Mr. Tony Walsh President & Executive VP Alevo Manufacturing, Inc Concord Parkway South Concord, NC 28027

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1 PAT MCCRORY Governor DONALDR. VAN DER VAART Secretary Air Quality ENVIRONMENTAL QUALITY SHEILA C. HOLMAN Director October 17, 2016 Mr. Tony Walsh President & Executive VP Alevo Manufacturing, Inc Concord Parkway South Concord, NC Subject: Air Permit No R41 Alevo Manufacturing, Inc. Concord, Cabarrus County, North Carolina Permit Class: Synthetic Minor Facility ID# Dear Mr. Walsh: In accordance with your completed application received August 26, 2016, we are forwarding herewith Permit No R41 to Alevo Manufacturi:qg, Inc., Concord, Cabarrus County, North Carolina for the construction and operation of air emissions sources or air cleaning devices and appurtenances. Additionally, any emissions activities determined from your air permit application as meeting the exemption requirements contained in 15A NCAC 2Q.0102 have been listed for information purposes as an 11 A'ITACHMENT 11 to the enclosed air permit. Please note the records retention requirements are contained in General Condition 2 of the General Conditions and Limitations. If any parts, requirements, or limitations contained in this permit are unacceptable to you, you have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of the entire permit. This hearing request must be in the form of a written petition, conforming to G.S. 150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC The form for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings. Unless a request for a hearing is made pursuant to G.S. 150B-23, this air permit shall be final and binding. You may request modification of your air permit through informal means pursuant to G.S. l 50B-22. This request must be submitted in writing to the Director and must identify the specific. provisions or issues for which the modification is sought. Please note that the permit will become final and binding regardless of a request for informal modification unless a request for a hearing is also made under G.S. 150B-23. State of North Carolina I Environmental Quality I Air Quality Mooresville Regional Office I 610 East Center Avenue, Suite 301 I Mooresville, NC T I F

2 Tony Walsh October 17, 2016 Page2 Unless exempted by a condition of this permit or the regulations, construction of new air pollution sources or air cleaning devices, or modifications to the sources or air cleaning devices described in this permit must be covered under a permit issued by the Division of Air Quality prior to construction. Failure to do so is a violation of G.S and may subject the Permittee to civil or criminal penalties as described in G.S A and B. This permit shall be effective from October 17, 2016 until July 31, 2017, is nontransferable to future owners and operators, and shall be subject to the conditions and limitations as specified therein. Changes have been made to the permit stipulations. The Permittee is responsible for carefully reading the entire permit and evaluating the requirements of each permit stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in this permit. Noncompliance with any permit condition is grounds for enforcement action, for permit termination, revocation and reissuance, or modification, or for denial of a permit renewal application. Should you have any questions concerning this matter, please contact Jim Hafner at Sincerely, Bruce J. Ingle, Acting Regional Supervisor Division of Air Quality, NC DEQ JAH Enclosures c: Mooresville Regional Office G:\AQ\SHARED\WPDATA\COUNTIES\CABARRUS\00048\R41_ PERMIT.DOCX

3 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR QUALITY AIR PERMIT NO R41 I '. Issue Date: October 17, 2016 Expiration Date: July 31, 2017 Effective Date: October 17, 2016 Replaces Permit: 03717R40 To construct and operate air emission source(s) and/or air cleaning device(s), and for the discharge of the associated air contaminants into the atmosphere in accordance with the provisions of Article 21B of Chapter 143, General Statutes of North Carolina (NCGS) as amended, and other applicable Laws, Rules and Regulations, Alevo Manufacturing, Inc Concord Parkway South Concord, Cabarrus County, North Carolina Permit Class: Synthetic Minor Facility ID# (the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air cleaning devices and appurtenances described below: - Emission Emission Source Control Control System Source ID Description System ID Description ' ~lectrolyte Process B-200, L-911, L-921, concentrated electrolyte K-810 packed bed scrubber with R-110 storage tank (ID No. B-200, mesh pad mist eliminator 15,000 gallon capacity) (100 gallons per minute minimum injection rate and finished electrolyte storage ph range of8 to 10) tank (ID No. L-911, 15,000 gallon capacity) finished electrolyte storage tank (ID No. L-921, 15,000 gallon capacity) electrolyte dilution mixing vessel (ID No. R-110, 750 gallon) with two (2) overhead condensers FL-1, FL-2 battery cell filling line (ID K-820 packed bed scrubber with No. FL-1) mesh pad mist eliminator (80 gallons per minute battery cell filling line (ID minimum injection rate and No. FL-2) - ph range of8 to 10) - J

