AQ_F_0400056_20200304_CMPL_CompRpt

REVIEW OF TITLE V
2019 ANNUAL COMPLIANCE CERTIFICATION
Reviewer Assigned: EVANGELYN LOWERY-JACOBS
FACILITY PIEDMONT NATURAL GAS — FACILITY
NAME: WADESBORO COMPRESSOR STATION ID: 0400056
1. Is the Certification sheet signed by the authorized/responsible official? QY N
2. Print the "Summary of Violations for a Facility" report from IBEAM and attach. 121
3. Are all NOD/NOV/NREs accounted for in the Deviation Summary Report? Y N(Q)
4. If deviations are noted, did FRO address them all? (i.e. send letter)? Check paper file
for any issues that may not be recorded in IBEAM Violations. Y N
5. Discuss deviations details with Compliance Coordinator. 0 /A
6. If there was more than one permit applicable during the year, have all the permits
been addressed in this ACC? Permit Numbers 140 -+TO# aKd /009 ON N/A
-r-
7. Do reported sources and conditions match those in the permit(s)? OYN
8. Is the Compliance Summary Report for Specific Conditions complete and accurate? P-� N
9. Is the Compliance Summary Report for General Conditions complete and accurate? �Y,� N
10. Is compliance with the ACC requirements indicated? N
11. Record in IBEAM Actions/Reporting (date received, date reviewed, compliance status, comments).
Completed on 04 of Zo (date)
REMEMBER—Compliance determination here refers to the ACC submitting requirements (late, not
submitted, incomplete, etc). Talk to the Compliance Coordinator before you code a facility in
violation.
12. Initial and date the top of the ACC Certification Sheet (not this cover sheet). 0'
13. File FRO copy in a"Reports" or an "ACC" folder in facility file after Compliance Coordinator
review.
14. Comments:
Reviewed by: Date: 0 0()-r-0 Zd
i it' ls)
Coordinator Review: Date 0
(initials)

Piedmont
EC D
�raP Gas
February 24, 2020
Air and EPCRA Enforcement Branch MAR 4 2020
U.S. Environmental Protection Agency
Region 4 Division of Air Quality
61 Forsyth Street, SW Fayetteville Regional Office
Atlanta, GA 30303
Subject: 2019 Annual Compliance Certification
Piedmont Natural Gas Company,Inc.—Wadesboro Compressor Station
Wadesboro,North Carolina; Anson County
Title V Permit No. 10097T; Facility ID 0400056
To Whom It May Concern:
Piedmont Natural Gas Company, Inc. (Piedmont)operates a compressor station located at
379 Pleasant Grove Church Road, Wadesboro,Anson County,North Carolina
(Wadesboro Compressor Station). The Wadesboro Compressor Station operated under
North Carolina Division of Air Quality(DAQ)Title V Permit No. 10097TO I and T02
during the 2019 reporting year.
Piedmont is submitting this 2019 CY Annual Compliance Certification by March 1, 2020
in accordance with General Condition 3.P.of the Title V permit.
The required Annual Compliance Certification form is included as Attachment 1. The
Permit Conditions Summary table indicating the compliance status of the federally-
enforceable permit conditions is included as Attachment 2 to this letter. The Compliance
Summary for the general permit conditions is included in Attachment 3. The facility did
not experience any deviations during the period from January 1, 2019 through December
31,2019.
Please contact Cynthia Winston at(919)546-5538 or via email at
c%nth ia.winston°a duke-ener(gy.com if you have any questions concerning this compliance
certification.
Sincerely, r�
Adam B. Long, P.E.
General Manager,Gas Pipeline Operations
cc: Heather Carter, Regional Supervisor Fayetteville Regional Office
p;edmontng.com

04/0 l/2020 Page 1 of 1
Summary of Violations
Violator:
Facility ID:
Letter Date(s): Violation(s):
County:
Letter Type: Case#:
Date Assessed: Amount Assessed:
Case Closed: Total Amount Paid:

,� d 4ol/Z,20
North Carolina Department of Environmental Quality
Division of Air Quality(DAQ)
Title V Annual Compliance Certification Forms t
Facility Name: Piedmont Natural Gas Company,Inc.-Wadesboro Compressor Station
Facility Location: 379 Pleasant Grove Church Road,Wadesboro,NC
Facility ID Number: 0400056 (Refer to first page of Title V Permit)
Title V Permit Number: 10097TOI & 10097T2 (Refer to first page of Title V Permit)
Start of Reporting Period: January 1,2019 _ (Month,Day,Year)
End of Reporting Period: December 31,2019 (Month,Day,Year)
Compliance Statement(Check only pne cif the follo►trod options)
X During the reporting period specified above,this facility was in compliance with all terms and conditions identified
in the above referenced Title V Operating Permit. As such,there were no deviations'`,excess emissions events,or
other reportable incidents including those attributable to equipment malfunctions,breakdown,or upset conditions
(please fill out the Compliance Summary Report).
During the reporting period specified above,this facility was in compliance with ALL terms and conditions
identified in the above referenced Title V Operating Permit,EXCEPT for the deviationsZ identified in the Deviation
Summary Report(please fill out both the Compliance Summary Report and Deviation Summary Report).
Does the above compliance statement differ from what is indicated on your most recent Title V Report(i.e.,last Semi-
Annual Monitoring Report,Annual Emissions Inventory,etc.)?
❑Yes No
Are you submitting this Annual Compliance Certification form to also fulfill a Title V Semi-Annual Monitoring reporting
requirement? If so,this certification must be submitted by January 30.
