Department of Toxic Substances Control Matthew Rodriquez Secretary for Environmental Protection Barbara A. Lee, Director 9211 Oakdale Avenue Chatsworth, California 91311 Edmund G. Brown Jr. Governor Please note that the violations alleged in this report are addressed in the Stipulation and Order executed by the Department on November 21, 2014. Printed on Recycled Paper State of California Environmental Protection Agency Department of To'xio Substances Control SAMPLING REPORT GENERAL INFORMATION Company Name: Facility Address: TelephoneNurnber: EPA Number: Facility Type: Regulated Unite: Permit Status: I Person Collecting Samples: Note Takers: Photographers: . Exide Technologies, Inc. 2700 South indiana Avenue Loe Angeiee, California 90058 (323) 262-1101 ext.259 CAD 097 854 54-1 'Otf?ite Hazardous Waste Storage and Treatment Faloy The facility operates the following hazardous waste. management units under interim Status: The Reverberatory and Blast Smelting furnaces and the furnaces ancillary equipment; the Containment Building; the Waste Water Treatment Pia nt; and six Spent Lead- Aoid Battery and' Lead Hazardous Waste Storage areas. Interim Statue - Ruth Williams-Morehead, Environmental Scientist (ES) . and Brian Wu, ES - April 29, 2014, Ruth Williams-Morehead, ES and Brian Wu, ES - June - 10,2014_ Ellen Patea, ES April 29, 2014 - Ruth Williams-Morehead, ES - June 10, 2014 Tolu Awosika, as -Apri120, 2014 Brian Wu, ES June 10, 2014 Dates Sampling inspection: April 29, 2014 and June 10, 2014 Type of inspection: Sampling inspection- Facility Representatives: April 29, 2014 - Rafael Perez,.Operations Manager . . .. June .10, EnvironmentalMenager I CONSENT Consent givenby?. Rafael Perez, Operations Manager?- April 29-, 2014 - - Ed Mopa?s, Environmental Managern-June 10, 2014 HLNARRAHVE On April 29, 2014,. l, Ruth Brian Wu, Tolu Awosika, and Ellen I Rates of the Department of Toxic Substance Control (DTSC), Enforcement and Emergency Response Division (EERD) conducted a sampling inspection at Exide. Thesamplinginspection was in response to a report from the South Coast Air Quality Management District (SCAQMD) that the High Volume Air Monitor on the east side'of the facility detected "significant exceedanees fer lead on March 20 and 21, 2014. The purpose of the sampling inspection was to determine if the exceedances on March 20 and 21 EM 4 resulted in a release of lead in the proximal area Exide. We met with Mr. Rafael Perez, Operations Manager and explained the purpose-cf our Visit. i told himthat woold be collecting" soil samples at the facility and areas surrounding the facility. Mr. Perez granted us permission to collect soil samples at thetac??y. . . - During the April 29, 20,14 sampling inspection we collected eight soil samples, which were mixed between two jars and split into duplicate samples A and B. Photos were taken of each samples location (attachment 1). The samples Were given to Rafael Perez, of Exide and the A samples were taken to the DTSC Environmental Chemistry Laboratory by myself and Brian Wu. The first two samples were collected from Exide?s employee parking lot located directly across the street from the hazardods waste portion of the facility. Samples EXMZQ A were collected from the south end of the parking lot near a 'high volume air monitor facing .Bandinl AVenue, and samples EX2429 A were collectedi'rom the east side of the parking lot surrounding a tree. Samples EX3429 A were collected from the rail spur between Exide'and R'ehrlg Pacific, Samples EX4429 A were collected from the'soii surrounding a tree adjacent to the side walk and located next to the Storm Water Retention Pond . Samples were collected from around a tree on Indiana Street, one block north of Bandini next to a Exide?s building. located on I the hazardous waste portion of the facility. Samples EX6429 were collected from a break in the'asphalt on the West Yard next to a fence that separates Exide BNSE?gC'ontainerstorageyard; Samples SLB were-collected from theNorth est-cornerof the-West Yardiand-?the?samplee EX8429 A a were collected from a break in the asphalt next to "mo?Ha . we? "pr'ovi anal 29,1201eatapproximately 1:samples were delivered to Environmental Chemistry Laboratory in Los Angeleson April?29, 2014 at approximately 3:30 pm. The DTSC Environmental Chemistry Laboratory in Los Angeles analyzed. the samples and the results (attachments 3 38? 