AQ_F_0700151_20200922_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Iconic Marine Group,LLC
NC Facility ID 0700151
Inspection Report County/FIPS:Beaufort/013
Date: 09/23/2020
Facility Data Permit Data
Iconic Marine Group,LLC Permit 10534/T02
1653 Whichards Beach Road Issued 5/18/2020
Washington,NC 27889 Expires 4/30/2025
Lat: 35d 31.2900m Long: 77d 2.8680m 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
MACT Part 63: Subpart VVVV
Jeff Harris Jeff Harris Jeff Harris
Chief Operating Officer Chief Operating Officer Chief Operating Officer
[phone] [phone] [phone]
Compliance Data
Comments:Based on visual observation and records review,the facility appeared
to operate in compliance with all applicable air quality regulations and permit Inspection Date 09/22/2020
conditions at the time of inspection. Inspector's Name Robert Bright
Operating Status Operating
Compliance Code Compliance-inspection
Inspector's Signature: Action Code FCE
On-Site Inspection Result Compliance
Date of Signature: September 23,2020
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PM10 * HAP
2019 0.8900 --- --- 29.20 --- 0.4500 44740.00
2018 0.8700 --- --- 28.66 --- 0.4300 42797.60
2017 0.4500 --- --- 13.40 --- 0.2200 21668.90
*Highest HAP Emitted inpounds)
Five Year Violation History:None
Performed Stack Tests since last FCE:None
Location :
Iconic Marine Group, LLC is located at 1653 Whichards Beach Road, Washington,NC.
Traveling 17 South of Washington, approximately 1.5 miles from Washington take a left onto
Whichards Beach Road. The facility is located on the left approximately one mile.
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Process Description:
Iconic Marine Group, LLC manufactures fiberglass boats in open molds. The finished boats are
20-48 feet in length encompassing four(4)brands; Baja, Fountain, Donzi, Advance Performance
Marine. Normal operating hours are: 8-10 hours per day and 4 or 5 days per week. They are
currently producing about 3-4 boats each week with 200 employees.
On September 22, 2020, I conducted a full compliance evaluation with the assistance of Michael
Zawila, Environmental Consultant (Mike). The evaluation began with a records review (June
2019—August 2020) followed by a facility walkthrough. The facility was in operation, the
buildings/equipment were well maintained and no VE was observed.
Safety glasses and hearing protection are required. Per DAQ COVID-19 protocols, I wore a face
mask at all times and social distanced, as did Mike.
LIST OF PERMITTED SOURCES:
Emission Source Emission Source Description Control Device Control Device
Description
Building No. 3
ES-03 Small Part Lamination&Mating C-3 Dry filters
MACT VVVV
Building ID No.4
ES-04 Wood Finishing and Adhesive C-4 Dry filters
MACT VVVV Spraying
Building ID No. 5
ES-05 Deck&Hull Lamination C-5 Dry filters
MACT VVVV
Building ID No. 10
ES-10 Mold Maintenance C-10 Dry filters
MACT VVVV
Building ID No. 11
ES-11 Cruiser Lamination C-11 Dry filters
MACT VVVV
Building ID No. 15
ES-15 Tooling C-15 Dry filters
MACT VVVV
Building ID No. 16
ES-16 Paint Booth#1 C-16 Dry filters
Building ID No. 17
ES-17 Paint Booth#2 C-17 Dry filters
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Building ID No. 19
ES-19 Paint Booth#3 C-19 Dry filters
Insignificant Activities under 15A NCAC 2Q .0503(8)
Emission Source ID No. Emission Source Description
I-1 Solvent Cleaning Operations
I-2 One(1)resin storage tank(5,500 gallon capacity)
I-3 Twenty(20)gas-fired space heaters(125,000 to 175,000 Btu per hour capacity)
I-4 Eleven(11)gas-fired space heaters(325,000 to 375,000 Btu per hour capacity)
I-5 Three(3)gas-fired space heaters(2,000,000 to 2,600,000 Btu per hour capacity)
I-6 Two(2)gas-fired space heaters(3,500,000 to 4,000,000 Btu per hour capacity)
I-7 One(1)gas-fired space heater(6,650,000 Btu per hour capacity)
Regulatory Review:
Building ID No. 3 (ID No. ES-3; Small Parts Lamination & Mating)
This building is used for the manufacture of the small parts; glove boxes, storage boxes,
consoles, live wells, etc. The hardware is also installed in this area and the mating(attaching the
decks to the hulls) is done.
15A NCAC 2D.0515-Particulates from Miscellaneous Industrial Processes
Particulate matter emissions are controlled by a dry filter system. Monthly visual inspections of
the filter pads and an annual internal inspections for structural integrity of the dry filter system
are required with the results recorded in a logbook. Compliance is indicated via records
review.
15A NCAC 2D.0521 - Control of Visible Emissions
Visible emissions are limited to 20 percent opacity visible emissions. Monthly observations for
VE above normal are required with the results recorded in a logbook. Compliance is indicated
via records review. No VE was observed during the inspection.