4 Page2 Emission Emission Source Control Control System Source ID Description System ID Description ~01 cnspsi --J~~s~~ 1----= ::---1 EG (NESHAP) I diesel fuel-fired emergency 11 N/A II N/A / I. generator (750 kw)..... in accordance with the completed application A received August 26, 2016 including any plans, specifications, previous applications, and other supporting data, all of which are filed with the Department of Environmental Quality, Division of Air Quality (DAQ) and are incorporated as part of this permit. This permit is subject to the following specified conditions and limitations including any TESTING, REPORTING, OR MONITORING REQUIREMENTS: A. SPECIFIC CONDITIONS AND LIMITATIONS 1. Any air emission sources or control devices authorized to construct and operate above must be operated and maintained in accordance with the provisions contained herein. The Permittee shall comply with applicable Environmental Management Commission Regulations, including Title l 5A North Carolina Administrative Code (NCAC), Subchapter 2D.0202, 2D.0503, 2D.0516, 2D.0521, 2D :0524 (40 CFR 60, Subpart De), 2D.0535, 2D.0540, 2D.1111 (40 CFR 63, Subpart ZZZZ), 2D.2100, 2Q.0102, 2Q.0308, 2Q.0315 and 2Q.0317 (Avoidance). 2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter in accordance with ISA NCAC 2Q.0304(d) and (f): Pursuant to ISA NCAC 2Q.0203(i), no permit application fee is required for renewal of an existing air permit (without a modification request). The renewal request (with AA application form) should be submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration date of this permit, the Permittee shall submit the air pollution emission inventory report (with Certification Sheet) in accordance with ISA NCAC 2D.0202, pursuant to N.C. General Statute The report shall be submitted to the Regional Supervisor, DAQ and shall document air pollutants emitted for the 2016 calendar year. 3. PARTICULATE CONTROL REQUIREMENT- As required by ISA NCAC 2D.0503 "Particulates from Fuel Burning Indirect Heat Exchangers," particulate matter emissions from the fuel burning indirect heat exchangers shall not exceed the allowable emission rates listed below:

5 Page3 [ Source J Emission L=~) (lbs/m~~= natural gas/no. 2 fuel oil-fired boiler (96 million Btu per hour heat I 0.24 _ inpu!) (B ) _ 4. SULFUR DIOXIDE CONTROL REQUIREMENT- As required by l 5A NCAC 2D.0516 "Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input. 5. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D.0521 "Control of Visible Emissions," visible emissions from the emission sources, manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-minute period, except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period. However,.sources which must comply with 15A NCAC 2D.0524 "New Source Performance Standards" or.1110 "National Emission Standards for Hazardous Air Pollutants" must comply with applicable visible emissions requirements contained therein A NCAC 2D.0524 "NEW SOURCE PERFORMANCE STANDARDS"- For the natural gas/no. 2 fuel oil-fired boiler (ID No. B ), the Permittee shall comply with all applicable provisions, including the notification, testing, reporting, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D.0524 "New Source Performance Standards'' (NSPS) as promulgated in 40 CFR 60, Subpart De, including Subpart A "General Provisions." a. NSPS Reporting Requirements - In addition to any other notification requirements to the Environmental Protection Agency (EPA), the Permittee is required to NOTIFY the Regional Supervisor, DAQ, in WRITING, of the following: 1. Within 30 days after each six-month period of the calendar year (by January 30 for the previous six-month period between July and December and by July 30 for the previous six-month period between January and June), the Permittee must submit in writing to the Regional Supervisor, DAQ, the sulfur content of the distillate oil combusted in an affected source. If fuel supplier certification is used to demonstrate compliance, fuel supplier certification shall include the following information: A. The name of the oil supplier; B. A statementfrom the oil supplier that the oil complies with the specification under the definition of distillate oil in 40 CFR 60.41(c); and C. A certified statement signed by the owner or operator of an affected source that the records of fuel supplier certification submitted represent all of the fuel combusted during the reporting period. J

6 Page4 11. The owner or operator of each affected facility subject to the S02 emission limits of 60.42c, or the PM or opacity limits of 60.43c, shall submit to the Regional Supervisor, DAQ, the performance test data from the initial and any subsequent performance tests. (60.48c(b)) 111. The reporting period for the reports required under this subpart is each sixmonth period. All reports shall be submitted to the Regional Supervisor, DAQ, shall be postmarked by the 30th day of January or July, following the end of the reporting period. (60.48cG)) b. NSPS Recordkeeping Requirements - In addition to any other recordkeeping requirements of the EPA, the Permittee is required to maintain records as follows: 1. The amounts of each fuel combusted during each month; and 11. All records required under this section shall be maintained for a period of two years following the date of such record The Permittee operating boilers equal to or greater than 30 million Btu per hour but less than 100 million Btu per hour fired on distillate oil subject to the opacity limits in paragraph ( c) of this stipulation shall submit excess emission reports for any excess emissions from the affected facility that occur during the reporting period and maintain records according to the requirements specified in paragraphs (A) through (B) of this section, as applicable to the visible emissions monitoring method used. (60.48c(c)(l through 2)) A. For each performance test conducted using Method 9, the owner or operator shall keep the records including the information specified in paragraphs (I) through (III) of this section. I. Dates and time intervals of all opacity observation periods; IL III. Name, affiliation, and copy of current visible emission reading certification for each visible emission observer participating in the performance test; and Copies of all visible emission observer opacity field data sheets. B. For each performance test conducted using Method 22, the owner or operator shall keep the records including the information specified in paragraphs (I) through (IV) of this section. I. Dates and time intervals of all visible emissions observation periods; II. Name and affiliation for each visible emission observer participating in the performance test;

