AQ_F_0100299_20201207_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Honda Aero, Inc.
NC Facility ID 0100299
Inspection Report County/FIPS: Alamance/001
Date: 12/07/2020
Facility Data Permit Data
Honda Aero, Inc. Permit 09850/R02
2989 Tucker Street Issued 10/26/2017
Burlington,NC 27215 Expires 9/30/2025
Lat: 36d 3.1930m Long: 79d 27.5730m Class/Status Small
SIC: 3724/Aircraft Engines& Engine Part Permit Status Active
NAICS: 336412/Aircraft Engine and Engine Parts Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact
SIP
Jack Cox Anthony Brandewie Jack Cox MACT Part 63: Subpart ZZZZ
Facilities and Equipment Vice President/Plant Facilities and Equipment NSPS: Subpart III1
Coordinator Operations Coordinator
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 12/07/2020
Inspector's Name Chris Bryant
Inspector's Signature: Operating Status Operating
Compliance Code Compliance- inspection
Action Code FCE
Date of Signature: l Z �d v v MTH On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2016 0.1100 0.3600 0.6200 0.0300 0.1500 0.1100 8.14
2011 0.0200 0.0700 0.1100 0.0100 0.0300 0.0200 1.49
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
Permitted Sources
Emissions Source £ Control System
ID ID Source Description ID Control System Description
j Engine test cell#I (maximum of
I TC-Ol N/A N/A
6,000 pounds of thrust per engine)
1

Insignificant/Exempt Activities
EE Source of Source of Title'
Source ID Source Description E Exemption Regulation TAPS?, ; Pollutants?
I-T1 and I-T2 2Q.0102(g)(4) Yes
Two above ground Jet A fuel storage tanks
0,000 gallon capacity,each)
.... ... .......... ....... ..........._. . ... ......... ..._....... ............. ........... .. .........
1-PT ;Penetrant testing
I-UC --'-'-- -Ultrasonic cleaner _ No Yes
( I-EWS lEn me washdown system 2Q.0102(h)(5)
...__._..._..........
IEG-1 One 270 kW diesel-fired emergency generator Yes
(NSPS,NESHAP) 1064 hp output) �� �
Introduction
On December 7, 2020, Mr. Chris Bryant, Environmental Specialist of the DAQ WSRO, contacted Mr. Jack Cox
(Facilities and Equipment Coordinator)and Mr. Travis Young(Facilities)at Honda Aero, Inc. for the purpose of
conducting a compliance inspection. The inspection was scheduled in advance and followed proper NC DEQ Covid-19
safety protocols including social distancing and mask wearing. Mr. Cox said that the staff has been free from any positive
Covid-19 cases. He also said that most staff, including the majority of the engineering staff,are working remotely from
home. Some inspection requirements such as permit conditions and federal rules discussion were conducted via email
prior to the inspection. Mr. Cox provided email copies of the maintenance records for the emergency generator in lieu of
an on-site records review. The facility was found to be operating in compliance during the last compliance inspection,
which was performed by former DAQ WSRO Environmental Engineer, Mr. George Williams, on March 13, 2019.
Honda Aero, Inc. manufactures jet turbine engines for civil aircraft. The facility operates 16 hours a day, 5 days a week,
and 48 weeks a year.
Safety Equipment
Safety shoes, hearing protection, and safety glasses are required safety equipment needed when inspecting this facility.
The inspector and plant manager discussed Covid-19 safety concerns in advance,wore face masks,and maintained a safe
social distance during the inspection. Prior to entrance into the facility,the inspector had to complete a questionnaire and
perform a thermal temperature scan.
Latitude/Longitude Verifications
The latitude and longitude coordinates were verified to be accurate as documented in IBEAM.
Applicable Regulations
According to permit Condition A.I the facility is subject to the following regulations: Title 15A North Carolina
Administrative Code (NCAC), Subchapter 2D .0202, 2D .0516, 2D .0521, 2D .0535, 2D .0540,2D .1806, and 2Q .0102
(40 CFR 63, Subpart ZZZZ-Reciprocating Internal Combustion Engines and 40 CFR 60, Subpart I11I for Stationary
Compression Ignition Internal Combustion Engines). This rule applies to the exempt 270 kW diesel-fired emergency
generator, and as such will not appear in the permit. This facility is not subject to RMP requirements of the Section 112(r)
program since it does not use or store any of the regulated chemicals in quantities above the threshold levels in the rule.
The facility is only subject to the General Duty requirements contained in the General Duty Clause.
