AQ_F_0400056_20190529_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Piedmont Natural Gas-Wadesboro Compressor
Station
Inspection Report NC Facility ID 0400056
Date: 06/03/2019 County/FIPS:Anson/007
Facility Data Permit Data
Piedmont Natural Gas -Wadesboro Compressor Station Permit 10097/TO
259 Pleasant Grove Church Road Issued 9/15/2014
Wadesboro,NC 28170 Expires 8/31/2019
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)TV-Renewal
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
MACT Part 63: Subpart ZZZZ
Christopher Friel Adam Long Cynthia Winston NSPS: Subpart JJJJ
Lead EHS Professional Director, Gas Pipeline Manager, Permitting and
[phone] Operations Compliance
[phone] [phone]
Compliance Data
Comments: o
Inspection Date 05/29/2019
Inspector's Name Abdul Kadir
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
/ Action Code FCE
Date of Signature: O61O V/6 On-Site Inspection Result Compliance
Total Actual emissions{{{in TONS/YEAR:
TSP SO2 NOX VOC CO PM10 * HAP
2017 1.11 0.0800 12.92 5.09 0.9400 1.11 1860.30
2016 1.60 0.0800 18.51 7.24 1.31 1.60 2667.43
2015 1.43 0.0800 15.22 6.30 1.20 1.43 15288.34
* Highest HAP Emitted(in pounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
05/08/2019 Pending

1. 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 SUNC 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.
2. 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.
3. 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.
4. FACILITY INSPECTION SUMMARY:
On 29 May 2019 I,Abdul Kadir and Greg Reeves,both with DAQ FRO visited the Piedmont Natural Gas—
Wadesboro Compressor Station plant site in Wadesboro. We met with Richard Wentland and Delmar Keith,
both are Compressor Technician. We explained that we were at the site to conduct an air quality permit
compliance inspection. We showed Mr. Wentland the FacFinder and he indicated some changes and the update
were made in IBEAM.
Records for operating hours and operating loads on the engines is kept on the computerized control system.
The operator was able to show us the records of operating hours for each of the permitted engines. Operating
hours for each engine were as follows:
M 41
yl a.11'��
#1 Compressor 7,496 9,894
(COMP01
#2 Compressor 7,480 9,891
(COMP02)
#3 Compressor 7,496 9,812
(COMP03)
#4 Compressor 7,489 9,812
(COMP04)
Emergency Generator 142 165
(EGO1)

5. PERMITTED EQUIPMENT:
Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
COMPOI One four-stroke lean burn natural gas- COMPOI C Catalytic oxidizer(24.0 cubic
NSPS fired reciprocating internal feet of oxidation catalyst)
MACT combustion engine(4,735 horsepower
rating)powering a compressor
NOT OPERATING
COMP02 One four-stroke lean burn natural gas- COMP02C Catalytic oxidizer(24.0 cubic
NSPS fired reciprocating internal feet of oxidation catalyst)
MACT combustion engine(4,735 horsepower
rating)powering a compressor
NOT OPERATING
COMP03 One four-stroke lean burn natural gas- COMP03C Catalytic oxidizer(24.0 cubic
NSPS fired reciprocating internal feet of oxidation catalyst)
MACT combustion engine(4,735 horsepower
rating)powering a compressor
OPERATING, VE 0%Opacity
COMP04 One four-stroke lean burn natural gas- COMP04C Catalytic oxidizer(24.0 cubic
NSPS fired reciprocating internal feet of oxidation catalyst)
MACT combustion engine(4,735 horsepower
rating)powering a compressor
NOT OPERATING
COMP05 One four-stroke lean burn natural gas- COMP05C Catalytic oxidizer(24.0 cubic
NSPS fired reciprocating internal feet of oxidation catalyst)
MACT combustion engine(4,735 horsepower
rating)powering a compressor
NOT YET INSTALLED
COMP06 One four-stroke lean burn natural gas- COMP06C Catalytic oxidizer(24.0 cubic
NSPS fired reciprocating internal feet of oxidation catalyst)
MACT combustion engine(4,735 horsepower
rating)powering a compressor
NOT YET INSTALLED
COMP07 One four-stroke lean burn natural gas- COMP07C Catalytic oxidizer(24.0 cubic
NSPS fired reciprocating internal feet of oxidation catalyst)
MACT combustion engine(4,735 horsepower
rating)powering a compressor
NOT YET INSTALLED
COMP08 One four-stroke lean burn natural gas- COMP08C Catalytic oxidizer(24.0 cubic
NSPS fired reciprocating internal feet of oxidation catalyst)
MACT combustion engine(4,735 horsepower
rating)powering a compressor
NOT YET INSTALLED
EGO 1 One four-stroke lean burn natural gas-
MACT fired emergency generator(770 hp N/A N/A
maximum rating)
NOT OPERATING

