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AQ_F_0400056_20220510_CMPL_InspRpt
NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Piedmont Natural Gas-Wadesboro Compressor Station Inspection Report NC Facility ID 0400056 Date: 05/23/2022 County/FIPS: Anson/007 Facility Data Permit Data Piedmont Natural Gas-Wadesboro Compressor Station Permit 10097/T02 259 Pleasant Grove Church Road Issued 6/10/2019 Wadesboro,NC 28170 Expires 5/31/2024 Lat: 35d 1.4834m Long: 80d 1.6830m Class/Status Title V SIC: 4922/Natural Gas Transmission Permit Status Active NAICS: 48621 /Pipeline Transportation of Natural Gas Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V MACT Part 63: Subpart ZZZZ Kristen Belisario Adam Long Kristen Belisario NSPS: Subpart JJJJ Environmental Specialist GM Pipeline Operations Environmental Specialist I (704)731-4130 I (919)546-4005 (919)546-4005 Compliance Data Comments: Inspection Date 05/10/2022 Inspector's Name Evangelyn Lowery-Jacobs Inspector's Signature: Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2020 1.26 0.0800 20.45 1.02 0.6400 1.26 2091.58 2019 1.42 0.0800 23.30 1.16 0.7200 1.42 2386.10 2018 1.73 0.1200 20.18 7.91 1.44 1.73 2911.13 *Highest HAP Emitted(in pounds) Five Year Violation History:None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested Piedmont Natural Gas-Wadesboro Compressor Station Compliance Inspection Report Page 2 of 8 I. DIRECTIONS TO SITE: From FRO,head south on Green Street toward Maiden Lane. At the traffic circle,take the 2nd exit onto Gillespie Street and turn right onto W Russell Street. Travel for 0.5 mile and turn left onto Robeson Street for approximately 2 miles. Use the left 2 lanes to turn left onto Raeford Road for 10 miles and continue onto US- 401 for approximately 20 miles. Just passed Wagram,turn right onto Old Wire Road(NC Hwy 144)and travel 6.2 miles. At the traffic circle,take the 2nd exit onto NC-144 for approximately 6 miles. Make a slight right onto NC-1319 to Laurel Hill. Merge onto HWY 74 W.and continue for 30 miles to Lilesville. Turn right onto Camden Street,then left onto Wall Street. Travel for 1 mile and make a slight right onto Stanback Ferry Ice Plant Road for 1.3 miles. Turn left to stay on Stanback Ferry Ice Plant Road for approximately 1 mile,then turn right onto Winfree Road for 0.6 mile. Turn right onto NC-109 N for 1.7 miles,then left onto Pleasant Grove Church Road for 0.3 mile. Turn left to stay on Pleasant Grove Church Road and the facility is located on the left side of the road. II. SAFETY CONSIDERATIONS: The usual FRO safety gear is required,including hard hat,safety shoes,safety glasses,and hearing protection. There may be numerous pieces of equipment operating on site,including forklifts,personnel lifts,trucks,cars, and others. III. FACILITY DESCRIPTION: The facility is a large natural gas pipeline compressor station. The facility accepts natural gas from the Trans- Continental distribution pipeline at 500-800 psig pressure and compresses this gas to 800-1,000 psig for injection into the Piedmont pipeline to transport it to its destination. The gas pipeline leads eventually to the Duke Sutton electrical power generation plant in Wilmington. The Piedmont facility consists of four(4)natural gas-fired 4,735 HP compressors(8 are permitted at the facility),plus a 770 HP natural gas-fired emergency generator. All the engines are fueled by natural gas pulled directly from the gas transmission pipeline. Piedmont Natural Gas-Wadesboro Compressor Station Compliance Inspection Report Page 3 of 8 IV. PERMITTED EQUIPMENT: --777777777777 � c � ntrc �s �ritit I3II �+ � in One four-stroke lean burn natural gas-fired COMPOI reciprocating internal combustion engine yt Catal is oxidizer NSPS (4,735 horsepower rating)powering a compressor COMPO 1 C 3 (24.0 cubic feet of oxidation catalyst) MACT NOT OPERATING—15,230 hours COMP02 One four-stroke lean burn natural gas-fired reciprocating internal combustion engine COMP02C Catalytic oxidizer NSPS 4 735 horsepower rating)powering a compressor 24.0 cubic feet of oxidation catalyst) j ( � P g)P g p ( Y ) , MACT NOT OPERATING- 15,241 hours COMP43 One four-stroke lean burn natural gas-fired a reciprocating internal combustion engine Catalytic oxidizer NSPS COMP03 C MACT 1 (4,735 horsepower rating)powering a compressor (24.0 cubic feet of oxidation catalyst) NOT OPERATING—15,245 hours } COMP04 One four-stroke lean burn natural gas-fired reciprocating internal combustion engine I Catalytic oxidizer NSPS MACT ' (4,735 horsepower rating)powering a compressor COMP04C (24.0 cubic feet of oxidation catalyst) NOT OPERATING—15,256 hours } i COMP05 1 One four-stroke lean burn natural gas-fired reciprocating internal combustion engine Catalytic oxidizer NSPS 4 735 horsepower rating)powering a compressor COMPOSC 24.0 cubic feet of oxidation catal st MACT 3 ( , p g)p g p ; ( Y ) NOT YET INSTALLED COMP06 One four-stroke lean burn natural gas-fired reciprocating internal combustion engine Catalytic oxidizer NSPS COMP06C MACT (4,735 horsepower rating)powering a compressor (24.0 cubic feet of oxidation catalyst) r NOT YET INSTALLED z COMP07 One four-stroke lean burn natural gas-fired F f reciprocating internal combustion engine Catalytic oxidizer NSPS (4,735 horsepower rating)powering a compressor 3 COMP07C (24.0 cubic feet of oxidation catalyst) MACT NOT YET INSTALLED s One four-stroke lean burn natural gas-fired COMP08 reciprocating internal combustion engine E Catalytic oxidizer NSPS 1 (4,735 horsepower rating)powering a compressor COMP08C a (24.0 cubic feet of oxidation catalyst) MACT NOT YET INSTALLED t One four-stroke lean burn natural gas-fired EGO MACT emergency generator(770 hp maximum rating) N/A N/A OPERATING,WE 0% Opacity—229 hours } Piedmont Natural Gas-Wadesboro Compressor Station Compliance Inspection Report Page 4 of 8 V. FACILITY INSPECTION SUMMARY: On 10 May 2022 I,Evangelyn Lowery-Jacobs with DAQ FRO visited the Piedmont Natural Gas—Wadesboro Compressor Station plant site in Wadesboro. I met with Lance Eckford,Compression Supervisor,Aaron Muniz,and Alan Henderson, Senior Compressor Technicians. Mr.Muniz verified the FacFinder data is up to date and accurate. Records for operating hours and operating loads on the engines are kept on the computerized control system. The operator was able to show the records of operating hours for each of the permitted engines. Operating hours for each engine were as follows: Hours O erated as©f r Hours Operated as of f Engine 08125/2020�. 0511012022 (from previous in report) 3 #1 Compressor 12,217 15,230 (COMPO 1) 3 #2 Compressors ; ' COMP02 12,225 15,241 } ( ) E #3 Compressor ! (COMP03) 12,224 15,245 #4 Compressor 12,254 15,256 (COMP04) ' EmergenEcG Generator 193 229 ( )_ _ x Mr.Muniz led me on a tour of the engine room. The compressors were not operating at the time of inspection; however,the facility was conducting source testing on the emergency generator(EGO 1). The compressors last operated during the week of 01 May 2022 during hot weather days. The engines run alternately based on the number of operating hours for each. All of the engines appeared to be very well maintained,and no issues were observed. Mr.Muniz indicated there is no expansion planned for the facility and no new equipment has been added since the last inspection. VI. SPECIFIC PERMIT CONDITIONS: A. Eight 4,735 Four Stroke Lean Burn Natural Gas-fired Compressor Engines(ID Nos.COMP01 through COMP08) i. 15A NCAC 