AQ_F_1200076_20210714_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Saft America Inc.
NC Facility ID 1200076
Inspection Report County/FIPS: Burke/023
Date: 07/22/2021
Facility Data Permit Data
Saft America Inc. Permit 04595/T17
313 Crescent Street Issued 5/15/2020
Valdese,NC 28690 Expires 3/31/2024
Lat: 35d 45.9334m Long: 81d 33.3167m Class/Status Title V
SIC: 3692/Primary Batteries,Dry And Wet Permit Status Active
NAICS: 335912/Primary Battery Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V/112r
Steve Jenkins Richard Boyens Steve Jenkins MACT Part 63: Subpart ZZZZ
EH S Manager General Manager EH S Manager NSPS: Subpart JJJJ
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 07/14/2021
Inspector's Name Michael Koerschner
Inspector's Signature: Operating Status Operating
C Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: b Inspection Result Compliance
Z�Z J
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 x HAP
2019 --- 0.1300 0.5000 64.98 0.4200 --- 300.48
2018 --- 0.1400 0.5300 79.58 0.4500 --- 525.84
2017 0.0100 0.1300 0.5300 80.22 0.4500 0.0100 513.10
* Highest HAP Emitted(in pounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
Directions: Take 1-40 East to the Rutherford College Exit(Exit 113) and turn left. Proceed North through Rutherford
College to Lovelady Road and turn left. Go 1.5 miles and turn right on Crescent Street. The plant entrance is at the
end of this road.

Safety Equipment: Safety glasses and safety shoes. Facemask required indoors (COVID-19 precaution).
1. Purpose-The purpose of this site visit was to conduct a routine unannounced air quality inspection of the Saft
America,Inc. facility in Valdese,Burke County,North Carolina.This facility is engaged primarily in the
manufacture of lithium sulfur dioxide batteries. The manufactured battery has carbon/aluminum cathode;a
lithium metal anode; and a sulfur dioxide,lithium bromide,and acetonitrile electrolyte. The facility currently
operates 8 hours per day 5 days a week,and employs—185 people(production has declined since last
inspection).Typical operating hours are 07:00 am—3:30 pm. M-F.
I arrived at the facility—10:30 am July 14,2021 and met Mr. Steve Jenkins,EHS Manager to inspect the
facility.
2. Facility Contacts: The contact information above is current(verbally verified during inspection).
3. Permitted sources-The followinp,permitted air emission sources were observed as follows:
one Li-S02 cathode paste drying oven
ES-0 Li-S02 cathode paste manufacturing NA NA
ES-01 process such as the room exhaust,
blotter paper emissions,and vacuum
system emissions,
ES-02 one Li-SO2 cathode paste drying oven
Operation status The paste room was in operation. The oven was observed in operation with no
visible emissions.
Linespeed The line speed during my visit was 10 ft/minute(typically 8-13 ft/min).
Oven temperature The oven temperature was 360 Deg F(setpoint of 360 deg F).
ES-01 -Li-S02 cathode paste manufacturing process such as the room exhaust,blotter paper emissions,and
vacuums stem emissions:
Operation This source was opera-tin opeFa—ting with no visible emissions observed.
In this process,an IPA(isopropyl alcohol)and a distilled water mixture is combined
with carbon powder and teflon to form a paste. The paste is applied to an aluminum
screen,pressed to thickness by a roller,and then it goes through blotting paper and
two calendar rollers(with a felt belt)that have small holes that are under a vacuum,
Process Description which extract some of the IPA/water mixture.The extracted liquid is collected in a
tank, and is batch discharged daily to the POTW.The vacuum pump exhausts
outside. The screen/paste then goes into the oven.The blotting paper is rolled up,
stored outside,and sent off for disposal. Some blotter paper is used twice before
being recycled. The oven temperature is typically 360 degrees Fahrenheit.
The most common batch run(80-90%of production)is the AI(26sx)formulation
Batch formulation (low IPA formula)and was indicated to be 95.0 pounds water, 32.0 pounds IPA,and
other materials(carbon black,Teflon, etc.).
Less than 200 gallons per day(50-90 gallons)are typically collected.The tank is
batch discharged once per day by maintenance personnel and the amount sewered is
recorded via a totalizer(per Mr.Jenkins). I observe the totalizer and the method of
Vacuum meter discharge.
NOTE:The facility currently counts all IPA used as emitted.At one time,the
amount collected in this vacuum system(and sent to POTW)was NOT counted as
air emissions.