Discussion
This inspector was able to contact the facility contact, Mr. Jack Cox, prior to the inspection. The inspector and contact
discussed safety and Covid-19 risks at the facility and setup a scheduled time of Monday December 7, 2020(9am)to
perform the inspection. Mr. Venable and Mr. Young were able to safely guide the inspector around the facility to the
view the permitted and exempt sources. The facility provided copies of maintenance records to review off-site. Honda
Aero, Inc uses a R&P system that documents facility and equipment services including AC, equipment upkeep, and
manufacturing.
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The facility was issued the newest permit on October 26,2017 which will expire on September 30, 2025. During the
renewal process the facility declined the option to pursue a permit exemption under 15A NCAC 2Q .0102(d). Although
the facility's total aggregate emission totals would be less than 1.27 tons,the test engine(if ran at full capacity)would not
qualify for permit exemption. Currently the facility is permitted for the TC-01 Engine Test Cell (max. 6k thrust). The
exempt/unpermitted sources include the two aboveground fuel tanks(I-T1, I-T2), penetrant testing(I-PT), ultrasonic
testing(I-UC), engine washdown system (I-EWS),and one 270 kw diesel-fired emergency generator(IEG-1). The first
sources observed were the penetrant testing and ultrasonic cleaner. These are a series of tanks that contain a magnaflux
product that is used for checking for cracks in the individual components. These are not electroplating tanks. None of the
dip tanks were in use during the inspection. Next,the engine washdown system was observed, also not in use. The
outdoor portion of the inspection accounted for the evaluation of the 2 aboveground Jet A fuel tanks,the permitted engine
test cell (TC-01), and the emergency generator. The fuel tanks were clean and free from any spills. The engine test cell is
a fully enclosed container that is located halfway between the facility building and fuel tanks. The exhaust points on the
engine test cell area were clean with no noticeable buildup of smoke or fume residue. The engine cell was not in use and
visible emissions were zero.
The 270kW diesel-fired emergency generator was observed last. This generator, although exempt, is subject to 40 CFR
63, Subpart ZZZ and 40 CFR 60, Subpart II11. The engine is considered complaint with ZZZZ by meeting the
requirement of 1111. This generator is emergency use only and is rarely used. The engine is tested once a week and has not
been used for any emergency situations in the last twelve months. The engine is serviced quarterly and a full maintenance
(filter/oil change) is performed annually. The last two annual maintenance and oil changes were performed on January
11, 2019 and October 25, 2019. The Mr. Cox described a problem that occurred at the end of 2019 where the meter reader
had malfunctioned and had to be replaced. The meter times went from 67.9(10/25/2019)to 0.0 after the replacement.
The PM logs(emailed to inspector)and online database were consistent and appeared to show compliance.
Information for exempt diesel-fired generator IES-1):
Manufacturer Model: Serial Date Date Date Date Date Date Date
Number: Meter(HR) Meter(HR) Meter(HR) Meter Meter Meter Meter(HR)
Cummins DSHAC- H080903479 12/7/2020 11/30/20 9/2/20 6/10/20 3/16/20 10/25/19 3/13/19
Diesel 7232155 6.7Hr 6.2Hr 4AHr 3.3Hr 2.2Hr 67.9Hr 64.2Hr
Annual
The engine is certified to Tier 3 emission standards for Spec. C and 60 Hz engines. The facility must comply with the
New Source Performance Standards(NSPS)that are promulgated in 40 CFR 60, Subpart I111"Stationary Compression
Ignition Internal Combustion Engines."This generator, source IEG-1 was manufactured in 2008 and is applicable to the
rule since it commenced construction after July 11, 2005. A copy of the EPA Certification of Conformity is on file at the
WSRO. According to permit review R01 (Sharon Wyatt, 11/1/2012),"The certificate (#CEX-NRCI-08-38) was issued to
Cummins, Inc.for engine model QSL9-G2-NR3 with nameplate HP of 364, effective 1210412007. The certification
indicates that the applicable emission limits (Tier 3) are 3.0 NOx+HC, 2.6 CO, and 0.15 PM(g/HP-hr)."The facility
maintains records of fuel certification from Alamance Oil Company which demonstrate that the facility is using low sulfur
fuel. A full description of these NSPS requirements will be listed in the NSPS/NESHAP section below.
The facility has installed an argon vacuum furnace. This is a"heat treat"VAC AERO system that is Model
VAV5050/HZ-2. The unit was manufactured in 2019(Serial #1804). In a discussion with WSRO Compliance Supervisor,
Taylor Hartsfield on December 9, 2020, it was determined that this system was probably not a source of emissions.