❑Yes ED No
Certification By Responsible Official
Based on information and belief formed after reasonable inquiry,the undersigned certified under penalty of law(federal rule
40 CFR 70.5(d))that all information and statements provided in this form(including any attachments)are true,accurate,
and complete.
rD
(Signature of Responsible Official) (Date)
Flame: Adam B.Long,P.E.
(Type or Print)
Number of Attached Pages(not including Instructions Page) 19
t rIn annual compliance certification(ACC)is required pursuant to federal ride 40 CFR 70.6(c) state rules 15.4 hCAC Sections 3Q 0508(1)and
?Q 0508(bb),and Section 3-General Condition P of lire Title I'Operating Permit A copy of your A CC&to be subndried to both Mite North Carolina DAQ
and the U.S.EPA(Air and EPCRA Enforcement Branch,EPA,Region 4,61 Forsph Street,Atlanta,Get 30303). The submittal date for the ACC is
specified in Section 3-General Condition P of your Title I'pewit
" For the purposes of this form the term"deviation"ineans any action or circumstance not in accordance a ith the terms and conditions a,f the Title t'
Operating Permit inchiding those attributable to equipment maNnction.breatdoit n, or upset conditions and or excess errussias events The
acknowledgement of deviations from specific pernut requirements is not necessard)an m kno►rledgement of a►violation Hou rver failtire to report any and
all deviations may constitute a violation of the Title I.Operating Permit and the tenderly ing emission standard For more igformatron about deviations
please refer to the DAQ memorandum outlining lire definition of dectation jor Title t`reporting on the DAQ web sue(http deq nc°gov about divisions air-
Revision 3.0

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T1 & 10097T02
For Calendar Year 2019
'Perms and Conditions
Source or
Permit Permit Records Was Deviation a
Control Deviations:' Method(s)of Determining
Emission Source Description Condition Condition Maintained? non-compliance Comments
Device ID Condition Summary (Yes/No)
Number(s)
No.10097T1 No.10097T2 (Yes/No/NA) Issue. (Yes/No) Compliance Status
Jan-Jul 2019 Jul-Dec 2019
15A NCAC 2D.0516: No monitoring!
recordkeeping/reporting is
2.I.A.1 2.I.A.1 Sulfur Dioxide Emissions From No NA NA Use of natural gas only. required for sulfur dioxide
Combustion Sources emissions from the firing of
natural gas.
No monitoring/
15A NCAC 2D.0521: recordkeeping/reporting is
Eight four-stroke lean burn 2.I.A.2 2.1.A.2 Control of Visible No NA NA Use of natural gas only. required for visible emissions
naturall g gas-fired reciprocating
internal combustion engines(4,735 COMPOI- Emissions from the firing of natural
horsepower rating each)powering COMP08, gas.
compressors
eight com each equipped COMPOIC-
g PCompliance with the 30-day
with a catalytic oxidizer at least 24 COMP08C Piedmont complied with the
Yt� ( rolling average emissions of 125
3 30-day rolling average
ft of oxidation catalyst) ppm and the alternative
15A NCAC 2D.1423 monitoring and recordkeeping emission limit all times
2.I.A.3 2.1.A.4 Large Internal No Yes NA plan including submission of and submitted a timely ozone
Combustion Engines NOx emissions during ozone season report. All specified
- records are maintained on-
season from May I-September site for a period of at least
30 by October 31 of each year. five years.
Attachment 2-Page 2 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT- Permit No. 10097T1 & 10097T02
For Calendar Year 2019
Terms and Conditions
Source or
Permit Permit Deviations:' Records Was Deviation a
Control Method(s)of Determining
Emission Source Description Condition Condition Maintained? non-compliance Comments
Number(s)
Device I No.10097T1 No.10097T2 Condition Summary (Yes/No) (Yes/No/NA) Issue?(Yes/No) Compliance Status
Jan-Jul 2019 Jul-Dec 2019
15A NCAC 2D Compliance with this
.0524:New Source Units meet all applicable condition is demonstrated by
-- 2.1.A.3.a Performance Standards No Yes NA provisions under 40 CFR 60 meeting the emission
[40 CFR 60 Subpart Subpart JJJJ. standards in condition
JJJJ] 2.2.A.2.b through 2.2.A.2.k.
COMP05-COMP08 have
not yet commenced
construction. Initial
performance testing for
Eight(8)four-stroke lean burn COMPOI -COMP04 was
natural as-fired reciprocating 15A NCAC 2D
g p g Comply with general provisions conducted in February 2014
internal combustion engines 4,735 COMPOI- .0524:New Source
g ( COMP08, 2.1.A.3.b Performance Standards No Yes NA of 40 CFR 60 Subpart A as and subsequent testing was /
horsepower rating each)powering -- presented in Table 3 of 40 CFR conducted in August 2016.
ressors ei ht com each equipped COMPOIC- [40 CFR 60 Subpart
g pCOMP08C 60 Subpart JJJJ Performance testing was
with a catalytic oxidizer(at least 24 JJJJ] completed August 6,2019 on
ft3 of oxidation catalyst) COMPOI.Results
demonstrated compliance
with 40 CFR 60 Subpart JJJJ
Table 1.
Compliance with emission
15A NCAC 2D standards in 40 CFR 60 Subpart Performance testing for
COMPOI on
.0524:New Source JJJJ,Table 1 (Non-Emergency was performed
August
6,2019 and testt
-- 2.1.A.3.c Performance Standards No Yes NA Sl Engine,HP>500, results demonstrated
[40 CFR 60 Subpart manufacture date after
JJJJ] 7/l/2010)by conducting initial compliance with emission
and subsequent stack testing. limits.