2D.0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES— Emissions of sulfur dioxide from the eight 4,735 HP compressor engines shall not exceed 2.3 pounds per million Btu heat input. APPEARS IN COMPLIANCE—The engines use only natural gas, with an EPA AP-42 emission factor of 0.007 lb/mmBtu. As long as the engines only combust natural gas, they should not exceed the limitation. The compressors were not operating at the time of inspection;however, the facility was conducting source testing on the emergency generator(EGO]). Only 4 of the permitted compressor engines have been installed. Piedmont Natural Gas-Wadesboro Compressor Station Compliance Inspection Report Page 5 of 8 ii. 15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from the eight compressor engines shall not exceed 20 percent opacity when averaged over a 6-minute period. 6- minute averaging periods may exceed 20 percent opacity no more than once in any hour and not more than four times in any 24-hour period.In no event shall the 6-minute average exceed 87 percent opacity. APPEARS IN COMPLIANCE—The typical opacities for these engine exhausts are zero. The facility should have no difficulty complying with these limits. There were no visible emissions observed from the emergency generator(EGO]) exhaust during the inspection. iii. 15A NCAC 2D.1423 LARGE INTERNAL COMBUSTION ENGINES—The Permittee shall not cause to be emitted into the atmosphere nitrogen oxides(NOx)in excess of 125 ppm,corrected to 15 percent by volume stack gas oxygen on a dry basis,averaged over a rolling 30-day period. This limit may be adjusted basis the engine efficiencies. Compliance with the limits will be demonstrated by conducting stack testing at the engine exhausts. A report is required by October 31 of each year, documenting the total nitrogen oxide emissions during the period Mayl through September 30 of each year,beginning with the year of the first ozone season that the engines operate. Records are required to be maintained for each engine for ID and location of each engine;number of hours of operation of each engine each day,including startups, shutdowns,and malfunctions,and the type and duration of maintenance and repairs;date and results of any emissions corrective maintenance taken;results of compliance testing. Emission standards do not apply during periods of start-up and shutdown and periods of malfunctions,not to exceed 36 consecutive hours,or regularly scheduled maintenance activities. APPEARS IN COMPLIANCE—The facility maintains all records electronically through the DCS control system, which maintains hours of operation and other data. Some paper records are also maintained for the preventative maintenance activities. The last ozone season report was received at FRO on 1 012 512 02 1, and the facility was in compliance.. B. 880 HP Four Stroke Lean Burn Natural Gas-fired Emergency Generator(ID No.EG01) i. 15A NCAC 2D.0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES— Emissions of sulfur dioxide from the emergency generator engine shall not exceed 2.3 pounds per million Btu heat input. APPEARS IN COMPLIANCE—The engine combusts only natural gas. The EPA AP-42 emission factor for sulfur dioxide for natural gas combustion is 0.001 lb/mmBtu. As long as this engine only combusts natural gas, it should easily meet this limitation. The facility was conducting source testing on the emergency generator(EGO]), during the inspection. ii. I5A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS-Visible emissions from the emergency generator engine shall not exceed 20 percent opacity when averaged over a 6-minute period.6-minute averaging periods may exceed 20 percent opacity no more than once in any hour and not more than four times in any 24-hour period. In