However,the source will be listed in the"Permit Discussion" section below and should be re-evaluated during the next
permit renewal.
3

Tile facility has four wash tanks in the manufacturing area. These are self-maintained and appeared to be clean and free
from any spills. These are not ducted and vent internally. Honda Aero, Inc. also has two hot water heaters(1 gas/1
electric). No boilers or fire pumps are located at the facility.
Permit Conditions/Applicable Regulations
Condition A.2 contains 15A NCAC 2D .0202 permit renewal and emissions inventory requirements. The facility was
issued the most recent permit on October 26, 2017. The permit will expire on September 30, 2025. Tile facility decided to
keep the permit active and not accept a permit rescission (based on permit applicability of source and low emission rates)
during the last renewal process. Tile facility will be required to submit a renewal request and air pollution emission
inventory report for the 2024 calendar year 90 days prior to the expiration of the permit. This condition was discussed
with Mr. Cox. Compliance is expected.
Condition A.3 contains the 15A NCAC 2D .0516 requirements for 0516 "Sulfur Dioxide Emissions from Combustion
Sources."
This rule applies to any combustion source at the facility that discharges from any vent, stack, or chimney and should not
exceed 2.4 lbs/MMBtu S02. Specifically,this applies to the engine test cell(TC-01) and the exempt diesel generator
(IEG-1). A compliance evaluation from Taylor Hartfield's last permit review(R02, 10/26/2017) indicated that the facility
would emit 0.001 lb/MMBtu.
TC-01 -Engine test cell(Jet A fuel)
S02 = 14.2 kg/long mode test @ 3.5 hr/test or 8.1 kg/short mode test @ 2 hr/test per CY2016 emissions inventory
S02= 8.9 Ib/hr for either mode
According to the previous permit review, maximum fuel rate is 1,143 gallons per hour.
Assume that jet kerosene contains 0.135 MMBtu/gallon.
S02= 8.9 Ib/hr_ 1,143 gal/hr x 0.135 MMBtu/gal=0.001 lb/MMBtu
Condition A.4 contains the requirements for 2D. 0521 "Control of Visible Emissions."The facility must limit emissions
to 20%opacity when averaged over a six-minute period for sources manufactured after July 1, 1971,and 40%opacity for
sources manufactured as of July 1, 1971, when averaged over a six-minute period. All sources at the facility were
manufactured after July 1, 1971. There were no visible emissions over 20%opacity observed during the inspection.
Compliance with 2D .0521 is anticipated.
Condition A.5 15A NCAC 2D .0535 is a notification requirement for excess emissions during a malfunction or
breakdown that lasts for more than 4 hours. Mr. Cox stated that no incidents or malfunctions have occurred. There are no
issues registered in IBEAM for this facility. Compliance with the condition is expected.
Condition A.6 contains the 15A NCAC 2D .0540 fugitive dust control requirement.No fugitive dust was observed
traveling beyond the property boundaries during this inspection. According to the DAQ IBEAM database, no complaints
have been received regarding fugitive dust emissions at this facility. The facility is located in a commercial area and the
parking lot is paved. Compliance with this condition is indicated.
Condition A.7 15A NCAC 2D .1806 contains the control of odorous emissions requirement. No objectionable odors
around the facility boundary were noted during the inspection. There have been no complaints regarding odors at the
facility. Compliance with the condition is expected.
Condition A.8 contains the Federal Rules Applicable to Sources Exempt from Air Permitting Requirements. This rule
applies to the emergency generator (IEG-1). This engine is subject to National Emissions Standards for Hazardous Air
Pollutants (NESHAP) 40 CFR 63, Subpart ZZZZ for "Stationary Reciprocating Internal Combustion Engines." Also,
engine IEG-1 is subject to New Source Performance Standard (NSPS) 40 CFR 60, Subpart II11. These rules will be
discussed in the NSPS/NESHAP section below.
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NSPS/NESHAP
This facility is subject to NESHAP 40 CFR 63, Subpart ZZZZ for"Stationary Reciprocating Internal Combustion
Engines" in regard to the emergency generator. According to permit review RO1 (Sharon Wyatt, I I/l/20120), "Engines
at area sources are considered to be existing if construction commenced before June 12, 2006, and are new if on or after
this date.According to the most recent inspection report, the emergency generator(IEG-1) was manufactured in 2008,
and therefore would have also commenced construction after June 12, 2006 and is considered to be a new affected
source. In accordance with§63.6590(c), a new or reconstructed stationary RICE located at an area source must meet the
requirements of this part by meeting the requirements of 40 CFR 60 Subpart IN."
