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Home My WebLink AboutAQ_F_0100299_20190313_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: 03/13/2019 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 NAILS: 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 1111 Coordinator Operations Coordinator (336)513-0248 (336)513-6692 j (336)513-0248 Compliance Data Comments: Inspection Date 03/13/2019 Inspector's Name George Williams Inspector's Signature: Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: o2 ) 2Co 1 1 y 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 Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE: None Date Test Results Test Method(s) Source(s)Tested Permitted Emission and Insignificant/Exempt Sources: The following Permitted Emission Sources and Insignificant/Exempt Activities tables were obtained from the Air Permit Review R02. 1 Permitted Emissions Sources m. _.. �. m� mom _. . Emission Emissibn Source Control Control System P. Source ID Description Syste Description on .... .... l TC Ol Engine test cell #I (maximum of 6,000 pounds of thrust per engine) N/A N/A ......_.. . .. ..... .. ...... _....... . ... ...... ...... Insignificant/Exempt Activities Soule . .. le:V; .. Exemption �Suurce ofSource of .............................. Rngulatto' TAPS? Pollutants? I-PT-Penetrant testing Ultrasonic cleaner No 2Q.0102(h)(5) I-EWS-Engine washdown system Yes IEG 1 One 270 kW diesel fired emergency generator(364 hp output) -...................I.-..................:.:. ... .,.:. ......... m.: .:......_ .......................................I..........-.................................................. ..... .: Yes ............................................. I T1,I-.......................T2-Two above ground Jet A fuel storage tanks(4,000 gallon capacity,each) �2Q.0102(g)(4) .................................................................................................................................................................................................................................................................................... Introduction: On March 13,2019, Mr. George Williams, Environmental Engineer of WSRO Division of Air Quality(DAQ),conducted an unannounced compliance inspection of Honda Aero, Inc. Mr.Williams met with the facility contact, Mr.Jack Cox, Facilities and Equipment Manager, and he confirmed that the facility contact information listed in IBEAM was accurate, Furthermore, Mr. Cox confirmed that the facility operates Monday through Friday, 16 hours per day, 11:00 PM to 4:00 PM, 5 days a week for approximately 48 weeks a year. The previous compliance inspection was conducted by Mr. Mohammad Khan, Environmental Chemist of WSRO DAQ,on June 25,2018.At the time of the inspection,the facility appeared to be operating within compliance of all Air Quality rules and standards. Safety Requirements: The Personal Protective Equipment(PPE)required to enter the production area for this facility includes safety shoes and eye protection.The facility is located Geographically at Latitude: 36d 3.1930m and Longitude: 79d 27.5730m. Discussion: Honda Aero, Inc. manufactures engines for light weight aircrafts, mainly for small planes or jets.The inspector met with Mr. Jack Cox (Facilities and Equipment Manager)where they reviewed the facility's permit and records. Mr. Cox keeps the facility's inspection records in a log book,but they are also accessible from the facility's computer database. After reviewing the records, Mr. Cox lead the inspector through the facility. The first source observed was the one 270 kW diesel-fired emergency generator(IEG-1),which is located outside on the left side of the building. The facility's two above ground Jet A fuel storage tanks(4,000 gallon capacity,each) (I-T1 and I-T2)are also located outside the facility, but are located in the back with the facility's dust collector systems. From here, Mr. Cox lead the inspector inside where they observed the facility's engine test cell#1 (TC-01),engine washdown system(I-EWS), ultrasonic cleaner(1-UC),and penetrant testing(I-PT).At the time of the inspection,the engine test cell#1 was not in operation. Before the end of the inspection,Mr. Cox did state that the facility is planning to add an argon vacuum furnace sometime soon. Applicable Regulations: j The applicable regulations listed in the air permit include Title 15A North Carolina Administrative Code(NCAC), Subchapter 2D .0202,2D.0516,2D.0521,2D .0535,2D .0540,and 2D .1806.This facility is not required to implement a Section 112(r)risk management plan(RMP)according to federal regulation 40 CFR 68.The facility does not purchase,produce,use or store the regulated chemicals in quantities above their threshold limits stated in the rule.The facility is subject to the requirements contained in the General Duty clause in this rule. Permit Conditions: Condition A.2-This condition states the requirements for 2D. 0202. In the permit condition, in order for the facility to renew their permit they must submit a renewal request in according to 2Q. 0304(d)and(f).The permit for this facility will expire on April 30, 2024. Compliance with 2D .0202 is indicated,and future compliance with this regulation is anticipated. Condition A.3-This condition states the requirements for 2D. 0516 "Sulfur Dioxide Emissions from Combustion Sources." Emissions of sulfur dioxide from any source of