Attachment 2-Page 3 of 20

North Carolina Department of Environmental Quality
Division Air f Quality o Qua ty
COMPLIANCE SUMMARY REPORT-Permit No. 10097T1 & 10097T02
For Calendar Year 2019
"Perms and Conditions
Source or
Permit Permit Records Was Deviation a
non-compliance
Control Deviations:' Method(s)of Determining
Emission Source Description Device Ill Condition Condition Condition Summary (Yes/No) Maintained'.' Compliance Status Comments
Number(s) No. 10097T1 No.10097T2 (Yes/No/NA) Issue?(Yes/No)
Jan-Jul 2019 Jul-Dec 2019
15A NCAC 2D Testing shall be performed in Performance testing for
.0524:New Source accordance with General COMPOI was performed on
-- 2.1.A.3.d Performance Standards No 1'es NA Condition JJ;and each August 6,2019 and test /
[40 CFR 60 Subpart performance test shall follow results demonstrated
JJJJ] the procedures in 60.4244 compliance with emission
limits.
A copy of the maintenance
Non-Certified engine:keep plan and recorded
maintenance plan,maintain maintenance is maintained
15A NCAC 2D records of conducted on-site. Initial performance
Eight(8)four-stroke lean burn .0524:New Source testing was conducted in
g reciprocating COMPOI- performance tests and
natural as-fired reci rocatin -- 2.I.A.3.e Performance Standards No Yes NA maintenance. Conduct initial February 2014 and
internal combustion engines(4,735 [40 CFR 60 Subpart subsequent testing was
horsepower rating each)powering COMP08, JJJJ] subsequent performance tests conducted in August 2019.
eight compressors each equipped COMPOIC- every 8,760 hours or 3 years, Results demonstrated
with a catalytic oxidizer(at least 24 COMP08C whichever comes first. compliance with 40 CFR 60
ft3 of oxidation catalyst) Subpart JJJJ Table 1.
15A NCAC 2D
015A New Source Operate and maintain the Units are operated and
-- 2.1.A.3.f Performance Standards No Yes NA stationary SI ICE to achieve the maintained to meet emission
[40 CFR 60 Subpart emission standards as required standards over the life of
JJJJ] over the entire life of the engine each engine.
15A NCAC 2D Maintain and operate air-to-fuel The AFR controllers are used
.0524:New Source and proper operation of the
-- 2.1.A.3.g Performance Standards No Yes N n ratio(AFR)controller to ensure engines and corresponding
[40 CFR 60 Subpart proper operation of the engine catalytic oxidizers is
JJJJ] and control device. maintained.
Attachment 2-Page 4 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT- Permit No. 10097T1 & 10097T02
For Calendar Year 2019
"Terms and Conditions
Source or
Permit Permit Deviations? Records Was Deviation a
Control :Method(s)of Determining
Emission Source Description Device I1) Condition Condition Maintained? non-compliance Comments
Number(s)
No.10097T1 No.10097T2 Condition Summary (�esm`o) (Yes/No/NA) Issue?(Yes/No) Compliance Status
Jan-Jul 2019 Jul-Dee 2019
Maintain records and supporting
15A NCAC 2D documentation for all
.0524:New Source notifications,reports, All required records are /
-- 2.I.A.3.h Performance Standards No Yes NA performance tests,and
maintained on-site.
[40 CFR 60 Subpart maintenance records that show
JJJJ] compliance with emission
standards.
15A NCAC 2D
.0524:New Source Initial notifications were
-- 2.1.A.3.i Performance Standards No Yes NA Submit initial notifications. submitted and captured
under previous ACC
[40 CFR 60 Subpart submittals.
Eight(8)four-stroke lean burn JJJJ]
natural gas-fired reciprocating All required records are
internal combustion engines 4,735 COMPOI-
g ( COMP08 maintained on-site.
,
horsepower rating each)powering Maintain records and supporting Initial notification for
compressors
eight com each equipped COMPOI C-
g pCOMP08C documentation for all COMPO I-COMP04 was
with a catalytic oxidizer(at least 24 15A NCAC 2D notifications,reports, submitted no later than 30
ft3 of oxidation catalyst) .0524:New Source performance tests,and days after construction.
-- 2.1.A.3.j Performance Standards No Yes NA maintenance records that show Performance testing for
[40 CFR 60 Subpart compliance with emission COMPOI was conducted in
JJJJ] standards. Submit performance August 6,2019 and the
test reports within 60 days of performance test report was
test completion. submitted September 20,
2019,within 60 days of test
completion.
15A NCAC 2D Submit summary reports of Semiannual reports were
.0524:New Source monitoring and recordkeeping submitted in a timely manner
-- 2.1.A.3.k Performance Standards No Yes NA
[40 CFR 60 Subpart activities 30 days after the end and included all required
JJJJ] of the semiannual period. elements.
Attachment 2-Page 5 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT- Permit No. 10097T1 & 10097T02
For Calendar Year 2019
'Perms and Conditions
Source or
Permit Permit Records Was Deviation a
Control Deviations? Method(s)of Determining
(.mission Source Description Condition Condition Maintained? non-compliance Comments
Device 11) No. 10097T1 No.10097T2 Condition Summary (Yes/No) (Yes/No/NA) Issue?(Yes/No) Compliance Status
Number(s)
Jan-Jul 2019 Jul-Dec 2019
15A NCAC 2D.0516: No monitoring/
Sulfur Dioxide recordkeeping/reporting is
2.1.B.1 2.1.B.1 Emissions From No NA NA Use of natural gas only. required for sulfur dioxide
Combustion Sources emissions from the firing of
natural gas.
No monitoring/
15A NCAC 2D.0521: recordkeeping/reporting is
2.1.B.2 2.1.B.2 Control of Visible No NA NA Use of natural gas only. required for visible emissions
Emissions from the firing of natural
gas.
