AQ_F_1200076_20180403_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: 04/03/2018
Facility Data Permit Data
Saft America Inc. Permit 04595/T15
313 Crescent Street Issued 4/1/2014
Valdese,NC 28690 Expires 3/31/2019
Lat: 35d 45.9334m Long: 81d 33.3167m Classification Title V
SIC: 3692/Primary Batteries,Dry And Wet Permit Status Active
NAILS: 335912/Primary Battery Manufacturing Current Permit Application(s)TV-Minor
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V/112r
Michael McGuire Richard Boyens Michael McGuire
Environmental Health General Manager Environmental Health
and Safety Manager [phone] and Safety Manager
[phone] [phone]
Compliance Data
Comments:
Inspection Date 04/03/2018
Inspector's Name Harold Brady
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 1 A On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2016 0.0400 0.0600 0.4600 78.61 0.4000 0.0200 457.80
2015 0.0200 0.0450 0.3600 51.97 0.3200 0.0200 118.49
2014 0.0200 0.0357 0.3700 56.15 0.3200 0.0200 50.30
*Highest HAP Emitted inpounds)
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. The facility requests that vehicles be backed into the parking
places. Visitors are required to have citizenship papers signed by the supervisor prior to arrival at the facility.
1. The purpose of this site visit was to conduct a routine 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 16 hours per day with one
full 8-hour shift and a second partially-manned shift,5 days a week,and employs—260 people. Production is
currently—550,000 S02 cells per month(6 to 7 million cells per year)where peak production several years ago
was—75,000 cells per day. Mn02 batteries are also manufactured on site and used in communication devices.
2. Facility Contacts: Mr.Michael McGuire is the new Facility and Technical Contact and,as of the date of this
inspection,has been at the facility for less than two weeks. The update is in IBEAM.
3. 1 arrived at the facility at 10:00 am on April 3,2018 and met with Mr.McGuire to inspect the facility. Mr.
McGuire was recently hired and had contacted this office requesting some assistance with the reporting
requirements of the permit. It appears that he was able to find and access the required information. Mr.Mark
Beigay,Production Manager,or Mr.Mark Miller,Facilities Maintenance,have historically been the backup
inspection contacts.The last inspection at this site was March 15,2017. The site visit concluded at about noon.
4. The following permitted air emission sources were observed as follows:
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6 fi
"neathode aste d n oven
The paste room was in operation. The oven was observed in operation with no
visible emissions.
The linespeed was 9.5 ft/min and is typically 8-13 ft/min.
Oven temperature The oven temperature was 360 Deg F.
ES-0I -Li-S02 cathode paste manufacturing process such as the room exhaust,blotter paper emissions,and
vacuums stem emissions:
Operation Hus source was operating 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,
which extract some of the IPA/water mixture.The extracted liquid is collected in a
Process Description tank, and is then discharged 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 recycling(some landfilled). 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.
There are several different batch formulations run. The company previously had
switched to a lower IPA formulation(25/75 IPA to water)in 2005,but due to issues
with new carbon being used they had to return to the old formulation of 50/50 for a
Batch formulation few mixes.
The most common batch run(80-90%of production)is the Al(26sx)formulation
(low IPA formula)and was indicated to be 95.0 pounds water,32.0 pounds IPA,and
other materials carbon black Teflon etc.).

t
At the time of the site visit they were running Al(26sx)formulation(low IPA
formula).
Vacuum meter Less than 200 gallons per day(50-90 gallons) are typically collected.The tank is
discharged once per day. I did not observe the meter.
o er a er stored outside tor rec c m atter use.
Mixing area:The electrolyte consists of a mixture of SOZ,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
no mixing being conducted during this inspection. A general room exhaust is also vented to the scrubber.
Fill stations: There are four(previously five)automated battery filling stations with hoods(3 double head and 1
single head). Some of the fill material is emitted at these fill stations. Three double head were in operation
during this inspection. As a part of the fill stations a Metal Guard 410 rust inhibitor is applied.The compound
consists of 80%kerosene.The batteries are later placed in a 150 degree oven,and this kerosene may be
evaporated on site. The metalguard air emissions are included in the quarterly reports.
S02 storage area:No continuous emissions. The tank vapors are conveyed back to the truck 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 175 gpm.The pH was 7.02,with a set point range of 6.69 to 6.91. The sump is drained and refilled
each weekend,with additional purges 1-2 X Eer week.
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 prolonged use. This scrubber previously controlled the I-2 pilot line but it has
been removed. The scrubber was in operation(25%caustic(NaOH)added). I did not observe the flow rate or
the pH. Note that with the removal of pilot line,the facility has applied to completely remove the control
device due to reduced emissions coupled with high maintenance costs for the scrubber.
A tank delivery is received every 12 weeks with about 38,000 pounds received per delivery. The tank can hold
up to 48,000 pounds. There were 23,390 ounds in the tank.
MN02 7ventedoutside,
—The line is a MN02/carbon cathode, lithium anode,line with an electrolyte of ethylene glycol
dimether,propylene carbonate,tetrahydrof Iran, and lithium perchlorate. This was previously a pilot line
but has enlarged to be a full production line. The following sources are on this line(air emissions only
from p below):
i. ode manufacture part I: cathode mix area vented to internally venting cartridge filter. The cathode
consists of MN02 powder,carbon,Teflon,and water(no IPA or other volatile). This operation was
tly moved to an external building,but still vents internally.
ii. ode manufacture part II:Mix application to screen,blotting paper, electric oven-no apparent air
sions.
iii. yRoll"manufacture—battery assembly excluding electrolyte fill—anode is lithium—no apparent air
sions.
iv. trolyte filling process—There are two(and one prototype)fill lines and only the protoype was in
ation.The electrolyte is Purolyte 6110(not mixed on site—obtained in small drums). The filling
ns are vented outside, and reviousl vented through a carbon canister when this was a pilot line.

