AQ_F_0700151_20170719_PRMT_PmtRvw

NORTH CAROLINA DIVISION OF Region: Washington Regional Office
AIR QUALITY County: Beaufort
Application Review NC Facility ID: 0700151
Inspector's Name:
Issue Date:July 19,2017 Date of Last Inspection: N/A
Com liance Code: N/A
Facility Data Permit Applicability(this application only)
Applicant(Facility's Name): Iconic Marine Group,LLC SIP: 02D .0512,.0515,.0521, .1806, .1111
NSPS:
Facility Address: NESHAP: Subpart VVVV
Iconic Marine Group,LLC PSD:
1653 Whichards Beach Road PSD Avoidance: 02Q.0317
Washington,NC 27889 NC Toxics: 02D.1100,02Q.0711,
112(r):
SIC:3732/Boat Building And Repairing Other:Remove 2D.0958
NAICS: 336612/Boat Building
Facility Classification: Before: Permit/Registration Pending After: Title V
Fee Classification: Before: N/A After: Title V
Contact Data Application Data
Facility Contact Authorized Contact Technical Contact Application Number: 0700151.17A
Mike Fryer Mike Fryer Tom Klontz Date Received: 04/07/2017
Vice President of Vice President of Treasurer Application Type: New Permit
Operations Operations [phone] Application Schedule: State
[phone] [phone] PO Drawer 457 Existing Permit Data
PO Drawer 457 PO Drawer 457 Washington,NC 27889 Existing Permit Number: N/A
Washington,NC 27889 Washington,NC 27889
Existing Permit Issue Date: N/A
Existing Permit Expiration Date: N/A
Total Actual emissions in TONS/YEAR:
CY S02 NOX voC Co PM10 Total HAP Largest HAP
<No Inventory>
Review Engineer: Charles F. Yirka Comments/Recommendations:
Issue 10534/R00
Review Engineer's Signature• Date: July 19,2017 Permit Issue Date: July 19,2011
/ Permit Expiration Date: June 30,2025
Page 1 of 13

1. Purpose of Application:
Iconic Marine Group, LLC (Iconic Marine) submitted a Title V permit application for their
existing Washington Plant. Due to separation of different brands,the Fountain Powerboats, Inc.
(Fountain)Washington facility,existing operations will be re-permitted into two separate air
permits. The application indicates there are no new or modified sources with this modification.
Existing Title V Air Permit 06175T12 for Fountain will be revised to only cover emissions
sources Building 11 (ID No.ES-11)and Building 15 (ID No.ES-15)1. This TV permit is being
issued pursuant to 2Q .0300 as allowed under 2Q .0504.
Iconic Marine is leasing and owns and operates the emission units at the other sites areas and is
submitting this application for a separate air permit for Buildings 3 (ID No.ES-3),4(ID No.ES-
4), 5 (ID No.ES-5), 10(ID No.ES-10), 16(ID No.ES-16), 17 (I )No.ES-17), and 19(ID No.
ES-19)2. Fountain retains ownership of the emission units Building 11 (ID No.ES-11)and
Building 1 No.ES-15 as well as still owns the building structures as well as the land.
d 5 ) g
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In assuming control of most of Fountain's operations Iconic Marine will remain a Title V major_
source with a PTE of over 100 tons per year of VOCs and remains a major source of HAPs and
therefore remains subject to 40 CFR Part 63, Subpart VVVV.
2. Facility Description
As per the last inspection report dated July, 21,2016 performed by the Washington Regional
P P P Y
Office(WaRO), Fountain 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
currentlyproducing about 8 boats each week with 120 employees.
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Four(4)of the permitted sources have not been in operation since 2012 (Building ID Nos. 10, 11,
15, and 17)and are currently used for storage. The inspection began with records and documents
review and were found to be well organized, complete and thorough. The facility's control
devices and associated duct works were also inspected. According to the inspection everything
was well maintained. No visible emissions were observed during the inspection of the facility.
3. Application Chronology/History
ay 6,2016 Iconic Marine Group, LLC was formed per the Department of Secretary of State
website https://www.sosnc.gov/search/index/core
ay 13, 2016 Renewal issued to Fountain 06175T12 by Ms. Jenny Sheppard of the Raleigh
Central Office(RCO).
my 14, 2016 Last facility inspection report for Fountain issued by Mr. Steven Daniels of the
WaRO. Facility was found to be in compliance.
The DAQ's Permitting Section issued a 502(bx10)letter on February 28,2017 to Fountain approving the removal
from the permit of those emissions sources transferred to Iconic Marine. .
z This review does not include a determination of whether a"common control"relationship exists between different
entities(Fountain Power Boats,Inc.and Iconic Marine Group,LLC). The Section was convinced a relationship no
longer exists.
Page 2 of 13

