FINAL_Signed_HOR_wo Attachments-Northampton_Compressor_Station

Hearing Officer’s Report and Recommendations

Northampton Compressor Station Public Hearing
November 15, 2017
Garysburg Town Hall
Garysburg, NC

Public Comment Period: October 10, 2017 to November 20, 2017

Pertaining to Permit Application No. 6600169.15A and
Draft Air Permit No. 10466R00 for:

Northampton Compressor Station
718 Forest Road,
Pleasant Hill, NC, Northampton County
Facility ID No. 6600169
Fee Class: Small

Hearing Officer
Heather Sands, P. E.
Permit Engineer
Division of Air Quality, Central Office

January 31, 2018

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Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 1 of 29
I. Background
On September 17, 2015, the North Carolina Department of Environmental Quality (DEQ), Division of Air
Quality (DAQ), Raleigh Regional Office (RRO) received an air quality permit application (App. No.
6600169.15A) from Atlantic Coast Pipeline LLC (ACP) to construct and operate the Northampton
Compressor Station, a natural gas compressor station at 718 Forest Road, Pleasant Hill, NC, Northampton
County. According to their permit application, ACP is planning to construct a natural gas compressor station
consisting of natural gas-fired compressor turbines, emergency generators, storage tanks, and associated
equipment. The Northampton Compressor Station will provide compression to support a pipeline capacity of
1.5 billion cubic feet of natural gas per day as a part of the Atlantic Coast Pipeline Project. The proposed
compressor station will be subject to three federal New Source Performance Standard (NSPS) emission
standards, issued under 40 CFR Part 60, Subparts JJJJ, KKKK and OOOOa and one federal National
Emissions Standards for Hazardous Air Pollutants (NESHAP), issued under 40 CFR Part 63, Subpart ZZZZ.

II. Air Quality Permit Application and Permit Review
The DAQ’s mission is “to protect and improve the outdoor air quality of North Carolina.” To accomplish this
mission, the DAQ requires industrial facilities to apply for and receive air quality permits, prior to construction
and operation of the air pollution sources, to ensure compliance with all applicable federal and State air quality
regulations. As such, ACP is required to apply for and receive an air quality permit prior to installing a new
natural gas compressor station at 718 Forest Road, in Pleasant Hill, NC, Northampton County. On October 26,
2015, the application requesting an air quality permit for the Northampton Compressor Station site was deemed
administratively complete by DAQ. The application was deemed administratively complete and contained the
required fees and signatures of the responsible official, a Professional Engineer’s seal, and proof of submission
to the Northampton County Manager for a zoning consistency determination.

Charles McEachern, P.E., permit coordinator in DAQ’s RRO, reviewed the application submitted by ACP
and determined that the facility could comply with all applicable federal and State air quality requirements
provided that the specific conditions included in the draft air quality permit are met.

Unless the public comments received during the public hearing revealed that the DAQ was in error in its
evaluation of the proposed compressor station from an air quality standpoint, the Division is obligated to
issue an air quality permit for the Northampton Compressor Station since all indications are that the proposed
compressor station can comply with federal and State air quality.

III. Notice of Public Hearing
After receiving requests for a public hearing, Michael A. Abraczinskas, Director of DAQ, announced that a
public hearing would be held in Garysburg, NC. On October 10, 2017, a notice of public hearing was posted
on the DEQ website and in five newspapers: The Daily Record in Roanoke Rapids (Halifax County); Lake
Gaston Gazette-Observer in Littleton (Halifax County); Roanoke-Chowan News-Herald in Ahoskie (Bertie
County); Rocky Mount Telegram in Rocky Mount (Edgecombe County); and News & Observer in Raleigh
(Wake County). A Facebook “boost advertisement” was also placed to bring increased visibility to a posting
about the public hearing.1 The public hearing was held on November 15, 2017, at the Garysburg Town Hall
in Garysburg, NC, and the public comment period was open from October 10 through November 20, 2017.
Copies of the draft air quality permit and air permit review were also posted on the DEQ website for public
review. Copies of the air quality permit application and related documents were available for public review
in the DAQ’s RRO.

IV. Overview of Public Comments Received
From the numerous comments received during the public comment period, it is apparent that there is
considerable concern about the potential impacts on health and property around the location of the proposed
Northampton Compressor Station. At the public hearing on November 15, 2017, twenty-nine (29)

1 According to Facebook analytics, the ad reached 4,918 people and generated 460 clicks for additional information.
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 2 of 29
individuals spoke and a majority was in opposition to the proposed compressor station (11 speakers
supported the compressor station, 18 were opposed). Additionally, 3,731 written comments were received
during the public comment period. There were 2,934 comments opposing the compressor station and/or
pipeline. A total of 797 individuals commented that they supported the DAQ issuing the Northampton
Compressor Station an air quality permit or that they support the Atlantic Coast Pipeline, in general. An
additional 1,036 comments were received after the November 20, 2017, close of the comment period.2 Of
these, 982 were in support of the compressor station and/or pipeline. There were 33 comments opposing the
compressor station and 21 comments opposing the pipeline, in general. The late comments were reviewed
and it was determined that they would not have an impact on the recommendations in this report. Therefore,
those comments received on or after November 21, 2017, will not be further discussed in this report.

All comments received during the public comment period, both oral and written, have been evaluated by the
Hearing Officer and copies of all written comments are provided in the appendices of this report. Because of
the number of comments received, it is neither practical nor efficient to separately address every individual
comment in the Hearing Officer’s report. Instead, the comments are grouped below into broader subject
categories to more efficiently and effectively address a variety of comments that will ultimately result in the
same response. The following is a summary of common or relevant comments paraphrased to get the main
points across without repeating the comment verbatim. (NOTE: Commenters are identified by last name.
Those marked with a “*” are commenters that spoke at the November 15, 2017, public hearing. These
commenters may or may not have also submitted written comments.)

A. Comments Regarding Environmental Justice

1. Environmental Justice Review

Comment: Several commenters (*Exum, *Taylor, *Grant, *Neal, *Bearden, *Winstead, *Burnette,
*Faircloth, Geffner, Wood, Ambrose, Nyland (Lars), Nyland (Lauren), Manigrasso, Scott, Rodgers,
Emanuel (Andrea), Wilson, Jenkins, Adams, *Vick, Girolami, Norris, Ellis, Wooten, Runkle, Richmond,
Garbutt, Karasik, Weir, Reynolds, Osterbrink, Henderson/WeatherCenter, Form Letter No. 13
Comments, Form Letter No. 2 4 Comments) expressed concerns that an Environmental Justice (EJ)
review had not been conducted for the location of the ACP in general and, specifically, the Northampton
Compressor Station. In support of their comments, the following points were made:
• The planned location for the pipeline, using eminent domain, will run through the mostly rural, low
income, economically depressed communities and will disproportionately affect minorities. The
community does not have the ability to resist the pipeline and their political power is weak compared
to urban areas.
• The census block where the compressor station is planned is 79 percent African American and 32
percent of the population is at or below the federal poverty line. These demographics exceed the
State average.
• DEQ is required by their Environmental Equity Policy and Title VI, the Civil Rights Act, to consider
the environmental harm of the pipeline to minorities before approving a compressor station. While it
was appreciated that a public hearing was held in Garysburg, more is required to comply with DAQ’s
obligations under the Environmental Equity Policy and federal law. According to the Environmental
Equity Policy, DAQ should also determine whether there are “special health risks based on the nature
of the population” and “assess the cumulative effects of permitted facilities.”
• A study called “Fumes Across the Fenceline” by the Clean Air Task Force and the NAACP discusses
the environmental inequalities related to minorities and includes a case study of the ACP. According
to the report, the overall cancer rate for Northampton County exceeds the State rate.

2 The late comments continue to be received in the email inbox, but for the purposes of this hearing report, this total number of late
comments represents those comments received as of December 11, 2017.
3 See Attachment C.4 for the text of Form Letter No. 1.
4 See Attachment C.4 for the text of Form Letter No. 2.
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 3 of 29
• A health assessment by the Northampton County Health Department shows that the community is
unusually susceptible to additional health risks from pollution. The commenter stated that the report
shows high rates of asthma and high blood pressure and that the leading causes of death are cancer,
heart disease, and respiratory disease. The commenter further stated that these types of health issues
would be made worse from the pollution caused by the compressor station.
• A door to door survey was conducted in the community and many citizens had not received
information about the pipeline.
• The compressor station facilitates the development of the ACP and magnifies the pipeline’s
significant impacts on communities of color along the route.
• A rigorous EJ review was requested before granting the permit.

Hearing Officer’s Response to These Comments
Many of the comments (e.g., comments related to the route of the pipeline or the site of the compressor
station) were not related to the draft air quality permit for the Northampton Compressor Station. These
comments are outside the purview of this hearing report and will not be further addressed. However, the
Hearing Officer has reviewed the draft air quality permit application and permit review to assess the
Environmental Justice issues raised by the commenters with respect to the draft air quality permit. The
Northampton Compressor Station is expected to be in compliance with the State and federal air regulations
as required by the draft permit. The combustion turbines are subject to NSPS Subpart KKKK. Subpart
KKKK has limits on nitrogen oxides (NOX), 25 parts per million by volume (ppmv) at 15 percent oxygen,
and sulfur dioxide (SO2), 0.90 pounds per megawatt hour (lb/MWh), gross output or burn fuel which
contains total potential sulfur emissions of 0.060 pounds SO2 per million British thermal units (lb/MMBtu),
heat input. Subpart KKKK does not have limits for particulate matter (PM), volatile organic compounds
(VOC) and carbon monoxide (CO).

Due to the inherently low sulfur content of natural gas, no additional control was necessary for the SO2 limits
in Subpart KKKK. According to the air permit application, the combustion turbines will be equipped with
SoLoNOx dry low NOX combustor technology as well as add-on emission controls, including selective
catalytic reduction (SCR) for NOX and an oxidation catalyst for CO and VOC. With the low NOX combustor
technology and the proposed SCR, the outlet concentration of NOX is expected to be no more than 5 ppmv at
15 percent oxygen. This level of control is well below the NSPS limit of 25 ppmv at 15 percent oxygen.

As stated above, the NSPS does not require the control of VOC and CO. ACP is voluntarily equipping the
turbines with add-on controls to reduce VOC and CO emissions. Per vendor estimates, as documented in the
application, the oxidation catalyst will reduce CO emissions to less than 5 ppmvd CO at 15 percent oxygen
and will reduce VOC emissions (including formaldehyde) by 50 percent. These additional voluntary controls
far exceed the federal requirements for gas turbines.

Furthermore, even though a public hearing and public comment period are not required for an air quality
permit issued under 15A NCAC 02Q .0300, DAQ has engaged the public in the Northampton County
community by holding the public hearing on November 15, 2017, and soliciting comments on the draft
permit. The DAQ worked with Northampton County to post fliers, make documents available at a public
location, and provide a centrally located hearing space. Furthermore, the Department held several listening
sessions during August in Nash, Northampton, and Robeson Counties. This outreach far exceeds the average
public process for a draft air quality permit for a facility of this size. Therefore, potentially affected groups
have had informed opportunities to participate in the process, consistent with the applicable case-specific
aspects of DAQ’s Environmental Equity Policy and relevant air permitting statutes and rules.