6. 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 emission
factor of 0.001 lb/mmBtu. As long as the engines only combust natural gas,they should not exceed the
limitation. Only the#3 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 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. We observed no visible emissions from the#3
Compressor engine 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 May 1 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 11/05/18.
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 2.3 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 Ib/mmBtu. As long as this engine only
combusts natural gas,it should easily meet this limitation.The engine was not operating during the
inspection.

ii. 15A 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 engine was
not operating during the inspection.
C. Compressor Engines(COMPOI through COMP04)and Emergency Generator Engine(EGO I)
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.
APPEARSIN COMPLIANCE—Stack testing was performed on the emergency generator engine on
05/21/13, 05/12/16 and on 05/08/19. Results of the first two tests demonstrated compliance with the
emission limits and results of the last stack test has yet to be submitted by the facility. Stack tests for
the four compressor engines were conducted on 11/25-11/27/14,and again on 08/17-08/18/16. The
stack testing results indicated compliance with the emission limits(see the table below for stack testing
results for the engines). 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 03/04/13.
Engine Hours of Operation:
4;i h`�y i i s d st yy i 1 at��fi
Ny' �St 9 91 NMI � JLi
COMPOI 08/17/16 4,047 7,496 9,894
COMP02 08/17/16 4,198 7,480 9,891
COMP03 68/18/16 4,132 7,496 9,812
COMP04 08/18/16 4,193 7,489 9,812
EGO 65/08/19 NA 142 165
Stack testing of the compressor engines will be required in August 2019.

Stack Testing Results:
W y
nil e#1 fin!§ la its
,a 5/ Q / 6,
s, s� 6.
��. �_. �" 8•. ��
NOx 1.0 g/hp-hr 0.33 0.28
82 ppm 22 20.4
CO 2.0 hp-hr 0.02 0.03
270 ppm 1.8 3.4
VOC 0.7 hp-hr 0 0.09
60 ppm 0 1 6.2
T30
IN
i NOx 1.0 g/h -hr 0.42
82 ppm 30.9
CO 2.0 h -hr 0.02
270 m 2.6
VOC 0.7 g/hp-hr 0.49 0.25
60 p m 34.2 18
Itis
NOx 1.0 g/hp-hr 0.39 0.44
82 ppm 22 33.4
CO 2.0 g/hp-hr 0.03 0.03
270 ppm 2.5 3.3
VOC 0.7 g1 -hr 0.10 0.26
60 ppm 5.0 18.8
�iWl
k
MA
IsMM
NOx 1.0 h -hr 0.43 0.44
82 ppm 24 29.8
CO 2.0 h -hr 0.03 0.03
270 m 2.4 3.0
VOC 0.7 h -hr 0 0.02
60 ppm 0 1.0

9
i b ^ °
NOx 2.0 g/hp-hr 1.5 1.0
160 ppm 99 58
CO 4.0 g/hp-hr 1.6 1.8
540 pm 168 174
VOC 1.0 g/hp-hr 0.14 0.1
86 ppm 26 15
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
indicated compliance with the emission limits.
iv. PERMIT GENERAL CONDITION 3.I.A—EXCESS EMISSIONS REPORTING
REQUIREMENTS 115A NCAC 2D.0535 and 2Q .0508(f)(2)1—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. Wentland 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 02/11/19 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.
APPEARS IN COMPLIANCE—The last annual emission inventory for the facility was received at
FRO on 06/07/18 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).

7. COMPLIANCE HISTORY:
There have been no negative compliance instances since the permit was initially issued in 2011.
8. FACILITY PINK SHEET REVIEW:
There were no pink sheet items to be included in the facility inspection.
9. CONCLUSIONS/RECOMMENDATIONS:
The facility appeared to be IN COMPLIANCE during the inspection on 05/29/2019.