AQ_F_2100073_20170629_CMPL_InspRpt

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NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Regulator Marine,Inc.
NC Facility ID 2100073
Inspection Report County/FIPS: Chowan/041
Date: 06/30/2017
Facility Data Permit Data
Regulator Marine, Inc. Permit 07132/T11
187 Peanut Drive Issued 9/16/2014
Edenton,NC 27932 Expires 8/31/2019
Lat: 36d 4.9290m Long: 76d 35.4830m Classification Title V
I' SIC: 3732/Boat Building And Repairing Permit Status Active
NAILS: 336612/Boat Building Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contacctt�eP SIP/Title V
Erik Wiborg ® Owen Maxwell Efik TMichael Aust MALT Part 63: Subpart VVVV, Subpart ZZZZ
Facilities Manager Vice President Environmental Manager
[phone] [phone] [phone]
Compliance Data
Comments: Based on review of records and visual observations,this facility
appeared to operate in compliance with all applicable Air Quality regulations and Inspection Date 06/29/2017 w'
permit conditions at the time of this ins ection. Inspector's Name Yongcheng Chen
\ Operating Status Operating K
Inspector's Signature: Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 6/30/2017 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PM10 HA
P
2015 800 0.9700 40.07 0.4100 0.5800 67641.00
2014 500 --- 0.7500 44.58 0.3200 0.6500 74843.00
200 .0100 1.32 33.01 0.2800 0.5200 54949.00*Highest HAP Emitted(in pounds)
_Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
03/31/2017 NOV Part63 -NESHAP/MACT Subpart VVVV Boat 03/28/2017
Manufacturing
03/20/2013 NOV Permit Late Title V ACC 03/15/2013
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
11/03/2016 Pending
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Location:
The facility is located at 187 Peanut Drive, Edenton,NC. From WaRO,take US 17N to Edenton. Take
exit 230 off of Hwy. 17N (North Broad Street). Go approximately 1 mile and take a right onto Peanut
Drive. Go over railroad tracks and the facility will be on the left.
Process Description:
The facility manufactures 23', 25', 28', 31', 34' and 41' fiberglass boats in open molds. It requires 10
days to complete a boat. The facility has approximately 155 full-time employees.
Safety:
The only personal PPE required in shop areas of the facility is safety glasses. An inspector should wear
safety shoes and have hearing protection to use as required.
Currently Permitted Sources:
Emission Source ID Emission Source Description Control Device I Control Device Descripti
No. No.
ES-1 One fiberglass lamination/gelcoatin CD-1 Fiberglass mesh filters on
MACT Sub VVVV) operation four roof exhausts
ES-2 Trimming,routing and sanding of CD-5 Central vacuum system
gelcoat, resins and fiberglass consisting of cartridge filte
in series w/dual cyclones
ES44 Diesel-fired peak shaving generator CD-I4 Diesel Oxidation Catalyst
(MACT Sub ZZZZ) (764 hp)
Inspection Observations:
I, Yongcheng Chen, arrived at the facility on 6/29/2017 at 9:30 am to conduct an air permit annual
compliance audit with Erik Wiborg and Michael Aust(Environmental Manager,just hired by the
company). We began the inspection with a records and permit review. Their air quality log book
contained a current copy of the Air Permit, logs for weekly inspection and maintenance of the filter pads
(CD-1), every 6-monthly observations for VE of the Lamination/Gel coating(ES-1), and monthly
inspections of sources of VOCs (2I) .0958). I also reviewed the CMS report of the peak shaving
generator(ES44, MACT Subpart ZZZZ).
A separate trimming and sanding area(ES-2) has not been constructed and the permitted central vacuum
system (CD-5) has not been purchased or installed yet. The plan to expand and add a trim and sanding
area(ES-2) was prior to the economic downturn. They are currently manufacturing 4 or 5 boats per
week.
After the records review, we toured the facility. There were several boats being built, in various stages
of completion. The filters (CD-1) were securely in place and in good condition. The filters are
inspected each Thursday and replaced each Friday. The only exception to that policy was during
periods of down time when no boats are being built.
We then went to the area where the gel coating and lamination(ES-1) operations are carried out. The
gelcoat and resin is applied by spray. The area was very clean. No open VOC containers were observed
and there were no indications of spills or leaks.
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The current trim and sanding area is enclosed in the facility. The air from this area is filtered and
returned(not exhaust outside). This area was clean and well kept.
REGULATORY REVIEW:
15A NCAC 2D .0515: Particulates from Miscellaneous Industrial Processes
This applies to the laminating and gelcoating area(ES-1), and the trimming, routing, and sanding area
(ES-2), which has not been constructed yet. Particulates are controlled by fiberglass mesh filters. The
inspection and maintenance (I&M) shall consist of at least weekly inspections recorded in a logbook.
The last entry in the log book was 6/28/2017. Reports are required to be submitted semi-annually. The
last report was received 2/2/2017. 1 also saw the new report from 1/l/2017-6/30/2017 prepared to be
submitted. Compliance is indicated.
15A NCAC 2D .0521: Control of Visible Emissions
Visible emissions from ES-1 and ES-2, when constructed, shall not be more than 20 percent opacity
when averaged over a six-minu�e period. No VE was observed during the inspection. Once every 6
months, twice per calendar year, the facility is required to observe the emission points. The results and
any corrective actions are to be recorded in a logbook. The last inspection was recorded on 6/23/2017.