As part of the evaluation of the emissions profile of this facility, DAQ conducted a cumulative review of air
quality surrounding the Northampton Compressor Station site. This analysis included a review of current
ambient air quality data, air emissions by source category, wind data, satellite-derived air pollution data,
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 4 of 29
demographic and socioeconomic data, and health study information. DAQ will compile the information
reviewed in a separate document that will be part of the record.

Additionally, in response to the comment in Section IV.I.3, below, the Hearing Officer has recommended
that toxics modeling is likely to have been triggered for this facility and has requested that, if necessary, a
modeling analysis be conducted to determine compliance with the Acceptable Ambient Levels (AALs) in
15A NCAC 02D .1104. It is expected, given the level of emissions projected to be emitted from this
compressor station, that the analysis will demonstrate compliance with the AALs and will indicate that
human health will be protected through the inhalation pathway. Therefore, pending the outcome of the
modeling analysis, the Hearing Officer has determined that this permit action has met the requirements of the
DEQ’s Environmental Equity policies with respect to the DAQ permitting process and no further action is
recommended in terms of evaluating the current draft air quality permit with DEQ’s Environmental Equity
policies.

2. Environmental Justice Related to Tribal Governments

Comment: Two commenters (*Neal, Hardy) had concerns that DAQ had not conducted an EJ review
with respect to Tribal governments. In support of their comments, the following points were made:
• The Northampton Compressor Station would be built on ancestral lands of the Haliwa-Saponi Indian
Tribe and about 13 miles from the closest section of the Haliwa-Saponi State Designated Tribal
Statistical Area. The environmental justice review should consider the effects the compressor station
would have on human health of Tribal members.
• It would be inappropriate for DAQ to issue a final permit without engaging in a meaningful
government-to-government consultation with the Haliwa-Saponi Indian Tribe.

Hearing Officer’s Response to These Comments
On August 9, 2017, the DEQ met with the tribal governments across North Carolina, including those
impacted by the compressor station and the pipeline in general which included the Haliwa-Saponi Tribe.
Tribal Governments and the Indian Affairs Commission, especially the Haliwa-Saponi, have been included
in Departmental communications regarding the ACP via email. DEQ has made many efforts to engage Tribal
leaders and, as discussed in Section IV.A.1, above, this outreach far exceeds the average public process for
an air quality permit for a facility of this size. Therefore, Tribes have had informed opportunities to
participate in the process, consistent with the applicable case-specific aspects of the DEQ’s Environmental
Equity Policy and relevant air permitting statutes and rules. As a result, the Hearing Officer has determined
that this permit action has met the requirements of the DEQ Environmental Equity Policy with respect to the
DAQ permitting process and no further action is recommended in terms of evaluating the current draft air
quality permit with DEQ Environmental Equity Policies.

B. Comments Concerning Dust and Odor Controls

Comment: Some commenters (*Taylor, *Pair, Ambrose, *Neal, Ellis, Sheline) expressed concerns with the
levels of dust and odor controls specified in the draft permit. In support of their comments, the following
points were made:
• There should be specific plans for dust and odor control instead of complaint driven requirements.
The requirement for the facility to avoid causing “substantive complaints” or excessive odors or dust
beyond the facility boundary is unenforceable. “Substantive complaints” is not defined in the draft
permit.
• The draft permit says that the facility “may” be required to submit a dust control plan. This should be
a requirement.
• There is no monitoring required.
• The draft permit contains a requirement for control of odor, prohibiting the company from operating
the facility “without implementing management practices or installing and operating odor control
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equipment sufficient to prevent odorous emissions from the facility from causing or contributing to
objectionable odors beyond the facility’s boundary.” Nothing in the draft permit specifies how the
facility will comply with this requirement.
• The draft permit should be withdrawn and the Applicant should be required to demonstrate its
management practices or control equipment that will prevent odorous emissions from the facility.

Hearing Officer’s Response to These Comments
The commenters’ claims that the odor and dust control requirement in the draft air quality permit are
unenforceable are incorrect. Both of the permit conditions for odor and fugitive dust are standard conditions
contained in most of the permits issued by the Division. In each case, the draft permit language notes the
applicable standards with which compliance is required. The regulations go further to give the details on
how the Division is required to operate and document complaints. In the case of odor, 15A NCAC 02D
.1806(g) describes how a determination of whether a source or facility is causing or contributing to an
objectionable odor is conducted and includes health problems associated with odors:
(g) Determination of the existence of an objectionable odor. A source or facility is causing or
contributing to an objectionable odor when:
(1) A member of the Division staff determines by field investigation that an objectionable odor is
present by taking into account nature, intensity, pervasiveness, duration, and source of the odor
and other pertinent factors;
(2) The source or facility emits known odor causing compounds such as ammonia, total
volatile organics, hydrogen sulfide, or other sulfur compounds at levels that cause
objectionable odors beyond the property line of that source or facility; or
(3) The Division receives epidemiological studies associating health problems with odors
from the source or facility or evidence of documented health problems associated with odors
from the source or facility provided by the State Health Director.
A facility that has been determined to be emitting an objectionable odor by the procedures described above
will be required to implement maximum feasible controls (these controls are defined in 15A NCAC 02D
.1807).

The fugitive dust rule, 15A NCAC 02D .0540(a)(6) defines “substantive complaints” as “…complaints that
are verified with physical evidence.” Paragraph (d) of that same rule defines the requirements of the facility
once the Division has certified that a substantive complaint has been received:
(d) If fugitive dust emissions from a facility required to comply with this Rule cause or contribute to
substantive complaints, the owner or operator of the facility shall:
(1) within 30 days upon receipt of written notification from the Director of a second substantive
complaint in a 12-month period, submit to the Director a written report that includes the
identification of the probable source(s) of the fugitive dust emissions causing complaints and
what measures can be made to abate the fugitive emissions;
(2) within 60 days of the initial report submitted under Subparagraph (1) of this Paragraph,
submit to the Director a control plan as described in Paragraph (f) of this Rule; and
(3) within 30 days after the Director approves the plan, be in compliance with the plan.
The regulation specifies that the Director shall require a fugitive dust control plan if it is determined that
there is sufficient environmental benefit to justify a fugitive dust control plan per the information in 15A
NCAC 02D .0540(e). Based on the specifics provided in the underlying regulations, the Hearing Officer has
determined that the draft air quality permit is sufficient to require compliance for each of these regulations
and is not recommending any changes to the draft permit in response to these comments.

C. Comments Concerning the Emissions Estimates Provided in the Permit Application
Several commenters (Williams, Rodgers, Zeller, *Vick, *Neal, *Wagner) discussed the emissions estimates
provided in the permit application. The following provides summaries of these comments, grouped by topic.

Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 6 of 29
1. The Compressor Station was Improperly Designated as a Minor Source

Comment: The Northampton Compressor Station was improperly designated as a minor source. An
analysis was provided showing potential to emit being significantly greater than major source thresholds.
To determine the potential emissions from the turbines, the commenter used Environmental Protection
Agency (EPA) emission factors published in AP-42 for natural gas-fired turbines and the maximum heat
input at 100 percent load provided in the permit application. The compressor station should be deemed a
major source and DEQ should take steps to correct this error before issuing the permit. The following
additional information was provided in support of this comment:
• Compressor stations emit huge amounts of air pollution. An example of emissions from a single
compressor station investigated by BREDL was provided showing emissions much greater than those
estimated in the permit application.
• In support of the permit, emission estimates from the Northampton Compressor Station (21,700
horsepower (hp) compressors) were compared to a nearby, comparable facility (21,197 hp
compressors). The Northampton Compressor Station NOX emissions of 19.6 tons per year (tpy) were
shown to be significantly less than a station in Tennessee, which had NOX emissions of 62 tpy.
Likewise, the Northampton Compressor Station CO emissions of 33 tpy were significantly less than
the CO emissions of 68 tpy from the station in Tennessee. The decision to install add-on controls on
the Northampton Compressor Station turbines was commended.

Hearing Office Response to this Comment
As stated in the comment summary, the emissions estimates provided by the commenters appear to
indicate that emissions for the Northampton Compressor Station may be greater than major source
thresholds. However, the commenters used emission factors for natural gas-fired combustion turbines
from EPA’s AP-42. According to the permit application, ACP used manufacturer’s data to estimate
potential emissions from the turbines. DAQ typically considers AP-42 emission factors to be used when
no other data are available to estimate emissions and considers manufacturers data to be more accurate.
Furthermore, according to the permit application, at low load and cold temperature extremes, the turbine
system must be controlled differently resulting in higher emissions of NOX, CO, and VOC during these
periods of time. Furthermore, ACP calculated potential emissions by conservatively calculating higher
emissions during periods of sub-zero and low load conditions.

Using emissions from another compressor station as a comparison to the Northampton Compressor
Station does not necessarily demonstrate that the emissions have been underestimated (or overestimated).
ACP is required to conduct performance testing to demonstrate that they will be in compliance with the
air regulations and their permit (see Section IV.F.1, below, for more discussion on the testing
requirements). Based on the emission calculations provided in the permit application, the Hearing Officer
has determined that emissions were not underestimated as claimed by the commenters and recommends
that no further action by DAQ is necessary in response to these comments.

2. Fugitive Emissions from Tanks

Comment: DAQ did not consider the fugitive emissions from tanks, which underestimates the facility-
wide emissions.

Hearing Officer Response to This Comment
Fugitive emissions from storage tanks include evaporative losses from filling and transfer operations as
well as standing losses. ACP calculated emissions from the storage tank operation using accepted
methods of calculating emissions from storage tanks. EPA’s TANKS program was used to estimate
emissions from the waste oil tank. Evaporative losses from filling and transfer operations, or working
losses, occur when vapors are displaced due to the emptying and filling of storage vessels. Standing, also
known as breathing, losses are the release of gas associated with daily temperature fluctuations and other
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 7 of 29
equilibrium effects. Emissions related to breathing losses occur when temperature variations in the tank’s
location cause vapors in the tank to expand. The expansion of the gas raises the vapor pressure inside the
tank, and that resulting pressure forces some of the built-up vapors out through the vent.

The American Petroleum Industry’s (API) program entitled E&P Tanks was used to calculate emissions
from the hydrocarbon liquids tank. E&P Tanks calculates emissions related to working and breathing
losses using the same methods as the EPA TANKS program. The E&P Tanks program also estimates
what is referred to as flash emissions. Flash emissions occur when a liquid with entrained gases is
transferred from a vessel with higher pressure to a vessel with lower pressure, thus allowing entrained
gases or a portion of the liquid to vaporize or flash. The hydrocarbon liquids tank accepts hydrocarbon
liquids from the separator and according to the permit application, the Northampton Compressor Station
separator pressure is 552 pounds per square inch gauge (psig).

Because the storage tank emissions were estimated using accepted methods for calculating evaporative
losses, or fugitive tank emissions, the Hearing Officer determined that fugitive emissions from the tanks
were included in the facility-wide total VOC emissions. Therefore, the Hearing Officer recommends that
no further action by DAQ is necessary in response to these comments.

3. Accuracy of Emissions Provided in the Permit Application

Comment: According to the revised permit application, total VOC emissions would be 21.2 tpy. In the
initial application, total VOC emissions were estimated to be 41.1 tpy. DEQ should require additional
verification of whether the previous number was more accurate.

Hearing Officer Response to This Comment
The Hearing Officer was not familiar with the differences between the two permit applications. The
permit review engineer, Charles McEachern, P.E., was contacted to request additional information. In his
email on December 8, 2017, Mr. McEachern provided the following information.