4) showed lead above the regulatory limit in S'amples'EX1429 A1 A, and EX8429I-A and snowed'lead has a hazardws constituent in Samples A and-EX5429 A. - Subsequent to I the April 29, 201.4 Sampling inspection, a second Sampling inspection was conducted on June 10, 2014; On a prior inspection conducted bythe Otiiceot Permitting dustwas seen around the Containment Building doors. As a - result of the observation made during that inspection was asked to collect interior the ContainmentBuilding. On June 10, 2014, Brian Wu and l, Ruth Williams?M-orehead collected fourdust samples which were also ?split into duplicate and 13 samples from around the Containment Building doors. Photo's Were taken at the sampling locations (att'e'cnmen't Samples were Collected "from outside-the Containment Building at the Blast Feed Room door. Samples A 8: were collected from outside the Containment Building .'at the Corridor. Doors. Samples were. collected from inside theContainment Building near the Blast Feed Room Loading Dock, Samples A were collected from inside the Containment Building from the Refining Maintenance Door. We provided all the samples (attachment 6) to Mr. Ed Mopas oi Exide on June- 10, 2014 at approximately 11:00 am. The A Samples were delivered to the DTSC Environmental Chemistry Laboratoryin' Los Angeles on June 10, 2014 at approximately 12:30 pm. The DTSC Environmental Chemistry Laboratory in Los Angeles analyzed the samples and the results (attachment 7) showed lead and antimony above the regulatory limits in samples RW61 and The results shewed arsenic, cadmium and selenium above the regulatory limit in samples RW61 OEXAAS RW610EXA-4 and arsenic and cadmium as a hazardous constituent in sample The results also showed copper above the regulatory limit in sample and as a hazardous constituent in samples RW610EXA-1 and Prior to the Sampling inspections, conducted ?a ComprehenSive Evallia?iion inspection at Exide on A'prilri,? 20-13..Dpring that Inapection l' obserVed that'the 4.0 ft. trailers that contained hazardous waste?plastic werestoredfclosed andfnot I - leaking st- Sepiemberand an seem-6? that the trailers that contained the poo condition. The trailers were left open and the water, from the plastic-chips leaked from the trailers, Mr. Mopas stated that sometime after my inspection in April, the dryer used to remove'waterfrorn the plastic chips broke. Hestated that because the dryer is not working the plastic chips contain more water when they. are blown-into the trailers-which are causing the tasks. Heatated that they are slivers of the problem and that is why they put a catch basin beneath the trailers, to c'atoh the Water. The Office of Permitting which is revietrliing the Ex?ide Part-B permit application discovered that Exide did not have authorization to install thedryer. On my prior'inspections Exide has always inelu'ded the dryer. when describing their recycling process, but is cu'rrently?unable to determine when the dryer-Was installed. in mid-t QQO'the facility was citedforstoring wet plastic. chips in cc ntainers that leaked. Exide corrected the Violation by agreeing'in Consent Order 9319211006"(attachment that'the chipswould'be sufficiently dried to ensure leach-ate the chips do not leak. in a letter to DTSC dated September 18, 1993, page. 2 (attachment 9), Exide describes that'the chips will be allowed to air dry - before they'are shipped off-eitefordispos'al. The letter'does not state that the chips will be placed into a dryerto chips. Based on this information,'it seems likely the'drye'r'was' installed between the years iggd'and 1997. - Based on the-sample results from both of the sampling inspections, statements and. information regarding the installation of the dryer,the following pending violations have been cited. ly. 1. Title 22, California 0666 of Regulations (con), section 66265.31 Exide Technologies, Inc. (Exide) violated Title, 22 California Code of Regulations (OCR) section 66265.31 in that on orabout April 29 and June it), 2014, Exidefailed to maintain and operate the Facility to minimize the possibility of any unplanned sudden or non~sudden release of hazardous waste or hazardous constituents to air, soil, or surface water which could threaten health orthe environment. Dust/debris