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

Statement of Basis forVigor Shipyards, Inc.Administrative Amendment: June 13, 2011 Page 21 of 316. Monitoring, Maintenance and Recordkeeping ProceduresMany of the procedures in Section II of the permit are grouped according to types ofactivities or the Todd Pacific Shipyards organizational unit responsible for performingthe procedure. For example, the activities in Section II.A.2(e) Equipment Maintenanceare normally performed by maintenance personnel while the other activities in SectionII.A of the permit are normally performed by operators or environmental staff. Forexample, maintenance staff checks to see that the pressure drop gauge on a spray booth isoperating properly and that the acceptable ranges are marked, but the operator isresponsible for logging the pressure drop.6. 1 Following Monitoring, Maintenance and RecordkeepingProceduresTodd Pacific Shipyards must follow the procedures contained in Section II of the permit,Monitoring, Maintenance and Recordkeeping Procedures. Failure to follow arequirement in Section II may not necessarily be a deviation of the underlying applicableemission standard in Section I. However, not following a requirement of Section II is adeviation of Section II and Todd Pacific Shipyards must report such violations, as well asdeviations from any other permit condition, as a deviation under Section V.Q.1 of thepermit. In addition, all information collected as a result of implementing Section II canbe used as credible evidence under Section V.N.2. of the permit. Reporting a permitdeviation and taking corrective action does not relieve Todd Pacific Shipyards from itsobligation to comply with the underlying applicable requirement.6. 2 Standard Approval ConditionsA standard Puget Sound Clean Air Agency Notice of Construction Order of Approvalcondition, Condition No. 1, requires that the equipment, device or process be installedaccording to plans and specifications submitted to the Puget Sound Clean Air Agency.Once the equipment is installed, the Puget Sound Clean Air Agency requires certificationby the applicant that the installation was as approved; this is usually done with a Noticeof Completion. Normally within six months to a year after receiving a Notice ofCompletion, a Puget Sound Clean Air Agency inspector verifies by inspection that theequipment was installed as specified and in accordance with the Order of Approval.While the Notice of Completion is a one-time requirement that Todd Pacific Shipyardshas complied with, Todd Pacific Shipyards cannot change the approved equipment insuch a manner that requires an NOC Order of Approval without first obtaining an NOCOrder of Approval which is addressed in Section IV.A of the permit.6. 3 Work Practice InspectionsThe permit requires Todd Pacific Shipyards to conduct quarterly work practiceinspections. These inspections are to ensure that the work practices required by thepermit are being followed. The Puget Sound Clean Air Agency determined the frequencyof these inspections after considering the potential for emissions, the lack of federallyrequired monitoring, Todd Pacific Shipyards in-house training practices and similar