As pointed out by the [commenter], the facility-wide VOC emissions between the two
applications differ by about 20 tons per year. This is due to how the fugitive emissions from
compressors are estimated for the insignificant emission source titled, “Piping Leaks,” ID No. I-
Fug-02. In the first application, Table C-7 “Potential Emissions from Fugitive Leaks,” an
emission factor of 5.71 lb/hr/source is shown for the compressor emissions. Although this
emission factor is referenced to the “EPA Protocol for Equipment Leaks Emissions Estimates”
(EPA-453/R-95-017, Table 2-4, page 2-15), it doesn’t actually appear anywhere in this
document. The second application references the same EPA table but no longer separates
compressors (which are not listed separately in this table anyway), instead, they are shown in the
revised Table C-7 as being included under the “Others” emission factor of 8.80E-03
lb/hr/source. The EPA document has a footnote at the bottom of the table indicating this is the
correct emission factor for use with many pieces of equipment, including compressors. After
submission of the second application I noticed the EPA factors are in units of kg/hr/source, so
the applicant submitted a revised and corrected Table C-7 by e-mail on August 7, 2017.

To summarize, the first application shows I-Fug-02 VOC emission to be 20.0 tpy, the second
shows it to be 0.40, and the final revision for the units correction shows it to be 0.776 tpy. The
final version appears to be correct and the use of the emission factors appears correct.
Following is a link to the EPA document if you need it:
https://www3.epa.gov/ttnchie1/efdocs/equiplks.pdf

Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 8 of 29
Based on this information from the permit review engineer, the Hearing Officer has determined that the
VOC emissions in the revised permit application are the more accurate value and recommends no further
action by DAQ is necessary in response to this comment.

4. Emissions Profile
Comment: The DEQ fact sheet for the Northampton compressor station gave the following emissions
profile:
According to the commenter, this profile provides a very poor indication of the extent of the emissions
that will be released for several reasons: (1) the permitted pollutants are a very small subset of the toxic
releases that will be emitted annually; (2) the “Expected Actual Emissions” are actually the best-case
assumptions of what the compressor is likely to produce; and (3) the total tons per year – even if they are
correct – mask the exposure to extremely high emissions that pipeline compressor stations give off
during operation.

Hearing Office Response to this Comment
The commenter’s statement that the permitted pollutants are a small subset of the toxic releases that will
be emitted annually is incorrect. VOC, TSP, PM10, and PM2.5 each represent a broad category of
pollutants. For example, VOC has been defined by EPA to mean any compound of carbon, excluding
carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium
carbonate, which participates in atmospheric photochemical reactions (40 CFR 51.100).5 As discussed in
Section IV.F.1, below, ACP will be required to conduct performance tests for VOC emissions, which
will demonstrate compliance with permit. The performance tests will be conducted in accordance with
EPA test methods and the VOC emissions reported in the test results will represent the broad category of
pollutants as defined by EPA.

Furthermore, there appears to be confusion regarding the emissions in the table provided by the
commenter. According to the permit review published with the public notice,6 the following table
presenting emissions from the turbines is the correct version of the table referenced by the commenter:

Pollutant
Title V Emissions
(no add-on control,
8760 hr/yr) from
all 3 turbines,
combined (tpy)
Permit
Potential/Expected
Actual Emissions
from all 3 turbines,
combined (tpy)
TSP 18.1 18.1
PM-10 18.1 18.1
PM-2.5 18.1 18.1
SO2 3.08 3.08

5 Refer to 40 CFR 51.100(s) for a full definition of VOC, including those compounds EPA has defined as not being included as VOC.
6 https://files.nc.gov/ncdeq/Energy%20Mineral%20and%20Land%20Resources/DEMLR/Atlantic-Coast-
Pipeline/ACP%20Air%20Permit%20Draft%20Permit%20Review.pdf
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 9 of 29
Pollutant
Title V Emissions
(no add-on control,
8760 hr/yr) from
all 3 turbines,
combined (tpy)
Permit
Potential/Expected
Actual Emissions
from all 3 turbines,
combined (tpy)
NOx 47.3 18.0
VOC 2.90 1.65
CO 64.2 28.6

Because the Northampton compressor station is a new source, the potential emissions are considered
equal to the expected actual emissions for the purposes of determining major source status. As shown
in the table, the first of the two columns of emissions represents uncontrolled emissions from the
three turbines and the second column represents controlled turbine emissions, which are the
maximum emissions estimated for the facility. As discussed above, ACP calculated emissions for the
turbines (the largest source of emissions) using conservative assumptions. Therefore, the Hearing
Officer has determined that the emission estimates were a good estimate of emissions being released
by the turbines and recommends no further action by DAQ is necessary in response to this comment.

5. Draft Air Quality Permit Does Not Include Emissions of Several Compounds

Comment: Many studies of compressor station emissions have shown a very wide range of serious air
contaminants are released. For example, the independent lab results from air samples taken at Dish,
Texas on September 15th, 2009 found a wide range of toxins. Of those that were found exceeding
Texas’s Effect Screening Levels were:
benzene
dimethyl disulfide
methyl ethyl disulphide
ethyl-methylethyl disulfide
trimethyl benzene
diethyl benzene
methyl-methylethyl benzene
tetramethyl benzene
naphthalene
1,2,4-trimethyl benzene
m&p xylenes
carbonyl sulfide
carbon disulfide
methyl pyridine
dimethyl pyridine
The DEQ air quality permit does not mention or give expected tons per year for any of these.

Hearing Officer’s Response to this Comment
The permit application for the Northampton Compressor Station did include emissions of many of these
compounds (e.g., benzene, naphthalene, xylenes, etc.). These compounds are a subset of VOC emissions
which are being controlled using the oxidation catalyst. It should be noted that not all natural gas
composition is the same and will vary widely across regions. Additionally, the gas flowing through the
pipeline in North Carolina will have been processed many times and the emissions profile should be
much different than that of a Texas compressor station closer to the well. As such, the Hearing Officer
recommends that it is not necessary for DAQ to take action in response to this comment.

Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 10 of 29
6. The Draft Air Quality Permit Does Not Address Increases in Fugitive Emissions Over Time

Comment: Evidence from other compressor stations suggest that fugitive emissions will increase over
time as machinery begins to wear. DEQ only gave the annual expected tons per year for the compressor
station, and did not take into account aging equipment performance over time. This is especially
significant when Duke Energy’s aging equipment is poorly maintained and not replaced as needed.

Hearing Officer’s Response to These Comments
Experiences at Duke Energy and their maintenance practices are not a reliable indicator that similar
issues will occur at the Northampton Compressor Station. Regardless of individual experiences or
documented environmental compliance issues at other facilities, the Northampton Compressor Station is
its own entity. Furthermore, the compressor station is subject to NSPS Subpart OOOOa.7 Under Subpart
OOOOa, ACP is required to comply with the fugitive emissions standards for methane and VOC. As
such, the leak detection and repair (LDAR) standards under Subpart OOOOa should prevent increases in
fugitive emissions over time. Therefore, the Hearing Officer recommends that it is not necessary to
revise the permit in response to this comment.

D. Comments Regarding Greenhouse Gas Emissions
Several commenters (Emanuel (Andrea), Emanuel (Ryan), Wilson, Jenkins, Girolami, *Neal, *Taylor,
Bissette, Ellis, Richmond, Stephenson, Ewing, Weir, Tatta, Sasser, Osterbrink, Form Letter No. 5 8
Comments) were concerned about the level of greenhouse gases (GHGs) being emitted by the compressor
station. The following sections provide summaries of these comments, grouped by topic.

1. The Compressor Station was Incorrectly Designated as a Minor Source of Greenhouse Gas Emissions

Comment: The amount of GHGs being created by the compressor station should require major source
permit requirements.
• The compressor station would be a major new source of GHG pollution, with nearly 130,000 tpy of
carbon dioxide equivalent (CO2e), which is significantly over the 100,000 tpy threshold for major
source review.
• It is not clear from the draft permit whether DAQ considered additional methane emissions from
leaks and blowdowns, which can be more frequent and less predictable than indicated in the
application. The draft permit should be withdrawn and those additional methane emissions
considered in the total CO2e calculations.

Hearing Officer’s Response to this Comment
Table C-9 of the permit application provides a summary of Project Potential Emissions. Included in the
table are CO2e and methane emissions from blowdowns. As described in the text of the permit
application, although ACP intends to minimize blowdown events, they occur sometimes for safety
reasons and to ensure protection of the equipment. ACP also stated that although blowdowns typically
occur once every five years, the emissions provided in the permit application were conservatively
estimated to include one site-wide blowdown event per year. DAQ does not have any information to
indicate that full-station blowdown events would occur more often than estimated by ACP.

The Prevention of Significant Deterioration (PSD) regulations apply to new major stationary sources or
existing major stationary sources that propose a major modification. A source is considered major if total
facility emissions of any regulated pollutant (i.e., PM/PM10/PM2.5, NOX, SO2, VOC, CO) is greater than

7 It should be noted that On June 12, 2017, EPA proposed a stay of the fugitive emissions requirements under Subpart OOOOa [82 FR
27645]. On July 3, 2017, the U.S. Court of Appeals for the D.C. Circuit vacated EPA’s stay. EPA is considering its options in light of the
Court’s opinion. On November 1, 2017, EPA issued a notice of data availability related to the June stay. No resolution has been met and as
of the writing of this hearing report, the Subpart OOOOa requirements for fugitive emissions from compressor stations apply.
8 See Attachment C.6 for text of Form Letter No. 5.
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 11 of 29
250 tpy, unless the source is one of 28 listed sources for which the major source threshold is 100 tpy. On
June 23, 2014, the United States Supreme Court issued a decision addressing the application of stationary
source permitting requirements to GHG emissions. In its decision, the Supreme Court ruled that the EPA
may not consider GHGs as an air pollutant for the purposes of determining whether a source is a major
source required to obtain a PSD permit. Subsequent to this decision, DAQ revised its applicability rules
effective September 1, 2015, and 15A NCAC 02D .0544 specifically excludes facilities from the
requirement to obtain a PSD permit based solely on its GHG potential. As shown in the response to
comments in Section IV.C.4, the facility-wide emissions of PM/PM10/PM2.5, NOX, SO2, VOC, and CO
are well below the 250 tpy major source threshold for PSD.

The Hearing Officer has determined that the GHG emissions from the Northampton Compressor Station
included blowdown events, and in light of the Court’s decision regarding PSD applicability
determination with respect to GHG emissions, the compressor station was correctly designated as a
minor source for PSD. The Hearing Officer recommends no further action by DAQ is necessary in
response to this comment.

2. Concern with the Amount of Greenhouse Gas Emissions from the Compressor Station

Comment: In support of their comments, the following points were made:
• The Northampton Compressor Station will expose taxpayers in impacted communities to costly
restoration that will follow future catastrophic climate events due to increased GHG emissions and
pipeline leaks and explosions. DAQ should require the ACP to use a robust and continuous optical
monitoring system for leak detection of methane along the pipeline, metering and compressor
stations. Results should be reported to DEQ and the public.
• Methane emissions from compressor blowdown events and pipeline leaks and explosions will
increase the GHG emissions significantly.
• The draft air quality permit is out of alignment with the Governor’s plan to combat climate change.
• DEQ should weigh the full costs of expanding the pipeline on our climate. DAQ should limit and
require control of GHG emissions according to State constitutional provisions.
• The pipeline and compressor station will increase the concentration of methane in the atmosphere,
which is 86 times more potent a GHG than carbon dioxide. Governor Cooper’s Administration and
DEQ must enforce environmental regulations and laws to protect and preserve our environment.
Stopping methane release is the single most effective thing any nation and State can do to delay
temperature rise.
• DAQ should ask the applicant to address how GHG emissions fit into North Carolina’s membership
in the U.S. Climate Alliance.
• Increased methane use would make the transition to renewable energy slower and more difficult
because resources would be diverted to dealing with consequences of temperature rise from GHGs.