Reports are required to be submitted semi-annually. The last report was received on 2/2/2017. I also
saw the new report from 1/l/2017-6/30/2017 prepared to be submitted. Compliance is indicated.
15A NCAC 2D .1806: Control and Prohibition of Odorous Emissions
The facility shall not operate without implementing management practices or installing and operating
odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary. No objectionable odors were
detected during this inspection. Compliance is indicated.
15A NCAC 2D .0530: Prevention of Significant Deterioration
Facility-wide emissions shall be less than 250 tons of volatile organic compounds (VOCs)per
consecutive 12-month period. VOC emissions shall be recorded monthly in a logbook. The 12-month
period ending May 201,was 53,25 tons. Reports are required to be submitted semi-annually for each 12-
month period over 17 months. The last report was received on 2/2/2017 and the highest 12-month
period ended in Dec 2016 and was 53.25 tons. Compliance is indicated.
15A NCAC 2D .0958: Work Practices for Sources of Volatile Organic Compounds
The facility is required to use work practices that reduce the amount of VOCs emitted from the facility.
The facility shall, at a minimum,perform a visual inspection once per month of all operations and
processes utilizing VOCs and shall immediately initiate any corrective actions required. The records of
inspections are kept in a logbook. The last inspection was completed on 6/23/2017. The logbook was
current and complete. Reports are required to be submitted semi-annually. No open containers, or used
rags or cloths were observed in the work areas or storage areas during the inspection. Compliance is
indicated.
15A NCAC 2Q .0711: Emission Rates requiring a Permit
For each of the TAP's listed in their permit, the facility has demonstrated that facility-wide actual
emissions do not exceed the TPERS's listed in 2Q .0711. The facility is required to maintain
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operational information to demonstrate compliance with this rule. The facility's emission rates are
well below the requirements. Compliance is indicated.
15A NCAC 2D .1100: Control of Toxic Air Pollutants
The facility is limited to no more than 313 lbs/hour of styrene emissions. Quarterly reports are to be
submitted indicating the maximum hourly emissions rate for styrene. The last report was received
2/2/2017. I also saw the new report from 1/1/2017-6/30/2017 prepared to be submitted. The
maximum rate occurred in March 2017 and was 50.05 lbs/hour(<313 lbs/hour). Compliance is
indicated.
15A NCAC 2D .1111: MACT (40 CFR Part 63 Subpart VVVV)
The facility has elected the model point averaging option to meet the MACT emission limits in 40
CFR 63.5698 for the resins and gel coats used in the lamination and gel coating areas (ES-1). They
are currently using all compliant materials with the exception of one tooling resin. The Permittee
appears at the time of this inspection to be in compliance with all applicable provisions, including
the notification, testing,recordkeeping,reporting, and monitoring requirements by choosing the
emissions averaging compliance option. Under this compliance option, Regulator Marine is
currently tracking facility-wide monthly usage of each HAP containing: production resin,pigmented
gel coat,clear gel coat,tooling resin and tooling gel coat. They are calculating the facility-wide
monthly, 12-month rolling Equation I organic HAP emission limit calculations pursuant to 40 CFR
63.5698(b) and facility-wide monthly, 12-month rolling MACT model point value calculations in
accordance with 40 CFR 63.5710 procedures. For a given month, compliance is demonstrated if the
MACT model point value is less than the Equation I organic HAP emission limit calculations. The
facility met the compliance date of August 22, 2005. The initial notification of compliance was
received December 19, 2005.
The MACT semi-annual emissions averaging report for 12-months ending in December 2016 was
received 2/1/2017. The NESHAP HAP Limit for that period was 36 tons and the MACT Model
Point Value was 31 tons. Compliance is indicated.
The MACT requirement for carpet and fabric adhesive (40 CFR 63.5740) states the adhesives
contain no more than 5% HAP by weight. There is no carpet or fabric in their boats requiring
adhesives.
15A NCAC 2D .1111: Maximum Achievable Control Technology for RICE Diesel-fired Peak
Shaving Generator ES-I4 (40 CFR Part 63 Subpart ZZZZ)
On May 24, 2013 the instillation of a Diesel Oxidation Catalyst(CD-I4) was completed with a
continuous parameter monitoring system(CMS). The initial and subsequent performance test was
completed June 6, 2013,November 26, 2013,November 20, 2014, and November 3, 2016
respectively. The test results of all tests were approved by DAQ Stationary Source Branch as an
acceptable demonstration of compliance with the applicable CO emission limit, except the last one
that DAQ database is still showing Pending reviewing (Mr. Wiborg said that they already submitted
the report and I saw a copy of the test result).
COMPLIANCE HISTORY:
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An NOV was issued on 03/20/2013for a late reporting of the CY2012 Annual Compliance
Certification. The deviation was included in the 2013 Annual Compliance Certification. All
violations have been resolved.
An NOV was issued on 03/31/2017 for a late reporting(Part 63 -NESHAP/MACT Subpart VVVV
Boat Manufacturing). Mr. Wiborg explained to me that when he submitted the report, he misplaced
- on page. I reminded them that the new report is due soon and they should be more careful. Mr.
Wiborg said that they already prepared the report and will be sure not to miss anything and will be
on time.
COMMENTS, CONCLUSIONS, and RECOMMENDATIONS•
Based on review of records and visual observations, this facility appeared to operate in compliance
with all applicable Air Quality regulations and permit conditions at the time of this inspection.
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