February 24, 2017 A 502(b)(10)notification of upcoming change was received for the removal of
sources from Fountain's permit.
February 28, 2017 A 502(b)(10)notification acknowledgment was issued to Fountain for the removal
of emissions sources from Fountain's permit.
April 7, 2017 Permit application 0700122.14A was received from Iconic Marine for a state 02Q
.300 permit modification to transfer sources from Fountain's permit to Iconic
Marine's new permit.
ay 3, 2017 State air toxic air pollutant modeling was submitted by this engineer to Mr. Tom
Anderson Supervisor of the Air Quality Analysis Branch(AQAB).
ay 13, 2017 Additional information received from Mr. Paul Zawali consultant for Value
Environmental representing Iconic Marine concerning state air toxic air pollutant
modeling. Mr. Zawali indicated the s ene emissions allocated to Iconic should be
half of what is presently allowed. See Condition 2.2.A.4.
May 17, 2017 State air toxic modeling of the facility was approved by Mr. Alex Zarnowski of the
AQAB. Additional modeling was not required as the original modeling used a
word-case stack scenario with styrene emissions being emitted from a worst-case
stack. The proposed facility would split the facility-wide styrene emissions through
two separate sources. Thus,the modeled impact would not be higher than the
worst-case-stack scenario.
June 19, 2017 Draft permit and review was submitted for comment to Mr. Joe Voelker,Acting
Title V supervisor for review.
June 26,2017 Comments received on the draft permit and review from Mr. Joe Voelker,Acting
Title V supervisor.
my 5, 2017 Draft permit and review was submitted for comment to Mr. Yongcheng Chen and
Robert Bright of the WaRO,Mr. Zawali of Value Environmental, Mr. Samir
Parekh of the Stationary Source Compliance Branch(SSCB)
my 19,2017 Permit issued
4. Regulatory Review
Iconic Marine in assuming control of most of Fountain operations and will subject to the
following regulations:
15A NCAC 02D .0512-Particulates from Miscellaneous Wood Products Finishing Plants
15A NCAC 02D .0515-Particulates from Miscellaneous Industrial Processes
15A NCAC 02D .0521-Control of Visible Emissions
15A NCAC 02Q .0711-Toxic Air Pollutants Emissions Limitation Requirement
Page 3 of 13

*I 5A NCAC 02D .0958-Work Practices for Sources of Volatile Organic Compounds
15A NCAC 02Q .0317 -Avoidance Conditions
15A NCAC 02D .1100 -Toxic Air Pollutants Emissions Limitation Requirement
15A NCAC 02D .I I I I -40 CFR 63, Subpart VVVV;National Emission Standards for
Hazardous Air Pollutants for Boat Manufacturing
15A NCAC 02D .1806—Control and Prohibition of Odorous Emissions
* This regulation no longer applies.
Based on the Fountain facility's most recent compliance inspection,the facility was in
compliance with all applicable Air Quality regulations. In assuming control, Iconic Marine shall
assume all regulatory obligations including all the required monitoring,recordkeeping and
reporting associated with the SIP regulations, state air toxics regulations, and the MACT for the
specific affected sources as indicated below:
Emission Source Emission Source Description Control Control Device
Device Description
Building No. 3
ES-3 Small Parts Lamination&Mating C-3 Dry filters
MACT Subpart
VVVV
Building ID No.4
ES4 Wood finishing and adhesive C-4 Dry filters
MACT Subpart spraying
VVVV
Building ID No. 5
ES-5 Deck&Hull Lamination C-5 Dry filters
MACT Subpart
VVVV
Building ID No. 10
ES-10 Mold Maintenance C-10 Dry filters
MACT Subpart
VVVV
Building ID No. 16
ES-16 Paint Booth#1 C-16 Dry filters
Building ID No. 17
ES-17 Paint Booth#2 C-17 Dry filters
Building ID No. 19
ES-19 Paint Booth#3 C-19 Dry filters
Page 4 of 13