Hearing Officer’s Response to These Comments
Many of the comments (e.g., comments related to the leaks along the pipeline or the Governor’s plan to
combat climate change) were not related to the draft air quality permit for the Northampton Compressor
Station. These are outside the purview of this hearing report and will not be further addressed.
One of the commenters made a statement that the Governor’s Administration and N.C. DEQ must enforce
environmental regulations and laws to protect and preserve our environment. There are no specific GHG
regulations that apply to the Northampton Compressor Station. To this point, ACP has followed the proper
procedures for obtaining an air quality permit prior to constructing and operating the proposed compressor
station. DAQ has reviewed ACP’s application to ensure that compliance with State and federal air
regulations can be attained, and constructed a draft air quality permit that incorporates the applicable
regulations. As such, DAQ is enforcing applicable environmental regulations and laws.
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 12 of 29
The Northampton Compressor Station is also subject to two regulations that reduce GHG emissions. First, as
discussed above, the compressor station is subject to and will be required to comply with NSPS under
Subpart OOOOa. The fugitive emissions standards under Subpart OOOOa were developed to reduce
methane and VOC emissions from natural gas transmission compressor stations. Under this requirement,
ACP will be required to:
• Develop and implement a leak monitoring plan.
• Conduct a leaks survey using optical gas imaging to identify emissions of methane and VOCs
(NOTE: EPA Method 21 is an alternative to optical gas imaging. Method 21 is an EPA method for
determining VOC emissions from process equipment. The method is based on using a portable VOC
monitoring instrument, such as an organic vapor analyzer.)
• Conduct the initial survey within 60 days of the startup of the new compressor station.
• Repeat monitoring quarterly following the initial survey.
• Include the valves, connectors, pressure-relief devices, open-ended lines, flanges, compressors, and
thief hatches on controlled storage tanks, among others in the quarterly survey.
• Repair leaks found during the surveys.
Natural gas facilities with actual annual GHG emissions over 25,000 metric tons CO2e are required to report
GHG emissions from various processes within the facility under the Greenhouse Gas Reporting Rule under
40 CFR Part 98, Subpart W. In their permit application, ACP provided a compliance demonstration that
includes Subpart W reporting, which is incorporated into the permit by reference.9 Based on review of the
draft air quality permit and permit application and the applicable regulations, the Hearing Officer
recommends that no further action is necessary in response to these comments.
E. Draft Permit Language is Vague

Comment: Six commenters (Emanuel (Andrea), Wilson, Jenkins, Girolami, *Taylor, Ellis, Sheline)
described some of the language in the draft permit as being vague and permissive and they expressed their
concern that it would invite conditions for the surrounding community to be exposed to toxins without
holding ACP owners and operators accountable. In support of their comments, the following points were
made:
• As written, requirements are unclear due to the use of phrases such as “good pollution control
practice,” “to the extent practical,” “within the limits of practicality,” and “substantive complaints.”
These are not true parameters and would easily leave communities without recourse. The permit
provisions must be clear, quantitative, and enforceable through monitoring requirements, equipment
testing, and limits.
• DEQ should develop unequivocal language that is enforceable, rendering ACP’s developers
responsive to clear requirements such that they keep emissions below thresholds.

Hearing Officer’s Response to These Comments
Most of the phrases referred to by the commenters are directly quoted from federally approved NSPS and/or
maximum achievable control technology (MACT) standards. These regulations have been through federal
rulemaking processes and have been through notice and comment periods during which the rule language
referred to by the commenters was retained. The term “substantive complaints” is defined in the fugitive
dust regulation and has been defined (refer to Section IV.B, above, for additional information). Because

9 Although these compliance provisions are not specified in the draft air quality permit, the permit does contain the following statement
which requires ACP to comply with the proposed provisions:
The Permittee “is hereby authorized to construct and operate the air emissions sources and/or air cleaning devices and
appurtenances described below…in accordance with the completed application 6600169.15A received January 13,2016 including
any plans, specifications, previous applications, and other supporting data, all of which are filed with the Department of
Environmental Quality, Division of Air Quality (DAQ) and are incorporated as part of this permit.”
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 13 of 29
these phrases are directly quoted in the underlying regulations, the Hearing Officer recommends that no
changes to the draft air quality permit language are necessary based on these comments.

F. Comments Regarding the Stringency of Permit Requirements

Several commenters (Adams, Girolami, Wooten, *Clark, *Winstead, *Burnette, *Taylor, Ellis, *Neal,
Sheline, Garbutt, Emanuel (Ryan), Weir, Osterbrink) requested the draft permit be revised to include more
stringent requirements for emission limitations, control requirements, testing, and monitoring. The following
sections provide summaries of these comments, grouped by topic.

1. Emission Limitations, Monitoring and Testing Requirements

Comment: In support of their comments, the following points were made:
• DAQ should require ACP to perform continuous emission monitoring (CEM) at 60-foot high stacks
on each compressor.
• The draft permit’s requirements are weak for emission testing and controls. Emission testing for
methane, formaldehyde and other VOCs and particulates should be continuous and tightly restricted.
All emission and performance testing must be defined and not left to the operator’s discretion. Limits
must be defined and backed up with frequent testing.
• There are no monitoring requirements in the draft permit for VOCs or hazardous air pollutants
(HAPs). According to the permit application, the compressor station would emit 21.2 tpy of VOC,
and several different HAPs.
• The draft permit does not include formaldehyde limits.
• Formaldehyde is not okay to be emitted anywhere in NC.
• The final permit should hold ACP to the best standard.

Hearing Officer’s Response to These Comments
Subpart KKKK allows sources to choose to install CEM systems (CEMS) as an alternative to annual
performance testing. When not required by a regulation, CEMS would typically be expected to be
installed when the margin of compliance is small and a source would want to closely monitor its
emissions to ensure compliance with a standard. The turbines are subject to a 25-ppm NOX limit, and by
installing SCR in combination with the SoLoNOx installed on each turbine, the maximum potential NOX
emissions from the turbines are expected to be 5 ppmv (based on manufacturer’s specifications), which is
20 percent of the standard. Due to such a large margin of compliance, use of a CEMS is not warranted.
DAQ has determined that requiring CEMs was not necessary to ensure compliance with the standards to
which these units are subject.

Although there are no regulatory testing or monitoring requirements for PM10/PM2.5, VOC, and CO, ACP
has proposed ongoing compliance methods for PM10/PM2.5, VOC, and CO emissions from the turbines.
In their permit application (which is incorporated into the draft permit by reference 10), ACP states they
will conduct initial stack testing to determine PM10/PM2.5, VOC, and CO emission rates. Compliance
with the potential to emit will be demonstrated on a 12-month rolling total basis for all three pollutants,
as the following excerpt from the permit application shows:

Compressor Turbines (CT-01 through CT-03)
NOX: Annual stack testing (or semi-annual testing as allowed) will be completed to demonstrate
compliance with the NSPS Subpart KKKK emissions limits (NO2 emissions). Compliance with
the combustion turbines potential to emit will be demonstrated on a 12-month rolling total basis
by the sum of the following emissions:

10 See Footnote 9.
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 14 of 29
• Normal Operation: The average emission rate from the most recent stack test (pounds per
hour, lb/hr) times the number of hours operating in SoLoNOx mode (mode indication
provided and recorded by control logic on turbine).
• Low Temperature(< 0° F) Operation: The proposed controlled emission rates (lb/hr)
determined using the Solar provided emissions factor multiplied by the control efficiency of
the SCR times the number of hours when inlet combustion air for turbine was measured to
be below 0o F.
• Startup and Shutdown Emissions(< 50% load): The Solar-provided emission rates divided
by Solar-assumed duration for startups and shutdowns (1/6th of an hour each) times the
number of hours operating in non-SoLoNOx mode (mode indication provided and recorded
by control logic on the turbine).

CO, VOC, PM10/PM2.5: Initial stack testing will be completed to determine PM10/PM2.5 emission
rates (lb/MMBtu). Fuel firing will be tracked and used to calculate annual (rolling 12-month
total) ton per year emissions. Initial stack testing will be competed to determine VOC and CO
emission rates. Compliance with the combustion turbines potential to emit will be demonstrated
on a 12-month rolling total basis by the sum of the following emissions:

• Normal Operation: The average emission rate from the most recent stack test (lb/hour) times
the number of hours operating in SoLoNOx mode (mode indication provided and recorded by
control logic on turbine).
• Low Temperature (< 0o F) Operation: The proposed controlled emission rates (lb/hr)
determined using the Solar provided emissions factor multiplied by the control efficiency of
the oxidation catalyst times the number of hours when inlet combustion air for turbine was
measured to be below 0o F.
• Startup and Shutdown Emissions (< 50% load): The Solar-provided emission rates divided
by Solar-assumed duration for startups and shutdowns (1/6th of an hour each) times the
number of hours operating in non-SoLoNOx mode (mode indication provided and recorded
by control logic on the turbine).

Greenhouse Gases:
Total annual fuel volume will be tracked to determine total MMBtu of firing. This value times
the EPA Mandatory Reporting Rule natural gas emission factor (40 CFR Part 98 Subpart C)
times the Global Warming Potential (40 CFR Part 98 Subpart A) will be used to calculate ton per
year CO2e emissions.

Emergency Generator
Records of the monthly emergency and non-emergency use will be maintained to confirm
compliance with the annual limit for non-emergency operation. If a non-certified engine is
installed or if a certified engine is installed but operated as non-certified an initial stack test and
testing every 8760 operating hours or three years (whichever comes first) will be conducted.

Other Combustion Sources
If not otherwise specified above, the amount of fuel fired in units and/ or hours of operation will
be tracked and multiplied by the appropriate emission factor to calculate emissions on an annual
basis.

Additionally, the draft air quality permit requires inspection and maintenance on the oxidation catalyst.
The HAP emissions typically emitted from a compressor station are a subset of VOC, which will be
reduced by the oxidation catalyst.

Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 15 of 29
In response to the comment in Section IV.I.3, below, the Hearing Officer has determined that toxics
modeling is likely to have been triggered for this facility and has recommended that a modeling analysis
be conducted to determine compliance with the AALs in 15A NCAC 02D .1104 for all toxic air
pollutants (TAPs) that are emitted at a greater rate than the Toxic Air Pollutant Permitting Emission Rate
(TPER) in 15A NCAC 02Q .0711. The modeling analysis will determine the need for TAP limits in the
air quality permit.

The proposed testing requirements and the large margin of compliance with the NOX requirements under
Subpart KKKK indicate that ACP will be operating the sources at the Northampton Compressor Station
to a greater standard than required by regulation. Therefore, pending the outcome of the modeling
analysis with respect to TAP limits, the Hearing Officer recommends that no further action is required by
DAQ in response to these comments.

2. Emission Inventory

Comment: The facility is only required to submit the inventory 90 days prior to expiration of the 5-year
permit before renewal, which is five years after the facility would start operating. Emission inventories
should be required monthly instead of once every five years.