Blotter paper Stored outside for disposal. The paper had previously been recycled.
sulfur dioxide storage area,the one packed bed caustic wet scrubber
ES-03 electrolyte mixing area,and the CD-03 (230 gallons per minute liquid
battery filling line injection rate)

Mixing area: The electrolyte consists of a mixture of S02, LiBr,and acetonitrile. An electrolyte batch consists
of 36 pounds lithium bromide(solid),600 pounds sulfur dioxide(liquid), and 156 pounds acetonitrile(liquid).
The pressurized mix tank and two pressurized holding tanks are periodically vented to the scrubber.There was a
batch being mixed during this inspection.A general room exhaust is also vented to the scrubber.
Fill stations: There are four automated battery filling stations with hoods(3 double head and 1 single head).
Some of the fill material is emitted at these fill stations—all vented to the scrubber.
S02 storage area:No continuous emissions.The tank vapors are conveyed back to truck(s)during loading.
There may be some fugitive emissions during connection and disconnection of fill piping.
Scrubber: Caustic(NaOH)is used in the scrubber liquid to neutralize S02 from the fill area and mix area. The
scrubber was in operation with no visible emissions and appeared to be free of leaks. The flowrate of the
scrubber was—2225 gpm(analog gauge at recirculation tank)to the scrubber and—200 gpm return to the
recirculation tank.The pH was 6.47. Caustic is added to the recirculation tank to maintain a Setpoint pH.
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This source was NOT in operation. The cell destruction test room is used to QA/QC batteries by exposing them
to heat,pressure,puncture and/or prolonged use. There are two separate rooms—both venting the atmosphere
via the shell of the formerly used scrubber.
The scrubber previously controlled the I-2 pilot line but the I-2 line has been removed. With the removal of the
production line,the facility ceased using the scrubber and it has been removed from the air permit.
The scrubber under oes internal inspections twice er calendar year.
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The anhydrouns Sulfur Dioxide storage tank is located in a separate,locked,room. We observed the tank. The
tank is 5,000 gallons and vents to the scrubber at all times. Outside the tank is the 50%Caustic storage tank
which feeds to the scrubber recirculation tank to control pH.
The tank is on load cells(constantly weighed)and the amount of sulfur dioxide during my visit was 12,350
pounds(11:15 am).
MN02 Line—The line is a MN02/carbon cathode, lithium'anode,line with an electrolyte of ethylene glycol
dimethyl ether,propylene carbonate,tetrahydrofuran,and lithium perchlorate. This line was observed NOT in
operation. The following sources are on this line(air emissions only from part iv below):
i. Cathode manufacture part 1: cathode mix area vented to internally venting cartridge filter. The cathode
mix consists of MN02 powder,carbon,Teflon,and water(no IPA or other volatile).
ii. Cathode manufacture part Il: Mix application to screen,blotting paper,electric oven-no apparent air
emissions.
iii. "JellyRoll"manufacture—battery assembly excluding electrolyte fill—anode is lithium—no apparent air
emissions.
iv. Electrolyte filling process—There are two fill lines.The filling stations are vented outside.
4. The following nonpermitted air emission sources were observed as follows:
I-1 1 Metal canister seal checking operations
The company has eliminated the use of solvent for this operation and now pulls a vacuum on the battery and
measures vacuum degradation to detect a leak.This is not a source of air pollution and can be removed from
the"insignificant activities" list.

I-3 1 Natural gas-fired dehumidification gas packs(1.4 million Btu per hour heat input)
Observed in operation-Eight big(220 cfh)and two small(41 cfh). Total of 10 units.
I-4 1 One natural gas-fired boiler(3.4 million Btu per hour heat input)
Not observed not in operation-used only for heat in the wintertime. Kewanee Boiler. Gas-fired only.
Boiler plate indicated 3348-4185 MBH, 100 HP; manufactured in 1981.
I-6 1 One isopropyl alcohol storage tank(2400 gallon capacity)
Observed. This tank sits outside the facility.
I-8 1 Stepanfoam process
No longer used.Nobody at the plant was familiar with this process/operation and we did not observe it.
I-9 1 Ink'et printing operation
Inkjets on site using MEK—observed
I-12 1 Epoxy resin and catalyst application operation
Observed the station where the epoxy"caps"are put on cells.
I-13 One propane-fired emergency generator(22kW);not observed;not in operation.
(MA CT ZZZZ, This is a small emergency use(lighting/emergency power)generator.
