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HomeMy WebLinkAboutAQ_F_0700122_20170511_CMPL_InspRpt (4) NORTH CAROLINA DIVISION OF Washington Regional Office AIR QUALITY Fountain Powerboats NC Facility ID 0700122 Inspection Report County/FIPS:Beaufort/013 Date: 05/18/2017 Facility Data Permit Data Fountain Powerboats Permit 06175/T12 1653 Whichards Beach Road SR 1166 Issued 5/13/2016 Washington,NC 27889 Expires 4/30/2021 Lat: 35d 31.3270m Long: 77d 2.8530m Classification Title V SIC: 3732/Boat Building And Repairing Permit Status Active NAICS: 336612/Boat Building Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V David Hardison s David Hardison "` Paul Zawila MACT Part 63: Subpart VVVV Vice President of Vice President of Environmental Engineering Engineering Consultant (252)975-7009 (252)975-7009 (803)336-1086 Compliance Data Comments: The facility appeared to operate in compliance with all applicable air quality regulations and permit conditions at the time of inspection. Inspection Date 05/11/2017 Inspector's Name Yongcheng Chen Inspector's Signature: y„ ,- I Operating Status Operating �' Compliance Code Compliance-inspection Action Code FCE r Date of Signature: 5/18/2017 On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PM10 *HAP 2014 0.2900 --- --- 12.92 --- 0,1500 11680.70 2013 0.2200 --- --- 7.00 --- 0.1100 9162.00 2012 0.0300 --- --- 1.01 0.0100 955.60 *Highest HAP Emitted(in pounds) Five Year Violation History:None Performed Stack Tests since last FCE:None Location Fountain Powerboats, Inc. is located at 1653 Whichards Beach Road, Washington,NC. Traveling 17 South of Washington, approximately 1.5 miles from Washington take a left onto Whichards Beach Road. The facility is located on the left approximately one mile. ✓' G:\AQ\Shared\Beaufort07\00122\INSPECTIONS\2Ol7O5llal6.doc Page 1 of 13 Process Description: Fountain Powerboats manufactures fiberglass boats in open molds. The finished boats are 20-48 feet in length encompassing four(4) brands; Baja, Fountain, Donzi, Pro-Line and Custom Marine.Normal operating hours are: 8-10 hours per day and 4 or 5 days per week. They are currently producing about 8 boats each week with 120 employees. The air permit is going to be split into two Title V permits. One will be for Fountain Powerboats (Pro-Line,will keep the current air permit, with about 40 employees and 40,000 sf area: Building ID Nos. 11 and 15), and one will be for Iconic (Baja, Fountain, Donzi, applied for a new air permit on 4/24/2017, with about 80 employees and 200,000 sf area: Building ID Nos. 3, 4, 5, 10, 16, 17, and 19).Now the two facilities are operating on the same permit (06175 /T12). Fountain . Powerboats (Pro-Line) site is responsible for maintaining compliance of Title V permit 06175 / T12 for both sides. Iconic applied fora new air permit on 4/24/2017. Mr. Tom Moritz asked me when they can expect to get their permit. I told them that a 300 (Title V facility) permit will take 90 days. So they will expect to get the permit within 3 months (before July 24th,2017). The company (Fountain Powerboats) submitted a request on February 22, 2017 to make a 502(b)(10) change to the permit to take off the emission sources Building ID Nos. 3, 4, 5, 10, 16, 17, and 19 from their permit item list. RCO permit section wrote a letter on February 28, 2017 telling the company that they can make the change. RCO will incorporate the changes into the facility's Title V permit. The company must certify compliance with the existing permit terms for the 502(b)(10) change on the annual compliance certification. When I conducted my annual inspection,David Hardison, Vice President of Engineering, Fountain Powerboats (Pro-Line) said they do not want to change the permit now. Mr. Hardison said that the senior administrators changed their minds and do not want to do 502(b)(10) change anymore (just keep the permit as is). He will be responsible for all the compliance for both facilities. I,Yongeheng Chen, gonducted an annual air hermit inspection with the assistance of David Hardison,Vice President of Engineering on May 11, 2017 on Fountain Powerboats(Pro-Line) side, and Tom Klontz, Treasurer, and Steve Wallace, Environmental Manager,of Iconic side. We began with records and documents review and were found to be well organized, complete and thorough. Next we toured the facility and I inspected the control devices and associated duct works. All were well maintained and no visible emissions were observed during our walk around the facility. Safety glasses and hearing protection are required. G:\AQ\Shared\Beaufort07\00122\[NSPECTIONS\201705I IaMdoc Page 2 of 13 LIST OF PERMITTED SOURCES: Emission Source Emission Source Description Control Control Device Device Description Building No. 3 Small Parts Lamination& Mating C-3 Dry filters (ID No. ES-3) (MACT Subpart VVVV) Building ID No. 4 Wood finishing and adhesive C-4 Dry filters (ID No. ES-04) spraying (MACT Subpart VVVV) Building ID No. 5 Deck& Hull Lamination C-5 Dry filters (ID No. ES-5) (MACT Subpart VVVV) Building ID No. 10 Mold Maintanence C-10 Dry filters (ID No. ES-10) (MACT Subpart VVVV) Building ID No. 11 Cruiser Lamination, gel coating C-11 Dry filters (ID No. ES-11) (MACT Subpart VVVV) Building ID No. 15 Tooling C-15 Dry filters (ID No. ES-15) (MACT Subpart VVVV) Building ID No. 16 Paint Booth#1 C-16 Dry filters (ID No. ES-16) Building ID No. 17 Paint Booth#2 C-17 Dry filters (ID No. ES-17) Building ID No. 19 Paint Booth#3 C-19 Dry filters (ID No. ES-19) G:\AQ\Shared\Beaufort07\00122\TNSPECTIONS\20170511 a16.doc Page 3 of 13 Insignificant Activities under 15A NCAC 2Q .0503(8), Permit Number 06175T11 Emission Source Emission Source Description ID I-1 Solvent cleaning operations I 2 Resin storage tank(5,500 gallon capacity) Regulatory Review: 2.1 - EMISSION SOURCES AND CONTROL DEVICES A. Building ID No. 3.(ID No. ES-3; Small Parts Lamination & Mating) This building is used for the manufacture of the small parts; glove boxes, storage boxes, consoles, live wells, etc. The hardware is also installed in this area and the mating (attaching the decks to the hulls) is done. 15A NCAC 2D .0515 - Particulates from Miscellaneous Industrial Processes Particulate matter emissions are controlled by a dry filter system. To ensure compliance, monthly visual inspections of the filter pads are required and the results recorded. Records demonstrate weekly visual inspections are performed and the last recorded visual inspection was completed 4/28/2017. In addition, annual internal inspections for structural integrity of the dry filter system are required and the inspection was completed 2/25/2017. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. 15A NCAC 2D .0521 - Control of Visible Emissions The operation is limited to 20 percent opacity visible emissions. Visible emissions are controlled by a dry filter system. To ensure compliance monthly inspections are required and the results are recorded. Records indicate weekly inspections are performed and the last recorded inspection was completed 1/24/2017. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated There were no visible emissions observed during this inspection Compliance is indicated. G:\AQ\Shared\Beaufort07\00122\INSPECTIONS\2Ol7O5llal6.doe Page 4 of 13 15A NCAC 2D .1806— Control and Prohibition of Odorous Emissions. The facility is required to prevent objectionable odors beyond the facility's boundary. There were no objectionable odors detected during this inspection. There is no history of complaints of objectionable odors involving this facility. Compliance is indicated. B. Building ID No. 4 (ID No. ES-4; Wood Finishing and Adhesive Spraying) This building is used for the cutting of stringers, bulk heads, foam cutting, and gluing foam to plywood parts. 15A NCAC 2D .0512 -Particulates from Miscellaneous Wood Products Finishing Plants Particulate matter emissions are controlled by a dry filter system. To ensure compliance, monthly visual inspections of the filter pads are required and the results recorded. Records demonstrate weekly visual inspections are performed and the last recorded inspection was completed 4/28/2017. In addition, annual internal inspections for structural integrity of the associated ductwork are required and the inspection was completed 2/22/2017. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. w 15A NCAC 2D .0521 - Control of Visible Emissions The operation is limited to 20 percent opacity visible emissions. Visible emissions are controlled by a dry filter system. To ensure compliance monthly inspections are required and the results are recorded. Records indicate weekly inspections are performed and the last recorded inspection was completed 3/18/2017. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. There were no visible emissions observed during this inspection. Compliance is indicated. 15A NCAC 2D .1806— Control and Prohibition of Odorous Emissions. The facility is required to prevent objectionable odors beyond the facility's boundary. There were no objectionable odors detected during this inspection. There is no history of complaints of objectionable odors involving this facility. Compliance is indicated. G:W Q\Shared\Beaufort07\00122\INSPECTIONS\20170511 a 16.doc Page 5 of 13 C. Building ID No. 5 (ID No. ES-5; Deck& Hull Lamination) This building is used for the gel-coating and laminating of the large parts; decks, hulls, liners, etc. 15A NCAC 2D .0515 - Particulates from Miscellaneous Industrial Processes Particulate matter emissions are controlled by a dry filter system. To ensure compliance, monthly visual inspections of the filter pads are required and the results recorded. Records demonstrate weekly visual inspections are performed and the last recorded inspection was completed 4/28/2017. In addition, annual internal inspections for structural integrity of the dry filter system are required and the inspection was completed 2/22/2017. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. 