AQ_F_0400056_20190807_ST_STO-Rpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Piedmont Natural Gas-Wadesboro Compressor
Station
Stack Test Observation Report NC Facility ID 0400056
Date: 08/07/2019 County/FIPS: Anson/007
Facility Data Compliance Data
Piedmont Natural Gas-Wadesboro Compressor Station Observation Date 08/06/2019
259 Pleasant Grove Church Road Observer's Name Gregory Reeves
Wadesboro,NC 28170 Operating Status Operating
Lat:35d 1.4834m Long: 80d 1.6830m Action Code 23/STACK TEST
SIC: 4922/Natural Gas Transmission OBSERVED
NAICS: 48621 /Pipeline Transportation of Natural Gas
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 10097/T02
Christopher Friel Adam Long Cynthia Winston Issued 19 5/31/20
Expires 24
Lead EHS Professional Director,Gas Pipeline Manager,Permitting and
[phone] Operations Compliance Classificattionion Title�°((77/700044)7 1-4130 [phone] Permit Status Active
Inspector's Signature Comments:
Date of signature: 717 TRACKING NUMBER l� 2019-166ST
1. LOCATION:
Piedmont Natural Gas—Wadesboro Compressor Station,259 Pleasant Grove Church Road,Wadesboro,NC,
Anson County.
2. DIRECTIONS:
From FRO,take US Hwy 401 South through Raeford and Wagram. Just outside 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.
3. 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 other vehicles. Fire retardant(FR)clothing is also required when out in the plant. The facility will supply
FR coveralls for the inspector. At the time of this stack test,the facility was operating only one of the
compressor engines, ID No. COMPO1.

Piedmont Natural Gas—Wadesboro Compressor Station
Stack Test Observation Report
Page 2 of 4
4. FACILITY DESCRIPTION:
The facility is a large natural gas pipeline compressor station. The facility accepts natural gas from the Transco
distribution pipeline at 500-800 prig pressure,and compresses this gas to 800-1,000 prig for injection back into
the pipeline to transport it to its destination. This facility was installed to be able to supply natural gas to the
Progress Energy Sutton electrical power station in Wilmington. The Piedmont facility consists of eight(8)
permitted natural gas-fired 4,735 HP compressors,plus a 770 HP natural gas-fired emergency generator. Only
four of the eight compressors have been installed to date. The facility is performing stack tests one of the four
compressor engines and on the emergency generator engine in order to demonstrate compliance with NSPS
Subpart JJJJ emission limits for these engines. The testing for the one compressor engine will be deemed
representative of all four of the compressor engines,per the testing waiver issued by RCO SSCB
5. TEST CHRONOLOGY:
05/09/19 Piedmont submitted the stack test notification and testing protocol to SSCB. The
submittal included a request for testing of only one of the four compressor engines as
representative of all four. Testing was proposed to be conducted during the week of
August 5,2019. Testing will include the emergency generator engine.
06/19/19 RCO SSCB issued an approval letter for the proposed testing protocol. The request for
a waiver to test only one compressor engine was to be addressed separately.
06/26/19 Piedmont submitted a revised testing protocol,to include testing for metals using EPA
Method 29,with the results to be used for internal company information.
07/01/19 Piedmont submitted additional information regarding the request for a waiver to test
only one of the four compressor engines.
07/02/19 Cynthia Winston of Piedmont submitted additional information to Steve Hall in RCO
regarding the request for a waiver to test only one compressor engine.
07/08/19 RCO sent Piedmont a letter for approval of the waiver to test only one compressor
engine.
07/10/19 RCO sent Piedmont a revised approval letter for the testing waiver, which granted
approval for only this testing cycle. Future testing cycles will require a request for a
waiver at that time.
07/15/19 Reid Henderson of Piedmont sent an email with the proposed testing date for the
Wadesboro testing,to be performed during the week of August 5,2019.
07/29/19 RCO issued a second revision of the approval letter for the testing waiver. This letter
stated that DAQ is reviewing the procedures for processing these types of waiver
requests in the future to include conditional approval over multiple years. If DAQ
established procedures for multiple year approvals,Piedmont will be notified.
08/06/19 Stack testing commenced on the#1 compressor engine,ID No. CONDO 1.

