AQ_F_1200076_20200207_CMPL_InspRpt

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NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Saft America Inc.
NC Facility ID 1200076
Inspection Report County/FIPS:Burke/023
Date: 02/28/2020
Facility Data Permit Data
Saft America Inc. Permit 04595/T16
313 Crescent Street Issued 4/1/2019
Valdese,NC 28690 Expires 3/31/2024
Lat: 35d 45.9334m Long: 8ld 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)TV-Minor
Contact Data . Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V/112r
Steve Jenkins Richard Boyens Steve Jenkins
EHS Manager General Manager FITS Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 02/07/2020
Inspector's Name Michael Koerschner
Inspector's Signature: p J Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: n ry r� On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PM10 *HAP
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
2016 0.0400 0.0600 0.4600 78.61 0.4000 0.0200 457.80
*fhghest HAP Emitted(inpounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

2/07/2020 Inspection
Page 2
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.
1. 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 4 days a week,and employs—205 people(production has declined since last inspection).
2. Facility Contacts: The contact information above is current. Mr.Jenkins has been the environmental contact
for about 4 months.
3. I arrived at the facility at 13:05 pm on February 7.2020 and met with Mr. Jenkins to inspect the facility. The
last inspection at this site was December 4,2018.
4. The following permitted air emission sources were observed as follows:
ES-02 one Li-S02 cathode aste oven
Operation status The paste room was in operation. The oven was observed in operation with no
visible emissions.
Line s eed I did not record line speed (typically 8-13 ft/min).
Oven tem erature The oven temperature was 365 Deg F(setpoint of 360 deg F).
ES-01 -Li-S02 cathode paste manufacturing process such as the room exhaust blotter paper emissions,and
vacuum system emissions:
Operation is source was o er mg wi no visible emissions observed.
In this process,an IPA(isopropyl alcohol)and a distilled water mixture is combined
with carbon powder and tflon 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,
which extract some of the IPA/water mixture.The extracted liquid is collected in a
Process Description tank, and is then 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.There is
also a very small dust collector(Dust Hog)that exhausts inside the building and is
therefore exempt from permitting.
The most common batch run(80-90%of production)is the Al(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
discharged once per day and the amount sewered is recorded via a totalizer(per Mr.
Jenkins). I did not observe the meter.
Vacuum meter
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.

2/07/2020 Inspection
Page 3
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.
S02 storage area:No continuous emissions.The tank vapors are conveyed back to track(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—210 gpm(analog gauge at recirculation tank).The pH was 6.40. Caustic is added to the
recirculation tank to maintain a SetPoint pH—6-7 pH.
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 room-both venting the atmosphere via
the shell of the formerly used scrubber.
he scrubber previously controlled the 1-2 pilot line but the I-2 line has been removed. With the removal of the
production line,the facility ceased using the scrubber and has applied to remove the control device from the Air
rmit[Air Permit Application 1200076.18A].
OEM
The anhydrouns Sulfur Dioxide storage tank is located in a separate,locked,room. We did not observe 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 H.
MN02 L ne—The line is a MN02/carbon cathode, lithium anode, line with an electrolyte of ethylene glycol
dimethyl ether,propylene carbonate,tetrahydrofaran, and lithium perchlorate. This line was observed 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 II: 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.
5. 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 should be removed
from the"insignificant activities"list.

2/07/2020 Inspection
Page 4
I-2 One pilot line vented to the permitted scrubber(ID No. CD-04)—This line has been
removed. [removed October 2015].
I-3 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 cth). Total of 10 units.
1-4I One natural as-fired boiler(3.4 million Btu per hour heat input)
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 (per attached State Pressure Vessel report).
I-6 1 One isopropyl alcohol storage tank(2400 gallon capacity)
Observed. This tank sits outside the facility.
1-8 1 Ste anfoam process
No lop er used.Nobody at the plant was familiar with this process/operation and we did not observe it.
I-9 Ink jet printing operation
Ink'ets on site us in MEK—observed
I-12 Epoxy resin and catalyst application operation
Observed the station where the epoxy"caps"are put on cells.
6. Compliance with specific air permit conditions of Air Permit No.04595TI6:
b. ES-Ol/ES-02/ES-03/ES-04/ES-05
i. 2.LA.1.a-c 12.1.B.I.a-c Observed opacity was in compliance with the 20%opacity
requirements.
it. 2.1.A.212.I.B.2.—odorous emissions
There were no odorous emissions observed.
iii. 2.LA.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. SO27ANK)shall be
controlled by one packed-bed caustic wet scrubber(ID No. CD-03). Gaseous emissions from the
cell destruct room(ID No.ES-04)shall be controlled by one packed-bed caustic wet scrubber
(ID No. CD-04).
i. Inspection/Maintenance/Recordkeeping/Reporting Requirements—
No inspection/Maintenance/Recordkeeping/Reporting Requirements are required.
The large scrubber(ID No. CD-03)was observed in operation.The smaller scrubber(ID No.
CD-04)was observed but is no longer operating as a scrubber.The air permit application
was placed on hold at RCO in early 2018 and is now in process. I attempted to determine
when the liquid flow to the scrubber was discontinued but Mr.Jenkins was unable to
determine an exact date. In an email communication on February 24,2020,Mr.Jenkins
"estimated"the following:
"The best I can give you is a relative guess as to when the liquid flow was discontinued. And I am
stating upfront that this is a guesstimate... To the best I can deduce, the liquid was shut off during a
timeframe somewhere between mid 2016 and late 2017."
I discussed this discrepancy with Brendan Davey(Regional Supervisor)and it is our opinion
that the scrubber is not used/necessary to meet any air quality standards.Raleigh is acting
on the pending permit application(no longer on hold)and if there are issues with
discontinuation of this control device,we can follow up with the company at a later date.
iv. 2.2.A.].a,b PSD avoidance—monthly VOC calculations