A detailed regulatory review for Iconic Marine, based on the last inspection report
performed by WaRO for Fountain, follows:
Specific 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 02D .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 June 30,2016. In addition, annual internal inspections for structural integrity of the
dry filter system are required and,as of the last inspection report,the last inspection was
completed March 2, 2016. Continued compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .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 June 30,2016. Compliance is indicated.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26,2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
expected.
15A NCAC 02D .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. Continued compliance is expected.
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 02D .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
Page 5 of 13

demonstrate weekly visual inspections are performed and the last recorded inspection was
completed June 30,2016. In addition,annual internal inspections for structural integrity of the
associated ductwork are required and, as of the last inspection report,the inspection was
completed March 2,2016. Continued compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .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 June 30,2016. Continued compliance is indicated.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
expected.
15A NCAC 02D .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. Continued compliance is expected.
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 02D .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 June 30, 2016. In addition,annual internal inspections for structural integrity of the
dry filter system are required and the inspection was completed March 2, 2016. Continued
compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26,2016. Continued compliance is expected.
15A NCAC 02D .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 June 30, 2016. Continued compliance is expected.
Page 6 of 13

A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
indicated.
15A NCAC 02D .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. Continued compliance is expected.
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 02D .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. Continued compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .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. Continued
compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26,2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
expected.
15A NCAC 02D .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. Continued compliance is expected.
E. Building ID No. 16(ID No. ES-16; Paint Booth#1)
This building is used for the preparation and painting of boats.
Page 7 of 13

15A NCAC 02D .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 June 30,2016. In addition,annual internal inspections for structural integrity of the
dry filter system are required and the inspection was completed March 2, 2016. Continued
compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .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 June 30,2016. Continued compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26,2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
expected.
15A NCAC 02D .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 the inspection. There is no history of complaints of
objectionable odors involving this facility. Continued compliance is expected.
F. 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 02D .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. Continued compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .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 expected.
Page 8 of 13

A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26,2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
expected.
15A NCAC 02D .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. Continued compliance is expected.
G. Building ID No. 19 (ID No. ES-19; Paint Booth #3)
This building is used for the preparation and painting of boats.
15A NCAC 02D .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 June 30,2016. In addition,annual internal inspections for structural integrity of the
dry filter system are required and the inspection was completed March 2, 2016. Continued
compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .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 June 30,2016. Continued compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
expected.
15A NCAC 02D .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. Continued compliance is expected.
Page 9 of 13

Multiple Emission Sources
A. All Emission Sources
15A NCAC 02Q .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 13.10 tons from June, 2015 through May, 2016. Continued
compliance is expected.
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 2015 and 2016
reports have been submitted as required and indicate compliance. The last report was received
on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .0958-Work Practices for Sources of Volatile Organic Compounds
This regulation no longer applies.
15A NCAC 02Q .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 Carcinog Chronic Acute Systemic Acute
(CAS Number) ens Toxicants Toxicants Irritants
lb/ (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
As per the last inspection a review of the records indicated emission rates are well below the
TPERs. Continued compliance is expected.
Page 10 of 13

15A NCAC 02D .1100-Toxic Air Pollutants Emissions Limitation Requirement
For each of the below listed TAP's,the facility shall not exceed the modeled emission_limits as
indicated by strikethrough and highlighting:
EMISSION SOURCE TOXIC AIR EMISSI MAXIMUUM
POLLUTANT ON ACTUAL
LIMIT (lb/hr)
(lb/hr)
Building No. 3 (ID No. ES-3), Styrene (100-42-5) 8-2-.6 13.0*
Building No. 5 (ID No. ES-5), 41.3
44+
OUr�'�Ai n
Building No. 4(ID No. ES-4) Methylene 1.41 0*
Chloride 75-09-2 lb/hr
Building Nos. 16, 17, and 19 Styrene(100-42-5) 1.00 <0.01*
ID Nos. ES-16, 17, and 19) lb/hr
*Eountain-emmiom-from last inspection•
Notes: See May 13,2017 email from Mr. Zawila of Value Engineering outlining the allocation of
styrene emissions for Iconic Marine and Fountain.
To demonstrate compliance,the facility is required to report within 30 days after each calendar
year auar�er, the maximum emission rate of each TAP listed above from a various sources.
The 2015 and 2016 reports have been submitted as required and indicate compliance with the
emission limits. The last report was received on April 29, 2016. Continued compliance is
expected.
15A NCAC 02D .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 submitted the initial notification requirement for the NESHAP on December 14, 2001.
Iconic Marine submitted the initial notification requirement for the NESHAP on March 31, 2017.
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 months that the report covers. The report must
be submitted within 60 days after the end of the reporting period.
Page 11 of 13

