The URL can be used to link to this page

Home My WebLink AboutAQ_F_2100073_20210818_CMPL_InspRpt NORTH CAROLINA DIVISION OF Washington Regional Office AIR QUALITY Regulator Marine,Inc. NC Facility ID 2100073 Inspection Report County/FIPS:Chowan/041 Date: 08/25/2021 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 Michael Aust Michael Aust Michael Aust MACT Part 63: Subpart VVVV, Subpart ZZZZ Manager-Env.,Health& Manager-Env.,Health& Manager-Env.,Health& Safety Safety Safety (252)482-3837 (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 08/18/2021 Inspector's Name Yongcheng Chen Inspector's Signature: Operating Status Operating -4v &.�, Compliance Status Compliance-inspection Action Code FCE Date of Signature: 8/25/2021 Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 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 2017 0.8600 --- 1.12 54.89 0.4700 0.8600 92360.00 *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 10/20/2020 Pending 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 340 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 8/18/2021, 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 called Anna Miller,EHS Manager,Environmental Supervisor, (252)482-3837/843.535.7017 to arrange the onsite inspection. Mr. David Cullipher, Senior Manager Facilities,and Environmental, Health, & Safety showed me around the facility. No VE was observed during my inspection. The production is normal. They have 340 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 7/30/2021. Compliance is indicated. The records review indicated the required inspections/observations were being performed. 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 7/30/2021. 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 7/30/2021 and the highest 12-month period ended in Dec 2020 and was 76 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 7/30/2021. The maximum rate occurred in March 2020 and was 50.4 lbs/hour(< 313 lbs/hour). Compliance is indicated. 15A NCAC 2D .1111: MACT (40 CFR Part 63 Subpart VVVV) The facility has elected the model point averaging option to meet the MACT emission limits in 40 CFR 63.5698 for the resins and gel coats used in the lamination and gel coating areas(ES-1). They are currently using all compliant materials with the exception of one tooling resin. The Permittee appears at the time of this inspection to be in compliance with all applicable provisions, including the notification, testing, recordkeeping, reporting, and monitoring requirements by choosing the emissions averaging compliance option. Under this compliance option,Regulator Marine is currently tracking facility-wide monthly usage of each HAP containing: production resin,pigmented gel coat, clear gel coat, tooling resin and tooling gel coat. They are calculating the facility-wide monthly, 12-month rolling Equation 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 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 2020 was received 2/22/2021. 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, and October 29,2019, respectively. The test results of all tests(most recently test done on 10/29/2019) 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, 2021. 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. ,t S.. F �.. �..��...._.. -.,r.r.._. � � -- � �� .� `j�,� ,_ ��I �� _ i� ,., - � �,,, _ _ �. �� _ � � , �� v � � �� - � ' �.;-� �r�, _ ,1 � _: i � � u Y �J . � --a � g I r I. * of a � �g a �i � / � o �� __ � &g 4 _,}� � i � �� .� -r f 1F =ge age 'sa� e�, �. 4e9 ?Sy sew � ®� E ae 3 `a9 � 0 0 �, �i,® p, � � y 0 � - � `��„�� .