combustion that is discharged from any vent,stack,or chimney shall not exceed 2.3 pounds of 2 sulfur dioxide per million Btu input.This requirement applies to the engine test cell(TC-01)and the exempt diesel-fired emergency generator(IEG-1). Compliance with this regulation is indicated based on review R02's calculations shown below. TC-01 -Engine test cell(Jet A fuel) SOZ= 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 Ib/MMBtu Condition A.4-This condition states the requirements for 2D. 0521 "Control of Visible Emissions."This facility is limited 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 I, 1971,when averaged over a six-minute period. During the inspection,no visible emissions over 20% opacity were observed. During the inspection,Mr. Williams did not see any excess visible emissions from any of the permitted or insignificant sources.Compliance with 2D .0521 is anticipated. Condition A.5-This condition states the requirements for 2D.0535"Excess Emissions Reporting and Malfunctions."This facility must notify DAQ of any excess emissions lasting longer than four hours resulting from a malfunction,breakdown of process or control equipment or any other abnormal conditions. Mr. Cox indicated that there have not been any malfunctions prior to the inspection.Compliance with 2D .0535 is indicated,and future compliance with this regulation is anticipated. Condition A.6-This condition states the requirements for 2D. 0540"Particulates from Fugitive Dust Emission Sources."The facility shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints, visible emissions, or allow fugitive dust beyond their property boundary. During the inspection, no fugitive dust was observed,and no complaints have recorded in the DAQ IBEAM database. Compliance with 2D .0540 is indicated, and future compliance with this regulation is anticipated. Condition A.7-This condition states the requirements for 2D. 1806"Control and Prohibition of Odorous Emissions."The facility must implement management practices that prevent odorous emissions from the facility from causing objectionable odors beyond the facility's boundary. During the inspection Mr. Williams did not observe any objectionable odors,and no complaints have been found in the DAQ IBEAM database. Compliance with 2D .1806 is indicated, and future compliance with this regulation is anticipated. Condition A.8-This condition states the requirements for Subpart ZZZZ for"Stationary Reciprocating Internal Combustion Engines" and Subpart IIII for"Stationary Compression Ignition Internal Combustion Engines."The conditions apply to the one 270 kW diesel- fired emergency generator(IEG-1).Under Subpart IIII,the facility's emergency engine(IEG-1)must meet the following requirements; • The engines must be certified to the emission standards set in §60.4205(b).These are 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 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. The 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. At the time of the inspection, Mr. Cox provided maintenance records for the engine.Mr.Cox's records indicate that he inspects the engine quarterly and has full maintenance done once a year. The most recent full maintenance inspection was performed on January 11,2019;while quarterly inspections were conducted on January 18,2018,May 3,2018,and August 2,2018.The engine's hour meter read 64.2 hours which means the engine ran 5.7 hours since the last inspection. Compliance with Subpart IIII is indicated, which means that compliance with Subpart ZZZZ is also indicated,and continued compliance is anticipated. 3 NSPS/NESHAP: The facility is subject to 40 CFR 63, Subpart ZZZZ(4Z),"National Emission Standards for Hazardous Air Pollutants(NESHAP)for stationary RICE."A detailed review of the condition can be found in Condition A.8 of this review. The facility is subject to 40 CFR 63, Subpart IIII(4I),"Stationary Compression Ignition Internal Combustion Engines."A detailed review of the condition can be found in Condition A.8 of this review. Facility Wide Emissions: The following are the actual and potential emissions for the CY 2016 from this facility.This data was obtained from the most recent air permit review R02. Pollutant CY2616 Actual Emissions [tons/year] Potential Emissions [togs/year] ;{ :. j t 0.11 9.4 PM 10 0.11 9.4 SO2 [ 0.36 j 31.0 0.62 55.6 0.15 _� 13.2 VOC 0.03 2.5 I ........ ............. ............. .... .... ............._...................._..............................................._.........................................._..._..._... _. HAPTotai 0.03 HAPHig,est(Formaldehyde) F 6.004 <0.03 Permit Issues: The facility has two dust collectors which were deemed by the previous inspector,Mr. Mohammad Khan,as being exempt from permitting because of their low annual emissions.The dust collectors should probably be added to the permit's insignificant/exempt list during the next renewal. No other issues were observed at the time of the inspection. Stack Testing: No stack tests have been conducted at this facility. Compliance History: Within the last 5 year the facility has not experienced any compliance issues. Conclusion: Honda Aero,Inc. appears to be operating within compliance of all applicable Air Quality standards and regulations at the time of this inspection.This conclusion is based on visual observations during the inspection and the facility's personal record keeping. I 'I i i 4