AQ_F_0400056_20210301_CMPL_CompRpt

REVIEW OF TITLE V
2020 ANNUAL COMPLIANCE CERTIFICATION
Reviewer Assigned: GREG REEVES
FACILITY PIEDMONT NATURAL GAS FACILITY 0400056
NAME: WADESBORO COMPRESSOR STATION ID:
l. Is the Certification sheet signed by the authorized/responsible official? Y❑ N ❑
2. Print the"Summary of Violations for a Facility"report from IBEAM and attach. a
3. Are all NOD/NOV/NREs accounted for in the Deviation Summary Report? Y❑ N N/A
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 F-1 N 1-1 N!A ❑�
5. Discuss deviations details with Compliance Coordinator. Y❑ N/A F,/]
6. If there was more than one permit applicable during the year, have all the permits
been addressed in this ACC? Permit Numbers 10097T02 Y❑ N ❑ N1AFV-1
7. Do reported sources and conditions match those in the permit(s)? Y F,/] N ❑
8. Is the Compliance Summary Report for Specific Conditions complete and accurate? Y[1-4 N ❑
9. Is the Compliance Summary Report for General Conditions complete and accurate? Y❑� N ❑
10. Is compliance with the ACC requirements indicated? Y F7 N ❑
11. Record in IBEAM Actions/Reporting(date received, date reviewed,compliance status,comments). Completed
on 03/10/2021 (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). Fv/1
13. File FRO copy in a"Reports"or an"ACC"folder in facility file after Compliance Coordinator review.
14. Comments:
Reviewed by: _ C 2U2 Date: 0311012021
initials
Coordinator Review: 17e D 0311012021
� ate
(initials)

0 Page 1 of 1
3/10/2021
Summary of Violations
Violator: P EO�0� b�aAL 6AS - A
Facility I OqO n v 56
Letter Date77 iolation(s):
County:
Letter Type: Case#:
Date Assessed: Amount Assessed:
i
Case Closed: Total Amount Paid : j
'10
N o 20 vO
i

Piedmont
Natural Gas
February 22,2021
Air and EPCRA Enforcement Branch RECEIVED
U.S. Environmental Protection Agency
Region 4 MAR - 1 2021
61 Forsyth Street, SW
Atlanta,GA 30303
DEQ-FAYETTEVILLE REGIONAL
Subject: 2020 Annual Compliance Certification PO 2�zL LI
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. 10097T02 during the
2020 reporting year.
Piedmont is submitting this 2020 CY Annual Compliance Certification by March 1,2021
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 1,2020 through December
31,2020.
PIease contact Kristen Belisario at(440)668-8785 or via email at
kristenkristen.belisario,:ci duke-eners�eners�if you have any questions concerning this
complimnce certification.
Sincerely,
Adam B. Long,P.E. tt
VP,Gas Pipeline Operations
cc: Heather Carter,Regional Supervisor Fayetteville Regional
P.O,Box 33068 - Charlotte,North Carolina 28233
pledmontng.com

North Carolina Department of Environmental Quality
Division of Air Quality(DAQ)
Title V Annual Compliance Certification Forms
Facility Name: Piedmont Natural Gas Company,Inc.-Wadesboro Compressor Station
Facility Location: 379 Pleasant Grove Church Road,Wadesboro,NC
Facility ID Number: 0.100056 (Refer to first page of Title V Permit)
Title V Permit Number: 10097T2 (Refer to first page of Title V Permit)
Start of Reporting Period: January 1,2020 (Month, Day,Year)
End of Reporting Period: December 31,2020 (Month,Day,Year)
Compliance Statement(Check only one of the following 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 deviations2,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 Tide V Operating Permit,EXCEPT for the deviations 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.)?
O Yes (7) 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.
O Yes O 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.
(Signature of Responsible Official) (Date)
Name Adam B. Long, P.E.