7 Page 5 III. IV. Copies of all visible emission observer opacity field data sheets; and Documentation of any adjustments made and the time the adjustments were completed to the affected facility operation by the owner or operator to demonstrate compliance with the applicable monitoring requirements c. NSPS Emissions Limitations - As required by 15A NCAC 2D.0524, the following permit limits shall not be exceeded: ~ I Affected Sources _JI Pollutant II Emission Limit I IParticulatell20% opacity I natural gas/no. 2 fuel oil-fired boiler (ID No. B ) Sulfur Fuel sulfur content shall Dioxide not exceed 0.5% by weight d. NSPS Performance Testing- As required by 15A NCAC 2D.0524, the following performance tests shall be conducted: r Affected Source(s) =:J~];DIT~~t~l [iurtural gas/no. 2 fuel oil-fired boiler (ID No. B0-03-0l)j[htmculataj[Methods 9 an~~ 1. All performance tests shall be conducted in accordance with EPA Reference Methods, contained in 40 CFR 60, Appendix A. 11. The EPA Administrator retains the exclusive right to approve equivalent and alternative test methods, continuous monitoring procedures, and reporting requirements The Permittee shall be responsible for ensuring, within the limits of practicality, that the equipment or process being tested is operated at or near its maximum normal production rate or at a lesser rate if specified by the Director or his delegate. 1v. All associated testing costs are the responsibility of the Permittee. v. To afford the Regional Supervisor, DAQ, the opportunity to have an observer present, the Permittee shall PROVIDE the Regional Office, A. In WRITING, at least 30 days notice of any required performance test(s), and B. Notify the Director or his designee of any planned performance test by 9:00 a.m. Eastern Time of the Division's next business day of becoming aware of the planned performance test.

8 Page6 e. Particulate Matter Monitoring - (60.47c): After completion of the initial performance testing for particulate matter required in paragraph d, or within 45 days of switching fuel combustion from natural gas to a fuel with an opacity standard (such as coal, oil, or wood), the permittee shall comply with visible emissions testing in paragraphs i or ii as follows 1. When burning distillate oil, the permittee shall conduct subsequent Method 9 performance tests using the applicable schedule in paragraphs A through D of this section, as determined by the most recent Method 9 performance test results. (60.47c(a)(l)) A. If no visible emissions are observed, a subsequent Method.9 performance test must be completed within 12 calendar months from the date that the most recent performance test was conducted; (60.47c(a)(l)(i)) B. If visible emissions are observed but the maximum 6-minute average opacity is less than or equal to 5 percent, a subsequent Method 9 performance test must be completed within 6 calendar months from the date that the most recent performance test was conducted; (60.47c(a)(l )(ii)) C. If the maximum 6-minute average opacity is greater than 5 percent but less than or equal to 10 percent, a subsequent Method 9 performance test must be completed within 3 calendar months from the date that the most recent performance test was conducted; or( c( a )(1 )(iii)) D. If the maximum 6-minute average opacity is greater than 10 percent, a subsequent Method 9 performance test must be completed within 45 calendar days from the date that the most recent performance test was conducted. (60.47c(a)(l)(iv)) E. The observation period for Method 9 performance tests may be reduced from 3 hours to 60 minutes if all 6-mjnute averages are less than 10 percent and all individual 15-second observations are less than or equal to 20 percent during the initial 60 minutes of observation.( c( a)) 11. When burning distillate oil, if the maximum 6-minute opacity is less than 10 percent during the most recent Method 9 performance test, the owner or operator may, as an alternative to performing subsequent Method 9 performance tests, elect to perform subsequent monitoring using Method 22 according to the procedures specified in paragraphs A and B of this section. (60.47c(2)) A. The owner or operator shall conduct 10 minute observations ( during normal operation) each operating day the affected facility fires fuel for which an opacity standard is applicable using Method 22 and

9 Page 7 demonstrate that the sum of the occurrences of any visible emissions is not in excess of 5 percent of the observation period (i.e., 30 seconds per 10 minute period). If the sum of the occurrence of any visible emissions is greater than 30 seconds during the initial 10 minute observation, immediately conduct a 30 minute observation. If the sum of the occurrence of visible emissions is greater than 5 percent of the observation period ( i.e., 90 seconds per 30 minute period), the owner or operator shall either document and adjust the operation of the facility and demonstrate within 24 hours that the sum of the occurrence of visible emissions is equal to or less than 5 percent during a 30 minute observation ( i.e., 90 seconds) or conduct a new Method 9 performance test using the procedures in paragraph i of this section within 45 calendar days. (60.47c(2)(i)) B. If no visible emissions are observed for 10 operating days during which an opacity standard is applicable, observations can be reduced to once every 7 operating days during which an opacity standard is applicable. If any visible emissions are observed, daily observations shall be resumed. (60.47c(2)(ii)) iii. To afford the Regional Supervisor, DAQ, the opportunity to have an observer present, the Permittee shall PROVIDE the Regional Office notice of any planned performance test by 9:00 a.m. Eastern Time of the Division's next business day of becoming aware of the planned performance test. 7. NOTIFICATION REQUIREMENT - As required by ISA NCAC 2D.0535, the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall: a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time of the Division's next business day of becoming aware of the occurrence and describe: 1. the name and location of the facility, ii. the nature and cause of the malfunction or breakdown, 111. the time when the malfunction or breakdown is first observed, iv. the expected duration, and v. an estimated rate of emissions. b. Notify the Director or his designee immediately when the corrective measures have been accomplished. This reporting requirement does not allow the operation of the facility in excess of Environmental Management Commission Regulations.

