Statement of Basis Vigor Shipyards Inc. - Puget Sound Clean Air ...

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Statement of Basis forVigor Shipyards, Inc.Administrative Amendment: June 13, 2011 Page 16 of 315. 3.2 E-1 Abrasive Dust Collectors and Other ParticulateControl OperationsThis section includes all activities and equipment associated with abrasive blastingoperations on Vessels in dry dock, and component parts or equipment in specificenclosures.Todd Pacific Shipyards uses abrasive blasting to clean vessels, component parts andequipment before final finishing and assembly and conducts the operation inside boothsenclosures with particulate control equipment or in dry docks equipped with tarping tocontrol fugitive dust. Monitoring of the particulate control equipment is consistent withSection II of the Air Operating Permit. In addition, WAC 173-460-060(6) is a state onlyrequirement that regulates work practices that govern how and where abrasive blastingcan occur. Because these are work practices, the monitoring requirements are consistentwith other work practices and as with most other work practices, the Puget Sound CleanAir Agency has inspected the facility at least annually for the last five years and has notidentified violations.The Puget Sound Clean Air Agency has determined the monitoring frequency based onthe following.Initial compliance. The Puget Sound Clean Air Agency has not observed visibleemissions from any of these activities during any inspection in the last five years;therefore, we conclude that Todd Pacific Shipyards is generally in compliance withthe particulate and opacity requirements.Margin of compliance. Because of the type of process (woodworking, grinding andmachining) and the control equipment (baghouses and cyclones), the Puget SoundClean Air Agency expects the concentration of particulate to be much less than thestandard when there is no visible emission, fallout or fugitive emissions.Variability of process and emissions. Although the equipment runs periodically, theactual emissions are not significant and not likely to cause a nuisance.Environmental impacts of problems. These are small dust collectors that combinednormally emit less than a ton of particulate per year. A maintenance problem isunlikely to result in emissions that would have a significant environmental impact.Technical considerations. The mostly likely type of problem would be a gradualequipment failure like normal wear and tear. Such failure could easily be detected bychecking for visible emissions, fugitive emissions, fallout, and pressure drop acrossthe control equipment. Because of the nature of the potential problems, Puget SoundClean Air Agency has determined that the units should be divided into those systemsthat should be checked for visible emissions weekly and fugitive dust monthly.5. 3.3 EU 2 – Spray Coating OperationsThis section includes all activities and equipment associated with surface coating,operations for both Vessel repair and ship building activities. These operations includecoating mixing, application, drying, and curing; spray gun cleaning; solvent wipe and
Statement of Basis forVigor Shipyards, Inc.Administrative Amendment: June 13, 2011 Page 17 of 31solvent flush; and material and waste handling. The activities included in this section areconducted throughout the facility and the dry docks 1, 2, and 3. For the purpose ofdefining an “emission unit” in the permit, each piece of equipment listed below isconsidered a separate emission unit. The last column in this list indicates whether ShipBuilding and Repair NESHAP-regulated coatings are sprayed in the unit. However, fromtime to time Todd Pacific Shipyards may change the type of coatings applied or the partscoated.Order ofApprovalNo. Date Installed Source Description2277 10/15/1981 Paint spay booth Yes2452 12/21/1983 Paint spray booth and Yesabrasive blasting booth5671 11/22/1994 Outdoor spray coating Yesoperation7069 3/10/1998 Spray Booth T-230 in PaintShed #2YesShip Building and RepairNESHAP Coatings Used(a) Ship Building and Repair NESHAPS40 CFR 63 Subpart II requires Todd Pacific Shipyards use coatings to comply with theVOHAPS listed in table 2 of the rule. Option No. 2 was selected by Todd PacificShipyards to comply with the rule. This means that the volume of allowed thinners andVOHAPS in a coating category is compared with the actual facility usage each month.The actual usage cannot exceed the allowable usage of coatings and thinners in thecoating category.(b) Local RequirementsThe federally enforceable version of Puget Sound Clean Air Agency Regulation I,Section 9.16 requires that all spray coating operations be conducted inside an enclosurewith overspray controls and a vertical stack approved by the Puget Sound Clean AirAgency. It allows for some exemptions such as hand-held aerosol cans and largestationary objects like bridges and buildings. It also allows the Control Officer toapprove spray coating objects that cannot be reasonably handled in an enclosed sprayarea. The requirement is also listed in Section IV of the permit as an activity requiringadditional approval. Puget Sound Clean Air Agency has recently changed Section 9.16of Regulation I to exempt activities that must comply with the aerospace NESHAP. IfEPA approves this amended rule as a SIP change, this section will no longer apply whenTodd Pacific Shipyards conducts activities that must comply with the aerospaceNESHAP.The booths were approved by NOC Orders of Approval. The Puget Sound Clean AirAgency has determined, in addition to the Order of Approval Notice of Completion,Todd Pacific Shipyards will conduct periodic facility-wide inspections that includelooking for spray coating operations that do not comply with the requirements of Section9.16.
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