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 30 of 31initial observation, shut down the unit or activity until it can be corrected, or report theproblem as a deviation under Section V.Q.2." Shut down should be required immediatelyupon observation of non-compliance and a deviation report should be required for anyobservation of non-compliance.Agency ResponseThis monitoring requirement is in the Puget Sound Clean Air Agency Order ofApproval for the water remediation equipment.Part II.A.3.(c) requires inspection of the Stage 1 vapor recovery equipment of theunderground storage tank "prior to all gasoline deliveries." This is unclear andpractically unenforceable. This part of the draft permit also requires inspection after eachgasoline delivery. The post-delivery inspection is "prior" to the next delivery. What isthe intent of the requirement to inspect "prior to all gasoline deliveries"? To requireinspection before each gasoline delivery, the permit should clearly require inspection"immediately before", or, perhaps, "within two hours before", each gasoline delivery.This part also states that, if evidence of non-compliance is observed, the permittee "shall,as soon as possible, but no later than within 24 hours of the initial observation, shut downthe unit or activity until it can be corrected, or report the problem as a deviation underSection V.Q.2." Shut down should be required immediately upon observation of noncomplianceand a deviation report should be required for any observation of noncompliance.Agency ResponsePuget Sound Clean Air Agency gas station rule [Regulation II Section 2.07(b)(2)]requires the stage 1 system be visually inspected after each product delivery and anyequipment found defective is repaired or replaced as soon as possible but no later than7 days after the inspection. Requiring Todd Shipyards to correct the problem no laterthan 24 hours or shut down is more stringent that the rule. Gasoline emissionsgenerally occur from stage 1 equipment during product delivery only and this permitwould require correction prior to another delivery.The following comment was received by email from the EPA on November14, 2002.From: Kral.Laurie@epamail.epa.govSent: Thursday, November 14, 2002 11:31 AMTo: larryv@pscleanair.orgCc: Waddell.Elizabeth@epamail.epa.gov; Kenknight.Jeff@epamail.epa.govSubject: no epa comments re: Todd Pacific Shipyards T5 permit
Statement of Basis forVigor Shipyards, Inc.Administrative Amendment: June 13, 2011 Page 31 of 31Draft TV PermitRE:Todd Pacific Shipyards CorpThank you for the opportunity to review the above mentioned draftTitle V permit. I am writing to notify you that, EPA will not bereviewing this draft permit action.Please note that if the permit is later found to requirecorrective steps (including, but not limited to, objecting to theproposed permit or reopening the issued permit for cause), EPA'sfailure to review the draft permit does not compromise the Agency'sauthority to take such measures.If you have any questions or concerns regarding this letter orwould like to discuss these matters further, please call Jeff Kenknightat (206) 553-6641.cc:J. KenknightE. WaddellTV Source Activity FileTV Comment NotebookI. Administrative AmendmentOn June 9, 2011, the Agency received a request from Vigor Shipyards, Inc. to change thename from Todd Pacific Shipyards Corp. to Vigor Shipyards, Inc. The Operating Permitwas updated.
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Statement of Basis Vigor Shipyards Inc. - Puget Sound Clean Air ...

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