no event shall the 6-minute average exceed 87 percent opacity. APPEARS IN COMPLIANCE—Typical visible emissions for this engine during operation are zero opacity. The facility should have no difficulty complying with the permit limitation. The facility was conducting source testing on the emergency generator(EG01), during the inspection. There were no visible emissions observed from the emergency generator(EG01) exhaust during the inspection. Piedmont Natural Gas-Wadesboro Compressor Station Compliance Inspection Report Page 6 of 8 C. Compressor Engines(COMP01 through COMP04)and Emergency Generator Engine(EG01) i. 40 CFR 63,Subpart ZZZZ STATIONARY RECIPROCATING INTERNAL COMBUSTION ENGINES—The engines meet the requirements of Subpart ZZZZ by meeting all the requirements of NSPS Subpart JJJJ"Stationary Spark Ignition Internal Combustion Engines." APPEARS IN COMPLIANCE—The engines demonstrate compliance by complying with the requirements of NSPS Subpart JJJJ. ii. 40 CFR 60,Subpart JJJJ STATIONARY SPARK IGNITION INTERNAL COMBUSTION ENGINES—The compressor engines must meet the following emission limits: NOx— 1.0 g/HP-hr and 82 ppmvd @ 15%oxygen;CO 2.0 g/HP-hr and 270 ppmvd @ 15%oxygen;VOC 0.7 g/HP-hr and 60 ppmvd @ 15%oxygen. The emergency engine must meet the following emission limits: NOx— 2.0 g/HP-hr and 160 ppmvd @ 15%oxygen;CO 4.0 g/HP-hr and 540 ppmvd @ 15%oxygen;VOC— 1.0 g/HP-hr and 86 ppmvd @ 15%oxygen. VOCs do not include formaldehyde. The nine engines are not certified engines,and therefore the facility must conduct initial stack testing to demonstrate initial compliance on each engine. Records of maintenance plans and records of conducted maintenance must be maintained,as well as records of the stack testing. Subsequent stack testing must be conducted every 8,760 hours or 3 years,whichever comes first. Results of stack testing must be submitted within 60 days after the testing is performed. Initial notification is required. APPEARS IN COMPLIANCE—Source testing was being conducted on the emergency generator engine(EG01) on the day of the facility inspection. The previous source testing performed was for the emergency generator engine on 0510812019. Results of the test demonstrated compliance with the emission limits. The facility was granted a "Waiver for Emissions Testing of One Natural Gas Engine as Representative of Emissions for Engines COMP01-COMP04 and EGO]"in a letter dated 14 February 2022 from Mr. Stephen Hall. The waiver was issued to PNG Wadesboro allowing conditional approval of representative testing of identical units on an ongoing basis. This waiver exempts COMP01 from the 2022 subject testing. Engines COMP02 through COMP04 are all being tested in 2022 since none of these engines have been tested since 2016 After the 2022 testing is completed, at least half of the subject engines are tested once every three years with all engines being tested at least once every 6 years. Stack testing for one compressor engine(COMP01)was conducted on 6 August 2019. The test reports submitted demonstrated compliance with the emission limits. Source testing is scheduled for compressor engines(COMP02 through COMP04) during June 2022. The operating hours of the four compressor engines were as noted in the table below. The emergency engine is seldom run except for operational checks. The facility engine maintenance records were observed and indicate that the engines are serviced in accordance with manufacturer specifications. The initial notification for the 5 current engines was received at FRO on 0310412013. Engine Hours of Operation: .