NSPS JJJJ)
5. Compliance with specific air permit conditions of Air Permit No. 04595T17:
b. ES-Ol/ES-02/ES-03/ES-04/ES-05
i. 2.I.A.I.a-c /2.1.B.1.a-c Observed opacity was in compliance with the 20% opacity
requirements. No visible emissions were observed.
ii. 2.LA.2/2.1.B.2. —odorous emissions
There were no odorous emissions observed.
i i i. 2.1.A.3. . PACKED TOWER GAS ABSORBER REQUIREMENTS-
Gaseous emissions from the sulfur dioxide storage area, the electrolyte mixing area, and the
battery filling line(ID No. ES-03) and the sulfur dioxide storage tank(ID No. S02TANK)shall be
controlled by one packed-bed caustic wet scrubber(ID No. CD-03).
i. Inspection/Maintenance/Recordkeeping/Reporting Requirements—
No inspectionIMaintenance/Recordkeeping/Reporting Requirements are required.
The scrubber(ID No.CD-03)was observed in operation.The scrubber operates round-the-
clock.
iv. 2.2.A.La,b PSD avoidance—monthly VOC calculations
a. In order to avoid applicability of this regulation, the above emission sources
shall discharge into the atmosphere less than 250 tons of VOCs per consecutive
12-month period. [15A NCAC 2D.0530]
The last quarterly report was timely received on April 29,2021. 12-month rolling emissions
were 46.8 tons/year for 12-month periods ending March,2021. Compliance with the 250
TPY requirement is indicated.
b. Calculation of facility-wide monthly VOC emissions shall be made at the end of each month.
Mr.Jenkins showed me the spreadsheet(on his computer)he uses to determine monthly
emissions.This calculation is performed monthly,as required.

V. 2.2.A.I.e. -Calculations and the total amount of VOC emissions shall be recorded monthly in a
logbook(written or electronic format). The daily volume of the IPA/water effluent discharged
from the surge tank shall be recorded. The results of all analyses of the monthly composite
effluent samples for the weight percent IPA and the density shall also be recorded. In addition,
the Permittee must make available to officials of the DAQ, upon request, copies of the monthly
emissions log. The Permittee must keep each entry in the monthly emissions log and all required
records on file for a minimum of three years. The Permittee shall be deemed in noncompliance
with 15A NCAC 2D.0530 if the VOC emissions exceed this limit.
SAFT is no longer claiming wastewater credit per this condition [ceased claiming this credit
as of September 2005]. I viewed the electronic"emissions log"which Mr.Jenkins maintains
and updates monthly.
vi. 2.2.A.1.d. - The Permittee shall submit a summary report of monitoring and recordkeeping
activities within 30 days after each calendar year quarter, due and postmarked on or before
January 30 of each calendar year for the preceding three-month period between October and
December, April 30 of each calendar year for the preceding three-month period between January
and March, July 30 of each calendar year for the preceding three-month period between April and
June, and October 30 for the calendar year for the preceding three-month period between July
and September. The report shall contain the following:
i. The monthly VOC emissions for the previous 14 months. The emissions shall be
calculated for each of the 12-month periods over the previous 14 months. The report shall also
contain the weight percent IPA, the density of the IPA/water mixture, the volume of IPA/water
mixture discharged to the sewer, and copies of all analyses during the reporting period for the
weight percent IPA and density of the IPA/water mixture discharged to the sewer.
The last quarterly report was timely received on April 29,2021. 12-month rolling emissions
are approximately 46.8 tons per year, in compliance with the 250 TPY requirement. As
mentioned above,credit for the VOCs in the wastewater is no longer being taken.
vii. The annual compliance certification for CY 2020 was timely received January 25,2021 and
indicated no deviations.
6. Other compliance issues and requirements:
a. 112(r) -This facility is subject to 112(r)because it stores greater than 5000 pounds of anhydrous SOz. The
Company has the RMP on site. We discussed some aspects of the RMP but I did not review the RMP.
c. MACT Subpart ZZZZ/NSPS JJJJ—Per the Title V review,this small emergency generator is subject to
MACT ZZZZ and NSPS JJJJ and compliance with both rules is maintained via compliance with NSPS JJJJ.
Per NSPS JJJJ,for the propane-fired emergency generator the facility must maintain documentation of-
(1)Maintenance conducted on the engine; and
(2) Documentation from the manufacturer that the engine is certified to meet the emission standards and
information as required in 40 CFR Parts 90, 1048, 1054, and 1060, as applicable(normally supplied with
the operating and maintenance instructions with the engine.
Mr.Jenkins confirmed via 7/21/2021 email that these records are kept.
d. Five Year Compliance History: There have not been any Notices of Violation issued in the past five
years.
7. Conclusion and Recommendations-Based on my observations during the inspection, Saft America, Inc.
appeared to be in compliance with the applicable air quality regulations and Air Permit No. 04595T17.