(Type or Print)
Number of Attached Pages(not including Instructions Page) 19
i An annual compliance certification(ACC)is required pursuant to federal rule 40 CFR 110.6(c),state rules ISM!NCAC Sections?Q 0308rt)and
2Q.0508(bb),and Section 3-General Condition P of the Title V Operaling Permit A copy of your ACC is to be submitted to both the N arth Carolina DAQ
and the U.S EPA(Air and EPCRA Enforcement Branch,EPA,Region 4,61 Forsyth Street,Atlanta,GA 30303). The submittal date for the ACC is
specified in Section 3-General Condition P ofyour Title Vpermit
For the purposes of this form,the term "deviation"means anv action or circumstance not in accordance with the terms and conditions of the Title C
Operating Permit including those attributable to equipment malfunction,breakdown.or upset conditions and'or excess emissions events The
ackno►i ledgemeni of deviattons from specific permit requirements is not necessarily an acknowledgement of a violation.However,failure to report am,and
all deviations mm,constitute a violation of the Title V operating Permit and the underlying emission standard.For more information about deviations,
please refer to the DAQ memorandum outlining the definition of deviation for Title Vreportingon the DAQ web site(hip deq nc gov about divisions air-
qualit)-Air-quality-enforcenienilexcess-emissions-deviations-malfunction-determinations)
Revision 3.0

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T02
For Calendar Year 2020
Terms and Conditions
Source or
Records Was Deviation a
Control Permit Deviations? Method(s)of Determining
Omission Source Description Device ID Condition Condition Summary (Yes/No) Maintained? non-compliance Compliance Status (comments
(Yes/NO/NA) Issue. (Yes/No)
Number(s) No.10097T2
15A NCAC 2D.0516: No monitoring/
Sulfur Dioxide recordkeeping/reporting is
2.I.A.l Emissions From No N. N A Use of natural gas only. required for sulfur dioxide
Combustion Sources emissions from the firing of
natural gas.
15A NCAC 2D.0521: No monitoring/
Eight(8)four-stroke lean burn 2.1.A.2 Control of Visible No NA NA Use of natural gas only. recordkeeping/reporting is
natural gas-fired reciprocating required for visible emissions
COMP
01-
internal combustion engines(4,735 COMP08, Emissions from the firing of natural gas.
horsepower rating each)powering I
COMPO 1 C-
eight compressors each equipped Compliance with the 30-day
with a catalytic oxidizer(at least 24 COMP08C rolling average emissions of 125 Piedmont complied with the
ft3 of oxidation catalyst) ppm and the alternative 3 rolling average
15A NCAC 2D.1423: monitoring and recordkeeping emission
ssion limit all times
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 1-September
30 by October 31 of each year. site for a period of at least
five years.
Attachment 2-Page 2 of 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT- Permit No. 10097T02
For Calendar Year 2020
"Perms and Conditions
Source or Records Was Deviation a
Control Permit Deviations? Method(s)of Determining
Emission Source Description Device ID Condition Condition Summary (Yes/No) Maintained? non-compliance Compliance Status Comments
Issue?(Yes/No)
Number(s) No.10097T2
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 Ycs 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 15A NCAC 2D COMPOI-COMP04 was
natural gas-fired reciprocating COMPO 1- .0524:New Source Comply with general provisions conducted in February 2014
internal combustion engines(4,735 of 40 CFR 60 Subpart A as and subsequent testing was
horsepower rating each powering COMP08, 2.1.A.3.b Performance Standards No Yes NA
p g )po g presented in Table 3 of 40 CFR conducted in August 2016.
eight compressors each equipped COMPOIC- [40 CFR 60 Subpart 60 Subpart JJJJ Performance testing was
with a catalytic oxidizer(at least 24 COMP08C JJJJ] completed August 6,2019 on
113 of oxidation catalyst) COMPOI.Results
demonstrated compliance
with 40 CFR 60 Subpart JJJJ
Table 1.
Compliance with emission performance testing for
15A NCAC 2D standards in 40 CFR 60 Subpart
.0524:New Source JJJJ,Table I(Non-Emergency CO gustPOI was performed9adto on
August 6,2019 and test
2.1.A.3.c Performance Standards No Yes NA SI Engine,HP>500, results demonstrated
[40 CFR 60 Subpart manufacture date after
JJJJ] 7/I/2010)by conducting initial compliance with emission
and subsequent stack testing. limits.