exceeding hazardous waste regulatory limits for antimony, arsenic, cadmium, copper, lead and selenium were found outside the Containment Building at the Blast Feed Room and Corridor Doors. Soil samples collected at the employee parking lot, the "rail spur, the areas around the Storm Water Retention Fond, the portions of Indiana Street adjacent to the Facility, the fence line'area of the West Yard and the unpaved areas adjacent to the Cooling Tower exceeded hazardous waste limits for I lead. Corrective Action: Effective immediately Respondent shall maintain andoperaie the .I . constituents; No later than Novemberg, 2014, Exide shall submit to the Department a plan to mini'rnize'the escape of the, doors and any other opening of the Containment Building" at the Facility, and to enhance the current cleaning procedures of removing dust and deb'ris'containing hazardous-Waste levels offload and other constituents in areas outside of the Containment Building, including'but nctgiir?r?iiwdto, removal-offiner divided debris foundrin the cornersfand at the base Containment IB Uilding and other buildings,- parking lots, essential/ea area'sof the Department may direct Exide to make modifications to this plan. 2. Title 22, CCRsectlon 66270.42 Exideylolated Title 22,0012 section 66270.42 in that, since August a, 201 a, and for a- period ?of time prior thereto,?Exide?operated arrotary dryer to treat ?hazardous - weate plastic chips in its recycling process without prior authorization from the Department. Corrective Action: Effective immediately, Exide shall not use the rotary dryerwithout first "obtaining authorization from 'the Department, either through --approval-of a- modification of its interim status authorization to use the rotary dryer during interim status for through a hazardousWaste-facility permit to usegthe rotary dryerin the - . Facilityjs treatmentu'process. ThelDepartment will take appropriate actions to process an Exide application for modification one'mraimsetus?autiiareaton to usethe rotary dryer; during interim'status. lf Erode does not-seek a modification of its interim statuaauthcrization from the Department to operate this dryer, then Exide shall, no later than November 9, 2014, submit a closure plan and implementation schedule to the Department for closure of this rotary dryer. Exlde shall implement the?cloisure plan and schedule with respect to the rotary dryer as approved-or modified'by the? Department. lf Exide applies for, butdoes not receive, authorization from 'the Department to add the rotary dryer to its process during interim status, Exide shall complete closure of the rotary dryer in accordance With a plan approved by the Department no laterthan 60 days after the Department?s final determination on Exide?s permit modification. - Before resuming Use of the rotary dryer, Exide must obtain adthorization from the Department, either through a hazardous waste facility permit or through a modification of their interim status authorization (permit modification), to add the rotary dryer to the facility's treatment process; If Exide does not receive authorization from the Department to add the rotary dryerto its process, Exide shall Complete -- . Department no": later $1713.13. 50 Edi-etarmma?pnign y. I . . etatue??a?thorizationitrd the-dryer, then . . 1 Exlde thang Nievelniberif'g,? 2014, Submit? a feleear'e? plan and implementationepheduleto thedepartmentfer-Closure otthie rotary - 5'shall implement the-loleegre plan and eehe?dule'as apptove?d or modified by the Department] I . . '1 v. Photee ??April 29, 2014 - 8plit,Sam-ple Receipt April 29, 2014 Laboratory?Repor-t Total Metals May 7, 2014 Laboratpry Report Soluble Metals (TCLP) May'ts, 2014- Photoe June 10, 2014 . Split Sample Receipt Split Sample Receipt? June 10, 20-14 LaboratoryReportTotal Metals 4 June 20,2014 Consent Agreement and Order 93/94?006 . Letter dated September 18, 1993, to DTSC from GNB currently Exide Original signed MIK- Fiuth Williams-Morehmeacl, ES Date? . I . .g State of California Caliiorn-ia Environmental Protection Agency Department of Toxic Substances Control Miriam Barcellona lngenito, Acting Director 921.1 Oakdaie Avenue Chatsworth, California 91311 SUMMARY OF VIOLATIONS. On ?reirj, the Department of ,Toxic Substances Control (DTSC), California Environmental Protection