The 2015 and 2016 reports have been submitted as required and indicate compliance with the
open molding emission limit. The last report was received on January 26,2016. For the 12-
month period ending December 2015 the NESHAP HAP limit is 8.99 tons and the MACT Model
Point is 7.57 tons. Continued compliance is expected.
Monitoring/Recordkeeping/Reporting:
The facility monitoring/recordkeeping/reporting requirements have been met as noted above in
the regulatory review. WaRO reviewed the records at the facility for the past 12 months from
June 2015 through May 2016. The NESHAP's HAP limit is 9.60 tons and the MACT Model
Point is 8.13 tons. Continued compliance is expected.
Compliance history(5-years):
There have been no compliance issues.
WaRO 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. The facility was last inspected on July 14, 2016 by
Mr. Steven Daniels of the WaRO and found to be in compliance at the time of the inspection.
5. NSPS/ PSD/NAA/Increment/ MACT/CAM/ CAM/ Facility Wide Toxic Air Pollutants
• NSPS -This facility is not currently subject to any NSPS regulations.
• PSD/NAA/Increment-This facility is a Prevention of Significant Deterioration(PSD)minor
source. Iconic Marine shall assume the PSD avoidance condition and is responsible for the
associated monitoring,recordkeeping and reporting including assuming those from Fountain e.g.,
rolling averages of VOC emissions. Beaufort County is an in-attainment area and the non-
attainment(NAA)regulations do not apply. Beaufort County has been triggered for PSD
increment tracking for PM10, S02 and NOx. A review of the total PM10,the only increment
consumed, is less than 1 pound per hour:
Building PM10 actual emissions (pounds/hour)
Building 3 0.07
Building 4 0.00
Building 5 0.43
Building 10 0.00
Building 16 0.01
Building 17 0.01
Building 19 0.01
Total PM10 0.53
Therefore,no increment is consumed by Iconic Marine.
• MACT-This facility is subject to 40 CFR 63, Subpart VVVV(Boat Manufacturing MACT).
Iconic Marine shall assume the MACT conditions from Fountain and is responsible for the
associated monitoring,recordkeeping and reporting. This includes assuming the monitoring,
recordkeeping and reporting from Fountain and the periodic reporting of emissions(e.g., rolling
averages of HAP emissions,etc.).
Page 12 of 13

• 112(r) -This facility is not subject to 112(r).
• CAM-This facility is not subject to CAM.
• Facility Wide Toxic Air Pollutants-This modification did not trigger toxics review. However,
the Fountain facility was previously required to provide a facility-wide toxics compliance
demonstration as Subpart VVVV was their last applicable MACT. This demonstration included
those sources that were not subject or exempt from the MACT. As such,the Iconic Marine
facility has satisfied their last MACT demonstration. Iconic Marine shall assume the conditions,
including their new proposed limits associated with 02Q .1100 and 02D .0711 and is responsible
for the associated monitoring,recordkeeping and reporting including assuming those from
Fountain e.g., recordkeeping and reporting, etc.
A review of the existing state air toxic modeling of the facility was conducted and approved by
Mr. Alex Zarnowski of the AQAB approved on May 17,2017. Additional modeling was not
required as the original modeling used a worst-case stack scenario with styrene emissions being
emitted from the worst-case stack. Iconic Marine has proposed to flit the facility-wide styrene
emissions,with half assigned to Iconic Marine and half assigned to Fountain. Thus,the modeled
impact from Iconic Marine would not be higher than the worst-case-stack scenario.
5. Public Notice/EPA and Affected State(s)Review
Not required at this time.The Permittee shall file a Title V Air Quality Permit Application
pursuant to 15A NCAC 02Q .0504 on or before 12 months after assuming operation.
6. RCO Conclusions,Comments,and Recommendations:
Changes to the WEE equipment database were approved by Ms. Jenny Shepard on July 18,
g
2017.
A professional engineer's seal was not required for this permit modification.
A consistency determination was not required for this permit modification.
WaRO recommends issuance of Permit No. 10534R00.
Recommend issuance of Permit No. 10534R00.
Page 13 of 13