10 Page 8 8. FUGITIVE DUST CONTROL REQUIREMENT - As required by 15A NCAC 2D.0540 "Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. If substantive complaints are received or excessive fugitive dust emissions from the facility are observed beyond the property boundaries for six minutes in any one hour (using Reference Method 22 in 40 CFR, Appendix A), the owner or operator may be required to submit a fugitive dust plan as described in 2D.0540(:t). "Fugitive dust emissions" means particulate matter that does not pass through a process stack or vent and that is generated within plant property boundaries from activities such as: unloading and loading areas, process areas stockpiles, stock pile working, plant parking lots, and plant roads (including access roads and haul roads) A NCAC 2D.1111 "National Emission Standards for Hazardous Air Pollutants"- For the diesel fuel-fired emergency generator (ID No. EG-01-01), the Permittee shall comply with all applicable provisions, including the maintenance and recordkeeping requirements contained in Environmental Management Commission Standard 15A NCAC 2D.1111, as promulgated in 40 CFR 63, Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating Internal Combustion Engines (RICE)", including Subpart A "General Provisions." The Permittee shall comply with the definition of emergency stationary RICE in 40 CFR and the following stationary RICE provlslons. a. Compliance Date - The compliance date is May 3, b. Maintenance and Work Practices - Pursuant to 40 CFR (a), (e), (f), and (h) and (:t) the Permittee shall comply with the following: 1. Change the oil and filter every 500 hours of operation or annually, whichever comes first. The Permittee has the option to utilize an oil analysis program as described in Section c. below in order to extend the specified oil change requirements. 11. Inspect the air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. iv. Operate and maintain the engine and control device (if any) according to the manufacturer's emission related written instructions or maintenance plan developed by the Permittee that minimizes emissions from the engine to the extent practicable. v. Install a non-resettable hour meter ifone is not already installed.

11 Page 9 v1. Minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the non-startup emission limitations apply. vu. viii. If the engine is operating during an emergency and it is not possible to shut down the engine in order to perform the management practice requirements on the schedules required in Sections b.i., b.ii., and b.iii., above, or if performing the management practice on the required schedules would otherwise pose an unacceptable risk under federal, state or local law, the management practices can be delayed until the emergency is over or the unacceptable risk under federal, state, or local law has abated. The management practice shall be performed as soon as possible after the emergency has ended or the unacceptable risk has abated. The Permittee shall report any failure to perform the management practice on the schedule required and the federal, state, or local law under which the risk was deemed unacceptable. If the Permittee does not operate the engine according to the requirements in Sections A. through C. below, then the engine will not be considered an emergency engine under NESHAP Subpart ZZZZ and must meet all requirements for non-emergency engines. A. There is no time limit on the use in emergency situations. B. The Permittee may operate the engine for any combination of the purposes specified in Section (i) below for a maximum of 100 hours per calendar year. (i) The engine may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission authority or equivalent balancing authority and transmission operator, or the insurance company associated with the engme. The Permittee may petition the Division of Air Quality (DAQ) Regional Supervisor for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that federal, state, or local standards require maintenance and testing of the engine beyond 100 hours per calendar year. C. Pursuant to 40 CFR (±)(4), the engine may be operated for up to 50 hours,per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing provided in Section b.viii.b above. Except as provided in Section (i) below, the

12 Page hours per year for non-emergency situations cannot be used for peak shaving or to generate income for the facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity. (i) The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if ALL of the following conditions are met: (I) (II) (III) (IV) The engine is dispatched by the local balancing authority or local transmission or distribution system operator. The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. The power is provided only to the facility itself or to support the local transmission and distribution system. (V) The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator. 1x. At all times the Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to DAQ which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source.

13 Page 11 c. Oil Analysis Program - Pursuant to 40 CPR (i), the Permittee may utilize an oil analysis program in order to extend the oil change requirements specified in -Section b.i. above. The oil analysis must be performed at the same frequency specified for changing the oil. If any of the limits listed below are exceeded, the Permittee shall change the oil within two (2) business days ofreceiving the results of the analysis. If the engine is not in operation when the results of the analysis are received, then the oil must be changed within two (2) business days or before commencing operation, whichever is later. 1. Total base number is less than 30 percent of the total base number of the oil when new; or 11. Viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or 111. Water content (by volume) is greater than 0.5%. If all of the above limits are not exceeded, the Permittee is not required to change the oil before continuing to use the engine. d. Fuel Requirements,. Per 40 CPR (b), beginning January 1, 2015, emergency engines that meet all the following conditions shall use diesel fuel that meets the requirements in 40 CPR O(b) for nonroad diesel fuel., 1. Greater than 100 brake HP; 11. Displacement of less than 30 liters per cylinder; 111. Operates for the purposes specified in Section b.viii.c.(i) above. Any existing diesel fuel purchased prior to January 1, 2015 may be used until depleted. The diesel fuel requirements of 40 CPR O(b) are shown below: Sulfur content 15 ppm maximum. Cetane index or!aromatic content A minimum cetane index of 40; or A maximum aromatic content of 35 volume percent. e. Recordkeeping - Pursuant to 40 CPR (d), (e) and (f), the Permittee shall keep records for at least five ( 5) years showing: 1. The engine was operated and maintained according to the manufacturer's emission related operation and maintenance instructions or the Permittee's maintenance plan which must provide for the maintenance and operation of

