AQ_F_0400056_20200825_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Piedmont Natural Gas'-Wadesboro Compressor
Station
Inspection Report NC Facility ID 04000,56
Date: 09/14/2020 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
Cynthia Winston Adam Long Cynthia Winston MALT Part rt Subpart Z2ZZ
Manager,Permitting and GM Pipeline Operations Manager,Permitting and NSPS: Subpart JJJJ
Compliance [phone] Compliance
[phone] [phone]
Compliance Data
Comments:
Inspection Date 08/215/202;10
Inspector's Name Evangel�n Lowery-J$cobs
g
Inspec
tor's Signature: Operating Status Operating
�
Compliance Code Compliance-inspection I '
Action Code FCE
Date of Signature: 49 l/d/_wzp On-Site Inspection Result j Compliane',ie
Total Actual emissions in T/ONSIYEAR:
TSP S02 NOX VOC CO PM10 *'HAP
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 29I11.13
2017 1.11 0.0800 12.92 5.09 0.9400 1.11 1860.30
*Highest HAP Emitted in ounds'
Five Year Violation History:None
Date Letter Tvae Rule Violated Violation Resolution Date
Performed Stack T since last FCE:o ed tac Tests i
Date Test Results Test Method(s) Source(s)Tested
08/07/2019 Compliance Method 320 COMPOI

Piedmont Natural Gas-Wadesboro Compressor Station
Compliance Inspection Report
Page 2 of 7
I. DIRECTIONS TO SITE:
From FRO,take US Hwy 401 South through Raeford and Wagram. Just past Wagram,turn right onto Old Wire'.
Road(NC 144). Follow Old Wire Road across US 151501 and through Laurel Hill to US 74. Turn right onto
US 74. Follow US 74 35 miles to Wadesboro,then turn right onto N.Greene St/NC Hwy 109. Drive 4.9 miles,
then turn left onto Pleasant Grove Church Road. The Piedmont facility is located approximately 0.3 miles.on
the left side of the road.
11. 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.
I11. 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 prig 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.
IV. PERMITTED EQUIPMENT:
Emission Emission Source Description Control Control Devicg Description
Source Device
ID No. ID N4.
COMPOI One four-stroke lean burn natural gas-fired COMPO Catalytic oxidizer(24.0 cubic feet
NSPS reciprocating internal combustion engine 1C of oxidation catalyst)
MACT (4,735 horsepower rating)powering a compressor
F
One four-stroke lean burn natural gas-fired COMPO Catalytic oxidizer(24.0 cubic feet
reciprocating internal combustion engine 2C of oxidation catalyst)
(4,735 horsepower rating)powering a compressor
COMP03 One four-stroke lean bum natural gas-fired COMPO Catalytic oxidizer,(24.0 cubic feet
NSPS reciprocating internal combustion engine 3C of oxidation catalyst)
MACT (4,735 horsepower rating)powering a compressor
COMP04 One four-stroke lean burn natural gas-fired COMPO Catalytic oxidizer(24.0 cubic feet
NSPS reciprocating internal combustion engine 4C of oxidation catalyst)
MACT (4,735 horsepower rating)powering a compressor
COMP05 One four-stroke lean burn natural gas-fired COMPO Catalytic oxidizer(24.0 cubic feet
NSPS reciprocating internal combustion engine(4,735 5C of oxidation catalyst)
MACT horsepower rating)powering a compressor

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Piedmont Natural Gas-Wadesboro (Compressor Station]
Compliance Inspection Report
Page 3 of 7i
COMP06 One four-stroke lean burn natural gas-fired COMPO Catalytic oxidizer, (24.0 cubic feet
NSPS reciprocating internal combustion engine(4,735 6C of oxidation catalyst)
MACT horsepower rating)powering a compressor
COM207 One four-stroke lean bum natural gas-fired COMPO Catalytic oxidizer(24.0 cubic feet
NSPS reciprocating internal combustion engine(4,735 7C of oxidation catalyst)j
MACT horsepower rating)powering a compressor
COMP08 One four-stroke lean burn natural gas-fired COMPO Catalyticl�oxidize� r
NSPS reciprocating internal combustion engine(4,735 8C (24.0 cubic feet ofli oxidatior't
MACT horsepower rating)powering a compressor cat allyst)
EGO 1 One four-stroke lean burn natural gas-fired
MACT emergency generator(770 hp maximum rating) N/A N/A
V. FACILITY INSPECTION SUMMARY:
' � I
On 25 August 2020 I,Evangelyn Lowery-Jacobs with DAQ FRO visited the Piedmont Natural Gas,—
Wadesbom Compressor Station plant site in Wadesboro. I met with Lance Eckford,Compressiott Supervisor,)
Richard Wentland and Delma King;Compressor Technicians. Mr. Wantland verified the Fac,Finiier data is it
to date and accurate. I'
Records for operating hours and operating loads on the engines are kept on the computerized conirol system.
The operator was able to show the records of operating hours for each of the permitted engines. 01}eraiing
hours for each engine were as follows:
Hours Operated as of
Hours Operated as df
Engine 05/29/2019
08/25/2020
(from previous inspection report)
#1 Compressor 9,894 12,217
(COMP ess
#2 Compressor 9,891 12,225
(COMP02) --
#3 Compressor i
(COMP03) 9,812 12,224
COMPessor 9,812 12,254
Emergency Generator 165 193
EGOl
Mr. King led me on a tour of the engine room. The facility had one engine(COMP03)operating a l
the time of inspection. The engines run alternately based on the amount of operating hours for each.
All of the engines appeared to be very well maintained,and no issues were observed.
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Piedmont Natural Gas-.Wadesboro Compressor Station
Compliance Inspection Report,
Page 4 of 7'
VI. SPECIFIC PERMIT CONDITIONS:
A. Eight 4,735 Four Stroke Lean Burn Natural Gas-fired Compressor Engines(ID Nos.COMPOI;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 a !ii�ission
factor of 0.007 lb/mmBtu. As long as the engines only combust natural gas,they should not exceed
the limitation. Only the 43 Compressor engine was operating during the inspection. Only 4 of the
permitted compressor engines have been installed.
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 exceedl87 percent
opacity.
APPEARS INCOMPLIANCE—The typical opacities for these engine exhausts are lzero.;The facility
should have no difficulty complying with these limits. There were no visible emissions observed from
the#3 Compressor engine exhaust during the inspection.
iii. 15A NCAC 2D.1423 LARGE INTERNAL COMBUSTION ENGINES—The Pertrainee shall not
cause to be emitted into the atmosphere nitrogen oxides(NOx)in excess of 125 ppm,corrected to 15''l
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 Sep ember 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 hourg of operation of
each engine each day, including startups,shutdowns;and malfunctions,and the type land 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 10/21/2019.
B. 880 HP Four Stroke Lean Burn Natural Gas-fired Emergency Generator(ID No.EGO1) !
i. 15A NCAC 2D.0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES—
Emissions of sulfur dioxide from the emergency generator engine shall not exceed 2.13 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 I
combusts natural gas, it should easily meet this limitation. The emergency engine was notioperating
during the inspection.