NORTH CAROLINA DIVISION OF Region: Washington Regional Office
AIR QUALITY County: Beaufort
Application Review NC Facility ID: 0700151
Inspector's Name:
Issue Date:July 19,2017 Date of Last Inspection: N/A
Com liance Code: N/A
Facility Data Permit Applicability(this application only)
Applicant(Facility's Name): Iconic Marine Group,LLC SIP: 02D .0512,.0515,.0521, .1806, .1111
NSPS:
Facility Address: NESHAP: Subpart VVVV
Iconic Marine Group,LLC PSD:
1653 Whichards Beach Road PSD Avoidance: 02Q.0317
Washington,NC 27889 NC Toxics: 02D.1100,02Q.0711,
112(r):
SIC:3732/Boat Building And Repairing Other:Remove 2D.0958
NAICS: 336612/Boat Building
Facility Classification: Before: Permit/Registration Pending After: Title V
Fee Classification: Before: N/A After: Title V
Contact Data Application Data
Facility Contact Authorized Contact Technical Contact Application Number: 0700151.17A
Mike Fryer Mike Fryer Tom Klontz Date Received: 04/07/2017
Vice President of Vice President of Treasurer Application Type: New Permit
Operations Operations [phone] Application Schedule: State
[phone] [phone] PO Drawer 457 Existing Permit Data
PO Drawer 457 PO Drawer 457 Washington,NC 27889 Existing Permit Number: N/A
Washington,NC 27889 Washington,NC 27889
Existing Permit Issue Date: N/A
Existing Permit Expiration Date: N/A
Total Actual emissions in TONS/YEAR:
CY S02 NOX voC Co PM10 Total HAP Largest HAP
<No Inventory>
Review Engineer: Charles F. Yirka Comments/Recommendations:
Issue 10534/R00
Review Engineer's Signature• Date: July 19,2017 Permit Issue Date: July 19,2011
/ Permit Expiration Date: June 30,2025
Page 1 of 13

1. Purpose of Application:
Iconic Marine Group, LLC (Iconic Marine) submitted a Title V permit application for their
existing Washington Plant. Due to separation of different brands,the Fountain Powerboats, Inc.
(Fountain)Washington facility,existing operations will be re-permitted into two separate air
permits. The application indicates there are no new or modified sources with this modification.
Existing Title V Air Permit 06175T12 for Fountain will be revised to only cover emissions
sources Building 11 (ID No.ES-11)and Building 15 (ID No.ES-15)1. This TV permit is being
issued pursuant to 2Q .0300 as allowed under 2Q .0504.
Iconic Marine is leasing and owns and operates the emission units at the other sites areas and is
submitting this application for a separate air permit for Buildings 3 (ID No.ES-3),4(ID No.ES-
4), 5 (ID No.ES-5), 10(ID No.ES-10), 16(ID No.ES-16), 17 (I )No.ES-17), and 19(ID No.
ES-19)2. Fountain retains ownership of the emission units Building 11 (ID No.ES-11)and
Building 1 No.ES-15 as well as still owns the building structures as well as the land.
d 5 ) g
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In assuming control of most of Fountain's operations Iconic Marine will remain a Title V major_
source with a PTE of over 100 tons per year of VOCs and remains a major source of HAPs and
therefore remains subject to 40 CFR Part 63, Subpart VVVV.
2. Facility Description
As per the last inspection report dated July, 21,2016 performed by the Washington Regional
P P P Y
Office(WaRO), Fountain 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
currentlyproducing about 8 boats each week with 120 employees.
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Four(4)of the permitted sources have not been in operation since 2012 (Building ID Nos. 10, 11,
15, and 17)and are currently used for storage. The inspection began with records and documents
review and were found to be well organized, complete and thorough. The facility's control
devices and associated duct works were also inspected. According to the inspection everything
was well maintained. No visible emissions were observed during the inspection of the facility.
3. Application Chronology/History
ay 6,2016 Iconic Marine Group, LLC was formed per the Department of Secretary of State
website https://www.sosnc.gov/search/index/core
ay 13, 2016 Renewal issued to Fountain 06175T12 by Ms. Jenny Sheppard of the Raleigh
Central Office(RCO).
my 14, 2016 Last facility inspection report for Fountain issued by Mr. Steven Daniels of the
WaRO. Facility was found to be in compliance.
The DAQ's Permitting Section issued a 502(bx10)letter on February 28,2017 to Fountain approving the removal
from the permit of those emissions sources transferred to Iconic Marine. .
z This review does not include a determination of whether a"common control"relationship exists between different
entities(Fountain Power Boats,Inc.and Iconic Marine Group,LLC). The Section was convinced a relationship no
longer exists.
Page 2 of 13

February 24, 2017 A 502(b)(10)notification of upcoming change was received for the removal of
sources from Fountain's permit.
February 28, 2017 A 502(b)(10)notification acknowledgment was issued to Fountain for the removal
of emissions sources from Fountain's permit.
April 7, 2017 Permit application 0700122.14A was received from Iconic Marine for a state 02Q
.300 permit modification to transfer sources from Fountain's permit to Iconic
Marine's new permit.
ay 3, 2017 State air toxic air pollutant modeling was submitted by this engineer to Mr. Tom
Anderson Supervisor of the Air Quality Analysis Branch(AQAB).
ay 13, 2017 Additional information received from Mr. Paul Zawali consultant for Value
Environmental representing Iconic Marine concerning state air toxic air pollutant
modeling. Mr. Zawali indicated the s ene emissions allocated to Iconic should be
half of what is presently allowed. See Condition 2.2.A.4.
May 17, 2017 State air toxic modeling of the facility was approved by Mr. Alex Zarnowski of the
AQAB. Additional modeling was not required as the original modeling used a
word-case stack scenario with styrene emissions being emitted from a worst-case
stack. The proposed facility would split the facility-wide styrene emissions through
two separate sources. Thus,the modeled impact would not be higher than the
worst-case-stack scenario.
June 19, 2017 Draft permit and review was submitted for comment to Mr. Joe Voelker,Acting
Title V supervisor for review.
June 26,2017 Comments received on the draft permit and review from Mr. Joe Voelker,Acting
Title V supervisor.
my 5, 2017 Draft permit and review was submitted for comment to Mr. Yongcheng Chen and
Robert Bright of the WaRO,Mr. Zawali of Value Environmental, Mr. Samir
Parekh of the Stationary Source Compliance Branch(SSCB)
my 19,2017 Permit issued
4. Regulatory Review
Iconic Marine in assuming control of most of Fountain operations and will subject to the
following regulations:
15A NCAC 02D .0512-Particulates from Miscellaneous Wood Products Finishing Plants
15A NCAC 02D .0515-Particulates from Miscellaneous Industrial Processes
15A NCAC 02D .0521-Control of Visible Emissions
15A NCAC 02Q .0711-Toxic Air Pollutants Emissions Limitation Requirement
Page 3 of 13

*I 5A NCAC 02D .0958-Work Practices for Sources of Volatile Organic Compounds
15A NCAC 02Q .0317 -Avoidance Conditions
15A NCAC 02D .1100 -Toxic Air Pollutants Emissions Limitation Requirement
15A NCAC 02D .I I I I -40 CFR 63, Subpart VVVV;National Emission Standards for
Hazardous Air Pollutants for Boat Manufacturing
15A NCAC 02D .1806—Control and Prohibition of Odorous Emissions
* This regulation no longer applies.
Based on the Fountain facility's most recent compliance inspection,the facility was in
compliance with all applicable Air Quality regulations. In assuming control, Iconic Marine shall
assume all regulatory obligations including all the required monitoring,recordkeeping and
reporting associated with the SIP regulations, state air toxics regulations, and the MACT for the
specific affected sources as indicated below:
Emission Source Emission Source Description Control Control Device
Device Description
Building No. 3
ES-3 Small Parts Lamination&Mating C-3 Dry filters
MACT Subpart
VVVV
Building ID No.4
ES4 Wood finishing and adhesive C-4 Dry filters
MACT Subpart spraying
VVVV
Building ID No. 5
ES-5 Deck&Hull Lamination C-5 Dry filters
MACT Subpart
VVVV
Building ID No. 10
ES-10 Mold Maintenance C-10 Dry filters
MACT Subpart
VVVV
Building ID No. 16
ES-16 Paint Booth#1 C-16 Dry filters
Building ID No. 17
ES-17 Paint Booth#2 C-17 Dry filters
Building ID No. 19
ES-19 Paint Booth#3 C-19 Dry filters
Page 4 of 13

