AQ_F_0400056_20190619_ST_ProtRvw (4)

ry�uvr 4
ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS
Director
June 19,2019
Ms. Cynthia Winston
Piedmont Natural Gas
410 S.Wilmington Street
Raleigh,NC 27601
Subject: Piedmont Natural Gas -Wadesboro Compressor Station
Wadesboro,Anson County,North Carolina
Facility ID 04-00056,Air Permit No. 10097TO1
Proposed Emissions Testing of Natural Gas Engines COMP01-COMP04 and EGO
By Mostardi Platt,Week of August 5,2019
DAQ Tracking No.2019-166ST
Dear Ms.Winston:
The North Carolina Division of Air Quality(DAQ)has reviewed protocol submittal form(PSF)for the
proposed nitrogen oxides(NO,,), carbon monoxide(CO), and volatile organic compounds(VOC)
emissions testing of five four-stroke lean-burn(4SLB)natural gas-fired internal combustion engines
COMPOI through COMP04,and EGO1. The proposed testing is conditionally approved as discussed
below.
COMPO1 through COMP04 are four identical natural gas-fired,four-stroke lean burn internal combustion
reciprocating engines rated at 4735 horsepower(hp). Each engine is controlled by a catalytic oxidizer.
EGO is also a four-stroke lean burn engine rated at 880 hp. 40 CFR 60 Subpart JJJJ Standards of
Performance for Stationary Spark Ignition Internal Combustion Engines and 40 CFR 63 Subpart ZZZZ
National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines apply. Compliance with 63 Subpart ZZZZ is met by complying with the limits of 60
Subpart JJJJ.
The primary purpose of the testing is to satisfy 60 Subpart JJJJ requirements for periodic testing once
every three years or every 8760 hours,whichever occurs first. The testing is being conducted to meet the
three-year testing requirement since the engines have not met the 8760-hour threshold. Piedmont Natural
Gas is requesting a waiver to allow testing of one engine as being representative of emissions for all
engines. The request for a waiver is being addressed under separate cover. The emission limits are
summarized in the table below.
Pollutant Emission Limit'
NO, 1.0 /h -hr or 82 mvd@ 15%02
CO 2.0 g/hp-hr or 270 ppmvd 15%02
VOC 0.7 /l -hr or 60 ppmvd 15%02
1 g/hp-hr=grams per horsepower hour;ppmvd@15%02=parts per million volume dry corrected to 15%oxygen
, D_E
07
Dip-f
North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707.8400

Ms.Cynthia Winston
Page 2
DAQ Tracking No. 2019-166ST
Mostardi Platt proposes EPA Method 320 for measurement of NO,CO, and VOC. The proposed test
methods are acceptable for demonstrating compliance with the applicable regulations. Approval of the
protocol does not exempt the tester from the minimum requirements of the test methods. Since no
deviations from the applicable methods were addressed in the protocol,the testing should be performed in
strict accordance with the requirements of EPA Methods 2, 3A, and 320.
Testing must be conducted at full load±10%. Target process rate for testing is 4735 hp for COMPOI
through COMP04 and 880 hp for EGO 1. These rates are acceptable. If there are any questions regarding
this review,please contact Brent Hall at(919)707-84277 or Brent.Hall_.ncdenr.gov.
Sincerely,
rent W.Hall Y
Special Projects Engineer
Cc: David Ozawa,Mostardi Platt Bruce Ingle,MRO
Central Files, Cabarrus County IBEAM Documents— 1300155