Hearing Officer’s Response to These Comments
According to the requirements in 15A NCAC 02Q .0308, facilities of the size of the Northampton
Compressor Station (i.e., non-Title V facilities) are required to apply for permit renewal every eight
years and to submit an emissions inventory.11 DAQ has determined that the eight-year permit term for
non-Title V facilities does not interfere with the State’s ability to attain air quality standards and reduces
regulatory burden.

Under Subpart KKKK, ACP will be required to submit “…a written report of the results of each
performance test before the close of business on the 60th day…” following the completion of the annual
NOX performance test. Furthermore, ACP will be required by the permit to keep records of emissions
and report any changes in the information submitted in the application regarding facility emissions,
changes that modify equipment or processes of permitted sources, or changes in quantity or quality of
materials processed. New and increased emissions that would cause a violation of the permitted
emissions limitations are specifically prohibited.

The requirements in the draft air quality permit were written in compliance with DAQ air regulations and
the Hearing Officer does not have information to indicate that a more frequent inventory would be
warranted for this facility. As such, the Hearing Officer recommends that no further action by DAQ is
necessary in response to this comment.

3. Testing for Emergency Engine

Comment: In support of their comment, the following points were made:
• There should be more air controls for compressor engines bigger than 500 horsepower; but the draft
permit only requires inspections every three years after the initial testing the first year.
• Initial testing is only required within the first year, then every three years thereafter. The facility will
put more hazardous air pollutants, precursors of ozone (nitrogen oxides and VOCs), particulate
matter, GHG emissions, and other pollutants into the air people breathe.
• NOX and SO2 emissions are regulated in terms of the amount of pollutants released per million Btu
input. That is the more heat used, the greater pollution allowed.

11The air quality permit renewal date in the draft permit was incorrect. Per 15A NCAC 02Q .0308(c), permit renewal for non-Title V facilities (and the
emission inventory) is due 8 years after the date the final air quality permit is issued.
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 16 of 29
Hearing Officer’s Response to These Comments
The engine referred to by the commenter is not a compressor engine, it is an emergency engine designed
to provide backup power when the primary source of power to the facility is unavailable. Furthermore,
the commenters’ statement that subsequent testing is only required every three years after the initial
performance test is incorrect. The engine is subject to Standards of Performance for Stationary Spark
Ignition Combustion Engines under 40 CFR Part 60, Subpart JJJJ (Subpart JJJJ). After the initial
performance test, Subpart JJJJ requires ACP to conduct periodic performance tests after 8,760 hours of
engine operation. However, due to the infrequent use of engines installed for emergency purposes (based
on EPA Guidance,12 the potential to emit from an emergency engine is calculated using 500 hours of
operation per year), Subpart JJJJ requires a test at least once every three years. Furthermore, the draft air
quality permit requirements (including the form of the emissions limitations) are in line with the Subpart
JJJJ requirement and due to the inherently low emissions from a natural gas-fired engine, the Hearing
Officer does not believe more stringent testing or a change in emission limits for this engine is
warranted. No further action by DAQ is necessary in response to this comment.

4. Excess Emissions and Equipment Leaks

Comment: In support of their comments, the following points were made:
• The requirement in the draft permit for notification of excess emissions occurring for more than four
hours is not good enough. Notification isn’t required until 9:00 the next business day and four hours
of leaking would allow a tremendous amount of pollution into the air. Notification should be
immediate and 100 percent reporting of leaks should be required.
• Compressor station emissions vary during normal operation. Emissions tons per year are common
and are the typical values used by DEQ; however, these do not capture the very high peak values that
are experienced during blowdowns, accidental or planned pressure releases, equipment failures,
valve leakage or other episodes that release sudden high levels of the toxins.
• The handout provided by DAQ at the hearing contained a summary of emissions in tons per year.
These values represent average values and that short-term spikes from blow-downs or accidents were
more damaging to health.
• Documented reports show that 60 percent of leaks and spills are reported by passersby. Automatic
systems only detect leaks if the pressure drops more than two percent. The commenter stated that
with billions of cubic feet of gas flowing through the pipeline, this is a lot of gas.
• A leak at the existing compressor station in Pleasant Hill was observed. The event was described: the
vapors were observed spreading across the street and a hissing sound could be heard indicating a
leak. According to the commenter, the complaint was filed by citizens, not identified by the
company.
• There is no enforcement for failure to give 15 days’ notice to regional offices to observe testing.

Hearing Officer’s Response to These Comments
The four-hour notification requirement for excess emissions is in accordance with 15A NCAC 02D
.0535. With respect to leaks, the Hearing Officer reviewed the Federal Energy Regulatory Commission
(FERC) Environmental Impact Statement (EIS), in which ACP has committed to the following with
respect to leak prevention:
Standard operations at compressor stations include such activities as the calibration,
maintenance, and inspection of equipment; the monitoring of pressure, temperature, and
vibration data; and traditional landscape maintenance such as mowing and the application of

12 Memorandum from Sietz, J., Director, Office of Air Quality Planning and Standards, to Director, Air, Pesticides and
Toxics
Management Division, Regions I and IV, et. al. Calculating Potential to Emit (PTE) for Emergency Generators. September
6, 1995. https://www.epa.gov/sites/production/files/2015-08/documents/emgen.pdf
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 17 of 29
fertilizer. Standard operations also include the periodic checking of safety and emergency
equipment and cathodic protection systems.

[ACP] would install a supervisory control and data acquisition system, commonly referred to as
Supervisory Control and Data Acquisition (SCADA), on each pipeline system, which would
continuously monitor gas pressure, temperature, and volume at specific locations along the
pipeline. These systems would be continuously monitored from gas control centers. The systems
would provide continuous information to the control center operators and have threshold and
alarm values set such that warnings are provided to the operators if critical parameters are
exceeded. In the event of a drop in pressure within a pipeline, the gas control center would be
immediately alerted and could stop the gas flow to the problem area by selectively isolating
sections of the pipeline via valves until inspections are completed to determine the cause of the
problem and complete repairs.

According to DAQ’s Compliance Monitoring Strategy,13 small facilities (such as the Northampton
Compressor Station) will be inspected at least every two years. Should ACP fail to comply with any air
quality regulations, DAQ should be able to identify the violations during the compliance inspections or
through complaint investigations at the site. Nothing prevents DAQ from conducting more frequent
inspections to better target facilities more likely to have emissions or compliance problems. If air quality
violations, including failure to notify DAQ of excess emissions or upcoming testing, are discovered,
DAQ has the enforcement authority to deal with those violations accordingly.

The Hearing Officer believes that the procedures ACP has committed to having in place are above and
beyond what is required by State and federal air regulations, and that DAQ’s own policies will protect
the public from noncompliance; therefore, the Hearing Officer has determined that no further action by
DAQ is recommended in response to these comments.

As discussed in Section IV.I.3, below, the Hearing Officer has recommended an air toxics assessment
and it is likely a modeling analysis will be conducted in accordance with 15A NCAC 02Q .0711 to
demonstrate compliance with 15A NCAC 02D .1104. The Hearing Officer recommends that this
modeling analysis be conducted such that the fugitive emissions occurring due to equipment leaks and
blowdowns accurately represent the short-term nature of these types of emissions.

5. Visible Emissions

Comment: Visual emissions in the draft permit are limited to an average of 20 percent opacity measured
over a 6-minute period, but the monitoring is extremely subjective and infrequent, allowing for excess
releases with no reporting.

Hearing Officer’s Response to These Comments
The visible emissions requirements under 15A NCAC 02D .0521 apply to fuel burning operations and
industrial processes where an emission can reasonably be expected to occur. Visible emissions from
natural gas-fired internal combustion sources, such as turbines and engines, are inherently low.
Therefore, continuous compliance with this regulation is expected for these types of sources. More
frequent monitoring of visible emissions from the turbines and engines would be excessively
burdensome with no added benefit in reducing emissions. Therefore, the Hearing Officer has determined
that the visible emissions requirement in the draft air quality permit is appropriate and recommends that
no further action by DAQ is necessary in response to this comment.

13 https://files.nc.gov/ncdeq/Air%20Quality/enf/cms/cmsimplementation.pdf
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 18 of 29
6. DAQ Should Require More Stringent Controls for the Compressor Station

Comment: According to the draft air quality permit, the SCR will have a control efficiency of 80 percent
for the Centaur 40 turbine, but would drop to 44 percent for the Centaur 50L and Taurus 70 turbines.
ACP purports to use “best in class” controls, but this should not be confused with best available control
technology (BACT). BACT refers to the best demonstrated control technology subject to economic and
technical constraints, and was not required by DAQ. Had BACT been required, it is likely that the SCR
for all three turbines would be approximately 80 percent and would improve local air quality. Requiring
BACT may also have led to the identification of more efficient oxidation catalysts to control CO and
formaldehyde. Although not required, DAQ should inquire about more stringent emissions controls for
the compressor station.

Hearing Officer’s Response to These Comments
The Hearing Officer reviewed the permit application for the bases of the control efficiencies referenced
by the commenter. ACP has voluntarily installed selective catalytic reduction (SCR) for additional NOX
control and an oxidation catalyst for additional CO and VOC (including formaldehyde) control. These
controls are not being installed to comply with an applicable regulation. According to the permit
application, the SCR will reduce NOX emissions to an outlet concentration of 5 ppmv at 15 percent
oxygen. The emission reductions referenced by the commenter were back-calculated using the
uncontrolled concentration and the outlet concentration. When compared to the federal standard (Subpart
KKKK), the turbines will be operating at 20 percent of the standard. The emission reduction for the
oxidation catalyst was also back-calculated from the vendor estimate of 5 ppmvd CO at 15 percent
oxygen and the uncontrolled CO concentration. Again, the control device for CO (which also controls
VOC emissions) is being installed voluntarily. Furthermore, BACT is not required until PSD is triggered.
Since the Northampton Compressor Station is a minor source for PSD purposes, requiring BACT is not
warranted. Therefore, the Hearing Officer has determined that the level of control being achieved is more
than sufficient to meet the applicable regulations and recommends that no further action by DAQ is
necessary to respond to this comment.

G. Comments Regarding Information Provided in the Permit Application

Comment: Five commenters (Scott, Garbutt, Ambrose, Stephenson, Ewing) stated concern that the
information provided by ACP in their permit application for the Northampton Compressor Station was
incomplete and additional stations should be included. In support of their comments, the following points
were made:
• Because the compressor station will need to push gas a longer distance than most compressor
stations, either the pressure at the station will need to be dangerously high or more compressor
stations will be needed along the pipeline.
• The possibility that additional compressor stations will need to be built means the draft air quality
permit was issued for an incomplete application.
• The permit application did not contain critical information needed to properly regulate the
compressor station.
• Based on recent news investigations, Duke Energy Progress has been reported to edit independent
coal ash science reports from two UNCC professors. The data provided in the permit application
cannot be trusted and must be reviewed and viewed with great skepticism.

Hearing Officer’s Response to These Comments
Regarding the accuracy of what is included in the permit applications, the application for this facility is
signed by a responsible official. If found to be in error, the facility would find itself in a noncompliance
situation with notices of violations and possible recommendations for enforcement being levied if applicable.

Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 19 of 29
The commenter’s statements are incorrect that the application is incomplete because future compressor
stations will be necessary. If new stations were needed, each would have to go through an individual
permitting process. Air quality permit applications are required for each individual facility. In this case both
State and federal permitting/approvals are necessary for each individual facility. The permitting of future
compressor stations is outside the purview of this hearing report and the Hearing Officer recommends that no
further action by DAQ is necessary in response to these comments.

H. Comments Regarding Ambient Air Monitoring and Regional Modeling

Comment: Several commenters (*Vick, *Wagner, *Taylor, Adams, *Neal, Ambrose, Ellis, Wooten, Nyland
(Lars), Nyland (Lauren), Manigrasso, Scott, Emanuel (Andrea), Richmond, Sheline, Garbutt, Form Letter
No. 5 14 Comments) requested that DAQ conduct ambient air monitoring in the area surrounding the
proposed compressor station and regional modeling (for several pollutants such as formaldehyde, dust, and
odor), including impacts from sources of emissions nearby, including the existing Piedmont Natural Gas
Compressor Station, the Georgia Pacific mill, a natural gas-fired power plant in Virginia, Enviva as well as
the 37 permitted facilities in the county. The following sections provide summaries of these comments,
grouped by topic.

1. Regional Modeling and Ambient Monitoring

Comment: In support of their comments, the following points were made:
• DAQ did not have any mobile monitoring sites near the compressor station and if monitoring to
measure the spikes can’t be done, it shouldn’t happen. An example was provided of a Pennsylvania
resident that was driven from their home due to short term spikes in emissions from a nearby
compressor station.
• Emissions of criteria air pollutants such as NOX and VOCs from the Northampton Compressor
Station may cause future violations of the Clean Air Act National Ambient Air Quality Standards
(NAAQS) in the Raleigh area. Current protocols used for assessing compliance with ambient air
standards using annual averages, does not adequately determine the intensity, frequency or durations
of the actual human exposures to the mixtures of toxic materials released regularly at pipeline
compressor stations. Due to the low population density in Northampton County and surrounding
counties, there aren’t nearby air quality monitoring stations. It was asked what the probability is for
an exceedance of 70-ppb ozone standard due to the addition of the pipeline and the Northampton
Compressor Turbines. DAQ should deploy a special purpose monitoring site or site a monitor from
their rotating background monitoring network, to establish a baseline concentration data for SO2,
PM2.5, PM10, NOX near the proposed compressor station, prior to the installation of the pipeline.
• The community would be at added risk of air pollution from gas-fired combustion facilities that
might tap into the pipeline in the future. DAQ has an “independent obligation” to limit the potential
for adverse health effects from the proposed compressor station and DAQ should require monitoring
of existing, nearby major sources of air pollution.

Hearing Officer’s Response to These Comments
The DAQ currently has a robust array of air monitoring equipment located throughout North Carolina.
The quantity, type and location of every monitor is a collaborative effort between the EPA and DAQ.
DAQ’s Ambient Air Quality Monitoring Network plan is updated and approved by EPA on an annual
basis. The changes to the plan are subject to a public notice and comment period. A public notice was
issued on May 26, 2017 announcing the opening of the comment period for the most recent changes to
the monitoring network. Monitors are established based on numerous factors, including but not limited
to, State and federal regulatory requirements and budget constraints. It is not within the purview of the

14 See Attachment C.6 for text of Form Letter No. 5.
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 20 of 29
Hearing Officer to determine or recommend the location and operation of air monitoring equipment near
the proposed compressor station facility.

As discussed in response to the comment in Section IV.A.1, above, DAQ conducted a cumulative review
of air quality in the area surrounding the Northampton Compressor Station site and will be compiled in a
separate document that will be part of the record.

Concerns that the national standards are not protective enough are also outside the context of this hearing
report. The Clean Air Act requires EPA to evaluate the NAAQS at least every five years and to adjust
these standards, as needed for the purpose of protecting human health. EPA consults the Clean Air
Scientific Advisory Committee to determine the appropriate standard needed for each pollutant to protect
the health of all citizens. North Carolina is currently in attainment for all pollutants as determined by
State-wide ambient monitoring and as approved by the EPA.

The Hearing Officer recommends that no further action by DAQ is necessary with regards to comments
about the location of air monitoring equipment and NAAQS modeling.

2. Comments Regarding Modeling Analysis for Environmental Impact Statement
• The modeling data supplied to the Federal Energy Regulatory Commission (FERC) was not
submitted in the draft air quality permit application for the compressor station.
• The NAAQS modeling was flawed in that it did not include background levels of air pollution in the
community but instead from monitoring stations as far away as Roanoke, Charlottesville, and
Harrisonburg, Virginia. Furthermore, background levels for HAPs or toxic air pollutants were not
considered. New modeling should be performed that includes accurate information about the
background sources of existing pollution in the relevant area. The nearest air quality monitoring
stations are over 60 miles away from the proposed compressor station.
• DAQ should require accurate modeling of the expected air pollution from the proposed compressor
station. The ACP public permit findings do not disclose the full environmental risk and harm to
communities.

Hearing Officer’s Response to These Comments
The Northampton Compressor Station has been determined to be a minor stationary source for the
purposes of PSD and Title V. There are no regulatory requirements to conduct NAAQS modeling for a
source of this size. It is beyond the purview of this hearing report to respond to comments on the merits
of the modeling conducted for FERC. Therefore, the Hearing Officer recommends that no further action
by DAQ is necessary in response to this comment.

As discussed in response to the comment in Section IV.A.1, above, DAQ conducted a cumulative review
of air quality in the area surrounding the Northampton Compressor Station site and will be compiled in a
separate document that will be part of the record.

3. Chemical Transport Modeling
Comment: DAQ should perform Chemical Transport Modeling to model ozone and atmospheric
deposition of nitrate to determine the full impact of the pipeline on future NAAQS attainment and the
health of impaired watersheds. DAQ should assess the inputs of atmospheric nitrogen deposition from
the construction and operational phase of the pipeline to impaired watersheds.

Hearing Officer’s Response to this Comment
As stated above, the purpose of the public hearing was to receive comments assessing DAQ’s evaluation
of the proposed compressor station from an air quality standpoint. There are currently no air quality
regulations that would require this type of evaluation for the proposed compressor station. Chemical
Transport Modeling to determine the full impact of the pipeline on future NAAQS attainment and the
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 21 of 29
health of impaired watersheds is beyond the purview of this hearing report. Therefore, the Hearing
Officer recommends that no further action by DAQ is necessary in response to this comment.

4. Concerns about Formaldehyde Modeling Regulations

Comment: In support of their comments, the following points were made:
• A personal monitor detected formaldehyde emissions near the existing compressor station in
Pleasant Hill. The emissions in the permit application represent average emissions and short-term
spikes in emissions should be considered.
• Fluctuations in emission levels make it more difficult to assess potential health risks to individual
residents, such as fugitive emissions from leaking equipment. Current air quality monitoring methods
need to be revised to account for episodic air emissions and more advanced air quality modeling
studies are needed.
• The Department should ensure that the community is not going to be exposed to dangerous levels of
formaldehyde, a “known carcinogen,” on an annual basis. Therefore, annual formaldehyde modeling
should be considered given the other sources of formaldehyde near the proposed compressor station.
• More recent investigations on formaldehyde near compressor stations are focused on the chemical
reaction between methane and sunlight. While it is well known that stationary compressor station
engines emit formaldehyde, it is less well known that formaldehyde may also be formed at these sites
through this chemical reaction.
• DAQ should report on the baseline sources of formaldehyde emissions in North Carolina, how these
emission sources are distributed across the State, and how the pipeline will contribute to those
emissions. DAQ should review and model their regulations after learning from the challenges faced
by States who are having difficulty characterizing their regional air quality due to the presence of
multiple complex emission sources.
• The Ohio Department of Air Pollution Control (DAPC) is asking permittees to conduct formaldehyde
monitoring whenever a project is expected to emit more than 1.0 tpy of formaldehyde and stipulates
when the more sophisticated methods are to be used, the ambient modeling concentrations that must
be met are 49 µg/m3 maximum 1-hour concentration and 0.8 µg/m3 on an annual basis. Maximum 1-
hour concentration limits are more protective to local communities because short-term exposure is
masked when annual averages are used. DAQ should require that ACP demonstrate that the NC and
Federal Air Toxic Regulations are met using an optical formaldehyde monitor for continuous
emission fenceline monitoring. DAQ is recommended to create permit guidelines for compressor
stations that include guidelines for ambient monitoring and fenceline observed concentrations that
must be met for both maximum 1-hour concentrations as well as annual concentrations.

Hearing Officer’s Response to These Comments
It is beyond the purview of this hearing report to make changes to the modeling regulations and these
comments will not be directly addressed in this report.

The DAQ air toxics rules are established to protect the ambient air levels at the fenceline for each TAP
emitted from a facility. A toxics demonstration would be required for each pollutant for which the
associated TPER was expected to be exceeded. The AALs, as well as the TPERs, are time dependent
(i.e., based on exposure time) and were developed by the Science Advisory Board (SAB) to protect the
health of those outside the fenceline. With respect to the commenters’ recommendation to use the Ohio
DAPC guidelines, it should be noted that DAQ’s established AAL for formaldehyde is 0.15 µg/m3 for
the one-hour standard. This is two orders of magnitude below the Ohio AAL.

In response to the comment in Section IV.I.3, below, the Hearing Officer has recommended that ACP
conduct an analysis to determine which TAPs (including formaldehyde) are projected to be emitted at
rates greater than the associated TPERs and for those TAPs, demonstrate compliance with the associated
AAL. Therefore, the Hearing Officer has determined that the process by which formaldehyde will be
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 22 of 29
evaluated relative to the AALs will adequately protect those outside of the compressor station fenceline
and, pending the outcome of the modeling analysis, does not recommend any further action by DAQ in
response to this comment.

I. Comments Regarding Toxic Air Pollutants Modeling

Two commenters (*Neal, *Taylor) stated that DAQ incorrectly performed dispersion modeling for toxic air
pollutant emissions from the proposed compressor station. The following sections provide summaries of
these comments, grouped by topic.

1. Insignificant Activities

Comment: The draft air quality permit would allow emissions of toxic pollutants, including
formaldehyde and ammonia, from equipment that is associated with “insignificant activities” and thus
claimed as “exempt.” DAQ did not perform the necessary analysis to see if these emissions would
exceed health based safety standards when combined with other toxic emitters nearby. DAQ should
rescind the draft air quality permit and require the ACP to obtain an air toxic permit that fully evaluates
the public health risks.

Hearing Officer’s Response to These Comments
The commenter’s statement that the insignificant activities are claimed as being exempt from toxics
modeling is incorrect. Only sources identified in 15A NCAC 02Q .0702(a)(1) through (a)(25) are exempt
from toxics modeling. See the Hearing Officer’s response to the comment in Section IV.H.1 above for
discussion on modeling of nearby sources.