14 Page 12 the engine in a manner consistent with good air pollution control practice for minimizing emissions. 11. If applicable, the parameters that are analyzed as part of the oil analysis program, the results of the analysis, and the oil changes for the engine The hours of operation of the engine that is recorded through the nonresettable hour meter. The Permittee shall document how many hours are spent for emergency operation; including what classified the operation as emergency and how many hours are spent for non-emergency operation. If the engine is used for purposes specified in Section b.viii.c.(i) above, then the Permittee shall keep records of the notification of the emergency situation, and the date, start time and end time of the engine operation for these purposes. f. Reporting - Pursuant to 40 CFR (h), if the engine is greater than 100 brake HP that operates for the purposes specified in Section b.viii.c.(i) above, the Permittee shall submit an annual report to the DAQ Regional Supervisor. The first annual report s.hall be submitted no later than March 31, 2016 and cover the calendar year Subsequent annual reports shall be submitted by March 31 of each year and cover the previous calendar year. The annual report must also be submitted electronically to EPA through the specific NESHAP Subpart ZZZZ reporting form in the Compliance and Emissions Data Reporting Interface (CED RI) that is accessed through EPA's Central Data Exchange (CDX). However, if the reporting form specific to NESHAP Subpart ZZZZ is not available in CEDRI at the time that the report is due, the written report shall be submitted to EPA at the appropriate address listed in Section 63.13; EPA Region IV Director, Air, Pesticides and Toxics Management Division Atlanta Federal Center 61 Forsyth Street Atlanta, GA The annual report shall contain the following information: 1. Company name and address where the engine is located. 11. Date of the report and beginning and ending dates of the reporting period Engine site rated horsepower and model year for each engine. iv. Latitude and longitude of the engine in decimal degrees reported to the fifth decimal place.

15 Page 13 v. Hours spent for operation for the purpose specified in Section b.viii.c.(i) including the date, start time, and end time for engine operation. The report must also identify the entity that dispatched the engine and the situation that necessitated the dispatch of the engine. v1. If there were no deviations from the fuel requirements in Section d. above that apply to the engine (if any), a statement that there were no deviations from the fuel requirements during the reporting period. vu. If there were deviations from the fuel requirements in Section d. that apply to the engine (if any), information on the number, duration, and cause of deviations, and the corrective action taken CFR Part 68 "ACCIDENTAL RELEASE PREVENTION REQUIREMENTS: RISK MANAGEMENT PROGRAMS UNDER THE CLEAN AIR ACT, SECTION 112(r)" - The Permittee shall comply with all applicable requirements in accordance with 40 CFR Part 68 including submitting a Risk Management Plan to EPA pursuant to 40 CFR or as specified in 40 CFR Federal and State Rules Applicable to Sources Exempted from Air Permitting Requirements - Your facility is subject to the following federal and state rules: 40 CFR 60 - NSPS -- Subpart Standards of Performance for Stationary ~ression Ignition Internal Combustion Engines CFR 63 - NESHAP/MACT-- Subpart ZZZZ -- Reciprocating Internal Combustion Engines which are applicable to some of the emission sources at your facility fisted on the "Insignificant/Exempt Activities" list attached to this permit. The purpose of this permit condition is to inform you of your compliance obligations to these applicable rules as they are enforceable. 12. CONTINUED OPERATIONS - In accordance with 15A NCAC 2Q.0308, the existing equipment being modified is permitted to operate in compliance, per the following: A. The battery fill line (ID No. FL-1) is permitted to be controlled by packed bed scrubber with mesh pad mist eliminator (ID No. K-810) until packed bed scrubber with mesh pad mist eliminator (ID No. K-820) is operational. B. The packed bed scrubber with mesh pad mist eliminator (ID No. K- 810) is permitted to continue to operate with a minimum injection rate of 80 gallons per minute until it is operational with a minimum injection rate of 100 gallons per minute.