15A NCAC 2D .0521 - Control of Visible Emissions The operation is limited to 20 percent opacity visible emissions.Visible emissions are controlled by a dry filter system. To ensure compliance monthly inspections are required and the results are recorded. Records indicate weekly inspections are performed and the last recorded inspection was completed 4/28/2017. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. There were no visible emissions observed during this inspection Compliance is indicated. 15A NCAC 2D .1806—Control and Prohibition of Odorous Emissions. The facility is required to prevent objectionable odors beyond the facility's boundary. There were no objectionable odors detected during this inspection. There is no history of complaints of objectionable odors involving this facility. Compliance is indicated. D. Building ID NO. 10 (ID No. ES-10; Mold Maintenance) This building is used for mold preparation(waxing) and repair of molds. 15A NCAC 2D .0515 - Particulates from Miscellaneous Industrial Processes Particulate matter emissions are controlled by a dry filter system. To ensure compliance, monthly visual inspections of the filter pads are required and the results recorded. In addition, annual internal inspections for structural integrity of the dry filter system are required. This permitted source is not in operation and is used for storage. Compliance is indicated. G:\AQ\Shared\Beaufort07\00122\[NSPECTIONS\201705I106.doc Page 6 of 13 r A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. 15A NCAC 2D .0521 - Control of Visible Emissions The operation is limited to 20 percent opacity visible emissions. Visible emissions are controlled by a dry filter system. To ensure compliance monthly inspections are required and the results are recorded. This permitted source is not in operation and is used for storage. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. There were no visible emissions observed during this inspection Compliance is indicated. 15A NCAC 2D .1806—Control and Prohibition of Odorous Emissions. The facility is required to prevent objectionable odors beyond the facility's boundary. There were no objectionable odors detected during inspection. There is no history of complaints of objectionable odors involving this facility. Compliance is indicated. E. Building ID No. 11 (ID No. ES-11; Cruiser Lamination) This building is used for the gel-coating, laminating, and assembly of decks and hulls of cruisers. 15A NCAC 2D .0515- Particulates from Miscellaneous Industrial Processes Particulate matter emissions are controlled by a dry filter system. To ensure compliance, monthly visual inspections of the filters are required and the results recorded. In addition, annual internal inspections for structural integrity of the dry filter system are required. This permitted - source is not in operation and used for storage. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. 15A NCAC 2D .0521 - Control of Visible Emissions The operation is limited to 20 percent opacity visible emissions. Visible emissions are controlled by a dry filter system. To ensure compliance monthly inspections are required and the results are recorded. This permitted source is not in operation and used for storage. Compliance is indicated. GAAQ\Shared\Beaufort07\00122\INSPECTIONS\201705I laMdoc Page 7 of 13 �j A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. There were no visible emissions observed during this inspection Compliance is indicated. 15A NCAC 2D .1806—Control and Prohibition of Odorous Emissions. The facility is required to prevent objectionable odors beyond the facility's boundary. There were no objectionable odors detected during this inspection. There is no history of complaints of objectionable odors involving this facility. Compliance is indicated. F. Building ID No. 15 (ID No. ES-15; Tooling) This building is used for the manufacture of the molds or tooling. 15A NCAC 2D .0515 - Particulates from Miscellaneous Industrial Processes Particulate matter emissions are controlled by a dry filter system. To ensure compliance, monthly visual inspections of the filters are required and the results recorded. In addition, annual internal inspections for structural integrity of the dry filter system are required. This permitted source is not in operation and is used for storage. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. 15A NCAC 2D .0521 - Control of Visible Emissions The operation is limited to 20 percent opacity visible emissions. Visible emissions are controlled by a dry filter system. To ensure compliance monthly inspections are required and the results are recorded. This permitted source is not in operation. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. There were no visible emissions observed during this inspection Compliance is indicated. 