Piedmont Natural Gas—Wadesboro Compressor Station
Stack Test Observation Report
Page 3 of 4
6. PURPOSE OF STACK TEST:
The purpose of this test is to demonstrate continued compliance for the four natural gas-fired compressor
engines(ID Nos. COMPOI through COMP04)as required under NSPS Subpart JJJJ. These engines as well as
the emergency generator engine are not"certified" engines, and thus a stack test is required to demonstrate
compliance with the NOx,CO,and VOC emission limits under the NSPS regulation every 8,760 hours of
operation or every 3 years,whichever comes first. The company received approval to test one of the four
compressor engines,to be representative of all four compressor engines. The emergency generator engine is
also being tested.
The compressor engine being tested is a Caterpillar 4,735 HP four-stroke lean-burn natural gas-fired
reciprocating internal combustion engines,driving a natural gas compressor. Under NSPS Subpart JJJJ,the
emission limits for this engine are as follows: [40 CFR 60, Subpart JJJJ,Table 1] (Note that the owner or
operator can choose to comply with either the emission limit in g/hp-hr OR the emission limit in ppmvd% 15%
02.)
• d . ,� .tip. ..• . ., i�: ,,. ..... ., �n t .tl� d'
NOx 1.0 82
CO 2.0 270
VOC 0.7 60
The approved test methods are as follows:
West' d
is e .i1,7
,k1 $ h •' as
CO EPA Method 320 3 1 hr 1
02, CO2 EPA Method 3A 3 1 hr I No of sampling points is per M7E
NOx EPA Method 320 3 1 hr 1 stratification test
VOC EPA Method 320 3 1 hr I
Moisture EPA Method 320 3 1 hr I For moisture calculations,correction
to dry standard
Methane, EPA Method 320 3 1 hr 1 Correction of THC to report NMHC
Ethane
Metals EPA Method 29 3 1 hr I Internal Engineering Data for
Piedmont
THC=total hydrocarbon
NMHC=non-methane hydrocarbon
Testing is to be conducted at full load+ 10%. Proposed testing rate was 4,735 HP.
7. STACK TEST OBSERVATIONS:
On Tuesday August 6, 2016, I, Greg Reeves of the Fayetteville Regional Office, arrived at the Piedmont
Natural Gas—Wadesboro Compressor Station site at approximately 12:00 Noon to observe stack testing of the
#1 compressor engine (ID No. COMPOI). Testing for the emergency generator engine (ID No. EG01) was to
be conducted on Wednesday August 7. 1 met with Mr. Randy Wooten. Mostardi Platt of Elmhurst, IL was
performing the source test for Piedmont. The technician for Mostardi Platt was Mot.Ben Hendricks.
When I arrived at the facility the 11t test run for metals had already been completed(start 9:00 AM, completed
10:05 AM), and the 2"d test run was just finishing(start 11:00 AM,completed 12:05 PM). The 3`d metals run
started at 1:05 PM and completed at 2:10 PM.The first NSPS JJJJ compliance test run for the#1 engine

Piedmont Natural Gas—Wadesboro Compressor Station
Stack Test Observation Report
Page 4 of 4
commenced at approximately 3:27 PM. The facility process controls indicated that the engine load was varying
slightly between approximately 94 and 96%of full load. The I"test run was completed at approximately
4:27 PM. No problems were noted during this test run. The engine run time hours at the start of the test were
approximately 10,273 hours.
I noted the following process parameters and instrument readings during this first run:
„1}aram t R4 w'9M4!411041 VWtq F,
Engine Load 94% 96%
CO(ppm) 3 2.9
NOx(ppm) 67 65
CO2(%) 5.72 5.3
02(%) 11.1 11.1
Moisture(%) 11.5 11.3
Formaldehyde(ppm) 3.9 3.7
Methane(ppm) 1,460 1,460
Ethane(ppm) 39 39
VOC(ppm) ** 4 3
**Note the VOC(NMHC)emissions are corrected for methane/ethane
I left the facility at approximately 4:45 PM. The facility was to conduct two more 1-hour test runs on the
compressor engine this day.
I received an email from Randy Wooten on Wednesday August 7 stating that the two additional test runs on the
41 compressor engine were completed successfully on Tuesday August 6.
8. COMPLIANCE STATEMENT:
It appeared that the stack testing for#I compressor engine((ID No.COMP01)was conducted in accordance
with the requirements of the EPA methods specified. Final results will be submitted by the company,and are
due within 60 days after completion of the test,per the NSPS JJJJ requirements.
gwr
cc: FRO Facility Files