16 Page LIMITATION TO AVOID ISA NCAC Pursuant to ISA NCAC 2Q.0315 "Synthetic Minor Facilities," to avoid the applicability of 15A NCAC 2Q.0501 "Purpose of Section and Requirement for a Permit," as requested by the Permittee, facility-wide emissions shall be less than the following: Emission Limit Pollutan1 Tons per consecutive 12-month period) S a. Operations Restrictions - To ensure emissions do not exceed the limitations above, the following restrictions shall apply: 1. The No. 2 fuel oil combusted shall be less than 2,700,000 gallons per consecutive 12-month period when burning fuel that is 0.5 percent by weight sulfur. b. Inspection and Maintenance Requirements - 1. Packed Tower Gas Absorber Requirements - Gaseous emissions shall be controlled as described in the permitted equipment list. The inspection, maintenance and record keeping requirements shall become effective November 17, 2016 for packed bed scrubber (ID No. K-820). To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits, the Permittee shall perform periodic inspections and maintenance (I&M) as recommended by the manufacturer. In addition, the Permittee shall perform an annual (for each 12 month period following the initial inspection) internal inspection of each scrubber system. As a minimum, the I&M program and each annual inspection should include the following: A. inspection of spray nozzles, packing material, chemical feed system (if so equipped), and the cleaning/calibration of all associated instrumentation annually. B. two weeks following initial start-up and startup following major maintenance of each scrubber, the Permittee shall shut down the system and inspect for nozzle plugging and settling of the packing. c. Monitoring Requirements - 1. Packed Tower Gas Absorber Requirements - The Permittee shall ensure the proper performance of each absorber by monitoring the following operational parameters: A. The Permittee shall record the recycle liquid flow rate (range = 100 gallons per minute, minimum) once per month for packed bed scrubber (ID No. K-810).

17 Page 15 B. The Permittee shall record the recycle liquid flow rate (range = 80 gallons per minute, minimum) once per month for packed bed scrubber (ID No. K-820). C. For packed bed scrubbers (ID Nos. K-810 and K-820), the Permittee shall record the ph of each recirculation tank absorber solution (range = 8 to 10) monthly. d. Recordkeeping Requirements 1. A log book (in written or electronic format) shall be kept on site for packed bed scrubber with mesh pad mist eliminator (100 gallons per minute miriimum injection rate and ph range of 8 to 10) (K-810) and packed bed scrubber with mesh pad mist eliminator (80 gallons per minute minimum injection rate and ph range of 8 to 10) (K-820) and made available to Division of Air Quality personnel upon request. The Permittee shall record all inspection, maintenance and monitoring requirements listed above in the log book. Any variance from the manufacturer's recommendations shall be investigated with corrections made and date of actions recorded in the log book. 14. AVOIDANCE CONDITION FOR AREA SOURCES SUBJECT TO 40 CFR 63 Subpart JJJJJJ (6J)- In accordance with 15A NCAC 2Q.0317, the Permittee is avoiding applicability of 40 CFR 63 Subpart JJJJJJ (6J) "Industrial, Commercial, and Institutional Boilers Area Sources." The Permittee is permitted to operate a natural gas I No. 2 fuel oilfired boiler (ID Nos. B ). Per 40 CFR (e), these/this source(s) is/are exempt from this Subpart because they are defined as gas-fired boiler(s) in 40 CFR In order to maintain this exemption, the Permittee is allowed to fire liquid fuel only during periods of gas curtailment, gas supply interruptions, startups, or for periodic testing on liquid fuel (periodic testing not to exceed a combined total of 48 hours during any calendar year). a. The Permittee shall maintain records that document the time periods when liquid fuel is fired and the reasons the liquid fuel is fired. b. If the Permittee fires liquid fuel for reasons other than gas curtailment, gas supply interruptions, startups, or for periodic testing on liquid fuel, the Permittee is no longer exempt from Subpart JJJJJJ (6J). As required by 40 CFR 62.l 1225(g), the Permittee must provide notice within 30 days of the fuel switch. The notification must identify: 1. The name of the owner or operator of the affected source, the location of the source, the boiler(s) that have switched fuels, and the date of the notice. 11. The date upon which the fuel switch occurred. As required by 40 CFR (h), the Permittee must demonstrate compliance within 180 days of the effective date of the fuel switch.

18 Page LIMITATION TO AVOID 15A NCAC 2D.0530 "PREVENTION OF SIGNIFICANT DETERIORATION" - In accordance with 15A NCAC 2Q.0317, to comply with this permit and avoid the applicability of 15A NCAC 2D.0530 "Prevention of Significant Deterioration," as requested by the Permittee, emissions shall be limited as follows:!affected Source(s)IIPollutantll!_mission Limit (Tons Per Consecutive 12-month Period)! ~cility Wide J[~O? ]@50 l a. Operations Restrictions - To ensure emissions do not exceed the limitations above, the following restrictions shall apply: 1. All monitoring, recordkeeping and reporting requirements contained in the Synthetic Minor condition above will be used to monitor compliance with this condition. 16. LIMITATION TO AVOID 15A NCAC 2D.1402 "APPLICABILITY" - In accordance with l 5A NCAC 2Q.0317, to comply with this permit and avoid the applicability of l 5A NCAC 2D.1402 "Applicability," as requested by the Permittee, emissions shall be limited as follows: Affected Source(s) Pollutant I Emission Limit!Facility Wide IINOx EJ tons per year I Facilit Wide 560 pounds per calendar day from May J y through September 30 o~any year The facility-wide potential uncontrolled NOx emissions are less than 100 tons per year. The permittee is already tracking and recording the hours of operation for each generator through the use of a non-resettable hour meter in order to comply with NESHAP Subpart ZZZZ ( 4Z). The permittee shall use this information to show the facility-wide NOx emissions do not exceed 560 pounds per day from May 1 through September 30 of each year. As a result, there are no additional recordkeeping requirements for this condition. B. GENERAL CONDITIONS AND LIMITATIONS 1. In accordance with G.S (c)(l), TWO COPIES OF ALL DOCUMENTS, REPORTS, TEST DATA, MONITORING DATA, NOTIFICATIONS, REQUESTS FOR RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall be submitted to the: Regional Supervisor North Carolina Division of Air Quality Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, NC I