2. Ammonia Modeling
Comment: DAQ determined that an air toxics permit was not needed for the facility’s ammonia
emissions. Ammonia emissions require air toxics permit and air dispersion modeling for the following
reasons:
o The facility ammonia emissions were compared to the TPER for facilities “where all emission
release points are unobstructed and vertically oriented,” pursuant to 15A NCAC 02Q .0711(b).
Diagrams were not included in the application that would show the emissions points from storage
tanks, but these emission points are likely to be obstructed or non-vertically oriented. Therefore,
DAQ cannot assume that emissions points from storage tanks are vertically oriented or
unobstructed. Thus, the facility should have been subject to the 15A NCAC 02Q.0711(a)
regulations, for “…any facility where one or more emission release points are obstructed or non-
vertically oriented….” The compressor stations’ projected emissions of 2.83 pounds per hour of
ammonia, are greater than 0.68 lb/hr TPER under subsection (a).
o If DAQ determines that emissions release sources are unobstructed and vertically oriented, the
emissions from the three turbines (2.83 lb/hr) are 0.01 lb/hr below the TPER for ammonia (2.84
lb/hr) for a source subject to 15A NCAC 02Q.0711(b). When a source is so close to the limit, and
given the real-world uncertainty of actual emissions, including any possible fugitive ammonia
emissions from the storage tank, DAQ should have required an air toxics permit for ammonia.

Hearing Officer’s Response to These Comments
The commenter stated when conducting the toxics analysis to determine which pollutants were being
emitted at a rate higher than the TPER contained in 15A NCAC 02Q .0711, ACP should have used the
table in 02Q .0711(a) for “facilities where one or more emission release points are obstructed or non-
vertically oriented” because storage vessels typically have non-vertical or obstructed release points. The
permit engineer, Charles McEachern, P.E., contacted ACP to request clarification on the release points
from the storage tanks. In a November 30, 2017, email response, ACP provided the following
information on the tanks:
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 23 of 29
“TK-1 (Pipeline Liquids Storage Tank aka Hydrocarbon Tank) will receive and store pipeline
liquids captured by the station’s separators and filter-separators. The emissions associated with
the operation of this Hydrocarbon storage tank are estimated using E&P Tanks to ensure
capture of any flash emissions (which the EPA TANKS program cannot estimate). We
conservatively estimated that this storage tank will complete five (5) turnovers per year. The tank
normal vent is vertical.

TK-2 (Accumulator Tank) receives liquids from the compressor building and auxiliary building
floor drains. The emissions associated with the operation of this Accumulator waste tank were
calculated using EPA’s TANKS program. The tank normal vent is vertical.

TK-3 (Aqueous Ammonia Storage Tank) will have no emissions during normal operation.”

In addition, ACP provided diagrams for the three tanks, which show that the two tanks have vertical
emission release points and that the ammonia tank is a pressure tank.15 Based on the information
provided by the applicant, DAQ determined that it was appropriate to compare facility-wide emissions to
the TPERs table in 15A NCAC 02Q .0711(b).

The commenter also stated that that the compressor station’s actual operation emissions could exceed the
TPER because the potential ammonia emissions for the compressor station are close to the TPER in 15A
NCAC 02Q .0711(b) and therefore a permit limit is required. The TPERs apply to actual emissions, but
because the Northampton Compressor Station is a new facility, the emissions used for the TPER analysis
represent maximum potential emissions. However, to address this concern, the Hearing Officer
recommends that a TPER table be added to the draft air quality permit for the TAPs evaluated. The
emission rates in TPER table would not be emission limits, but would be levels for which, if exceeded,
action would be needed.

3. Use of Exemption 15A NCAC 02Q .0702(25)

Comment: DAQ incorrectly applied 15A NCAC 02Q .0702(25), which exempts from the requirement to
obtain an air quality permit, “natural gas and propane fired combustion sources with an aggregate
allowable heat input value less than 450 million Btu per hour that are the only source of benzene at the
facility.” In its revised application, ACP reported that the only source of benzene would be from natural
gas combustion from turbines. However, the ACP permit application reveals that there is at least one
additional source of benzene emissions at the facility. According to Attachment C of the amended
application, the hydrocarbon waste storage tank (ID No. I-TK-1)16 is listed as a source of TAPs.
Removing the exemption for the compressor turbines means that the facility-wide benzene emissions are
greater than the TPER for benzene and an air toxics permit should have been required for the facility.

Hearing Officer’s Response to These Comments
The Hearing Officer has reviewed the permit application and agrees that the hydrocarbon waste storage
tank (ID No. I-TK-1) is likely a source of benzene emissions because the program output presented in the
application shows that benzene is expected to be present in the hydrocarbon liquid. As discussed in the
response to the comment in Section IV.C.2, above, the hydrocarbon waste storage tank, which accepts
hydrocarbon liquids from the separator, is a source of what is referred to as flash emissions. Flash
emissions occur when the liquid from this high-pressure separator (according to the permit application,
the separator pressure is 552 pounds per square inch gauge (psig)) are transferred to an atmospheric tank.
Whe n it enters the tank, the volatile compounds dissolved in the liquid are quickly released (i.e., flashed).
The relationship between emissions and throughput is linear. Therefore, due to the very low throughput

15 The email and attachments can be found in Attachment E of this hearing report.
16 NOTE: The commenter incorrectly identified the hydrocarbon waste storage tank as ID No. I-TK-2 in their comment letter. The ID
number for the waste oil tank is I-TK-2.
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 24 of 29
of hydrocarbon liquids projected to be stored in the tank, the API’s E&P Tanks Program output reported
benzene emissions of 0.000 lb/hr. It is likely that if the program reported emissions using scientific
notation, rather than three decimal places, some benzene emissions would be present. Therefore, the
Hearing Officer believes that if the program were run using a higher throughput, the program output
would report benzene emissions greater than zero.

As a result, the Hearing Officer has determined that the exemption in 15A NCAC 02Q .0702 does not
apply because the combustion sources (i.e., turbines, engines, and boilers) are not the only source of
benzene at the proposed compressor station. As such, the Hearing Officer recommends that ACP conduct
an analysis to determine whether any of the TAPs (including benzene) emitted from the compressor
station are greater than the TPERs in 15A NCAC 02Q .0711 and if so, conduct a modeling analysis to
determine compliance with the AALs in 15A NCAC 02D .1104. Pending the outcome of the toxics
analysis, the Hearing Officer recommends that the air quality permit be modified as required.

J. Comments Regarding Health and Well-Being of the Surrounding Communities

Comment: Several commenters (*Exum, *Murphy, *Clark, *Ethridge, *Vick, *Bearden, *Wagner, Scott,
*Neal, Bissette, Wooten, Richmond, Sheline, Wood, Vanderbush, Stephenson, Ewing, Weir, Reynolds,
Osterbrink, Henderson/WeatherCenter, Harris, Form Letter 1 17 Comments, Form Letter 2 18 Comments)
expressed their concern for the health and well-being of the residents of the communities in and around the
proposed compressor station due to the increase in toxic emissions. In support of their comments, the
following points were made:
• Reports document that health problems, such as breathing problems, COPD, cancers, birth defects,
skin irritations, result from the VOC being emitted from the compressor station. One commenter
stated their opposition to any increase in emissions. The commenter indicated that they preferred zero
emissions and that solar, wind and battery storage should be used instead. The commenter stressed
their belief that fossil fuels should be phased out and that we should not be increasing capacity.
• An October 2017 study by the Southwest Pennsylvania Environmental Health Project indicates that
every compressor station releases large volumes of chemicals into the air. The air impacts the entire
state.
• A report compiled by the NC NAACP says the overall cancer rate in the county is higher now than
the State average, with 517 cases per 100,000 people, compared to 489 cases per 100,000 people
across the state. Lung and bronchial cancers occur at a rate of 81 cases per 100,000 people in the
county, while the State average is 70 cases.
• What is the impact of pollution from the compressor station on children and on the earth. The
commenter stated that injection of chemicals into the earth to extract the natural gas was harmful.
• Studies showed that, due to air pollution, people living near compressor stations have benzene in
their blood and in their urine in higher concentrations than those that do not live near compressor
stations.
• A study connected to pipelines stated that “exposure to air pollution is known to cause a vast array of
health problems…” and the study found that there was an increase in bone fractures due to
particulate emissions.
• People living downwind of the compressor station and the pipeline are inhaling toxic fumes that are
released or leaked. They may not even be aware of the poor air quality conditions if they can’t smell
noxious or acrid odors. Repeated exposure to high, short-term doses of toxic gases puts individuals
with compromised lung function at greater risk.
• The compressor station threatens the health of the surrounding community and requires additional
scrutiny. Pollution from this facility would likely lead to adverse health effects to the surrounding
population. In its Environmental Impact Statement (EIS) for the pipeline, the FERC recognized the

17 See Attachment C.4 for the text of Form Letter No. 1.
18 See Attachment C.4 for the text of Form Letter No. 2.
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 25 of 29
health risks from pollution from the ACP’s compressor stations. The studies cited by the FERC
found elevated concentrations of dangerous pollutants from samples collected near compressor
stations. These include VOC, fine particulate matter, and gaseous radon.
• ACP has been inadequate in supplying data on projected impacts from the proposed compressor
station and have not proven they have taken the necessary steps and precautions to safely and
efficiently install a pipeline.
• DAQ should conduct a proximity analysis and demographic analysis to determine the special health
risks associated with the population in this community.
• NOX and VOC will contribute to formation of elevated nitrogen oxide and ozone levels that will
adversely affect public health.
• Mental health issues from the compressor station are often overlooked. Stress over health impacts to
family members or themselves, rapid change to the surrounding area, increased noise and increased
traffic all contribute.

Hearing Officer’s Response to These Comments
The State and federal air regulations that apply are designed to safeguard the public from adverse health
effects from this facility. In addition to the State and federal air regulations, as stated above, ACP will
voluntarily be putting into place additional requirements for testing, monitoring, and control. The siting of
the facility has undergone local zoning review for proper siting of the facility. The draft permit was written
such that compliance with the permit will also mean compliance with all State and federal air quality
regulations. It is beyond the purview of this hearing report to evaluate the facility siting and existing air
quality regulations. Furthermore, because ACP is voluntarily reducing emissions to levels well below the
emission standards, the Hearing Office recommends that no further action by DAQ is necessary in response
to these comments.

K. General Comments Not Directly Related to the Expressed Intent of the Public Hearing.

Several commenters submitted emails and spoke at the public hearing to express their opposition for various
aspects of the pipeline project as a whole and did not address specific concerns with the current draft air
quality permit or the permitting process involved in drafting the permit. Although these comments are not
directly related to the draft air quality permit for the Northampton Compressor Station, they reveal the
passion many in the general public feel about issues related to the proposed compressor station and the ACP
Project in general. All comments were reviewed to determine whether they would impact the draft air quality
permit and are summarized below.

1. Comments Related to the Northampton Compressor Station

Comment: Several commenters (*Hutchby, Ambrose, Rodgers, Adams, Bissette, Sheline, Stephenson,
Ewing, Henderson/WeatherCenter, Harris, Form Letter No. 2 19 Comments) expressed concern with the
noise pollution created by the compressor station.
o Sound waves are carried through the air and the air permit does not address excessive noise.
o According to a study conducted by the University of Maryland, noise from these compressor
stations can be heard from up to a mile away.
o Even if the average noise level is within the federal limit, the fact that it is incessant, and that it
can exceed those levels during blowdowns and other operational excursions, only adds to the
stresses that would be faced by residents within a few miles of the facility.
o Hearing aids cost $2,000/ear and people with no insurance cannot afford them. According to the
commenter, the two 22,000 horsepower engines would cause excessive noise.
o By regulations the noise level of a compression stations should not exceed an average day-night
sound level of 55 decibels at the nearest noise sensitive area. There is documentation that at

19 See Attachment C.4 for the text of Form Letter No. 2.
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 26 of 29
certain times and under certain conditions this limit is exceeded, sometimes to 100 decibels. In
any case there is an unnatural noise that disrupts lives of residence and animals in the area.
Negative health effects include severe headache, sleep disturbances, depression, tiredness,
anxiety to name a few.