Piedmont Natural Gas-Wadesboro Compressor Station
Compliance Inspection Report
Page 5 of 7
ii. 15A NCAC 213.0521 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 emergency
engine was not operating during the inspection.
C. Compressor Engines(COMPOI through COMP04)and Emergency Generator Engine(EGO 1)
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 ofNSPS 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—Stack testing was performed on the emergency generator engine on
05/08/19. Results of the test demonstrated compliance with the emission limits. The stack testing
results indicated 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 COMPOI-
COMP04 and EGO1"in a letter dated 29 July 2019 from Mr.Brent Hall. The waiver applied to the
2019 testing cycle only. NC DAQ is reviewing the procedures for processing these types of waiver
requests in the future to include conditional approval over multiple years. Stack testing for one
compressor engine(COMPOI)was conducted on 6 August 2019. The test reports submitted
demonstrated compliance with the emission limits. 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 and will be due for stack testing in May 2022. Maintenance records are readily accessible in
the operations office. The initial notification for the 5 current engines was received at FRO on
03/04/2013.
Engine Hours of Operation:
Ao r&at preui_ps ' Hourp at thrs'u;
sts#¢y pate 4T Last mpr�ion inspechqu
x SonXCe tai;$,"Stack Tb&t >
OS%0�/2p1� (18/25/2020.`
COMPOI 08/16/2019 9,894 12,217
COMP02 08/17/2016 9,891 12,225
COMP03 08/18/2016 9,812 12,224
COMP04 08/18/2016 9,812 12,225
EGO 1 05/08/2019 1 165 193

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Piedmont Natural Gas-Wadesboro Compressor Station
Compliance Inspection Report
Page 6 of 71
Stack Testing Results:
'i
Compressor Stack Testing
Engine#1 Emission Limits Results
(COMPOI) 08/16/2019
NOx 82 ppm 39.6 ppm
CO 270 ppm 1.9 ppm
VOC 60 ppm 2.2 ppm
Com pressor Stack Testing
Engine#2 Emission Limits Results
(COMP02) 1 08/17/2016'
NOx 82 ppm 30.9 ppm
CO 270 ppm 2.6 ppm
VOC 60 pprn 18.0 ppm
Compressor Stack Testing -
Engine#3 Emission Limits' Results �
(COMP03) 08/16/2019'
NOx 82 ppm 35.7 ppm
CO 270 ppm 5.0 ppm
VOC 60 ppm 3.5 ppm
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Compressor Stack Testing 'I
Engine#4 Emission Limits Results
(COMP04) 08/16/2019
NOx 82 ppm 33.4 ppm
CO 270,ppm 3.3 ppm
VOC 60 ppm 18.8 ppm
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Emergency Stack Testing
Generator Emission Limits Results
Engine(EG01) 05/18/2019
NOx 160 ppm 145.4 ppm
CO 540 ppm 163.1 ppm
VOC 86 ppm 10.1 ppm
iii. 15A NCAC 2Q.0317 AVOIDANCE CONDITION FOR 40 CFR 63 SUBPART ZZZZ(HAP
MAJOR CLASSIFICATION AVOIDANCE)—The facility has accepted an emission aitinit of no
more than 10 tons of formaldehyde per consecutive 12-month period to avoid the Title I#Major
Source rules for this Subpart. This requirement is met by conducting the required monit ring,
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 maiptgnance of
the catalytic oxidizers on the engines is required to comply with this limit. The stack teking results
indicated compliance with the emission limits.
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Piedmont Natural Gas-Wadesboro Compressor Station
Compliance Inspection Report
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iv. PERMIT GENERAL CONDITION 3.I.A—EXCESS EMISSIONS REPORTING
REQUIREMENTS 115A NCAC 2D.0535 and 2Q.0508(f)(2)]—Requires notificationto 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. King stated that no excess emission events have occurred,and
therefore no notifications have been required.
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 02/26/2020 and
appeared complete.
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.
APPEARSIN COMPLIANCE—The last annual emission inventory for the facility was received at
FRO on 05/26/2020 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 25 August 2020.
/elj