Building ID No. 4 (ID No. ES-4; Wood Finishing and Adhesive Spraying)
This building is used for the cutting of stringers,bulk heads, foam cutting, and gluing foam to
plywood parts.
15A NCAC 2D.0512-Particulates from Miscellaneous Wood Products Finishing Plants
Particulate matter emissions are controlled by a dry filter system. Monthly visual inspections of
the filter pads and an annual internal inspections for structural integrity of the dry filter system
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are required with the results recorded in a logbook. Compliance is indicated via records
review.
15A NCAC 2D.0521 - Control of Visible Emissions
Visible emissions are limited to 20 percent opacity visible emissions. Monthly observations for
VE above normal are required with the results recorded in a logbook. Compliance is indicated
via records review.No VE was observed during the inspection.
Building ID No. 5 (ID No. ES-5; Deck& Hull Lamination)
This building is used for the gel-coating and laminating of the large parts; decks, hulls, liners,
etc.
15A NCAC 2D.0515-Particulates from Miscellaneous Industrial Processes
Particulate matter emissions are controlled by a dry filter system. Monthly visual inspections of
the filter pads and an annual internal inspections for structural integrity of the dry filter system
are required with the results recorded in a logbook. Compliance is indicated via records
review.
15A NCAC 2D.0521 - Control of Visible Emissions
Visible emissions are limited to 20 percent opacity visible emissions. Monthly observations for
VE above normal are required with the results recorded in a logbook. Compliance is indicated
via records review.No VE was observed during the inspection.
Building ID No. 10 (ID No. ES-10; Mold Maintenance)
This building is used for mold preparation(waxing) and repair of molds.
15A NCAC 2D.0515-Particulates from Miscellaneous Industrial Processes
Particulate matter emissions are controlled by a dry filter system. Monthly visual inspections of
the filter pads and an annual internal inspections for structural integrity of the dry filter system
are required with the results recorded in a logbook. Compliance is indicated via records
review.
15A NCAC 2D.0521 - Control of Visible Emissions
Visible emissions are limited to 20 percent opacity visible emissions. Monthly observations for
VE above normal are required with the results recorded in a logbook. Compliance is indicated
via records review.No VE was observed during the inspection.
Building ID No. 11 (ID No. ES-11; Cruiser Lamination)
This building is used for the gel-coating, laminating, and assembly of decks and hulls of cruisers.
15A NCAC 2D.0515-Particulates from Miscellaneous Industrial Processes
Particulate matter emissions are controlled by a dry filter system. Monthly visual inspections of
the filter pads and an annual internal inspections for structural integrity of the dry filter system
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are required with the results recorded in a logbook. Compliance is indicated via records
review.
15A NCAC 2D.0521 - Control of Visible Emissions
Visible emissions are limited to 20 percent opacity visible emissions. Monthly observations for
VE above normal are required with the results recorded in a logbook. Compliance is indicated
via records review.No VE was observed during the inspection.
Building ID No. 15 (ID No. ES-15; Tooling)
This building is used for the manufacture of the molds or tooling.
15A NCAC 2D.0515-Particulates from Miscellaneous Industrial Processes
Particulate matter emissions are controlled by a dry filter system. Monthly visual inspections of
the filter pads and an annual internal inspections for structural integrity of the dry filter system
are required with the results recorded in a logbook. Compliance is indicated via records
review.
15A NCAC 2D.0521 - Control of Visible Emissions
Visible emissions are limited to 20 percent opacity visible emissions. Monthly observations for
VE above normal are required with the results recorded in a logbook. Compliance is indicated
via records review.No VE was observed during the inspection.
Building ID No. 16 (ID No. ES-16; Paint Booth #1)
This building is used for the preparation and painting of boats.
15A NCAC 2D.0515-Particulates from Miscellaneous Industrial Processes
Particulate matter emissions are controlled by a dry filter system. Monthly visual inspections of
the filter pads and an annual internal inspections for structural integrity of the dry filter system
are required with the results recorded in a logbook. Compliance is indicated via records
review.
15A NCAC 2D.0521 - Control of Visible Emissions
Visible emissions are limited to 20 percent opacity visible emissions. Monthly observations for
VE above normal are required with the results recorded in a logbook. Compliance is indicated
via records review.No VE was observed during the inspection.
Building ID No. 17 (ID No. ES-17; Paint Booth #2)
This building is used for the preparation and painting of small parts.
15A NCAC 2D.0515-Particulates from Miscellaneous Industrial Processes
Particulate matter emissions are controlled by a dry filter system. Monthly visual inspections of
the filter pads and an annual internal inspections for structural integrity of the dry filter system
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are required with the results recorded in a logbook. Compliance is indicated via records
review.
15A NCAC 2D.0521 - Control of Visible Emissions
Visible emissions are limited to 20 percent opacity visible emissions. Monthly observations for
VE above normal are required with the results recorded in a logbook. Compliance is indicated
via records review.No VE was observed during the inspection.