19 Page 17 For identification purposes, each submittal should include the facility name as listed on the permit, the facility identification number, and the permit number. 2. RECORDS RETENTION REQUIREMENT - In accordance with 15A NCAC 2D.0605, any records required by the conditions of this permit shall be kept on site and made available to DAQ personnel for inspection upon request. These records shall be maintained in a form suitable and readily available for expeditious inspection and review. These records must be kept on site for a minimum of 2 years, unless another time period is otherwise specified. 3. ANNUAL FEE PAYMENT- Pursuant to 15A NCAC 2Q.0203(a), the Permittee shall pay the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a timely manner will cause the DAQ to initiate action to revoke the permit. 4. EQUIPMENT RELOCATION - In accordance with 15A NCAC 2Q.0301, a new air permit shall be obtained by the Permittee prior to establishing, building, erecting, using, or operating the emission sources or air cleaning equipment at a site or location not specified in this permit. 5. REPORTING REQUIREMENT - In accordance with 15A NCAC 2Q.0309, any of the following that would result in previously unpermitted, new, or increased emissions must be reported to the Regional Supervisor, DAQ: a. changes in the information submitted in the application regarding facility emissions; b. changes that modify equipment or processes of existing permitted facilities; or c. changes in the quantity or quality of materials processed. If appropriate, modifications to the permit may then be made by the DAQ to reflect any necessary changes in the permit conditions. In no case are any new or increased emissions allowed that will cause a violation of the emission limitations specified herein. 6. In accordance with 15A NCAC 2Q.0309, this permit is subject to revocation or modification by the DAQ upon a determination that information contained in the application or presented in the support thereof is incorrect, conditions under which this permit was granted have changed, or violations of conditions contained in this permit have occurred. In accordance with G.S (c)(l), the facility shall be properly operated and maintained at all times in a manner that will effect an overall reduction in air pollution. Unless otherwise specified by this permit, no emission source may be operated without the concurrent operation of its associated air cleaning device(s) and appurtenances. 7. In accordance with G.S (c)(l), this permit is nontransferable by the Permittee. Future owners and operators must obtain a new air permit from the DAQ. 8. In accordance with G.S (c)(l), this issuance of this permit in no way absolves the Permittee of liability for any potential civil penalties which may be assessed for violations of State law which have occurred prior to the effective date of this permit.

20 Page In accordance with G.S (c)(l), this permit does not relieve the Permittee of the responsibility of complying with all applicaqle requirements of any Federal, State, or Local water quality or land quality control authority. 10. In accordance with 15A NCAC 2D.0605, reports on the operation and maintenance of the facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such intervals and in such form and detail as may be required by the DAQ. Information required in such reports may include, but is not limited to, process weight rates, firing rates, hours of operation, and preventive maintenance schedules. 11. A violation of any term or condition of this permit shall subject the Permittee to enforcement pursuant to G.S l 14A, l 14B, and l 14C, including assessment of civil and/or criminal penalties. 12. Pursuant to North Carolina General Statute (a)(2), no person shall refuse entry or access to any authorized representative of the DAQ who requests entry or access for purposes of inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or interfere with any such representative while in the process of carrying out his official duties. Refusal of entry or access may constitute grounds for permit revocation and assessment of civil penalties. 13. In accordance with G.S (c)(l), this permit does not relieve the Permittee of the responsibility of complying with any applicable Federal, State, or Local requirements governing the handling, disposal, or incineration of hazardous, solid, or medical wastes, including the Resource Conservation and Recovery Act (RCRA) administered by the Division of Waste Management. 14. PERMIT RETENTION REQUIREMENT - In accordance with 15A NCAC 2Q.0110, the Permittee shall retain a current copy of the air permit at the site. The Permittee must make available to personnel of the DAQ, upon request, the current copy of the air permit for the site. 15. CLEAN AIR ACT SECTION 112(r) REQUIREMENTS - Pursuant to 15A NCAC 2D.2100 "Risk Management Program," if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the Permittee is required to register this plan with the USEP A in accordance with 40 CFR Part PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I Part A Section 112(r)(l) of the Clean Air Act "Hazardous Air Pollutants - Prevention of Accidental Releases - Purpose and General Duty," although a risk management plan may not be required, if the Permittee produces, processes, handles, or stores any amount of a listed hazardous substance, the Permittee has a general duty to take such steps as are necessary to prevent the accidental release of such substance and to minimize the consequences of any release. This condition is federally-enforceable only.