15A NCAC 2D Compliance with this
.0524:New Source Units meet all applicable condition is demonstrated by
-- 2.1.B.3.a Performance Standards No Yes NA provisions under 40 CFR 60 meeting the emission
One(1)fnur-stroke lean burn natural [40 CFR 60 Subpart Subpart JJJJ. standards in condition
gas-fired emergency generator(880 EG-01 JJJJ] 2.1.B.2.b through 2.1.13.2.k.
hp maximum rating) 15A NCAC 2D
.0524:New Source Comply with general provisions
of 40 CFR 60 Subpart A as
-- 2.1.B.3.b Performance Standards No Yes NA presented in Table 3 of 40 CFR Compliance with this
[40 CFR 60 Subpart 60 Subpart JJJJ condition is demonstrated by
JJJJ]
15A NCAC 2D meeting the emission
standards in the following
.0524:New Source Comply with emission limits as conditions.
-- 2.1.B.3.c Performance Standards No Yes NA presented in Table 1 of 40 CFR
[40 CFR 60 Subpart 60 Subpart JJJJ
JJJJ]
15A NCAC 2D Testing shall be performed in
.0524:New Source accordance with General Testing was completed on
-- 2.1.B.3.d Performance Standards No Yes NA Condition JJ;and each XXX and followed the
[40 CFR 60 Subpart performance test shall follow required procedures.
JJJJ] the procedures in 60.4244
Attachment 2-Page 6 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T 1 & 10097T02
For Calendar Year 2019
"Perms and Conditions
Source or
Permit Permit Records Was Deviation a
Control Deviations:' Method(s)of Determining
Device Ill Condition Summary (Yes/No) Compliance Status Emission Source Description Condition Condition Maintained? non-compliance Comments
Number(s) No.10097T1 No.10097T2 (Yes/No/NA) Issue?(Yes/No)
Jan-Jul 2019 Jul-Dec 2019
15A NCAC 2D The emergency engine t�,
.0524:New Source The engine shall be equipped equipped with a non-
-- 2.1.B.3.e Performance Standards No Yes NA With a non-resettable hour meter resettable hour meter. /
if manufactued after July 1, Records are maintained on-
JJJJ][40 CFR 60 Subpart 2010 site.
A copy of the maintenance
Non-Certified engine:keep plan and recorded
maintenance plan,maintain maintenance is maintained
One(1)four-stroke lean burn natural 15A NCAC 2D records of conducted on-site. Initial performance
0524:New Source testing was conducted in
gas-fired emergency generator(880 EG-01 maintenance. Conduct initial /
h maximum rating) 2.1.B.3.f Performance Standards No Yes NA February 2014 and
p g) [40 CFR 60 Subpart performance tests and subsequent testing was
JJJJ] subsequent performance tests conducted in May 2019.
every 8,760 hours or 3 years, Results demonstrated
whichever comes first. compliance with 40 CFR 60
Subpart JJJJ Table 1.
15A NCAC 2D
015A524:New Source Operate and maintain the Units are operated and /
-- 2.1.B.3.g Performance Standards No Yes NA stationary SI ICE to achieve the maintained to meet emission
[40 CFR 60 Subpart emission standards as required standards over the life of
Jim] over the entire life of the engine each engine.
Attachment 2-Page 7 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T1 & 10097T02
For Calendar Year 2019
Terms and Conditions
Source or-
Permit Permit Records Was Deviation a
Control Deviations'.' Method(s)of Determining
Emission Source Description Condition Condition Maintained? non-compliance Comments
Device ID No.10097T1 No.10097T2 Condition Summary (Yes/No) (Yes/No/NA) Issue?(Yes/No) Compliance Status
Number(s)
Jan-Jul 2019 Jul-Dec 2019
Limit emergency engine
operation to 100 hrs/yr for Hours of operation of the
maintenance and testing, emergency engine are
emergency demand response, recorded using the non-
and operation in non-emergency resettable hour meter. Hours
15A NCAC 2D situations. Operation in non- of operation during CY 2019
.0524:New Source emergency situations is limited did not exceed the 50 hr/yr
-- 2.1.B.3.h Performance Standards No Yes NA to 50 hrs/yr,and is counted limitation for operation in
[40 CFR 60 Subpart towards the as part of the 100 non-emergency situations,or
JJJJ] hrs/yr total. Maintain records of the 100 hr/yr limitation for
runtime during emergency maintenance and testing and
situations,non-emergency operation in non-emergency
situations,and periods of situations. Records are
maintenance and readiness maintained on-site.
testing.
One(1)four-stroke lean burn natural
gas-fired emergency generator(880 EC;-01 Maintain records and supporting
hp maximum rating) 15A NCAC 2D documentation for all
0524:New Source notifications,reports, All required records are
-- 2.1.B.3.1 Performance Standards No Yes NA performance tests,and maintained on-site.
[40 CFR 60 Subpart maintenance records that show
JJJJ] compliance with emission
standards.
15A NCAC 2D
.0524:New Source Initial notification is not
-- 2.1.B.3.j Performance Standards No Yes NA required for emergency NA
[40 CFR 60 Subpart stationary SI ICE.
JJJJ]
15A NCAC 2D Performance testing for the
.0524:New Source Submit copy of each emergency engine was
-- 2.1.B.31 Performance Standards No Yes NA
performance test as conducted submitted June 17,2019 and
[40 CFR 60 Subpart in 60.4244 within 60 days after demonstrated compliance
JJJJ] the test has been completed. with 40 CFR 60 Subpart
JJJJ.