Attachment 2-Page 3 of 19
I

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T02
For Calendar Year 2020
Terms and Conditions
Source or Records Was Deviation a
Control Permit Deviations? Method(s)of Determining
k�:mission Source Description "Device ID Condition Condition Summary (Yes/No) Maintained? non-compliance Compliance Status Comments
Issue. (Yes/No)
Number(s) No.10097'1'2
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 Yes 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 on-site. Initial performance
Eight(8)four-stroke lean burn .0524:New Source records of conducted testing was conducted in
natural as-fired reciprocating maintenance. Conduct initial
g P g 2.1.A.3.e Performance Standards No Yes NA February 2014 and
internal combustion engines 4,735 COMPOI- performance tests and
g ( [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
113 of oxidation catalyst) Subpart JJJJ Table 1.
15A NCAC 2D
.0524:New Source Operate and maintain the Units are operated and
2.l.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
iiiii
over the entire life of the engine each engine.
15A NCAC 2D The AFR controllers are used
.0524:New Source Maintain and operate air-to-fuel and proper operation of the
2.1.A.3.g Performance Standards No Yes NA 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 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T02
For Calendar Year 2020
Terms and Conditions
Source or Records Was Deviation a
Control Permit Deviations? Method(s)of Determining
Emission Source Description Maintained? non-compliance Comments
Device ID Condition Condition Summary (Yes/No) (Yes/No/NA) Issue?(Yes/No) Compliance Status
Number(s) No.10097 T2
Maintain records and supporting
15A NCAC 2D documentation for all
.0524:New Source notifications,reports, All required records are
2.1.A.3.h Performance Standards No Yes NA performance tests,and
[40 CFR 60 Subpart maintenance records that show maintained on-site.
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
Eight(8)four-stroke lean burn
[40 CFR 60 Subpart previous ACC submittals.
JJJJ
natural gas-fired reciprocating COMPOI- All required records are
internal combustion engines(4,735 COMP08, maintained on-site.
horsepower rating each)powering COMPOI C- Maintain records and supporting Initial notification for
eight compressors each equipped
COMP08C 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.3.1 Performance Standards No Yes NA maintenance records that show Performance testing for
[40 CFR 60 Subpart compliance with emission COMP01 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
015A New Source Submit summary reports of Semiannual reports were
2.1.A.3.k Performance Standards No Yes NA monitoring and recordkeeping submitted in a timely manner
[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 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T02
For Calendar Year 2020
Terms and Conditions
Source or Records Was Deviation a
Control Permit Deviations? Method(s)of Determining
Emission Source Description Device 1D Condition Condition Summary (Yes/No) Maintained? non-compliance Compliance Status Comments
(Yes/No/NA) issue?(Ves/No)
Number(s) No.10097T2
15A NCAC 2D.0516: No monitoring/
Sulfur Dioxide recordkeeping/reporting is
2.1.B.1 Emissions From No N' NA Use of natural gas only. required for sulfur dioxide
Combustion Sources emissions from the firing of
natural gas.
15A NCAC 2D.0521: No monitoring/
recordkeeping/reporting is
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)four-stroke lean burn natural [40 CFR 60 Subpart Subpart JJJJ. standards in condition
gas-fired emergency generator(880 EG-01 iiiij 2.I.B.2.b through 2.1.13.21.
hp maximum rating) 15A NCAC 2D Comply with general provisions
.0524:New Source
2.1.B.3.b Performance Standards No Yes NA of 40 CFR 60 Subpart A as
[40 CFR 60 Subpart presented in Table 3 of 40 CFR Compliance with this
JJJJ 60 Subpart JJJJ condition is demonstrated by
meeting the emission
15A NCAC 2D
.0524:New Source Comply with emission limits as standards in the following
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 for
EGO1 was conducted May
2.1.B.3.d Performance Standards No Yes NA Condition JJ;and each 2019 and followed the
[40 CFR 60 Subpart performance test shall follow required procedures.
