AQ_F_0400056_20110330_CMPL_CmplDetLtr

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North Carolina Department nf Environment and Natural Resources
Division of Air Quality
Beverly Eaves Perdue Shei)aC. Holman Dee Freeman
Governor Director Secretary
March 3O. 2O11
Michael DePa|ma, PE
Manager, Environment and Safety Policy
PiedmontNotuna| Gas - Conoo/d Compressor
Post Office Box33068
Charlotte, NC28233
Subject: Piedmont Natural Goo. Inc. -VVadeoboro Compressor Station
VVadoaboro. Anson County, North Carolina
Facility |D04-OUU5G
Draft Permit No. 1OO&7ROO
Request for Testing uf Representative Units
Dear Mr. DePa|ma:
The North Carolina Division of Air Quality (DAQ) has reviewed the permit addendum and letter dated
February4. 2011 submitted by Piedmont Natural Gas, Inc. (Piedmont). The DA(] requires initial
performance testing of all non-certified engines and control systems.
Piedmont Natural Gas, Inc. plans on installing eight new natural gas internal combustion engines greater
than 5OO horsepower at the VVodeobono Compressor Station. The subject engines also have acatalyst
system to control carbon monoxide. These engines are subject to 40 CFR 00 Subpart JJJJ. |nitiaUy, the
facility planned on installing certified engines under the SubpadJJJJ definition. Howover, certified engines
are not available at this time. Therefore, Piedmont submitted u permit addendum to install non-certified
engines and control systems. Non-certified engines require periodic testing, including an initial
performance test.
Piedmont has requested to test representative sample of non-certified engines rather than testing each
individual engine This request is based on an applicability determination issued by US EPA to Consumer
Power on February 2. 1088 regarding NSPS performance testing of identical units.
DAQ does not believe this applicability determination applies to the subject units due to the addition of a
catalyst control system to the engines. The operation of the control system needs to be verified as well as
the emissions from the engine. While Piedmont may be able b>verify that the engines are identical, the
design and performance of the control systems may not ba identical.
In addition. DAQ has reviewed stack test reports from other facilities located in North Carolina with identical
turbine engines and C{} catalyst systems where the catalyst systems on several units did not perform as
specified by the manufacturer. These units required modification to the control system and retesting to
verify the performance of the control system.
1041 Mail Service Center,Raleigh, North Carolina 27O89'1O4i One
2728 Capital 8|vd,Raleigh,North Carolina 27604 NorthCarolina
Phone: 919-7%3-1728/FAX S19-733-1812/Internet: wwwoonicmg Nahmally

Mr. Michael DePalma, Piedmont Natural Gas, Inc.
March 30, 2011
Page 2
In conclusion, DAQ does not believe the 1988 applicability determination for Consumer Power presented by
Piedmont is applicable to the proposed non-certified engines at the Wadesboro Compressor Station. DAQ
requires initial performance testing of any non-certified engines and control systems. After the initial
performance test verifies the proper operation of the catalyst control system and demonstrates the
emissions are less than 25% of the applicable standard, representative testing would be allowed for these
non-certified engines.
If you have any questions regarding the results of this review, please contact me at (919) 919-733-1479
or at michael. 'etra' ncdenr. ov.
Since ly
d
icha .Pj t P.E., Supervisor
Stationary ource Compliance Branch
cc: Central Files, Anson County
Steve Vozzo, Fayetteville Regional Office
DAQ Permits, Kevin Goodwin