AQ_F_1600120_20220811_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Wilmington Regional Office
AIR QUALITY Parker Offshore,LLC
NC Facility ID 1600120
Inspection Report County/FIPS: Carteret1031
Date: 08/112022
Facility Data Permit Data
Parker Offshore,LLC Permit 06848/Tl l
2570 Highway 101 Issued 10/32019
Beaufort,NC 28516 Expires 9/302024
Lat: 34d 48.6580m Long: 76d 40.3280m Class/Status 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
Eric Denton Scott Bauer Eric Denton MACT Part 63: Subpart VVVV
Engineer President Engineer
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 08/10/2022
Inspector's Signature: Inspector's Name Ashby Armistead
Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 08/11/2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2020 --- 16.27 --- --- 28783.94
2019 --- 19.30 --- --- 34323.46
2018 — 20.50 36680.70
*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Tvoe Rule Violated Violation Resolution Date
03/16/2022 NOV Permit Late Title V ACC 03/16/2022
Performed Stack Tests since last FCE: None
Date Test Results Test Method(s) Source(s)Tested

General Facility Summary
The facility can be reached by taking Highway 70 through Morehead City. Follow the Hwy. 70 bypass
around Beaufort. Turn left at the light to take Hwy. 101 N. The facility is located approximately 6
miles up Hwy. 101 on the right. A BP station is across from it. To get to the office,take a right onto
Laurel. The first driveway on the left is the parking lot. Safety boots and glasses are required.
Parker manufactures 18 to 34 foot center console/cabin sport fishing boats in different configurations.
Currently Permitted Sources
;; mission Source ID No. Emission Source Description Control Device Control Device
ID No. Description
Building No. I Laminating,gel coating,and assembly DF Dry filters
(MACTVVVV) (110,500 square feet of production
area)
The equipment list for boat manufacturers is intentionally vague. It gives the facility more production
flexibility by allowing them to move equipment and add or remove lamination guns as needed without
going through a permit modification.
Inspection Results
I was accompanied during the inspection by Danny Brosnan, the new Safety & Compliance Manager.
The newer back building is attached to the old building and can be isolated by large doors. All
lamination is done in the newer building. Nine lamination of resin guns on booms were installed at the
time of inspection. Three were operating. These are"flow coater"guns. The foam gun on the small
boom was being used. There are 22 filters down the left side of the building. There are 20 on the right
side. Each side is vented via external ductwork to its own stack. The filters looked ok. No problems
were noted with the ductwork. The opacity was 0% from each stack.
The older gel coat booth (2 guns) is located against the shared wall between buildings. The booth was
being staged during the inspection. The 34 filters were ok.
Parker added a 2nd gel coat booth off the back of the building. The DAQ received a 502.b.10 change on
February 14, 2020. The new booth was modeled by their consultant to ensure compliance with the
AAL's. A copy of the results was submitted to RCO. The booth was not operating during the
inspection. The blanket type filters looked ok.
The grinding booth is installed in the old building. The booth draws air through the back wall into a
room containing 18 cylindrical filters. The air travels through the two banks of filters and is exhausted
over the top of the booth back into the plant via ductwork. The front of the booth is separated from the
plant by vertical sections of suspended clear plastic. Grinding was being done. The filters are cleaned
by air pulses and looked ok. The photohelic gauge read 5 inches of H2O on the left bank and 5 on the
right bank. A water mist system was added to comply with OSHA's explosion risk requirements.
The facility is keeping a record of their weekly filter inspections as required. No problems were noted
in the records for the period of June of 2021 through July of 2022.
All observed containers were covered, and the facility is keeping a monthly inspection log as required
by the MACT work practices requirement (63.5731). No problems were noted in the records reviewed
for the period of June of 2021 through July of 2022.

The facility is tracking VOC usage as required to stay below their PSD avoidance limit of 250 tons per
year. No problems were seen in the records for the period since the last inspection through July of
2022. The June VOC emission total for the previous 12 months is 19.8 tons. Parker has off-white,
yellow, gray,tan, light and dark blue gel coats. They have different VOC contents, and Parker uses the
highest value for all gel coats in their calculations.
Parker submitted their semi-annual reports for the 1"& 2"d halves of 2021 and the I`half of 2022.
They cover PSD avoidance and the filter and work practices inspections. No problems were noted.
The facility had additional monitoring and quarterly reporting for toxics due to styrene and MEK limits.
Resin, gel coat, and catalyst usage were tracked daily. The NC toxics conditions and quarterly
reporting requirements were removed with issuance of T09. Those VOC sources are covered by the
Boat MACT.
Under the averaging option for the Boat MACT, HAP emissions are compared to a calculated limit on a
monthly basis and reported on a semi-annual basis. Parker submitted their initial report
(Implementation Plan) on 09/21/05. The semi-annual reports for the l'& 2nd halves of 2021 and the l'
half of 2022 were submitted. Parker is using EPA"approved" software to track compliance. No
emission limits have been exceeded based on the data through June of 2022. They are keeping the
required product usage records.
Parker cleans their equipment with acetone which is not classified as a HAP. Compliance with 63.5734
is indicated.
63.5740 requires that carpet and adhesive fabric glue contain no more than 5% organic HAP. Parker
uses a water-based glue, so compliance is indicated.
Compliance History
Parker was issued a NOV on March 16, 2022, for submitting their 2001 ACC late. The WiRO did not
receive it until March 14's.
The facility was assessed a$1,000 civil penalty on 07/21/05 for failing to submit their 2004 emissions
inventory by 06/30/05. The inventory was submitted on July 12d. Parker also submitted a request for
remission which was denied by the EMC.
The facility was issued a NOV on 08/28/02 for submitting a semi-annual report late. No problems were
contained in the report itself.
Permit Revisions
Tl 1 was a renewal.
T10 was an ownership& name change. Parker is now owned by Correct Craft. The 2D .0958
condition was removed from the permit.
T09 was a renewal. The 2D .1100 condition was removed. Several Boat MACT conditions that don't
apply to this facility were also removed. SSM language was added since Subpart VVVV doesn't
address it and the SSM exemption rules were vacated.
T08 was a renewal.
T07 was an administrative amendment to correct a date.
T06 was a renewal.

I
History
The facility expanded their production area with the addition of a 39,000 ft' building. The facility
modeled styrene emissions to demonstrate compliance with toxics. The new permit was issued by RCO
before the modeling was completed. A condition [Section 2.2(3)] (T04) was placed in the permit
requiring a demonstration of compliance for styrene within 90 days of permit issuance. The original
modeling request was sent to AQAB in September 2000. After revisions on March 16 and March 28,
2001, the modeling was approved by AQAB on April 3,2001. Two different production scenarios
were modeled, a temporary one in which all VOC emissions exit through the lamination stacks, and the
normal operating configuration in which emissions from lamination exit through the lamination stacks
and gel coat emissions exit the gel coat booth stack. The worst case was the normal operation, in which
styrene emissions would be 93% of the 1-hour AAL. In both cases, the stacks had to be raised to
achieve compliance. The two lamination stacks by—15 ft. to 45 ft. above ground level (agl), and the gel
coat booth one by—15 ft. to 40 ft. agl. All the stacks have been raised and the facility is operating
under the normal configuration. (NC Toxics no longer applies.)
Conclusions, Comments, and Recommendations
Mr. Brosnan and I spent some time discussing the reporting requirements in the permit.
Parker does not have any emergency generators.
No stack testing has been performed at this facility in at least 20 years.
The facility has two 6,000 gallon resin tanks that were previously determined to be exempt from
permitting. They are considered part of the laminating process and were included in the modeling.
The facility added a 213 x 35ft section to the old building in 2002. It is used for storage. The
woodworking operation moved in there as well. The woodworking operation is not permitted, it
exhausts inside. No lamination or gel coating is done in there.
A ventilation system for worker comfort is installed in the old building. The system exhausts through a
stack on the roof. No lamination is done in this building.
Mr. Peffer(former employee) submitted a permit exemption request to RCO in June of 2003. Parker
wanted to exhaust the new grinding booth outside in the summer to keep the plant cooler. The booth
was determined by RCO Permits to be an insignificant source. As of this inspection, Parker had not
altered the booth to vent outside.
In their 2007 emissions inventory, Parker began using the Unified Emission Factors for open molding
of composites published on 07/23/01. Boat manufactures were instructed to start using these factors.
Parker was using factors from the study published in August of 1997 for the National Marine
Manufacturers Association. The Unified Emission Factors appear to have lowered Parker's estimated
emissions.
The facility appeared to be operating in compliance with their air permit at the time of the inspection.