A detailed regulatory review for Iconic Marine, based on the last inspection report
performed by WaRO for Fountain, follows:
Specific 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 02D .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 June 30,2016. In addition, annual internal inspections for structural integrity of the
dry filter system are required and,as of the last inspection report,the last inspection was
completed March 2, 2016. Continued compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .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 June 30,2016. Compliance is indicated.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26,2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
expected.
15A NCAC 02D .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. Continued compliance is expected.
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 02D .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
Page 5 of 13

demonstrate weekly visual inspections are performed and the last recorded inspection was
completed June 30,2016. In addition,annual internal inspections for structural integrity of the
associated ductwork are required and, as of the last inspection report,the inspection was
completed March 2,2016. Continued compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .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 June 30,2016. Continued compliance is indicated.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
expected.
15A NCAC 02D .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. Continued compliance is expected.
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 02D .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 June 30, 2016. In addition,annual internal inspections for structural integrity of the
dry filter system are required and the inspection was completed March 2, 2016. Continued
compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26,2016. Continued compliance is expected.
15A NCAC 02D .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 June 30, 2016. Continued compliance is expected.
Page 6 of 13

A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
indicated.
15A NCAC 02D .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. Continued compliance is expected.
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 02D .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. Continued compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .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. Continued
compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26,2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
expected.
15A NCAC 02D .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. Continued compliance is expected.
E. Building ID No. 16(ID No. ES-16; Paint Booth#1)
This building is used for the preparation and painting of boats.
Page 7 of 13

15A NCAC 02D .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 June 30,2016. In addition,annual internal inspections for structural integrity of the
dry filter system are required and the inspection was completed March 2, 2016. Continued
compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .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 June 30,2016. Continued compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26,2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
expected.
15A NCAC 02D .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 the inspection. There is no history of complaints of
objectionable odors involving this facility. Continued compliance is expected.
F. 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 02D .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. Continued compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .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 expected.
Page 8 of 13

A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26,2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
expected.
15A NCAC 02D .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. Continued compliance is expected.
G. Building ID No. 19 (ID No. ES-19; Paint Booth #3)
This building is used for the preparation and painting of boats.
15A NCAC 02D .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 June 30,2016. In addition,annual internal inspections for structural integrity of the
dry filter system are required and the inspection was completed March 2, 2016. Continued
compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .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 June 30,2016. Continued compliance is expected.
A semiannual report is required by January 30 and July 30 of each calendar year. The 2015 and
2016 reports have been submitted as required and indicate compliance. The last report was
received on January 26, 2016. Continued compliance is expected.
There were no visible emissions observed during this inspection. Continued compliance is
expected.
15A NCAC 02D .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. Continued compliance is expected.
Page 9 of 13

Multiple Emission Sources
A. All Emission Sources
15A NCAC 02Q .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 13.10 tons from June, 2015 through May, 2016. Continued
compliance is expected.
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 2015 and 2016
reports have been submitted as required and indicate compliance. The last report was received
on January 26, 2016. Continued compliance is expected.
15A NCAC 02D .0958-Work Practices for Sources of Volatile Organic Compounds
This regulation no longer applies.
15A NCAC 02Q .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 Carcinog Chronic Acute Systemic Acute
(CAS Number) ens Toxicants Toxicants Irritants
lb/ (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
As per the last inspection a review of the records indicated emission rates are well below the
TPERs. Continued compliance is expected.
Page 10 of 13

15A NCAC 02D .1100-Toxic Air Pollutants Emissions Limitation Requirement
For each of the below listed TAP's,the facility shall not exceed the modeled emission_limits as
indicated by strikethrough and highlighting:
EMISSION SOURCE TOXIC AIR EMISSI MAXIMUUM
POLLUTANT ON ACTUAL
LIMIT (lb/hr)
(lb/hr)
Building No. 3 (ID No. ES-3), Styrene (100-42-5) 8-2-.6 13.0*
Building No. 5 (ID No. ES-5), 41.3
44+
OUr�'�Ai n
Building No. 4(ID No. ES-4) Methylene 1.41 0*
Chloride 75-09-2 lb/hr
Building Nos. 16, 17, and 19 Styrene(100-42-5) 1.00 <0.01*
ID Nos. ES-16, 17, and 19) lb/hr
*Eountain-emmiom-from last inspection•
Notes: See May 13,2017 email from Mr. Zawila of Value Engineering outlining the allocation of
styrene emissions for Iconic Marine and Fountain.
To demonstrate compliance,the facility is required to report within 30 days after each calendar
year auar�er, the maximum emission rate of each TAP listed above from a various sources.
The 2015 and 2016 reports have been submitted as required and indicate compliance with the
emission limits. The last report was received on April 29, 2016. Continued compliance is
expected.
15A NCAC 02D .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 submitted the initial notification requirement for the NESHAP on December 14, 2001.
Iconic Marine submitted the initial notification requirement for the NESHAP on March 31, 2017.
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 months that the report covers. The report must
be submitted within 60 days after the end of the reporting period.
Page 11 of 13