The facility was granted permission in 2015 to expand the MNO2 manufacturing. The proposal is to add a paste
line and oven(with thermal degradation of PVA(acetic acid and VOC))and an additional fill line for larger
batteries(VOC and ethylene glycol dimethyl ether).A 502(b)(10)notification received 2/23/15,but on 2/25/15
Brian Bland of Central Office indicated no permit modification or 502 b 10 notification was required.
5. The following nonpermitted air emission sources were observed as follows:
I-1 1 Metal canister seal checking operations
This source was in operation. 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. Genesolv solvent has been
com letel discontinued around 2008.
I-2 I One pilot line vented to the permitted scrubber ID No. CD-04
Removed October 2015.
1-3 1 Natural as-fired dehumidification gas packs 1.4 million Btu per hour heat input)
Observed in operation -Eight big 220 cfli and two small 41 cfh .
I-4 1 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
late indicated 1398-4185 MBH.
I-6 One isopropyl alcohol storage tank 2400 gallon capacity)
Observed.
I-8 Ste anfoam process
Still on site in limited format.
1-9 1 Ink'et printing operation
Ink'ets on site us MEK—observed
I-12 Epoxy resin and catalyst application operation
Not observed. This process is switching over to hot melt which does not appear to have VOC content.
Some epoxy resin usage remains.
Welding—There are small unvented welding operations. TIG welding in the dry room,Plasma welding in
the fill room,and Resistance/Spot welding in assembl .
6. Compliance with specific air permit conditions of Air Permit No. 04595T15:
b. ES-Ol/ES-02/ES-03/ES-04/ES-05
i. 2.I.A.I.a-c /2.1.B.l.a-c Observed opacity was in compliance with the 20%opacity
requirements. Monthly VE monitoring is no longer required.
ii. 2.I.A.2/2.I.B.2. —odorous emissions
There were no odorous emissions noted outside the facility.
in. 2.I.A.3. (2D.0958) a-e/2.1.B.3.a-e work practice standards, once per month visual inspection of
all processes, semi-annual summary report
The Company's work practice standards appeared to be in compliance with these requirements.
The monthly logs were complete and available for review. The most recent semi-annual summary
report was timely received July 30,2018 and indicated compliance with this requirement. The
company previously reported missing the June 2015 inspection.A NOD was forwarded for this
issue on August 24,2015. Note that effective November 1,2016,2D .0902 removes the
applicability of 2D .0958 to facilities in Burke county, but the requirement is still in the current
permit..
iv. 2.I.A.4. PACKED TOWER GASABSORBER 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. SO2T4NK)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).
1. Inspection/Maintenance/Recordkeeping/Reporting Requirements—
No inspection/Maintenance/Recordkeeping/Reporting Requirements are required. The control
devices were in operation.
V. 2.2.A.La,b PSDavoidance—monthlyVOCcalculations
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 October 30,2018. 12-month rolling emissions are
approximately 76 tons per year, in compliance with the 250 TPY requirement.
b. Calculation offacility-wide monthly VOC emissions shall be made at the end of each month.
Yes-being conducted.
vi. 2.2.A.1.c. -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.
The monthly VOC log was on site and a copy of the daily effluent discharge records(50-150 gpd
typical effluent). SAFT is no longer claiming wastewater credit per this condition since
wastewater concentrations would have changed due to formulation changes. They were informed
in an e-mail dated 9/23/05 that they would need to modify the air permit to reflect the new
wastewater concentrations. The company appears to no longer need the wastewater credit to
demonstrate compliance, and has ceased claiming this credit as of September 2005.
vii. 2.2.A.I.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 October 30,2018. 12-month rolling emissions are
approximately 76 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 2017 was timely received January 31,2018 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; however, it is noted that the facility submitted
the last update to the EPA on November 9,2018.
li

Mr. Mike Reid,Mr. Chris Scott,and Ms.Terri Davis of NCDAQ
RMP conducted a 112r inspection on July 27,2017. Several
deficiencies were noted see file).
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
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.04595T15.