Attachment 2-Page 8 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT- Permit No. 10097T1 & 10097T02
For Calendar Year 2019
Terms and Conditions
Source or
Permit Permit Records Was Deviation a
Control Deviations`.' Method(s)of Determining
Emission Source Description Condition Condition Maintained? non-compliance Comments
Device Ill Condition Summary (Yes/No)
Number(s)
No.10097T1 No.10097T2 (Yes/No/NA) Issue?(Yes/No) Compliance Status
Jan-Jul 2019 Jul-Dec 2019
15A NCAC 2D Submit summary reports of Semiannual reports were
One(1)four-stroke lean burn natural .0524:New Source monitoringand recordkee in submitted in a time) manner ,
gas-fired emergency generator(880 EG-01 -- 2.1.B.3.1 Performance Standards No Yes NA
P g Y
after h end and included all required
hp maximum rating) [40 CFR 60 Subpart
activities 30 days a to the e a q
JJJJ] of the semiannual period. elements.
Eight(8)four-stroke lean burn 15A NCAC 2D.1111: Compliance with 40 CFR Part There are no requirements /
natural gas-fired reciprocating Maximum Achievable 63 Subpart ZZZZ by complying for these emission sources
2.2.A.1 2.2.A.1 Control Technology[40 No NA NA
internal combustion engines(4,735 with 40 CFR Part 60 Subpart under Subpart ZZZZ. No
horsepower rating each)powering COMPOI- CFR Part 63,Subpart JJJJ. further requirements apply.
eight compressors each equipped COMP08, ZZZZ]
with a catalytic oxidizer(at least 24 COMPOIC-
ft3 of oxidation catalyst)and 01 8C,
EG-COMP0
One(1)four-stroke lean burn natural
gas-fired emergency generator(880
hp maximum rating) 15A NCAC 2D.0524: Compliance with this
New Source Units meet all applicable condition is demonstrated by
2.2.A.2.a -- Performance Standards No Yes NA provisions under 40 CFR 60 meeting the emission
[40 CFR 60 Subpart Subpart JJJJ. standards in condition
JJJJ] 2.2.A.2.b through 2.2.A.2.s.
Attachment 2-Page 9 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T1 & 10097T02
For Calendar Year 2019
"Terms and Conditions
Source or
Permit Permit Records Was Deviation a
Control Deviations? Method(s)of Determining
Emission Source Description Device ID Condition Condition Condition Summary (Yes/No) Maintained? non-compliance Compliance Status Comments
Number(s) No•10097T1 No.10097'I'2 (Yes/No/NA) Issue?(Yes/No)
Jan-Jul 2019 Jul-Dec 2019
COMP05-COMP08 have
not yet commenced
construction. Initial
Compliance with emission performance testing for
15A NCAC 2D.0524: standards in 40 CFR 60 Subpart COMPOI-COMP04 was
New Source JJJJ,Table 1(Non-Emergency conducted in February 2014
2.2.A.2.b -- Performance Standards No Yes NA SI Engine,HP>500, and subsequent testing was
[40 CFR 60 Subpart manufacture date after conducted in August 2016
JJJJ] 7/1/2010)by conducting initial and performance testing for
Eight(8)four-stroke lean burn COMPOI was conducted in
natural gas-fired reciprocating and subsequent stack testing. August st 6 2019.. Results
internal combustion engines(4,735 demonstrated compliance
horsepower rating each)powering COMP01- with 40 CFR 60 Subpart JJJJ
eight compressors each equipped COMP08,
with a catalytic oxidizer(at least 24
COMPOIC- Table 1.
s COMP08C, Not Applicable. All engines
ft of oxidation catalyst)and Compliance with field testing
EG-01 at the Wadesboro facility /
One(1)four-stroke lean burn natural 2 2 A.2.c -- No NA NA provisions for engines required meet the emission standards
gas-fired emergency generator(880 to meet standards referenced in in 40 CFR 60 Subpart JJJJ,
hp maximum rating) 40 CFR 1048.101.
Table 1.
15A NCAC 2D.0524: Units are operated and
New Source Units meet all applicable maintained to meet emission /
2.2.A.2.d -- Performance Standards No Yes NA provisions under 40 CFR 60 standards over the life of
[40 CFR 60 Subpart Subpart JJJJ.
each engine.
JJJJ]
After July 1,2009,do not install All engines>:500 HP were
2.2.A.2.e -- No Yes NA Sl ICE>500 HP that do not installed after July 1,2009
meet the applicable and meet the applicable
requirements of§60.4233. requirements of§60.4233.
Attachment 2-Page 10 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T1 & 10097T02
For Calendar Year 2019
'Perms and Conditions
Source or
Permit Permit Records Was Deviation a
Control Deviations? Method(s)of Determining
Emission Source Description Device ID °ndition Condition Condition Summary (Yes/No) Maintained'.' non-compliance Compliance Status Comments
Number(s) No.10097T1 No.10097T2 (Yes/No/NA) Issue?(Yes/No)
Jan-Jul 2019 Jul-Dec 2019
A copy of the maintenance
plan and recorded
Non-Certified engine:keep maintenance is maintained
15A NCAC 2D.0524: maintenance plan,maintain on-site. Initial performance
New Source records of conducted testing for COMPOI - /
2.2.A.2.f -- Performance Standards No Yes NA
maintenance. Conduct initial COMP04 was conducted in
[40 CFR 60 Subpart performance tests and February 2014 and
JJJJ] subsequent performance tests subsequent testing was
every 8,760 hours or 3 years, conducted in August 2016.
whichever comes first. Results demonstrated
compliance with 40 CFR 60
Eight(8)four-stroke lean burn Subpart JJJJ Table 1.
natural gas-fired reciprocating
internal combustion engines(4,735 The AFR controllers are used
COMPOI- Maintain and operate air-to-fuel
horsepower rating each)powering and proper operation of the
eight compressors each equipped COMP08, 2 2 A 2 g __ No Yes NA ratio(AFR)controller to ensure engines and corresponding
with a catalytic oxidizer(at least 24 COMPOI C- proper operation of the engine /
catalytic oxidizers is
ft3 of oxidation catalyst)and COMP08C, and control device.