As the engine was manufactured in 2008, after the 40 CFR 60, Subpart IIII construction date of July 11, 2005. It is subject
to IIII. The engine is EPA certified to Tier 3 emission standards and had previously submitted an EPA Certificate of
Conformity(on file at WSRO). The certificate(#CEX-NRCI-08-38)was issued to Cummins, Inc. for engine model
QSL9-G2-NR3 with nameplate HP of 364, effective 12/04/2007. The certification indicates that the applicable emission
limits(Tier 3) are 3.0 NOx+HC, 2.6 CO, and 0.15 PM(g/HP-hr). Additionally, the facility must meet the following
requirements:
• The engines must be certified to the EPA Tier 3 emission standards listed in 40 CFR§89.112.
• The facility must use diesel fuel with a sulfur content of less than 15 ppm.
• A non-resettable hour meter must be installed on the engine.
• The engine is allowed to operate with no time limit if being used for emergency situations. Limit operation for
maintenance, testing and emergency demand response to 100 hours per calendar year. The engine may operate up
J_
to 50 hours per year in non-emergency situations, but those 50 hours are counted towards the 100 hours per year
provided for maintenance and testing. Tile 50 hours per year used towards non-emergency situations can't be used
for peak shaving, non-emergency demand response,or to generate income for the facility.
• The facility is required to keep records of all maintenance conducted on the engine.
• The facility must maintain records of operation through the non-resettable hour meter and it must document how
many hours are spent for emergency and non-emergency operations.
The facility is properly maintaining and documenting PM activities on the engine. The generator is serviced quarterly by
Cummins diesel and the oil and filter are changed annually. The engine ran for 11.0 hours in the last 21 months. The
meter reader malfunction in January 2020 and was replaced. The documentation provided by the facility was consistent
with the maintenance records and previous inspection reports.
Information for exempt diesel-fired generator IES-1 :
Manufacturer Model: Serial Date Date Date Date Date Date Date
Number: Meter(HR) Meter(HR) Meter(HR) Meter Meter Meter Meter(HR)
Cummins DSHAC- H080903479 12/7/2020 11/30/20 9/2/20 6/10/20 3/16/20 10/25/19 3/13/19
Diesel 7232155 6.7Hr 6.2Hr 4.4Hr 3.3Hr 2.2Hr 67.91-Ir 64.21-Ir
Annual
Compliance with Subpart IIII and Subpart ZZZZ are indicated. Ongoing compliance is expected.
Permit Issues
The facility has installed an argon vacuum furnace. This is a"heat treat"VAC AERO system that is Model
VAV5050/HZ-2. The unit was manufactured in 2019 (Serial #1 804). In a discussion with WSRO Compliance Supervisor
Taylor Hartsfield on December 9, 2020, it was determined that this system was probably not a source of emissions.
However,the source will be listed in the"Permit Discussion"section below and should be re-evaluated during the next
permit renewal.
5

The facility has four wash tanks in the manufacturing area. These arc self-maintained and appeared to be clean and free
from any spills. These are not ducted and vent internally. Honda Aero, Inc. also has two hot water heaters(I gas/1
electric).
The facility declined a permit exemption during the last renewal process.
Source Tests
No stack testing or VE testing has been conducted at this facility.
Facility Wide Emissions
The following table, showing 2016 emission information is from Permit Review R02 (Taylor Hartsfield, 10/26/2017):
Pollutant CY2016 Actual Emissions Potential Emissions [tons/year]
�..._.__ .. ......
[tons/year]
PM10 _ _ .�...0.11 9.4
.. ..... ........__..
NOx 0.62....__.. �. ._. �. 55.6
0.15
..............
.._._. .................��.._.............._......_..........._.....................
............_............__ .._..............._�..__......._
2.5
............................................................................................................................._..........._................................_...................._ .._ . ...__..............._............................................_........................................................................................._......._.....................................................................
HAPTota� 0.008 0.03
F HAPffignest(Formaldehyde) �� � � 0.004� <0.03
Compliance History
The facility has not had any compliance issues in the last five years.
Conclusion
Based on the visual observations and review of records during the inspection and subsequent review, Honda Aero, Inc.
was found to be in likely compliance with its Air Quality Permit and other DAQ and federal air quality rules.
6