15A NCAC 2D .1806—Control and Prohibition of Odorous Emissions. The facility is required to prevent objectionable odors beyond the facility's boundary. There were no objectionable odors detected during this inspection. There is no history of complaints of objectionable odors involving this facility. Compliance is indicated. G:\AQ\Shared\Beaufort07\00122\INSPECTIONS\2017051la16.doc Page 8 of 13 G. Building ID No. 16 (ID No. ES-16; Paint Booth #1) This building is used for the preparation and painting of boats. 15A NCAC 2D .0515 - Particulates from Miscellaneous Industrial Processes Particulate matter emissions are controlled by a dry filter system. To ensure compliance, monthly visual inspections of the filters are required and the results recorded. Records demonstrate weekly visual inspections are performed and the last recorded inspection was completed 1/28/2017. In addition, annual internal inspections for structural integrity of the dry filter system are required and the inspection was completed 2/22/2017. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. 15A NCAC 2D .0521 - Control of Visible Emissions The operation is limited to 20 percent opacity visible emissions. Visible emissions are controlled by a dry filter system. To ensure compliance monthly inspections are required and the results are recorded. Records indicate weekly inspections are performed and the last recorded inspection was completed 1/28/2017. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. There were no visible emissions observed during this inspection Compliance is indicated. 15A NCAC 2D .1806—Control and Prohibition of Odorous Emissions. The facility is required to prevent objectionable odors beyond the facility's boundary. There were no objectionable odors detected during this inspection. There is no history of complaints of objectionable odors involving this facility. Compliance is indicated. H. Building ID No. 17 (ID No. ES-17; Paint Booth #2) This building is used for the preparation and painting of small parts. 15A NCAC 2D .0515 - Particulates from Miscellaneous Industrial Processes Particulate matter emissions are controlled by a dry filter system. To ensure compliance, monthly visual inspections of the filters are required and the results recorded. In addition, annual internal inspections for structural integrity of the dry filter system are required. This permitted source is not in operation. Compliance is indicated. G:\AQ\Shared\Beaufort07\00122\INSPECTIONS\20170511 a16.doc Page 9 of 13 A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. 15A NCAC 2D .0521 - Control of Visible Emissions The operation is limited to 20 percent opacity visible emissions.Visible emissions are controlled by a dry filter system. To ensure compliance monthly inspections are required and the results are recorded. This permitted source is not in operation. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. There were no visible emissions observed during this inspection Compliance is indicated. 15A NCAC 2D .1806—Control and Prohibition of Odorous Emissions. The facility is required to prevent objectionable odors beyond the facility's boundary. There were no objectionable odors detected during this inspection. There is no history of complaints of objectionable odors involving this facility. Compliance is indicated. L Building ID No. 19 (ID No. ES-19; Paint Booth #3) This building is used for the preparation and painting of boats. 15A NCAC 2D .0515 -Particulates from Miscellaneous Industrial Processes Particulate matter emissions are controlled by a dry filter system. To ensure compliance, monthly visual inspections of the filters are required and the results recorded. Records demonstrate weekly visual inspections are performed and the last recorded inspection was completed 1/28/2017. In addition, annual internal inspections for structural integrity of the dry filter system are required and the inspection was completed 2/22/2017. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. 15A NCAC 2D .0521 - Control of Visible Emissions The operation is limited to 20 percent opacity visible emissions. Visible emissions are controlled by a dry filter system. To ensure compliance monthly inspections are required and the results are recorded. Records indicate weekly inspections are performed and the last recorded inspection was completed 4/28/2017. Compliance is indicated. G:\AQ\Shared\Beaufort07\00122\INSPECTIONS\20170511aM.doc Page 10 of 13 A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. There were no visible emissions observed during this inspection Compliance is indicated. 15A NCAC 2D .1806—Control and Prohibition of Odorous Emissions. The facility is required to prevent objectionable odors beyond the facility's boundary. There were no objectionable odors detected during this inspection. There is no history of complaints of objectionable odors involving this facility. Compliance is indicated. 2.2 - MULTIPLE EMISSION SOURCES A. All Emission Sources 15A NCAC 2Q .0317: Avoidance Conditions This condition allows for the avoidance of PSD by limiting facility wide VOC emissions to less than 250 tons per consecutive 12-month period(PSD minor). The facility is required to calculate and record monthly VOC emissions. A review of the log book indicated that VOC emissions were 42.11 tons for 2016. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The emissions must be calculated for each of the 12-month periods over the past 17 months. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. 15A NCAC 2D .0958 -Work Practices for Sources of Volatile Organic Compounds The VOC usage at this facility is subject to this Rule. The facility must comply with the work practice standards in 2D .0958 (c) and the parts cleaning standards of 2D .0958 (d). To ensure compliance,monthly inspections are performed and the results are recorded. Records indicate the last inspection was completed 4/28/2017. Compliance is indicated. A semiannual report is required by January 30 and July 30 of each calendar year. The 2016 reports have been submitted as required and indicate compliance. The last report was received on 1/24/2017. Compliance is indicated. There were no rags left out, neither open containers nor other compliance issues observed during this inspection. Compliance is indicated. G:\AQ\Shared\Beaufort07\00122\INSPECTIONS\2017051 N16.doc Page 11 of 13 15A NCAC 2Q .0711 - Toxic Air Pollutants Emissions Limitation Requirement In accordance with the permit,the Permittee shall maintain records of operational information demonstrating that the TAP emissions do not exceed the TPERs as listed below: TPERs Limitations Pollutant Carcinogen Chronic Acute Systemic Acute (CAS Number) s Toxicants Toxicants Irritants (lb/yr) (lb/day) lb/hr (lb/hr) Ethyl Acetate 36 (141-78-6) Methyl Ethyl Ketone 78 22.4 (78-93-3) Methyl Isobutyl Ketone 52 7.6 (108-10-1 Toluene 98 14.4 (108-88-3 Xylene 57 16.4 1330-20-7 Formaldehyde 0.04 (50-0-0 n-Hexane 23 110-54-3) A review of the records indicated emission rates are well below the TPERs. Compliance is indicated. 15A NCAC 2D .1100 - Toxic Air Pollutants Emissions Limitation Requirement For each of the below listed TAP's,the facility shall not exceed the modeled emission limits: EMISSION SOURCE TOXIC AIR EMISSION MAXIMUUM POLLUTANT LIMIT ACTUAL Building No. 3 (ID No. ES-3), Styrene (100-42-5) 82.6 lb/hr 13.0 lb/hr Building No. 5 (ID No. ES-5), Building No. 11 (ID No. ES-11), Building No. 15 ID No. ES-15 Building No. 4 (ID No. ES-4) Methylene 1.41 lb/hr 0 Chloride 75-09-2) Building Nos. 16, 17, and 19 Styrene (100-42-5) 1.00 lb/hr <0.01 (ID Nos. ES-16, 17, and 19) To demonstrate compliance, the facility is required to report within 30 days after each calendar year quarter, the maximum emission rate of each TAP listed above from the various sources. G:\AQ\Shared\Bcaufort07\00122\INSPECTIONS\20170511a16.doc Page 12 of 13 r � The 2016 reports have been submitted as required and indicate compliance with the emission limits. The last report was received on 1/24/2017. Compliance is indicated. B. 15A NCAC 2D .1111 —MACT - 40 CFR Part 63, Subpart VWV The facility is complying with the open molding emission limit by using the emissions averaging option. They must assure that the emission limit established by 40 CFR 63.5698, equation 1, is not exceeded using the procedures set in 40 CFR 63.5704(a). Compliance using the emissions averaging option is demonstrated on a 12-month rolling-average basis and is determined at the end of every month(12 times per year). The effective date was August, 2005. The facility had one year to collect data since it is a 12-month rolling standard. For the fabric adhesive operations, the HAP content has to be < 5%to comply with the MACT. The effective date was August, 2004. Fountain Powerboats submitted the initial notification requirement for the NESHAP on December 14, 2001. The facility is required to submit reports for each 6-month period ending on July 30 and December 31. The report must evaluate compliance with the open molding emission limit for each 12-month averaging period ending on each 6-month that the report covers. The report must be submitted within 60 days after the end of the reporting period. The 2016 reports have been submitted as required and indicate compliance with the open molding emission limit. The last report was received on 1/24/2017. For the 12- month period ending December 2016 the NESHAP HAP limit is 8.99 tons and the MACT Model Point is 7.93 tons. Compliance is indicated. Monitoring/Recordkeeping/Reporting: The facility monitoring/recordkeeping/reporting requirements have been met as noted above in the regulatory review. I reviewed the records at the facility for the past 12 months for 2016. NESHAP HAP limit is 9.60 tons and the MACT Model Point is 7.21 tons. Compliance was indicated. Compliance history (5-years): There have been no compliance issues. Comments, Conclusions and Recommendations: The facility appeared to operate in compliance with all applicable air quality regulations and permit conditions at the time of inspection. G:\AQ\Shared\Beaufort07\00122\INSPECTIONS\2Ol7O5llal6.doc Page 13 of 13