JJJJ the procedures in 60.4244
Attachment 2-Page 6 of 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T02
For Calendar Year 2020
"Perms and Conditions
Source or
Records Was Deviation a
Control Permit Deviations? Method(s)of Determining
Emission Source Description . Device ID Condition Condition Summary (Yes/Nt►) Maintained? non-compliance Compliance Status Comments
(Yes/No/NA) Issue?(Yes/No)
Number(s) No.10097T2
15A NCAC 21) The emergency engine is
.0524:New Source The engine shall be equipped equipped with a non-
with a non-resettable hour meter resettable hour meter.
2.1.B.3.e Performance Standards No Yes NA 140 CFR 60 Subpart if manufactued after July 1, Records are maintained on-
JJJJ] 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 21) records of conducted on-site. Initial performance
gas-fired emergency generator(880 EG-01 0524:New Source maintenance. Conduct initial testing was conducted in
hp maximum rating) 2.1.B.3.f Performance Standards No Yes Nn performance tests and February 2014 and
[40 CFR 60 Subpart subsequent testing was
Jim] conducted 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 21)
.0524: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
JJJJ over the entire life of the engine each engine.
Attachment 2-Page 7 of 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T02
For Calendar Year 2020
Terms and Conditions
Source or
Records Was Deviation a
Control Permit Deviations? Method(s)of Determining
Emission Source Description Device ID Condition Condition Summary (Yes/No) Maintained? non-compliance Compliance Status Comments
Number(s) No.10097T2 (Yes/No/1�A) Issue. (Yes/No)
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 2020
.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 Maintain records and supporting
gas-fired emergency generator(880 EG-01 15A NCAC 2D documentation for all
hp maximum rating) .0524:New Source notifications,reports, All required records are
2.1.13.31 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
2.1.13.31 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 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T02
For Calendar Year 2020
Terms and Conditions
Source or Records Was Deviation a
Control Permit Deviations? Method(s)ol'Determining
Emission Source Description Maintained? non-compliance Comments
Device ID Condition Condition Summary (Yes/No) (Yes/No/NA) Issue?(Yes/No) Compliance Status
Number(s) No.10097T2
15A NCAC 2D Submit summary reports of Semiannual reports were
One(1)four-stroke lean burn natural .0524:New Source monitoring and recordkeeping submitted in a timely manner
gas-fired emergency generator(880 EG-01 2.1.13.3.1 Performance Standards No Y C', NA activities 30 days after the end and included all required
hp maximum rating) [40 CFR 60 Subpart of the semiannual period. elements.
JJJJ
Eight(8)four-stroke lean burn 15A NCAC 2D.I 111: Compliance with 40 CFR Part There are no requirements
Maximum Achievable uirements
natural as-fired reciprocating 63 Subpart ZZZZ by complying for these emission sources
g p g 2.2.A.1 Control Technology[40 No Nn NA with 40 CFR Part 60 Subpart under Sub art ZZZZ. No
internal combustion engines(4,735 COMPOI- CFR Part 63,Subpart p p
horsepower rating each)powering ZZZZ] JJJJ• further requirements apply.
eight compressors each equipped COMP with a catalytic oxidizer(at least 24 COMPOIC-
COMP08C,
ft3 of oxidation catalyst)and EG-01
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
-- 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 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT- Permit No. 10097T02
For Calendar Year 2020
'Perms and Conditions
Source or Records Was Deviation a
Control Permit Deviations? (Yes/No/NA) Issue?(Yes/No) Method(s)of Determining Comments
Emission Source Description Device ID Condition Condition Summary (Yes/No) Maintained? non-compliance Compliance Status
Number(s) No,10097T2
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
conducted in February 2014
New Source JJJJ,Table 1 (Non-Emergency and subsequent testing was
-- Performance Standards No Yes NA SI Engine,HP>500,
[40 CFR 60 Subpart manufacture date after conducted in August 2016
] 7/1/2010 JJJJ and performance testing for
Eight(8)four-stroke lean burn )by conducting initial COMPOI was conducted in
natural gas-fired reciprocating and subsequent stack testing. August 6,2019.. Results
internal combustion engines(4,735
horsepower rating each)powering COMP01- demonstrated compliance
COMP08, with 40 CFR 60 Subpart JJJJ
eight compressors each equipped
with a catalytic oxidizer(at least 24 COMPOIC- Table I.