2/07/2020 Inspection
Page 5
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 January 30,2020. 12-month rolling
emissions were 65-71 tons/year for 12-month periods ending October,November,and
December,2019. Compliance with the 250 TPY requirement is indicated.
b. Calculation offacility-wide monthly VOC emissions shall be made at the end of each month.
Mr.Jenkins showed me the spreadsheet he uses to determine monthly emissions.This
calculation is performed monthly,as required.
V. 2.2.A.Le. -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 lag. 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 20051. I did view 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:
t. 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 January 30,2020. 12-month rolling
emissions are approximately 65-70 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 2019 was timely received January 30,2020 and
indicated no deviations.
7. Other compliance issues and requirements:
a. 112(r) -This facility is subject to 112(r)because it stores greater than 5000 pounds of anhydrous S02. The
Company has the RMP on site. I did not review the RMP.
b. MACT Subpart ZZZZ—The emergency generator on site has been removed with no plans of
replacement. It has been removed from the air permit.

2/07/2020 Inspection
Page 6
c. Five Year Compliance History: There have not been any Notices of Violation issued in the past five
years. A Notice of Deficiency was issued August 24,2015 for failure to conduct a monthly work practice
standard inspection.
8. 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. 04595T16.

i
I
Koerschner, Michael F
From: Davey, Brendan
Sent: Tuesday, February 25, 2020 8:57 AM
To: Koerschner, Michael F
Cc: Scott, Chris
Subject: RE: [External] RE: SAFT;Air Permit 04595T16
I
Based on my discussion with Michael,ARO will not take any enforcement letter action at this time. This source has very
little air emissions (lbs/yr),the scrubber is not needed for compliance with any standard, and the permit application was
submitted years ago for its removal. If RCO determines the scrubber is needed for some reason,we can re-evaluate.
- Brendan
BreodanDavey,P.E.
Dtv mo enisar
1]ivn of AirQuality,Aahevile ReRiaaal Office �
629.296.4500(Office) 2090 U.S.Ifighway 70
M-M-7043(Fax) Swaaiama,NC 29M
Brendan.Davey .gov
£ida:N'a .�maerlh€+w t� � #BatAtE4�rr+dns� ,
From: Koerschner, Michael F<[e-mail]>
Sent: Monday, February 24, 2020 4:40 PM
To: Davey, Brendan <[e-mail]>
Cc:Scott, Chris<[e-mail]>
Subject: FW: [External] RE:SAFT; Air Permit 04595T16
I was awaiting finalizing my inspection report until this issue was resolved. Review of past inspection reports indicates:
12/04/2018—"The facility has applied to completely remove the control device"
4/3/2018—"scrubber ON"
01/08/2018—Air Permit Application (to remove scrubber) rec'd at RCO
4/04/2017—"Scrubber ON"
2/06/2017—Brendan emailed Beth Anderson and Mark Beigay that they would have to file an application "to remove
scrubber CD-04 from operation"
Not sure how to proceed. NOV?
Lets discuss.
From:Jenkins, Steve [mailto:[e-mail]]
Sent: Monday, February 24, 2020 4:12 PM
To: Koerschner, Michael F<[e-mail]>
Cc: Lyons, Mary<Mary.Lyons@safta merica.com>; Ryan Orborne, PE<[e-mail]>
Subject: RE: [External] RE:SAFT; Air Permit 04595T16
Hello Michael,
1

Unfortunately, I cannot find an actual date that the device was taken out of service. Many of the personnel that would
have knowledge of this have retired or moved on to another job.
It has been indicated to me by the people that I have interviewed that this scrubber issue was discussed with an Air
Quality Inspector from your regional office. This would have been back in the days of Beth Anderson, EHS Manager and
Mark Beigay, Facilities Manager 2015 -2017 time frame. I do not know if this is fact or not. Brandan Davey may have
some insight to this matter as I think at one time he was the AQ inspector for this facility.
The best I can give you is a relative guess as to when the liquid flow was discontinued. And I am stating up front that this
is a guesstimate ... To the best I can deduce,the liquid was shut off during a timeframe somewhere between mid 2016
and late 2017.
Please discuss this with Brandan. I am given the impression by the people I have interviewed that he may know some of
the story and timeline also.
Thanks and best regards,
Steve
8Cp14�18t1�Oj
Steve Jenkins,CSP,REM EHS Manager
A. 313 Crescent Street,Valdese, North Carolina 28690, USA
P. [phone] D.+1-828-879-5052 W. www.saftbatteries.com
We energize the world.
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From: Koerschner, Michael F<[e-mail]>
Sent: Friday, February 21,2020 8:22 AM
To:Jenkins, Steve<[e-mail]>
Cc: Lyons, Mary<[e-mail]>; Ryan Orborne, PE<[e-mail]>; Ballard, Patrick
<[e-mail]>; Bland, Brian <[e-mail]>
Subject: RE: [External] RE: SAFT; Air Permit 04595T16
Mr.Jenkins;
We received the copies of the application and check at this office.
Have you had a chance to determine when the facility stopped liquid flow to the cell destruct scrubber?
2