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 24 of 31The recently amended Puget Sound Clean Air Agency Regulation I, 6.03(c) exemptscertain equipment from new source review. It does not exempt any equipment from anyfederally required new source review or federally required notifications. For purposes ofcomplying with the recordkeeping requirement in Puget Sound Clean Air AgencyRegulation I, 6.03(c), Todd Pacific Shipyards shall provide in a timely manner, uponrequest by the Agency, any information reasonably necessary to document theexemption. However, physical evidence of the emission unit or activity itself canoftentimes fully document the applicability of the exemption.8. 2 Requirement IV.D Spray CoatingBoth the 1993 federally enforceable version and the current version of Regulation I,Section 9.16 are included in the permit. However, the two versions differ enough thatTodd Pacific Shipyards could only comply with one. Therefore, the Puget Sound CleanAir Agency will only enforce the current version.9. Standard Terms and ConditionsSome of the requirements Todd Pacific Shipyards identified in the operating permitapplication are included in Section V, Standard Terms and Conditions. This provided aneasier mechanism for describing requirements that are more general in nature. Thissection also contains the standard terms and conditions specifically listed in WAC 173-401-620.9. 1 V. O RecordkeepingWAC 173-401-615(2) requires maintain a record of the time that each sample ormeasurement is taken. If the sample or measurement needs to be recorded once a shift orless frequently, then Todd Pacific Shipyards needs to identify the shift that the sample ormeasurement was take. If sample or measurement needs to be recorded more frequentlythan once a shift, then Todd Pacific Shipyards must record the hour that the sample ormeasurement was taken.9. 2 V. P Data recoverySome of the applicable requirements in the permit did not have specific monitoringrequirements associated with them. For such requirements, the Puget Sound Clean AirAgency developed monitoring requirements. (This is sometimes called gap filling.)Section V.P Data recovery addresses the amounts of data recovery required for thesemonitoring requirements that were developed specifically for the permit. The sectionalso address procedures to follow if the monitoring system fails or data is lost. Therequirements of the section only apply as noted in Section II of the permit and under nocircumstances does this section apply if a specific underlying applicable requirement ismore stringent.In developing the data recovery requirements, the agency consider similar data recoveryrequirements such as Regulation I, Section 12.03, the frequency of the monitoring, andthe nature of the information required to monitor.
Statement of Basis forVigor Shipyards, Inc.Administrative Amendment: June 13, 2011 Page 25 of 319. 3 V. Q ReportingSection V.Q lists the reports that Todd Pacific Shipyards must submit, and theresponsible official must certify the report. In many cases, Puget Sound Clean AirAgency used its authority under 40 CFR 60.7 and 40 CFR 63.10 to adjust the reportingdates and reporting frequencies to be consistent with other reporting requirements. Forexample, Puget Sound Clean Air Regulation I, Section 12.03(f) requires all continuousemissions monitoring reports to be submitted to the Agency within 30 days after the endof each calendar month. However, 40 CFR 60.7(c) requires such reporting semiannuallyunless the administrator determines that more frequent reporting is necessary. The PugetSound Clean Air Agency rule clearly requires more frequent reporting, and the reportsare similar. In addition, WAC 173-401-615(3)(b) specifically requires monthly reportingof all deviations. Rather than Todd Pacific Shipyards submitting two or three differentreports with the same information at different times, the Agency determined that morefrequent reporting of the federal requirement is warranted.Similarly, 40 CFR 63.788 requires certain deviation reporting semiannually, normally onJanuary 31 and July 31 of each year. However, 40 CFR 63.9(i) allows Puget SoundClean Air Agency to adjust the reporting date. In this case, the Puget Sound Clean AirAgency requires the semiannual report by January 30 for the reporting period of June 1 stthrough December 31st and by July 31 for the reporting period of January 1st throughJune 30. In addition the permit requires monthly reporting of all deviations. Thosedeviation reports contain different information and are not intended to be a substitute forthe semiannual or annual reports.Section V.M.2(e) Startup, Shutdown, and Malfunction Reports requires Todd PacificShipyards to report certain startup, shutdown and malfunctions. After reviewing therequirements of 40 CFR 63.6 and 63.10, the Puget Sound Clean Air Agency hasdetermined that such reports are only required if the startup, shutdown or malfunctionresulted in excess emissions. In addition, 40 CFR 63.10(d)(5)(ii) allows the permittingauthority to make alternative reporting arrangements. For example, in this case PugetSound Clean Air Agency established an alternative reporting arrangement for theImmediate Startup, Shutdown, and Malfunction Reports, for the Ship Building andRepair NESHAP, to be consistent with other deviation reports.10. Permit ShieldThe permit shield applies to all requirements contained in Sections I through VI of thepermit, including a monitoring, maintenance, recordkeeping, and reporting requirements.
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Statement of Basis Vigor Shipyards Inc. - Puget Sound Clean Air ...

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