The 2015 and 2016 reports have been submitted as required and indicate compliance with the
open molding emission limit. The last report was received on January 26,2016. For the 12-
month period ending December 2015 the NESHAP HAP limit is 8.99 tons and the MACT Model
Point is 7.57 tons. Continued compliance is expected.
Monitoring/Recordkeeping/Reporting:
The facility monitoring/recordkeeping/reporting requirements have been met as noted above in
the regulatory review. WaRO reviewed the records at the facility for the past 12 months from
June 2015 through May 2016. The NESHAP's HAP limit is 9.60 tons and the MACT Model
Point is 8.13 tons. Continued compliance is expected.
Compliance history(5-years):
There have been no compliance issues.
WaRO 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. The facility was last inspected on July 14, 2016 by
Mr. Steven Daniels of the WaRO and found to be in compliance at the time of the inspection.
5. NSPS/ PSD/NAA/Increment/ MACT/CAM/ CAM/ Facility Wide Toxic Air Pollutants
• NSPS -This facility is not currently subject to any NSPS regulations.
• PSD/NAA/Increment-This facility is a Prevention of Significant Deterioration(PSD)minor
source. Iconic Marine shall assume the PSD avoidance condition and is responsible for the
associated monitoring,recordkeeping and reporting including assuming those from Fountain e.g.,
rolling averages of VOC emissions. Beaufort County is an in-attainment area and the non-
attainment(NAA)regulations do not apply. Beaufort County has been triggered for PSD
increment tracking for PM10, S02 and NOx. A review of the total PM10,the only increment
consumed, is less than 1 pound per hour:
Building PM10 actual emissions (pounds/hour)
Building 3 0.07
Building 4 0.00
Building 5 0.43
Building 10 0.00
Building 16 0.01
Building 17 0.01
Building 19 0.01
Total PM10 0.53
Therefore,no increment is consumed by Iconic Marine.
• MACT-This facility is subject to 40 CFR 63, Subpart VVVV(Boat Manufacturing MACT).
Iconic Marine shall assume the MACT conditions from Fountain and is responsible for the
associated monitoring,recordkeeping and reporting. This includes assuming the monitoring,
recordkeeping and reporting from Fountain and the periodic reporting of emissions(e.g., rolling
averages of HAP emissions,etc.).
Page 12 of 13

• 112(r) -This facility is not subject to 112(r).
• CAM-This facility is not subject to CAM.
• Facility Wide Toxic Air Pollutants-This modification did not trigger toxics review. However,
the Fountain facility was previously required to provide a facility-wide toxics compliance
demonstration as Subpart VVVV was their last applicable MACT. This demonstration included
those sources that were not subject or exempt from the MACT. As such,the Iconic Marine
facility has satisfied their last MACT demonstration. Iconic Marine shall assume the conditions,
including their new proposed limits associated with 02Q .1100 and 02D .0711 and is responsible
for the associated monitoring,recordkeeping and reporting including assuming those from
Fountain e.g., recordkeeping and reporting, etc.
A review of the existing state air toxic modeling of the facility was conducted and approved by
Mr. Alex Zarnowski of the AQAB approved on May 17,2017. Additional modeling was not
required as the original modeling used a worst-case stack scenario with styrene emissions being
emitted from the worst-case stack. Iconic Marine has proposed to flit the facility-wide styrene
emissions,with half assigned to Iconic Marine and half assigned to Fountain. Thus,the modeled
impact from Iconic Marine would not be higher than the worst-case-stack scenario.
5. Public Notice/EPA and Affected State(s)Review
Not required at this time.The Permittee shall file a Title V Air Quality Permit Application
pursuant to 15A NCAC 02Q .0504 on or before 12 months after assuming operation.
6. RCO Conclusions,Comments,and Recommendations:
Changes to the WEE equipment database were approved by Ms. Jenny Shepard on July 18,
g
2017.
A professional engineer's seal was not required for this permit modification.
A consistency determination was not required for this permit modification.
WaRO recommends issuance of Permit No. 10534R00.
Recommend issuance of Permit No. 10534R00.
Page 13 of 13