EG-01 maintained.
One(1)four-stroke lean burn natural
gas-fired emergency generator(880 Subsequent performance
hp maximum rating) 15A NCAC 2D.0524: Conduct initial stack testing to testing for the emergency /
New Source meet the emission limit for
2.2.A.2.h -- No Yes NA emergency stationary ICE in 40 engine was conducted in
Performance Standards May 2019 and demonstrated
[40 CFR 60 Subpart CFR 60 Subpart JJJJ Table I compliance with 40 CFR 60
JJJJ (Emergency>_ 130 HP).� Subpart JJJJ.P
Performance testing was
Conduct performance testing in conducted in May 2019 for /
2.2.A.2.i -- No Yes NA accordance with§60.4244 of EGO and in August 2019
Subpart JJJJ. for COMPOI and test results
demonstrated compliance
with emission limits.
Attachment 2-Page 11 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T1 & 10097T02
For Calendar Year 2019
"berms and Conditions
Source or
Permit Permit Records Was Deviation a
Control Deviations? Method(s)of Determining
Emission Source Description Condition Condition Maintained? non-compliance Comments
Device ID Condition Summary (Yes/No)
Number(s) No.10(197T1 No.10097T2 (Yes/No/NA) Issue?(Yes/No) Compliance Status
Jan-Jul 2019 ,Jul-Dec 2019
All required records are
maintained on-site.
Initial notification for
COMPOI-00MP04 was
Maintain records and supporting submitted no later than 30
documentation for all days after construction.
Performance testing for
notifications,reports, EGO was conducted on May
Eight(8)four-stroke lean burn performance tests,and 2019 and the performance
natural gas-fired reciprocating maintenance records that show
2.2.A.2.j -- N o Yes N n test report was submitted in
internal combustion engines(4,735 compliance with emission
horsepower rating each)powering COMPO 1- 15A NCAC 213.0524: standards. Submit initial June 2019,within 60 days of
C0MP08, New Source test completion.
eight compressors each equipped notifications. Submit
COMPOIC- Performance Standards Performance testing for
with a catalytic oxidizer(at least 24 performance test reports within
C0MP08C, [40 CFR 60 Subpart C0MP014 was conducted in
113 of oxidation catalyst)and EG-01 Jim] August days of test completion. August 2019 and the
One(1)four-stroke lean burn natural
performance test report was
gas-fired emergency generator(880 submitted September
hp maximum rating)
20,2019,within 60 days of
test completion.
The emergency engine is
Equip the emergency engine equipped with a non-
2.2.A.21 -- No Yes NA with a non-resettable hour meter resettable hour meter.
prior to startup.
Records are maintained on-
site.
Attachment 2-Page 12 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T1 & 10097T02
For Calendar Year 2019
'Perms and Conditions
Source or
Permit Permit Records Was Deviation a
�
Control C Deviations? Method(s)of Determining Emission Source Description Condition Condition Maintained? non-compliance Comments
Device ID Condition Summary (Yes/No) Compliance Status
Number(s) No.10097TI No.10097T2 (Yes/No/NA) Issue?(Yes/No)
Jan-Jut 2019 Jul-Dec 2019
COMP05-COMP08 have
Non-Certified engine:keep not yet commenced
2.2.A.2.1 -- No Yes NA maintenance plan,maintain construction. A copy of the
records of conducted maintenance plan and
maintenance. recorded maintenance is
maintained on-site.
Limit emergency engine
Eight(8)four-stroke lean burn operation to 100 hrs/yr for Hours of operation of the
natural gas-fired reciprocating maintenance and testing, emergency engine are
internal combustion engines(4,735 emergency demand response, recorded using the non-
horsepower rating each)powering COMPO I- 15A NCAC 2D.0524: and operation in non-emergency resettable hour meter. Hours
eight compressors each equipped
COMP08, New Source situations. Operation in non- of operation during CY 2019
/
with a catalytic oxidizer(at least 24 COMPOIC- Performance Standards emergency situations is limited did not exceed the 50 hr/yr
s COMP08C, 2.2.A.2.m -- [40 CFR 60 Subpart No Yes NA to 50 hrs/yr,and is counted limitation for operation in
ft of oxidation catalyst)and EG-01 JJJJ] towards the as part of the 100 non-emergency situations,or
One(1)four-stroke lean burn natural hrs/yr total. Maintain records of the 100 hr/yr limitation for
gas-fired emergency generator(880
hp maximum rating) runtime during emergency maintenance and testing and
situations,non-emergency operation in non-emergency
situations,and periods of situations. Records are
maintenance and readiness maintained on-site.
testing.
Limit propane usage for the No propane was burned by
2.2.A.2.n -- No Yes NA emergency engine to less than the emergency engine in CY /
100 hours per year during
2019.
emergency operations.
Attachment 2-Page 13 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T1 & 10097T02
For Calendar Year 2019
'Perms and Conditions
Source or
Permit Permit Records Was Deviation a
Control Deviations'.' Method(s)of Determining
Emission Source Description Condition Condition Maintained? non-compliance Comments
Device Ill Condition Summary (Yes/No) Compliance Status
Number(s)
No.1009'1T1 No.10097T2 (Yes/No/NA) Issue?(Yes/No)
Jan-Jul 2019 Jul-Dec 2019
Non-Certified engine <500 Not Applicable. All engines
HP:Conduct an initial at the Wadesboro facility are
performance test and conduct greater than 500 HP in size.