ft3 of oxidation catalyst)and COMP08C, g Not Applicable. All engines
Compliance with field testing
One(1)four-stroke lean burn natural EG-01 -- p g. q at the Wadi s ion facility
No NA NA provisions for en mes re wired meet the emission standards
gas-fired emergency generator(880 to meet standards referenced in in 40 CFR 60 Subpart JJJJ,
hp maximum rating) 15A NCAC 2D.0524: 40 CFR 1048.101. Table 1.
New Source Units are operated and
Performance Standards Units meet all applicable
No Yes NA provisions under 40 CFR 60 maintained to meet emission
[40 CFR 60 Subpart standards over the life of
JJJJ] Subpart JJJJ. each engine.
After July 1,2009,do not install All engines>_500 HP were
-- No Yes NA SI 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 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T02
For Calendar Year 2020
"Perms and Conditions
Source or Records Was Deviation a
Control Permit Deviations? Method(s)of Determining
Emission Source Description Comments
Device ID Condition Condition Summary (Yes/No) Maintained? non-compliance Compliance Status
Number(s) No,10097'1'2 (Yes/No/NA) Issue?(YesfNo)
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-
-- 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 The AFR controllers are used
internal combustion engines(4,735 Maintain and operate air-to-fuel and proper operation of the
horsepower rating each powering COMPOI- ratio(AFR)controller to ensure
horse
p g ) g COMP08, -- No Yes NA engines and corresponding
eight compressors each equipped proper operation of the engine catalytic oxidizers is
with a catalytic oxidizer(at least 24 COMPOIC- and control device.COMP08C, maintained.
113 of oxidation catalyst)and EG-01
One(1)four-stroke lean burn natural
gas-fired emergency generator(880 15A NCAC 2D.0524: Conduct initial stack testing to Subsequent performance
testing for the emergency
hp maximum rating) New Source meet the emission limit for
-- Performance Standards No Yes N A emergency stationary ICE in 40 engine was conducted in
May 2019 and demonstrated
[40 CFR 60 Subpart CFR 60 Subpart JJJJ Table 1
JJJJ] (Emergency z 130 HP). compliance with 40 CFR 60
Subpart JJJJ.
Performance testing was
Conduct performance testing in conducted in May 2019 for
-- 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 19

of Environmental Quality
North Carolina Department � y
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T02
For Calendar Year 2020
Terms and Conditions
Source or
Records Was Deviation a
Control Permit Deviations'' Method(s)of Determining
Emission Source Description Device 1D Condition Condition Summary (Yes/No) Maintained? non-compliance Com Hance Status Comments
Number(s) No.10097'1'2 (Yes/No/NA) Issue?(Yes/No) p
All required records are
maintained on-site.
Initial notification for
COMPOI-COMP04 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 -- No Yc, NA maintenance records that show test report was submitted e
internal combustion engines(4,735 compliance with emission June report within 60 days n
horsepower rating each werinof
COMPOI- 15A NCAC 2D.0524: standards. Submit initial
P g )Po g test completion.
eight compressors each equipped COMP08, New Source notifications. Submit
1� PCOMPOI C- Performance Standards Performance testing for
with a catalytic oxidizer at least 24 performance test reports within
� ( 40 CFR 60 Subpart COMP014 was conducted in
3 COMPOBC, [ P 60 days of test completion.
ft of oxidation catalyst)and EG-01 JJJJ] 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-
No Y cs NA with a non-resettable hour meter resettable hour meter.
prior to startup. Records are maintained on-
site.