Agency, conducted an inspection at: Facility Name: Exide Technologies inc. . Facility Address: 2700 lndiana Street Vernon, California 90023 EPA ID Number: CAD 097 854 541 County: Los Angeles As a result of this inspection, violations of hazardous waste laws, regulations, and requirements listed on the attached pages were discovered. All violations must be corrected; the actions you must take to correct the violations are listed with each violation. if you disagree with any of the violations or proposed corrective actions listed in this Summary of . Violations, you should inform DTSC. Additional violations may be found after-the site visit, and these will be identified in the Violation section of the inspection report. DTSC will provide youa complete inspection report within 65 days of the date of this inspection. Youlmay request a meeting with'DTSC to discuss the inspection, inspection report, or the Summary of Violations. The issuance of this Summary of Violations does not precludeDTSC from taking administrative, civil, or criminal action as a result of the, violations noted in the Summary of Violations or violations that have not been corrected within the time provided. Afalse statement that compliance has been achieved is a violation of the law and punishable by a fine of not less than $2,000 or more than $25,000 for each occurrence. DTSC may re?inspect this facility at any time. Company Representative Accepting Seminary DTSC Representative Name: 3 JAGWTW Name: Brian-?Wu Signature: Original signed Signature: Original signed . we? . . r? . - Title: (WM i'itie: Envrronmental - I Date: . wr- Date:_ [ale/Lia 0T801563(O4fi?if2014) Page 1 Oil State of California California Environmental Protection Agency Department of Toxic substances Control Miriam Barcellona Ingenito, Acting Director . 9211 Oakdale Avenue Chateworth, California 91311 SUMMARY OF VIOLATIONS Facility Name: Exide Technologies Inc. . Date: 08i12i14 SECTION I: NON - MINOR VIOLATIONS AND REQUIRED CORRECTIVE ACTION (Violatione not considered Minor Violatione) You must correct the following violation(e) within the specified time frame for each violation. 1. Failure to maintain the primary barrier of the containment buiiding to be free of eigni?cant cracks, gape, corrosion, or other deterioration Exide Technologies Inc. (Exlde) violated Code of Reguiations, title 22, section in that on or about August 5, 2014', Exide failed to maintain the primary barrier of the containment building free of significant cracks, gape, corrosion, or deterioration that Could hazardous waste to be released from the primary barrier. Two areas approximately two to five feet in diameter in the concrete floor was eroded from an the to an inch and half deep. The areas where the erosion occurred in the concret' a?rleviocated at the east end of the Corridor in the Containment Building. Corrective Action: Effective immediately, Exide'ehall toilovv the procedure (described in section 66265.1101(o) (3) to repair the erosion of the concrete at occurred in the east end of the Corridor In the Containment Building. R3212 3 State of California - Cailfornla Environmental Protection Agency - XE Department of Toxic Substances Control Miriam Baroellona Ingenito, Acting Director 9211 Oakdale Avenue Chateworth, California 91311 I. SUMMARY 0F VIOLATIONS Facility Name: Exide Technologies Inc. I Date: 0811212014 Continuation Sheet for SECTION I NON-MINOR VIOLATIONS AND REQUIRED CORRECTIVE ACTION (add title of eeotion) 2. Failure to inspect and record the monitoring data, containment building, and eurrounding areas Exide Technologies Inc. (Exide) violated California Code of Regulations, title 22, section in that on or about August ?11, 2014, Exide failed to inspect and record data gathered from the monitoring equipment, leak detection qu?g?gg Agrd the Containment Building and the area immediately surrounding the ui [rig to detect signs of reieasea of hazardous waste, to wit: Exide did not conduct inspection. of the above mentioned equipment, the Containment Building and the area surrounding the Containment Building. Corrective Action: Effective immediately, Exide shall inepth and record data gathered from the monitoring equipment, leak detection equipment, the Containment Building and he area surrounding the Containment Buiiding, in the Operating Record. ?3 {if 3)