2.2.A.2.o -- No NA NA subsequent performance tests if Initial and subsequent
the stationary engine is rebuilt performance tests for EGO 1
or undergoes major repair or are conducted in accordance
maintenance. with§60.4243(b)(2)(ii).
Eight(8)four-stroke lean burn air- The AFR controllers are used
natural gas-fired reciprocating COMPOI- 1 SA NCAC 2D.0524: Maintain and operate ratio(AFR)controller to e ensunsu proper operation of the engine re el and proper operation of the
internal combustion engines(4,735 2.2.A.2.p -- No Yes NA engines and corresponding
horsepower rating each)powering catalytic oxidizers is
eight compressors each equipped COMP08, New Source and control device. maintained.
COMP08C
with a catalytic oxidizer(at least 24 COMPOIC, Performance Standards Maintain records and supporting
s [40 CFR 60 Subpart
ft of oxidation catalyst)and EG-01 JJJJ] documentation for all
One(1)four-stroke lean burn natural notifications,reports, All required records are /
gas-fired emergency generator(880 2.2.A.2.q -- No Yes NA performance tests,and
hp maximum rating) maintenance records that show maintained on-site.
compliance with emission
standards.
Initial notification is not
2.2.A.2.r -- No NA NA required for emergency NA
stationary SI ICE.
Submit summary reports of Semiannual reports were
2.2.A.2.s -- No Yes NA
monitoring and recordkeeping submitted in a timely manner
activities 30 days after the end and included all required
of the semiannual period. I elements.
Attachment 2-Page 14 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT- Permit No. 10097T1 & 10097T02
For Calendar Year 2019
"Perms and Conditions
Source or
Permit Permit Records Was Deviation a
Control Deviations:' Method(s)of Determining
Emission Source Description Device II) -ondition Condition Condition Summary (Yes/No) Maintained'' non-compliance Compliance Status Comments
No.10097T1 No.10097T2 (Yes/No/NA) Issue. (Yes/No)
Jan-Jul 2019 Jul-Dec 2019
Eight 8 four-stroke lean bu
g ( ) rn
natural gas-fired reciprocating CO is a surrogate for
internal combustion engines(4,735 COMPOI- 15A NCAC 2Q.0317: Total annual emissions from formaldehyde. Compliance
horsepower rating each)powering COMPOI-08 and EGO less
COMP08, Avoidance Conditions with this condition is /
eight compressors each equipped than 10 tpy for a single HAP
COMPOIC- 2.2.A.3 2.2.A.2 for HAP Major Source No Yes NA demonstrated by complying
with a catalytic oxidizer(at least 24 and less than 25 tpy for all
3 COMP08C, Classification with the CO monitoring,
ft of oxidation catalyst)and EG-01 Avoidance HAP,per consecutive 12-month recordkeeping,and reporting
One(1)fnur-stroke lean burn natural period. of 2.2.A.2.
gas-fired emergency generator(880
hp maximum rating)
Attachment 2-Page 15 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-GENERAL CONDITIONS
For Calendar Year 2019
Terms and Conditions Records Was Deviation a
Deviations? non-compliance Method(s)of Determining Compliance
Permit Condition Maintained? Comments
No Condition Summary (Yes/No) (Yes/No/NA) Issue? Status
(Yes/No)
3.A General Provisions[NCGS 143-215& 15A No NA NA General Provisions acknowledged. NA
NCAC 2Q.0508(i)(16)]
3.13 Permit Availability[15A NCAC 2Q No Yes NA Permit available on-site. NA
.0507(k)&.0508(i)(9)(B)]
3.0 Severability Clause[15A NCAC 2Q No NA NA No administrative challenges. NA
.0508(i)(2)]
3.D Submissions[15A NCAC 2Q.0507(e)& No Yes NA Two copies of all documents and reports NA
2Q.0508(i)(16)] submitted. Records maintained on-site.
3.E Duty to Comply[15A NCAC 2Q No Yes NA Complied with all terms,conditions, NA
.0508(i)(3)] requirements,limitations,and restrictions.
Records maintained on-site.
3.G Permit Modifications[15A NCAC 2Q No Yes NA No changes. NA
.0514,2Q.0524&2Q.0505,2Q.0515,
2Q.0516&2Q.0517]
3.H Changes Not Requiring Permit No NA NA No changes. NA
Modifications[15A NCAC 2Q.0523(a),2Q
.0523(b)&2Q.0523(c)]
3.I.A Reporting Requirements for Excess No NA NA No excess emissions or permit deviations NA
Emissions and Permit Deviations[15A occurred during CY 2019.Records
NCAC 2D.0535(f)and 2Q.508(f)(2)] maintained on-site.
3113 Other Requirements under 15A NCAC 2D No NA NA No excess emissions occurred during CY NA
.0535 2019.
3.J Emergency Provisions[40 CFR 70.6(g)] No NA NA No emergencies occurred during CY 2019. NA
3.K Permit Renewal[15A NCAC 2Q.0508(e) No NA NA No permit renewal required under 2Q.0500 NA
and 2Q.0513(b)] during CY 2019.
Attachment 3-Page 16 of 20

i
North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-GENERAL CONDITIONS
For Calendar Year 2019
Terms and Conditions Was Deviation a
Records
Deviations? Maintained.? non-compliance Method(s)of Determining Compliance
Permit Condition Comments
No.