Attachment 2-Page 12 of 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT- Permit No. 10097T02
For Calendar Year 2020
"Perms and Conditions
Source or Records Was Deviation a
Control Permit Deviations? Method(s)of Determining
Emission Source Description Maintained? non-compliance Comments
Device 1D Condition Condition Summary (Yes/No) p
Com lianee Status
Number(s) No.10097T2 (Yes/No/NA) Issue?(Yes/No)
COMP05-COMP08 have
Non-Certified engine:keep not yet commenced
-- 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 , New Source 15A NCAC 2D.0524: and operation in non-emergency resettable hour meter. Hours
eight compressors each equipped COMP08 situations. Operation in non- of operation during CY 2020
with a catalytic oxidizer(at least 24 COMPOIC, Performance Standards emergency situations is limited did not exceed the 50 hr/yr
ft
s of oxidation catalyst)and COMP08C __ [40 CFR 60 Subpart No Yes NA to 50 hrs/yr,and is counted limitation for operation in
One(1)four-stroke lean burn natural EG-01 JJJJ] towards the as part of the 100 non-emergency situations,or
gas-fired emergency generator(880 hrs/yr total. Maintain records of the 100 hr/yr limitation for
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
emergency engine to less than No propane was burned by
-- No Yes NA the emergency engine in CY
100 hours per year during 2019.
emergency operations.
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.
-- No NA NA subsequent performance tests if Initial and subsequent
the stationary engine is rebuilt performance tests for EGO
or undergoes major repair or are conducted in accordance
maintenance. with§60.4243(b)(2)(ii).
Attachment 2-Page 13 of 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-Permit No. 10097T02
For Calendar Year 2020
"terms and Conditions
Source or Records Was Deviation a
Emission Source Description Control Permit Deviations? 1N1aintained? non-compliance Method(s)of Determining Comments
Device ID Condition Condition Summary (Ves/No) (yes/No/NA) Issue.?(Yes/No) Compliance Status
Number(s) No.10097T2
iR(8)lour-stroke lean bum The AFR controllers are used
natural gas-fired reciprocating Maintain and operate air-to-fuel and proper operation of the
internal combustion engines(4,735 ratio(AFR)controller to ensure
COMPOI- -- 15A NCAC 2D.0524: No Yes NA engines and corresponding
horsepower rating each)powering proper operation of the engine
COMP08 New Source catalytic oxidizers is
COMPOIC- Performance Standards
eight compressors each equipped and control device. maintained.
with a catalytic oxidizer(at least 24
3 COMP08C, [40 CFR 60 Subpart Maintain records and supporting
ft of oxidation catalyst)and EG-01 JJJJ] documentation for all
One(1)four-stroke lean burn natural notifications,reports, All required records are
hp maximum rating)
gas-fired emergency generator(880 q
-- N o Yes NA performance tests,and
maintenance records that show maintained on-site.
compliance with emission
standards.
Initial notification is not
-- No NA NA required for emergency NA
stationary SIICE.
Submit summary reports of Semiannual reports were
-- 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. elements.
Eight(8)four-stroke lean burn
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
COMP08,
horsepower rating each)powering Avoidance Conditions COMPOI-08 and EGO less with this condition is
eight compressors each equipped than 10 tpy for a single HAP
COMPOIC- 2.2.A.2 for HAP Major Source No Yes NA demonstrated by complying
with a catalytic oxidizer(at least 24 COMP08C, Classification and less than 25 tpy for all with the CO monitoring,
W of oxidation catalyst)and EG-01 Avoidance HAP,per consecutive 12-month recordkeeping,and reporting
One(1)four-stroke lean burn natural period. of 2.2.A.2.
gas-fired emergency generator(880
hp maximum rating)
Attachment 2-Page 14 of 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-GENERAL CONDITIONS
For Calendar Year 2020
Terms and Conditions Was Deviation a
Records
Deviations? ? non-compliance Method(s)of Determining Compliance
Comments
Condition Maintained. omments
Condition Summary (Yes/No) (Yes/No/NA) Issue',� Status
No. (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)]
3.13 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]
3.11 Changes Not Requiring Permit No NA NA No changes. NA
Modifications[15A NCAC 2Q.0523(a),2Q
.0523(b)&2Q.0523(c)]
31A Reporting Requirements for Excess No NA NA No excess emissions or permit deviations NA
Emissions and Permit Deviations[15A occurred during CY 2020.Records
NCAC 2D.0535(f)and 2Q.508(f)(2)] maintained on-site.