Hearing Officer’s Response to These Comments
While the comments received were thoughtful and worth considering in the proper forum, these
comments received are not directly related to the Northampton Compressor Station air quality permit
application or the air quality permitting process. As such, these comments fall outside the purview of
this hearing report and are therefore not directly addressed.

However, it should be noted that the consultant for ACP on the permit application spoke during the
public hearing and indicated that the Environmental Impact Statement prepared for the Federal
Energy Regulatory Commission (FERC) included a noise assessment. The Hearing Officer reviewed
this document, in which ACP states the following:
“Our noise evaluations incorporate noise level reductions from the companies’ proposed
mitigation measures. Noise controls for the compressor buildings include acoustical
specifications for wall, roof, and entry door materials; prohibition of windows or
skylights; and acoustical specifications for the ventilation system.

[ACP] would implement noise mitigation measures for the proposed and modified
compressor stations. These measures include, but are not limited to:
• exhaust silencers;
• air intake cleaner/silencers and air intake duct acoustic insulation;
• noise attenuating materials for wall, roof, and doors of compressor buildings;
• lubrication oil cooler maximum noise level of 50 dBA at 50 feet;
• ventilation air inlet and discharge mufflers;
• acoustical insulation for aboveground piping; and
• unit blowdown silencers (60 dBA at 50 feet).”

Comment: Fifty-five commenters submitted letters via email to express their opposition to the
Northampton Compressor Station in general. Outside of the concerns raised in the previous sections
above, these commenters did not provide additional information. These commenters are identified and
their full comments are included in Attachment C.3.

Hearing Officer’s Response to These Comments
While these comments are related to the Northampton Compressor Station, they have been addressed in
the sections above and will not be addressed here.

2. Comments Expressing Opposition to the Atlantic Coast Pipeline Project

• Comment: Several commenters (*Exum, *Joyner, *Ethridge, *Faircloth, *Cook, Nyland (Lars),
Nyland (Lauren), Manigrasso, Raines) referred to the claims that there would be additional jobs
created by the project.
o The claim of increases in jobs for residents are not believable.
o Temporary jobs may be created but not permanent jobs and that people will not move to the area
to work because of the toxic air pollution and danger.
o Jobs are available now but people are not taking them.
o The jobs created by the pipeline would not last after the pipeline was built.
o The jobs created would only be for highly educated people and not people that did not have
college degrees.
o Jobs created will be filled by people profiting by the project.
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 27 of 29
• Comment: Many commenters (*Taylor, *Faircloth, *Murphy, Nyland (Lars), Nyland (Lauren),
Manigrasso, Adams, Bissette, Sheline, Garbutt, Raines, Tatta, Sasser) stated that the pipeline is not
necessary.
o Natural gas from the ACP is not necessary for economic development and will increase electric
utility costs in affected counties in Virginia and North Carolina.
o Energy use in North Carolina is flat and the additional energy provided by the pipeline natural
gas is not needed.
o Sun, wind, and battery storage could supply 100 percent of North Carolina’s electricity needs and
will allow the country to transition away from petroleum to electric vehicles.
o Incorrect and outdated assumptions about the costs, benefits and public necessity of building the
Atlantic Coast Pipeline may lock us into a costly and dangerous future.
o The pipeline will create future threats that will make it more likely that the pipeline will be
damaged by storms, flooding, and other climate catastrophes. DEQ should require a Hazard
Assessment Plan and provide a full report to the public for comment.
o DEQ should perform a baseline study using camera traps to document pre-existing number and
varieties of birds, amphibians, and mammals and ensure their protection along the length of the
pipeline.
o There have been documented studies and reports published that states the pipelines currently in
place are sufficient to meet the current and future needs. A study (Sept 12, 2016) by Synapes
Energy Economics, Inc. found that “given existing pipeline capacity, exiting natural gas storage,
the expected reversal of the direction of flow on the existing Transco pipeline, and the expected
upgrade of the existing Columbia pipeline, the supply capacity of the Virginia-Carolinas region’s
existing nature gas infrastructure is MORE than sufficient to meet expected future peak demands.
• Comment: Many commenters (*Taylor, *Grant, *Pair, *Joyner, Geffner, Ambrose, Bennett/Owens,
Raines, Tatta, Sasser) were concerned about the blast zone and pipeline safety. 20
o The proximity of their residences to the blast zone was of concern. Reference was made to the
2010 pipeline explosion in California as proof that the pipelines are dangerous.
o The streets that were within the blast zone were identified.
o Concern was expressed that people living within or close to a blast zone might not be aware.
o Concern was expressed regarding compressor station accidents and news reports of explosions
and fires at compressor stations.
o Is adequate funding for local emergency response staff to handle and contain explosions?
o The ACP crosses more than 1300 parcels of land and an explosion would endanger homes and
families as well as farm animals and pets.
o One commenter asked what measures would be put in place to prevent leaks or explosions.
• Comment: Some commenters (*Pair, *Joyner, *Winstead) questioned who would benefit from the
pipeline.
o No one working for Dominion lives near a compressor station and that only Duke and Dominion
and those associated with them benefit from this pipeline.
o Only investors will benefit from the pipeline, not the impacted community.
o The pipeline company will make billions of dollars but who pays for injuries?
• Comment: Some commenters (*Winstead, Ambrose, Girolami) expressed their distrust of Dominion
and energy corporations in general, as well as EPA.
o Concern was expressed that Dominion would eventually extend the pipeline into South Carolina.
How will Dominion Energy’s plans to extend the ACP pipeline into South Carolina (for the LNG
export market?) alter the design requirements for this permit?
o The amount of gas being promised to North Carolina would eventually go to South Carolina and
be sold at an liquified natural gas (LNG) plant in Georgia.

20 The “blast zone” is the area that would be impacted should the pipeline explode.
Hearing Officer’s Report – Northampton Compressor Station Public Hearing – November 15, 2017 Page 28 of 29
o Ads for the proposed ACP claim a need for the pipeline and benefits to NC’s economy that do
not ring true to affected property owners. Eminent domain is a real issue–threatening the
property rights of long-time landowners–and is considered as a taking of land.
o In March of 2017, EPA Administrator Scott Pruitt announced a withdrawal of its Information
Collection Request from the oil and gas sector to respond to the EPA survey of methane pollution
from existing sources to identify sources of methane emissions and develop and apply standards.
In the prevailing political climate, any federal studies to identify and correct air emission
regulatory gaps and strengthen enforcement are not likely.
o ACP appears to fail to acknowledge the broad scope of impacts that would result from the
proposed pipeline.
• Comment: Several commenters (Nyland (Lars), Nyland (Lauren), Manigrasso, *Joyner, Raines,
Reynolds, Tatta, Sasser) expressed concern with the impact of the pipeline on their property.
o The proposed pipeline will damage farmland now and into the future. Farmers with pipelines on
their property note that the yield has decreased.
• Comment: Six hundred and six (606) commenters submitted letters via email to express their
opposition to the Atlantic Coast Pipeline project in general. In addition to those concerns raised in the
previous bulleted comments, these commenters cited various reasons for their opposition, including,
but not limited to: a need to transition away from fossil fuels and toward renewable energy, health
effects of residents along the pipeline, impact on tourism in the State, and mental health effects of the
pipeline. These comments are included in Attachment C.6.

Hearing Officer’s Response to These Comments
While the comments received were thoughtful and worth considering in the proper forum, these comments
received are not directly related to the Northampton Compressor Station air quality permit application or the
air quality permitting process. As such, these comments fall outside the purview of this hearing report and
are therefore not directly addressed.

L. Comments Expressing Support for the Atlantic Coast Pipeline and the Northampton Compressor
Station

Several commenters (*Brown, *Betts, *Hughes, *Heaton, *Hoque, *Glover (Catherine), *Greene, *Warner,
*Worsinger, *Glover (Matt), *Ausby, True, Williams, Form Letter Nos. 6 through 11 21 Comments)
expressed their support for the pipeline project and the location of the compressor station. In support of their
comments, the following points were made:
• The site has an unusually large buffer (6,100 feet from the nearest commercial structure, and 7,000
feet from the nearest residence) to minimize impacts.
• Companies are considering locations in Northampton County but need access to the gas the pipeline
will provide. This will create jobs.
• The pipeline and compressor station have been designed to very exacting standards (lowest emitting
compressors, additional controls) and will be monitored continuously (via air and foot patrol).
o The station will use a turbine design that includes SoLoNOx technology to minimize NOX
emissions.
o Further reductions will be achieved by a selective catalytic reduction system.
o The NOX emission rate represents the lowest permitted level for turbines currently in
compression service.
o Oxidation catalysts will be installed to reduce VOC (including HAPs) and CO emissions.
• The commenter also stated that existing station in the Pleasant Hill community have operated for
decades without incident, other than occasional mercaptan odor.
• Dominion is very safety conscious. Employees will be highly trained and certified by various
industries.

21 See Attachment C.7 for text of Form Letters Nos. 6 through 11.
. Ambient air quality modeling and noise impacts were conducted for the FERC report.
. Pipeline transport of natural gas is safer than rail or truck transport. 2.5 million miles of pipeline in
the United States and incidents are very rare.
. Proposed operation of the pipeline and its compressor stations are part of Duke and Dominion's plans
to shut down seven coal-fired power plants and install thousands of megawatts of solar power,
backed by additional gas-fired generation.
. The pipeline provides urgently needed infrasbucture that will bring lower-cost energy supplies and
new economic development.
Hearin Officer's Res onse to These Comments
These coiiunents are helpful to provide additional infomiation regardmg the Northampton Compressor
Station along with background information used in the development of the pennit application. The
mfonnation provided in these comments was reviewed by the Hearing Officer and when verified
independently by information available, it was used in responses elsewhere in this report and will not be
further addressed.
V. Conclusions and Recommendations
ACP has provided all data necessary to show that the proposed compressor station can meet the applicable
State and federal air quality regulations. After considering all the public comments related to the issue of
whether or not the DAQ should issue an air quality permit to ACP to allow the constmction and operation of
a natural gas compressor station at 718 Forest Road, Pleasant Hill, Northampton County, NC, the following
recommendations are made:
. ACP should conduct an analysis to determine whether any of the TAPs emitted from the compressor
station are greater than the TPERs in 15A NCAC 02Q .0711 and if so, conduct a modeling analysis
to determine compliance with the AALs in 15A NCAC 02D .1104. Once the analysis is submitted,
DAQ will review the analysis to determine that the modeling was conducted using EPA modeling
guidance and that the emissions used in the analysis adequately represent short-term and annual
emissions. It is expected that the modeling analysis will show that even under worst-case operation
conditions, the proposed plant would meet all ambient air emission standards for toxic air pollutants.
The draft permit should be modified to include TAP emission limits based on the emission rate used
in the modeling analysis.
. DAQ should include in the final air quality permit, a table ofTPERs for all TAPs for which an
analysis was conducted and it was detennined that facility-wide emissions were below the TPER.
If the modeling analysis demonstrates compliance with the AALs, it is the recommendation of the Hearing
Officer that the Air Permit 10466ROO be issued.
Heather P. Sands, P.E., Hearing Officer
3J ^0;<
Date
Hearing Officer's Report - Northampton Compressor Station Public Hearing - November 15,2017 Page 29 of 29

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