Standard mud at 1,5,°o;4?zJ
NOx 2.0 -hr 160 ppmvd at 15% OZ
CO 4.0 -hr 540 ppmvd af!5%OZ
VOC 1.0 -hr 86 ppmvd at 15%02
g/hp-hr=gram/horsepower—hour;ppmvd=parts per million by volume, dry basis
Table 2:Approved Test Methods for May 15, 2013:
-_ Number
Target Proposed Test of Test Test Run Number of
Pollutant Method Runs Duration Sampling Points Comments
CO EPA Method 10 3 60
OZ EPA Method 3A 3 60 No. of sampling points is
NCx EPA Method 7E 3 60 1-3 per
VOC EPA Method 25A 3 6p WE stratification test
Moisture EPA Method 4 3 60 1-3 For moisture calculations,
correction to standard
CH4 EPA Method 18 3 60 1-3 Correction of THC to
re ort NMHC
THC=total hydrocarbon;NMHC=non-methane hydrocarbons
The proposed test methods are acceptable for the specified pollutants. Approval of the protocol does not
exempt the tester from the minimum requirements of the applicable methods and 60 Subpart JJJJ
requirements. Since no deviations from the applicable testing methodology were addressed in the test
protocol,the testing should be conducted in strict accordance with the requirements of EPA Methods 3A,
4, 7E, 10, 18, and 25A.
Testing must be conducted at full load f 10%. Testing proposed operating process rate of 770 hp is
acceptable. If you have questions,please,contact me at(919)707-8413 or [e-mail].
Sincerely,
L. Saunders
Environmental Engineer
cc: Steven Vozzo,Fayetteville Regional Office
Central Files,Anson County
1BEAM Documents

Reeves, Gregory W
From: Revels, Mitchell
Sent: Tuesday, May 07, 2013 8:48 AM
To: Reeves, Gregory W
Subject: FW: Wadesboro and Lumberton Emergency Generator Testing Notifications
From: Gil Vinzanlgn pied montnc com [mailto:Gil Vinzanl(&piedmontnc.com]
Sent: Monday, May 06, 2013 2:32 PM
To: Revels, Mitchell
Cc: tiabon(o)trinityconsultants.com
Subject: Wadesboro and Lumberton Emergency Generator Testing Notifications
Mitch:
_ In response to your inquiry this afternoon, I am confirming that the subject testing will occur on May 21 for Lumberton and
_ on May 15 for Wadesboro. This is in agreement with the notice and testing protocols that were submitted on April 9 ,
2013 to Shannon Vogel. As you have suggested, I will follow up this E-mail notification with notifications in writing today
through the US postal service.
Should you have any questions, please contact me at one of the numbers shown below. Thanks,
Gil Vinzani, P. E.
Environmental Engineer
Piedmont Natural Gas
150 Fayetteville St. Suite 2810
Raleigh, NC 27601
[phone] Office
[phone] Mobile
1

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