3.1.13 Other Requirements under 15A NCAC 2D No NA NA No excess emissions occurred during CY NA
.0535 2020.
3.J Emergency Provisions[40 CFR 70.6(g)] No NA NA No emergencies occurred during CY 2020. 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 2020.
3.L Need to Halt or Reduce Activity Not a No N A NA Not required. NA
Defense[15A NCAC 2Q.0508(i)(4)]
Attachment 3-Page 15 of 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-GENERAL CONDITIONS
For Calendar Year 2020
'Perms and Conditions Was Deviation a
Records
Deviations? ? non-compliance Method(s)of Determining Compliance
Permit Condition Yes/No) Maintained. Issue? Status Comments
No. Condition Summary ( (Yes/No/NA)
(Yes/No)
3.M Duty to Provide Information(submittal of No NA NA No information requested. NA
information)[15A NCAC 2Q.0508(i)(9)]
3.N Duty to Supplement[15A NCAC 2Q No NA NA No information requested. NA
.0507(f)]
3.0 Retention of Records[15A NCAC 2Q No Yes NA Records maintained on-site for a period of at NA
.0508(f)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
2020.
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.U Property Rights[15 A NCAC 2Q No N A NA No rights conveyed by permit. N A
.0508(i)(8)]
3.V Inspection and Entry[I 5A NCAC 2Q No N A NA Inspection and entry granted with NA
.0508(1)and NCGS 143-215.3(a)(2)] credentials.
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]
Attachment 3-Page 16 of 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-GENERAL CONDITIONS
For Calendar Year 2020
'Perms and Conditions
Records Was Deviation a
Deviations? non-compliance Method(s)of Determining Compliance
Permit Condition Yes/No) Maintained? Issue? Status Comments
No Condition Summary ( (Yes/No/NA)
(Yes/No)
3.Y Confidential Information[15A NCAC 2Q No NA NA No contidential intonnation 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 2020.
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 2020.
3.1313 Financial Responsibility and Compliance No NA NA Not required. NA
History[15A NCAC 2Q.0507(d)(4)]
3.CC Refrigerant Requirements(Stratospheric No Yes NA Complied with the requirements of 40 CFR NA
Ozone and Climate Protection)[I 5A 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
112 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 I I2(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)]
3.GG Air Pollution Emergency Episode[15A No NA NA No emergency episodes occurred. NA
NCAC 2D.0300]
3.HH Registration of Air Pollution Sources[15A No NA NA Not required. NA
NCAC 2D.0202]
3.I1 Ambient Air Quality Standards 1 15A No NA NA Facility does not cause or contribute to NA
NCAC 213.0501 c AAQS exceedances.
Attachment 3-Page 17 of 19

North Carolina Department of Environmental Quality
Division of Air Quality
COMPLIANCE SUMMARY REPORT-GENERAL CONDITIONS
For Calendar Year 2020
Terms and Conditions Was Deviation a
Records
Deviations? ? non-compliance Method(s)of Determining Compliance
Permit Condition �es/No) Maintained. Issue? Status Comments
No Condition Summary ( (Yes/No/NA)
(Yes/No)
_)j.1 General Emissions Testing and Reporting No Yes NA Performance testing for C0MPU1 was N;1
Requirements[15A NCAC 2Q.0508(i)(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.K K Reopening for Cause[I 5A NCAC 2Q N o N A NA Not required. N A
.0517
3.LL Reporting Requirements for Non-Operating No Yes NA Records of operation of all sources N A
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 18 of 19

North Carolina Department of Environmental Quality
Division of Air Quality
DEVIATION SUMMARY REPORT
For Calendar Year 2020
Page 1 of 1
Source or Deviation Deviation Suspected Cause of Corrective Action
Emission Source Description Control Device Pollutant Deviation Description Date(s) Duration Deviation Taken
1D Number(s)
No deviations occurred during the 2020 calendar year.
Attachment 4-Page 19 of 19