Building ID No. 19 (ID No. ES-19; Paint Booth #3)
This building is used for the preparation and painting of boats.
15A NCAC 2D.0515-Particulates from Miscellaneous Industrial Processes
Particulate matter emissions are controlled by a dry filter system. Monthly visual inspections of
the filter pads and an annual internal inspections for structural integrity of the dry filter system
are required with the results recorded in a logbook. Compliance is indicated via records
review.
15A NCAC 2D.0521 - Control of Visible Emissions
Visible emissions are limited to 20 percent opacity visible emissions. Monthly observations for
VE above normal are required with the results recorded in a logbook. Compliance is indicated
via records review.No VE was observed during the inspection.
15A NCAC 2D.1806— Control and Prohibition of Odorous Emissions (Facility-wide)
The facility is required to prevent objectionable odors beyond the facility's boundary. There
were no objectionable odors detected during this inspection and there is no history of complaints
of objectionable odors involving this facility. Compliance is indicated.
2.2 - MULTIPLE EMISSION SOURCES
15A NCAC 2Q.0317.Avoidance Conditions
To avoid PSD applicability, facility wide VOC emissions shall not exceed 250 tons per
consecutive 12-month period (PSD minor). The facility is required to calculate and record
monthly VOC emissions. A review of the log book indicated that VOC emissions for the 12-
month period ending in August 2020 were 24.21 tons. Compliance is indicated.
A semiannual report is required by January 30 and July 30 of each calendar year. The emissions
must be calculated for each of the 12-month periods over the past 17 months. The CY2019
reports have been submitted on time and WaRO's review indicates compliance.
15A NCAC 2Q.0711 - Toxic Air Pollutants Emissions Limitation Requirement
In accordance with the permit, the Permittee shall maintain records of operational information
demonstrating that the TAP emissions do not exceed the TPERs as listed below:
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TPERs Limitations
Pollutant Carcinogens Chronic Toxicants Acute Systemic Toxicants Acute Irritants
(CAS Number) (lb/yr) (lb/day) (lb/hr) (lb/hr)
Ethyl Acetate 36
(141-78-6)
Methyl Ethyl Ketone 78 22.4
(78-93-3)
Methyl Isobutyl Ketone 52 7.6
(108-10-1)
Methylene Chloride 1600 0.39
(75-09-2)
Toluene 98 14.4
(108-88-3)
Xylene 57 16.4
1330-20-7
Formaldehyde
50-0-0 0.04
n-Hexane
110-54-3 23
A review of the monthly VOC emissions reports indicated emission rates well below the TPERs.
Compliance is indicated.
15A NCAC 2D.1100- Toxic Air Pollutants Emissions Limitation Requirement
For each of the below listed TAP's, the facility shall not exceed the modeled emission limits:
EMISSION SOURCE TOXIC AIR POLLUTANT EMISSION LIMIT
Building No. 3 (ID No.ES-03), Styrene(100-42-5) 45.0 lb/hr
Building No.4(ID No.ES-04),
Building No. 5 (ID No.ES-05),
Building No. 11 (ID No.ES-11),
Building No. 15 (ID No.ES-15),
Building Nos. 16, 17 and 19
(ID Nos.ES-16,ES-17 and ES-19)
To demonstrate compliance, the facility is required to report within 30 days after each calendar
year quarter, the maximum emission rate of each TAP listed above from the various sources.
The most recent report was received on 7/30/2020 and WaRO's review indicated compliance.
Compliance is indicated.
15A NCAC 2D.1111—MA CT-40 CFR Part 63, Subpart VVVV
The facility complies with the open molding emission limit by using the emissions averaging
option and must demonstrate that the emission limit established by 40 CFR 63.5698, equation 1,
is not exceeded using the procedures set in 40 CFR 63.5704(a). Compliance is demonstrated on
a 12-month rolling-average basis and is determined at the end of every month(12 times per
year). For the fabric adhesive operations, the HAP content must be< 5%to comply with the
MACT.
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The facility is required to submit reports for each 6-month period ending on July 30 and
December 31. The report must evaluate compliance with the open molding emission limit for
each 12-month averaging period ending on each 6-month that the report covers. The report must
be submitted within 60 days after the end of the reporting period.
The required reports have been submitted as required and WaRO's review indicates compliance.
The most recent report was received on 7/30/2020. For the 12-month period ending August
2020, the NESHAP HAP limit is 16.39 tons and the MACT Model Point is 14.87 tons.
Compliance is indicated.
Monitoring/Recordkeeping/Reporting:
The facility monitoring/recordkeeping/reporting requirements have been met as noted above in the
regulatory review. Compliance was indicated.
The 12-month VOC (ending August 2020) and MACT VVVV emissions reports are stored on
the DAQ-WaRO Sharepoint site: August 2020 VOC and VVVV report.
Compliance history (5-years):
There have been no compliance issues.
Comments, Conclusions and Recommendations:
The facility appeared to operate in compliance with all applicable air quality regulations and permit
conditions at the time of inspection.
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