Condition Summary (Yes/No) (Yes/No/NA) Issue? Status
(Yes/No)
3.L Need to Halt or Reduce Activity Not a No NA NA Not required. NA
Defense[15A NCAC 2Q.0508(1)(4)]
3.M Duty to Provide Information(submittal of No NA NA No information requested. NA
information)[I 5A NCAC 2Q.0508(i)(9)]
3.N Duty to Supplement[15A NCAC 2Q No NA NA No information requested. NA
.0507(fl]
3.0 Retention of Records[15A NCAC 2Q No Yes NA Records maintained on-site for a period of at NA
.0508(o and 2Q.0508(1)] least 5 years.
3.P Compliance Certification[15A NCAC 2Q No Yes NA This report serves as the Title V annual NA
.0508(n)] compliance certification.
3.Q Certification by Responsible Official[15A No Yes NA Responsible Official signed all required NA
NCAC 2Q.0520] Title V reports and submissions during CY
2019.
3.R Permit Shield for Applicable Requirements No NA NA Compliance with terms and conditions of the NA
[15A NCAC 2Q.0512] permit.
3.S Termination,Modification,and Revocation No NA NA Not required. NA
of the Permit[15A NCAC 2Q.0519]
3.T Insignificant Activities[15A NCAC 2Q No Yes NA Insignificant activities documented in NA
.0503] application and permit. Records maintained
on-site.
3.0 Property Rights[15A NCAC 2Q No NA NA No rights conveyed by permit. NA
.0508(i)(8)]
3.V Inspection and Entry[15A NCAC 2Q No NA NA Inspection and entry granted with NA
.0508(1)and NCGS 143-215.3(a)(2)] credentials.
Attachment 3-Page 17 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-GENERAL CONDITIONS
For Calendar Year 2019
Terms and Conditions Was Deviation a
Permit Condition
Deviations? Records non-compliance Method(s)of Determining Compliance
Maintained? Comments
No Condition Summary (Yes/No) (Yes/No/NA) Issue? Status
(Yes/No)
3.W Annual Fee Payment[15A NCAC 2Q No Yes NA Annual fee payment completed within 30 NA
.0508(i)(10)] days after being billed.
3.X Annual Emission Inventory Requirements No Yes NA Emission inventory submitted by due date. NA
[15A NCAC 2Q.0207]
3.Y Confidential Information[15A NCAC 2Q No NA NA No confidential information submitted. NA
.0107 and 2Q.0508(i)(9)]
32 Construction and Operating Permits[15A No NA NA There were no construction or operating NA
NCAC 2Q.0100 and.0300] permit applications submitted during
CY 2019.
3.AA Standard Application Form and Required No NA NA There were no construction or operating NA
Information[15A NCAC 2Q.0505 and permit applications submitted during
.0507] CY 2019.
1.1313 Financial Responsibility and Compliance No NA NA Not required. NA
History[15A NCAC 2Q.0507(d)(4)]
3.('C Refrigerant Requirements(Stratospheric No Yes NA Complied with the requirements of 40 CFR NA
Ozone and Climate Protection)[15A NCAC 82,as applicable.
2Q.0501(e)]
3.DD Prevention of Accidental Release-Section No NA NA The facility does not store any chemicals NA
I I2(r)[15A NCAC 2Q.0508(h)] listed in 40 CFR 68.130.
3.EE Prevention of Accidental Release General No Yes NA The facility does not store any chemicals NA
Duty Clause-Section 112(r)(1)- listed in 40 CFR 68.130.
FEDERALLY-ENFORCEABLE ONLY
3.FF Title IV Allowances[15A NCAC 2Q No NA NA Facility does not participate in Title IV. NA
.0508(i)(1)]
Attachment 3-Page 18 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-GENERAL CONDITIONS
For Calendar Year 2019
Terms and Conditions Was Deviation a
Records
Deviations? ? non-compliance Method(s)of Determining Compliance
Permit Condition Maintained. Comments
No. Condition Summary (Yes/No) (Yes/No/NA) Issue? Status
(Yes/No)
3.GG Air Pollution Emergency Episode 1 15A No NA NA No emergency episodes occurred. NA
NCAC 2D.0300]
3.1111 Registration of Air Pollution Sources[15A No NA NA Not required. NA
NCAC 2D.0202]
3.11 Ambient Air Quality Standards[15A No NA NA Facility does not cause or contribute to NA
NCAC 2D.0501(c)] AAQS exceedances.
3.JJ General Emissions Testing and Reporting No Yes NA Performance testing for COMPOI was NA
Requirements[15A NCAC 2Q.0508(1)(16)] conducted on August 2019 and testing for
EGO was conducted May 2019. All testing
was conducted in accordance with NSPS
Subpart JJJJ requirements and General
Condition 3.JJ. Performance test protocol
and test reports were submitted as required.
3.KK Reopening for Cause[15A NCAC 2Q No NA NA Not required. NA
.0517]
3.1.L Reporting Requirements for Non-Operating No Yes NA Records of operation of all sources NA
Equipment [15A NCAC 2Q.0508(i)(16)] maintained on-site.
3.NN Specific Permit Modifications[15A NCAC No NA NA Not required. NA
2Q.0501 and.0523]
3.00 Third Party Participation&EPA Review No NA NA Piedmont acknowledges EPA's right to a 45- NA
[15A NCAC 2Q.0521,.0522,and day review period.
.0525(7)]
Attachment 3-Page 19 of 20

North Carolina Department of Environmental Quality
Division of Air Quality
DEVIATION SUMMARY REPORT
For Calendar Year 2019
Page I of 1
Source or
Deviation Deviation Suspected Cause of Corrective Action
Emission Source Description Control Device Pollutant Deviation Description p p Dates Duration Deviation 'taken
ID Number(s)
No deviations occurred during the 2019 calendar year.
Attachment 4-Page 20 of 20