AQ_F_1200076_20170906_CMPL_NOD

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
Air Quality MICHAEL A. ABRACZINSKAS
ENVIRONMENTAL QUALITY Director
September 6, 2017
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Richard Boyens
General Manager
SAFT America, Inc.
313 Crescent Street NE
Valdese,NC 28690
SUBJECT: Notice of Deficiency
15A NCAC 2D .2100—Risk Management Program
SAFT America, Inc.
Burke County,North Carolina
EPA ID: 1000-0008-7595
NC Facility ID: 1200076
Dear Mr. Boyens:
On July 27, 2017, Mr. Chris Scott, Ms. Terri Davis, and Mr. Michael Reid,with the
Division of Air Quality met Ms. Beth Anderson, Mr. Eric Sims and other staff at the SAFT
America, Inc. facility to conduct an inspection to determine compliance with 15A NCAC 2D
.2100—Risk Management Program(RMP) which adopted 40 CFR Part 68 by reference. For the
purposes of determining compliance,the inspection focused on the electrolyte mix process as
part of a Program Level 3 regulated process involving the storage and use of sulfur dioxide.
The inspection determined deficiencies in certain elements of the Risk Management
Program. Elements of concern are as follows:
1. Process Safety Information [§68.65(d)] —requires complete and accurate written
information pertaining to the equipment in the process. The information pertaining to
process equipment design must be documented. The referenced codes and standards
establishes the basis for establishing good engineering practices for construction and
maintenance of the equipment related to the regulated process:
a. [§68.65(d)(vi)] —no references to design codes and standards employed in the
design of the system was readily available for review upon request.
b. [§68.65(d)(vii)] —no documentation demonstrating that equipment complies with
recognized and generally accepted good engineering practices was readily
available for review upon request.
State of North Carolina Environmental Quality I Air Quality
Asheville Regional Office 1 2090 U.S.Highway 70 1 Swannanoa,NC 28778
828 296 4500 T 1 828 299 7043 F

Mr. Boyens
September 6, 2017
Page 2
2. Process Hazard Analysis [§68.67(e)] —Provided Process Hazard Analysis (PHA)records
failed to document how actions taken to correct potential problems were prioritized to
assure they were resolved in a timely manner; failed to document what actions were to
take place; and failed to document how these actions were to be communicated with
operators, maintenance,and other employees whose work assignments may be affected
by the recommendations or actions.
3. Compliance Audits (§68.79)—requires the owner or operator to evaluate compliance
with 40 CFR Part 68 at least every three years:
a. [§68.79(c)] —report certifying that recent compliance audit(s)had been completed
were not readily available for review upon request.
b. [§68.79(d)] —no documentation of responses to each compliance audit finding
was readily available for review upon request.
Please respond in writing to the Asheville Regional Office by no later than
September 28,2017. The response should outline the steps that you plan to take or have taken
to ensure that the facility is in full compliance with all the requirements of 40 CFR Part 68.
Please note that failure to comply with the requirements noted above could result in a Notice of
Violation. Violations of any air quality rule is subject to the assessment of civil penalties per
North Carolina General Statute 143-215.114A.
If you have any questions with reference to this matter, please do not hesitate to contact
Mr. Chris Scott or me at(828)296-4500.
Sincerely,
Brendan Davey; P.E., Regional Supervisor
Division of Air Quality,NCDEQ
BGD:ces
c: Michael Reid, Raleigh Central Office