21 Page GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS -If emissions testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing to the DAQ in support of a permit application or to demonstrate compliance, the Permittee shall perform such testing in accordance with ISA NCAC 2D.2600 and follow all DAQ procedures including protocol approval, regional notification, report submittal, and test results approval. Permit issued this the 17th of October, NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION Bruce J. Ingle Acting Regional Supervisor By Authority of the Environmental Management Commission Air Permit No R41

22 ATTACHMENT to Permit No R41, October 17, 2016 Page 20 Insignificant I Exempt Activities r - source_ J_~:;:~::: :;;:: :.~::::? I-EG diesel fuel-fired emergency generator 2Q.0102 r-:=-ll I (350 kw) [NESHAP Subpart ZZZZ] (h)(5) ~ Yes I-EG diesel fuel-fired emergency generator :=2Q=O=l=02=~Ges 8es (407 kw) [NSPS Subpart 1111 and NESHAP Subpart (h)(s) ZZZZ] I-EG diesel fuel-fired emergency generator 2 Q 0102 G~ (839 kw) [NSPS Subpart 1111 and NESHAP Subpart (h)(s) Yes ZZZZ] JI ' I I-EG diesel fuel fired emergency generator 2Q.0102 [ Yes Yes (200 kw) [NESHAP Subpart ZZZZ] (h)(5). J. I-EG-04-01: diesel fuel-fired emergency generator-- :=2Q==.0=1=02=~~l y (200 kw) [NESHAP Subpart ZZZZ] (h)(5) '----~~~--j es _ ~l I-EG propane-fired emergency generator 2Q.0102 y --- J es {60 kw) [NESHAP Subpart ZZZZ] (h)(5) L ~_J I-EG propane-fired emergency generator 2Q.0102 r-:=-ll Yes I (35 kw) [NESHAP Subpart ZZZZ] (h)(5) ~ I-PU diesel fire pump engine (99 bhp) 2Q.0102 ~l y J [NESHAP Subpart ZZZZ]. (h)(5) L--~~~-J es I-PU diesel fire pump engine (290 bhp) -- 2Q ~L----- Yes [NESHAP Subpart ZZZZ] (h)(5) ~. I-L-931A-packed bedscrubberwithmeshpadmist 2 Q 0102 G8 eliminator (ID No. K-810) installed on a finished (h)(s) Yes electrolyte batch tank (10 liter capacity) I-L-93 lb - packed bed scrubber with mesh pad mist 2 Q 0102 G8 eliminator (ID No. K-810) installed on a finished (h)(s) No Yes electrolyte batch tank (10 liter capacity)_, I-L-932A - packed bed scrubber with mesh pad mist Q ~~ G~eliminator (ID No. K-810) installed on a finished (h)(s)... Yes No eliminator (ID No. K-810) installed on a finished (h)(s) l~_:_jl_: J ;'.~::::::e:':j~~~:::a:-:~eshpadmist 2 Q 0102 electrolyte batch tank (10 liter capacity) I-CR packed bed scrubber with mesh pad mist 2 Q 0102 eliminator (ID No. K-820) installed on a waste h 5 electrolyte handling consisting _of a waste collection ( )( )

23 ATTACHMENT to Permit No R41, October 17, 2016 Page 21 Source Source of Source I Exemption of Title V. ~egulation I TAPs? Pollutants? J,:=ta=nk=(=1=30=ga=l=lo=n=c=ap=a=c=ity=)=, =a =drum==(=5=5=g=al=lo=n===:l. IDl ~acity) and a glove box. G8 I-MV-3-packedbedscrubberwithmeshpadmist 2 Q 0102 eliminator (ID No. K-820) installed on a manual (h)(s) No Yes mixing vessel (10 liters capacity). ~i~!to;r.~~~.b~8~~~::i~o~:-~adri;-;.o,;-r :] -Ye~ -I G8 ~_quipment cleaning P!Ocess _ ~h)(s) - - I-V AC-1 - packed bed scrubber with mesh pad mist 2 Q 0102 eliminator (ID No. K-820) installed on a vacuum (h)(s) No Yes pump enclosure _!==:===~ G8 I-T0-1 -natural gas-fired thermal oxidizer ( Q _ 0102 million BTU per hour maximum heat input) (h)(l)(b) Yes Yes installed on a waste acetone process _ ~-B02 - acid w~te tank (300 gallon ~apacity) _ ~~ [ No_ J~[--N-o--]~ I-TK boiler water treatment chemical 2Q 0102 ~1 I storage tanks (g)(4) _ [~_J No l Yes Yes I (g)(4). ""--~ - ~ ~----- ~ I-TK ~ No. 2 fuel oil storage tank (40,000 2Q gallon capacity) 1. Because an activity is exempted from being required to have a permit or permit modification does not mean that the activity is exempted from an applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement. 2. When applicable, emissions from stationary source activities identified above shall be included in determining compliance with the permit requirements for toxic air pollutants under 15A NCAC 2D.1100 "Control of Toxic Air Pollutants" or 2Q.0711 "Emission Rates Requiring a Permit." 3. Sample permit conditions showing the regulatory requirements for exempt sources subject to NESHAP, NSPS, and NCAC rules may be found here: