HomeMy WebLinkAboutAQ_F_2100073_20220305_CMPL_InspRpt (3) NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Regulator Marine,Inc.
NC Facility ID 2100073
Inspection Report County/FIPS:Chowan/041
Date: 03/08/2022
Facility Data Permit Data
Regulator Marine,Inc. Permit 07132/T13
187 Peanut Drive Issued 11/12/2019
Edenton,NC 27932 Expires 10/31/2024
Lat: 36d 4.9290m Long: 76d 35.4830m Class/Status Title V
SIC: 3732/Boat Building And Repairing Permit Status Active
NAILS: 336612/Boat Building Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
David Cullipher David Cullipher David Cullipher MACT Part 63: Subpart VVVV, Subpart ZZZZ
SeniorManager—Faci., SeniorManager—Faci., SeniorManager—Faci.,
Env.,Health&Safety Env.,Health&Safety Env.,Health&Safety
(252)482-3837 11 (252)482-3837 (252)482-3837
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 03/03/2022
Inspector's Name Yongcheng Chen
Inspector's Signature: Operating Status Operating
-4v Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 3/8/2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2020 0.8600 --- 0.6600 70.06 0.2800 0.8600 114910.60
2019 1.10 --- 0.9600 74.62 0.4100 1.10 128362.40
2018 0.9800 --- 0.9600 59.21 0.4100 0.9800 97117.00
*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
03/31/2017 NOV Part 63 -NESHAP/MACT Subpart VVVV Boat 03/28/2017
Manufacturing
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
10/19/2021 Compliance Method 10 ES-I4
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Location:
The facility is located at 187 Peanut Drive, Edenton, NC. From WaRO, take US 17N to Edenton. Take
exit 230 off of Hwy. 17N (North Broad Street). Go approximately 1 mile and take a right onto Peanut
Drive. Go over railroad tracks and the facility will be on the left.
Process Description:
The facility manufactures 23',25',25',28',31', 34' and 41' fiberglass boats in open molds. It requires 10
days to complete a boat. The facility has approximately 240 full-time employees.
Safety:
The only personal PPE required in shop areas of the facility is safety glasses. An inspector should wear
safety shoes and have hearing protection to use as required.
Currently Permitted Sources:
Emission Source ID Emission Source Description Control Device 11 Control Device Descripti(
No. No.
ES-1 One fiberglass lamination/gelcoatin CD-1 Fiberglass mesh filters on
MACT Sub VVVV operation four roof exhausts
ES-2 Trimming, routing and sanding of CD-5 Central vacuum system
gelcoat, resins and fiberglass consisting of cartridge filte
in series w/dual c clones
ES-I4 Diesel-fired peak shaving generator CD-I4 Diesel Oxidation Catalyst
MACT Sub ZZZZ 764 h
Inspection Observations:
On 3/3/2022, I, Yongcheng Chen, conducted a state Full Compliance Evaluations of the facility.
I first reviewed IBEAM the facility files including permit/compliance/inventory review of the facility. I
made sure that all IBEAM modules and all data are complete and up to date for the facility. I also
reviewed the last inspection report. The facility was issued one NOV on 03/27/2017.
I met with David Cullipher, Senior Manager—Faci., Env., Health& Safety (Anna Miller, EHS Manager
left). Mr. David Cullipher showed me around the facility.No VE was observed during my inspection. The
production is normal. They have about 240 employees now.
REGULATORY REVIEW:
15A NCAC 2D .0515: Particulates from Miscellaneous Industrial Processes
This applies to the laminating and gelcoating area(ES-1), and the trimming, routing, and sanding area
(ES-2), which has not been constructed yet. Particulates are controlled by fiberglass mesh filters. The
inspection and maintenance (I&M) shall consist of at least weekly inspections recorded in a logbook.
Reports are required to be submitted semi-annually. The last report was received 1/25/2022 (deadline
1/30/2022). Compliance is indicated. The records review indicated the required inspections/observations
were being performed.
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15A NCAC 2D .0521: Control of Visible Emissions
Visible emissions from ES-1 and ES-2,when constructed, shall not be more than 20 percent opacity when
averaged over a six-minute period. No VE was observed during the inspection. Once every 6 months,
twice per calendar year, the facility is required to observe the emission points. The results and any
corrective actions are to be recorded in a logbook. Reports are required to be submitted semi-annually.
The last report was received on 1/25/2022 (deadline 1/30/2022). The records review indicated the required
inspections/observations were being performed. Compliance is indicated.
15A NCAC 2D .1806: Control and Prohibition of Odorous Emissions
The facility shall not operate without implementing management practices or installing and operating odor
control equipment sufficient to prevent odorous emissions from the facility from causing or contributing
to objectionable odors beyond the facility's boundary. No objectionable odors were detected during this
inspection. Compliance is indicated.
15A NCAC 2D .0530: Prevention of Significant Deterioration
Facility-wide emissions shall be less than 250 tons of volatile organic compounds(VOCs)per consecutive
12-month period. VOC emissions shall be recorded monthly in a logbook. Reports are required to be
submitted semi-annually for each 12-month period over 17 months. The last report was received on
2/22/2022 (deadline 3/l/2022) and the highest 12-month period ended in Dec 2021 and was 72.84 ton.
Compliance is indicated.
15A NCAC 2Q .0711: Emission Rates requiring a Permit
For each of the TAP's listed in their permit, the facility has demonstrated that facility-wide actual
emissions do not exceed the TPERS's listed in 2Q .0711. The facility is required to maintain
operational information to demonstrate compliance with this rule. The facility's emission rates are
well below the requirements. Compliance is indicated.
15A NCAC 2D .1100: Control of Toxic Air Pollutants
The facility is limited to no more than 313 lbs/hour of styrene emissions. Quarterly reports are to be
submitted indicating the maximum hourly emissions rate for styrene. The last report was received
1/25/2022 (deadline 1/30/2022). Compliance is indicated.
15A NCAC 2D .1111: MACT (40 CFR Part 63 Subpart VVVV)
The facility has elected the model point averaging option to meet the MACT emission limits in 40
CFR 63.5698 for the resins and gel coats used in the lamination and gel coating areas(ES-1). They are
currently using all compliant materials with the exception of one tooling resin. The Permittee appears
at the time of this inspection to be in compliance with all applicable provisions, including the
notification, testing, recordkeeping, reporting, and monitoring requirements by choosing the
emissions averaging compliance option. Under this compliance option,Regulator Marine is currently
tracking facility-wide monthly usage of each HAP containing: production resin,pigmented gel coat,
clear gel coat, tooling resin and tooling gel coat. They are calculating the facility-wide monthly,
12-month rolling Equation 1 organic HAP emission limit calculations pursuant to 40 CFR 63.5698(b)
and facility-wide monthly, 12-month rolling MACT model point value calculations in accordance
with 40 CFR 63.5710 procedures. For a given month,compliance is demonstrated if the MACT model
point value is less than the Equation 1 organic HAP emission limit calculations. The facility met the
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compliance date of August 22, 2005. The initial notification of compliance was received December
19, 2005.
The MACT semi-annual emissions averaging report for 12-months ending in December 2021 was
received 2/28/2022 (deadline 3/l/2022). The NESHAP HAP Limit for that period was 34,899 kg and
the MACT Model Point Value was 38,124 kg. Compliance is indicated.
The MACT requirement for carpet and fabric adhesive (40 CFR 63.5740) states the adhesives contain
no more than 5%HAP by weight. There is no carpet or fabric in their boats requiring adhesives.
15A NCAC 2D .1111: Maximum Achievable Control Technology for RICE Diesel-fired Peak
Shaving Generator ES-I4 (40 CFR Part 63 Subpart ZZZZ)
On May 24, 2013 the instillation of a Diesel Oxidation Catalyst (CD-I4) was completed with a
continuous parameter monitoring system (CMS). The initial and subsequent performance test was
completed June 6, 2013, November 26, 2013,November 20, 2014,November 3, 2016, October 30,
2017, October 25, 2018, October 29, 2019, and October 19, 2021, respectively. The test results of all
tests (most recently test done on 10/19/2021 and reviewed/approved 12/8/2021)were approved by
DAQ Stationary Source Branch as an acceptable demonstration of compliance with the applicable CO
emission limit. The next testing date is on October 19, 2022.
COMPLIANCE HISTORY:
An NOV was issued on 03/31/2017 for a late reporting (Part 63 -NESHAP/MACT Subpart VVVV
Boat Manufacturing).
COMMENTS, CONCLUSIONS, and RECOMMENDATIONS:
Based on review of records and visual observations, this facility appeared to operate in compliance
with all applicable Air Quality regulations and permit conditions at the time of this inspection.
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