AQ_F_1600120_20200212_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Wilmington Regional Office
AIR QUALITY Parker Offshore,LLC
NC Facility ID 1600120
Inspection Report County/FIPS:Carterett031
Date: 02/12/2020
Facility Data Permit Data
Parker Offshore,LLC Permit 06848/TI 1
2570 Highway 101 Issued 10/3/2019
Beaufort,NC 28516 Expires 9/30/2024
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 Lynwood Parker III Eric Denton MACT Part 63: Subpart V V VV
Engineer President Engineer
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 02/05/2020
Inspector's Signature: 1/ Inspector's Name Ashby Armistead
/`�' Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 02/12/2020 On-Site Inspection Result Compliance
Z
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PMIO *HAP
2018 -- -- 20.50 --- --- 36680.70
2017 -- -- 18.80 -- --- 34268.76
2016 -- -- 18.20 --- --- 33115.80
*Highest HAP Emitted inpounds)
Five Year Violation History: None
Date Letter Type Rule Violated Violation Resolution Date
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. Many different
configurations are available.
Currently Permitted Sources
Emission Source ID No. Emission Source Description Control Device Control Device
ID No. Description
Building No. 1 Laminating,gel coating,and DF Dry filters
(MACT VVVV) assembly(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 Mr. Denton. 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. Four were operating.
These are"flow coater" guns. The foam gun on the small boom was not 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 gel coat booth(2 guns)was not moved to the new building as originally planned. Instead it was
moved against the shared wall between buildings. As a result, Parker had to remodel their normal
operating scenario. Compliance was indicated,though the stack had to be raised. The second gel
coat booth, which has not been installed, was also remodeled. The plan at the time of remodeling
was to also put it on the shared wall, on the other side of the bay door. The relocation of the existing
booth began around the end of May of 2001,the booth resumed operation during the first week of
September according to Mr. Harrison(former employee). During that time, all gel coating was done
in the new building, as modeled in the temporary scenario. The booth was in use during the
inspection. The 34 filters were ok. Parker wants to add the 2nd gel coat booth off the back of the
building. The requirements were discussed, and it appears the booth can be added as a 502.b.10
change. Parker will send a notification/determination request letter to DAQ.
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 the right bank was not in use. 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 September of 2019 through January of 2020.
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 September of 2019 through January of 2020.
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
December of 2019. The December VOC emission total for the previous 12 months is 19.3 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 report for the 2nd half of 2019. It covers 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 report for the 2"d half of 2019 was submitted.
Parker is using EPA"approved"software to track compliance. No emission limits have been
exceeded based on the data through December of 2019. 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
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 12a'. 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.

• r
T07 was an administrative amendment to correct a date.
T06 was a renewal.
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 stacks. 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
Parker does not have any emergency generators.
No stack testing has been performed at this facility in at least 18 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/O1. 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.