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

Statement of Basis forVigor Shipyards, Inc.Administrative Amendment: June 13, 2011 Page 27 of 31Part II.A.1.(a) addresses opacity monitoring. It requires that the permittee "shall conductweekly inspections of the coating booths, abrasive blasting areas, and combustion sources…."Although it specifies that "[i]nspections are to be performed while the equipment isin operation during daylight hours", the frequency of inspections required is not clear.Must each identified area of the facility be inspected at least once a week while it is inoperation or is a single weekly inspection of all of these areas all that is required? It ispredictable that all of these emissions units will not be operating at any one time duringany given week. The permit language should be clarified to require inspections for eachemissions unit on a weekly basis while that unit is operating. As written, thisrequirement is practically unenforceable.Agency ResponseIn Part II.A.1 requires the coating booths, abrasive blasting areas and combustionsources to be inspected once a week when they are in operation and during daylighthours. Todd Pacific Shipyards must have logs indicating the inspections have beenconducted. If the equipment is not operated during the week Todd Pacific Shipyardswill note this on the log. Normally, the equipment operator inspects the equipmentprior to startup and maintains the log.This first paragraph of part II.A.1.(a) also requires that, if visible emissions are observed,the permittee shall "within 24 hours of the initial observation, take corrective action untilthere are no visible emissions or, alternatively, record the opacity using the reference testmethod or shut down the unit or activity until it can be repaired." Is this consistent withthe remedy requirements for the specific substantive requirements found elsewhere in thepermit? Corrective action should be required immediately if visible emissions areobserved.Agency ResponseIn Part II.A.1 Todd Pacific Shipyard must correct opacity problem immediately but nolater than 24 hours from initial observation. This is consistant with the notice ofconstruction order of approvals issued for the specific equipment . The enforcementhistory at Todd Pacific Shipyards supports the condition to maintain compliance at thefacility.The first sentence of the second paragraph of part II.A.1.(a) is unclear. It requires thepermittee "or subcontractor [to] monitor opacity using Ecology reference test Method 9Afrom all ships located at their facility during startup, propulsion system testing and shutdown." Is the opacity of emissions from ships to be monitored or is opacity of otherfacility emissions to be monitored from shipboard? Also, what ensures that any"subcontractor" is qualified to do opacity monitoring? The permittee should be requiredto have its own qualified personnel conduct opacity monitoring.