� � •��'Y �1��- fi '- ) 1 +,''fr`F '""' 'k �x e`:-w'k"^T'�T's<,n`Z ,x 5-''-Y COMP01 08/06/2019 12,217 15,230 M COMP02 08/17/2016 12,225 15,241 66M403 __F -08/18/2016 12,224 15,245 COMP04 08/18/2016 12,225 15,256 _ _ — _ EG01 05/08/2019 193 229 Piedmont Natural Gas-Wadesboro Compressor Station Compliance Inspection Report Page 7 of 8 Stack Testing Results: r .; a rear �� ine :�miss�►n mils _ 77+�v�i - --c"W 08l1612 9 NOx 82 ppm 3 9.6 ppm ....P..n.�».dam-»,_. .,m.»..e .,..��...._..�....., .........._.._...e.....es-...f CO t 270 ppm 1.9 ppm VOC 60 ppm 2.2 ppm S �`� 1 oprr ib 9 mi" Lets R"' S t}81l?��1�6 NOx $2 ppm — 30.9 ppm CO 270 ppm 2.6 ppm VOC 60 ppm 18.0 ppm C�mpresQr Mack T(CO ' %ng Ex 3missa�Limas esu�Is MP NOx 82 ppm 3 5.7 ppm CO 270 ppm 5.0 ppm VOC 60 ppm ppm m M M Stack T�smg 44 Carssr R nemis }inlet r - (O{3:�PO4 0811612�19 NOx �82 ppm. 33.4 ppm s CO 270 ppm 3.3 ppm - VOC 60 ppm 18.8 ppm w 7 Eme enc St +ck Testing nerd or, � s €n inats gists engine� 01) Q 11812019 } NOx 160 ppm 145.4 ppm CO 540 ppm 163.1 ppm ��..�._VOC _ g�ppm10.1 ppm_.u....._ iii. 15A NCAC 2Q.0317 AVOIDANCE CONDITION FOR 40 CFR 63 SUBPART ZZZZ(HAP MAJOR CLASSIFICATION AVOIDANCE)—The facility has accepted an emission limit of no more than 10 tons of formaldehyde per consecutive 12-month period to avoid the Title III Major Source rules for this Subpart. This requirement is met by conducting the required monitoring, recordkeeping,and reporting of emissions of CO based on stack testing. APPEARS IN COMPLIANCE—The review of the potential controlled emissions during the permit review process showed that this limit should not be exceeded. Proper operation and maintenance of the catalytic oxidizers on the engines is required to comply with this limit. The stack testing results- from 2019 indicated compliance with the emission limits. Piedmont Natural Gas-Wadesboro Compressor Station Compliance Inspection Report Page 8 of 8 iv. PERMIT GENERAL CONDITION 3.I.A—EXCESS EMISSIONS REPORTING REQUIREMENTS (15A NCAC 2D.0535 and 2Q.0508(t)(2)]—Requires notification to DAQ when an excess emission event occurs that lasts more than 4 hours,or when a deviation from the permit conditions occurs.For excess emissions events,must be reported by 9 AM the following business day. Deviations from permit conditions must be reported quarterly. APPEARS IN COMPLIANCE—Mr. Muniz stated that no excess emission events have occurred; therefore, no notifications have been required by the facility. He is aware of the notification requirement for excess emissions events. v. PERMIT GENERAL CONDITION 3.P-ANNUAL COMPLIANCE CERTIFICATION—An annual compliance certification report is required to be submitted to DAQ and EPA postmarked by no later than March 1 each year,noting any deviations from permit conditions. APPEARS IN COMPLIANCE—The last ACC report was received at FRO on 0310212022 and appeared to be in compliance. vi. PERMIT GENERAL CONDITION 3.X-ANNUAL EMISSION INVNETORY REQUIREMENTS—An annual emission inventory is required to be submitted no later than June 30 of each year. APPEARS IN COMPLIANCE—The last annual emission inventory for the facility was received at FRO on 0512812021 and appeared complete. vii. PERMIT GENERAL CONDITION 3.DD-CLEAN AIR ACT,SECTION 112(r) REQUIREMENTS APPEARS IN COMPLIANCE—The facility does not store any of the listed 112(r) chemicals in amounts that exceed the threshold quantities. Therefore, the facility is not required to maintain a written Risk Management Plan(RMP). VII. COMPLIANCE HISTORY: There have been no negative compliance instances since the permit was initially issued in 2011. VIII. FACILITY PINK SHEET REVIEW: There were no pink sheet items to be included in the facility inspection. IX. CONCLUSIONS/RECOMMENDATIONS: The facility appeared to be operating IN COMPLIANCE with the specific conditions contained in the facility's current Air Permit on 10 May 2022. /elj