AQ_F_1600120_20200526_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Wilmington Regional Office
AIR QUALITY Parker Offshore,LLC
NC Facility ID 1600120
Inspection Report County/FIPS: Carteret/031
Date: 05/26/2020
Facility Data Permit Data
Parker Offshore,LLC Permit 06848/Tl 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 VVVV
Engineer President Engineer
[phone] [phone] [phone]
Compliance Data
Comments: Partial Compliance Inspection
Inspection Date O5/19/2020
Inspector's Signature: Inspector's Name Ashby Armistead
Operating Status Operating
Compliance Code Compliance-inspection
Action Code PCE
Date of Signature: 05/26/2020 l _ l� co On-Site Inspection Result Compliance
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 Tyne 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. I 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
Due to the ongoing virus pandemic, I spoke with Mr. Denton on the telephone. Parker shutdown for
3 weeks in April. They have resumed operations on a smaller scale and are ramping up as demand
increases.
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. Parker wants to add the 2"d gel coat
booth off the back of the building. DAQ received a 502.b.10 notification/determination request
letter from Parker on February 14d'. Mr. Denton has been in touch with RCO Permits and provided
some additional information.
Parker submitted their semi-annual report for the 2"d 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.

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 12'h. 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
T1 I 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.
History
The facility expanded their production area with the addition of a 39,000 ft2 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 19 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.
A site visit did not occur. Based on the available information, the facility appeared to be operating
in compliance with their air permit at the time of the inspection.