Department of Toxic Substances Control Matthew Rodriquez Secretary for Environmental Protection Deborah o. Raphael, Director 9211 Oakdale Avenue Chatsworth, California 91311 Edmund G. Brown Jr. Governor May 31,2012 Certified Mail Mr. Ed Mopas Environmental Manager Exide Technologies 2700 South Indiana Street Los Angeles, California 90058 Dear Mr. Mopas: On March 29, April 2 and 4, 2012, the California Environmental Protection Agency, Department of Toxic Substances Control (DTSC), conducted a Compliance Evaluation Inspection of Exide Technologies located at 2700 South Indiana Street, Los Angeles, California 90058. EPA 10 Number CAD097854541. The enclosed report describes the findings of this inspection. However, subsequent to the)nspection, additional violations were cited. Therefore as stated in Summary of Violations issued to you on April 4, 2012, additional violations may be found after the site visit, and these will be identified in the Summary of Violations section of the inspection report. You are required by section 25183 © (3) of the Health and Safety Code to submit a written response to the Department within 30 days describing the corrective actions that you have taken or propose to take to bring your company into compliance. If you dispute the violation, you should explain your disagreement in this written response. The issuance of this letter and report does not preclude the Department from taking administrative, civil or criminal action as a result of the violation noted in the report. All pertinent information derived from the inspection, including documents and photographs are included as attachments to the report. The report will become public document. You may request that any trade secret or facility security information be withheld from public disclosure (See Health and Safety Code section 25173). If you wish to assert the trade secret privilege, please provide DTSC specific written answers to each of the following questions within 10 days of receipt of the inspection report. Mr. Ed Mopas May 31,2012 Page 2 of 2 • • • • • • To what extent is there knowledge of the information conveyed by the photograph/document outside of your business? To what extent is there kriowledge of the information conveyed by the photograph/document? To what extent has measures been taken to guard the secrecy of the information? Is the information valuable to competitors? If so why? Has there been sUbstantial monetary expenditure in the development of the information? Could the information be easily and properly acquired or duplicated by others? DTSC will review your response to these questions to determine if the information should be treated as trade secret and will notify you of its decision. If you have questions regarding this letter, or if you wish to meet with the Department to discuss any questions or concerns you have with the inspection, the report, the violations, or proposed corrective action, please contact me at (818) 717-6668 or Ruth Mukul Agarwal Supervising Senior Hazardous Substances Scientist Enforcement and Emergency Response Program Chatsworth Office Enclosures Certified Mail No.: 70092820000243039065 Return Receipt Requested. State of California Environmental Protection Agency Department of Toxic Substances Control INSPECTION REPORT I. GENERAL INFORMATION Company Name: Exide Technologies, Inc. Facility Address: 2700 South Indiana Avenue Los Angeles, California 90058 Telephone Number: (323) 262-1101 ex1.259 EPA ID Number: CAD 097 854 541 facility Type: Off-Site Hazardous Waste Storage and Treatment Facility Regulated Units: The facility operates the following hazardous waste management units under an ISO: The Reverberatory and Blast Smelting furnaces and the furnaces ancillary equipment; the Containment Building; the Waste Water Treatment Plant; and six Spent Lead-Acid Battery and Lead Hazardous Waste Storage areas. Permit Status: Interim Status Document (ISO) Inspected by: Ruth Williams-Morehead, HSS - March 29, April 2 and 4,2012 Tina Roberson-Holefield, HSS - March 29, April 2 and 4,2012 Dates of Comprehensive Evaluation Inspection: March 29, April 2 and 4, 2012 Type of Inspection: Comprehensive Evaluation Inspection Facility Representatives: Ed Mopas, Environmental Manager Pat Curran, Process Engineer Galindo Felix, Waste Water Treatment Unit Supervisor Vianey Mendez, Health and Safety Manager. II. CONSENT Consent to conduct an inspection that involves: taking photographs, reviewing and copying records, questioning personnel and inspecting hazardous waste management areas. Consent given by: Ed Mopas on March 29, April 2 and 4, 2012 III. a. DOCUMENTS REVIEWED Manifests, Bills of Lading, LOR's, Exception Reports: No violations were found during the review of the manifests or bills of lading. No Exception Reports were filed since the last inspection. b. Contingency Plan: No violations were found during the review of the Contingency Plan. c. Training Plan and Records: No violations were found during the review of the Training plan or Training records. However, the outlines for drum labeling, manifesting, and implementation of the contingency plan needs to be more detailed to ensure that employees are being trained on the required information. d. Incident Report: No reportable incidents occurred in the past year. e. Waste Analysis Plan and Records: No violations were found during the review of the Waste Analysis Plan. f. Operation Record: The facility has an excellent operating record which can track and provide the locations of incoming and outgoing hazardous waste. g. Inspection Records: No violations were found during the review of the Inspection Records. h. Tiered Permitting Applications and Authorization Letters: N/A I. Annual/Biennial Reports: No violations were found during the review of the Annual Report. j. SB 14 Plans: Exide Technologies is a recycling facility. k. Closure Cost Estimates and Updates: No violations cited. I. Part A: An application was filed in 1981 by Gould, Inc., the former owner of GNB. Exide purchased GNB in 2000, and the facility currently operates under the name Exide Technologies. The facility has never been issued a Hazardous Waste Facility permit and is currently operating under Interim Status Document. m. Part B: The Part B application is under review by the Southern California Permitting and Corrective Action Branch. n. POTW Compliance Data: Exide operates a Waste Water Treatment Plant that treats hazardous waste water generated on site, and is eventually discharged into POTW after treatment. o. Tank and/or Containment Certifications: No violations were found during the review of the Tank and Containment Certifications. p. Air Board Permits: Several of the facility's hazardous waste management units are equipped with Air Monitoring Control Devices .. AII permits for these devices are current. q. N/A Variances: r. Recycling Records: N/A s. Other: The facility imports hazardous waste (lead acid batteries) from mainly Canada. Mr. Mopas showed me copies of Exide's most recent import notifications that were sent to DTSC. IV. NARRATIVE OF OBSERVATIONS/DISCUSSION WITH OPERATOR On March 29, 2012, Tina Roberson-Holefield and I, Ruth Williams-Morehead began a Comprehensive Evaluation Inspection (CEI) at Exide Technologies. Initially we met with Ms. Vianey Mendez, Health and Safety Manager. Mr. Mopas was not at the facility when we arrived, but arrived before we began the inspection. He granted us permission to conduct the inspection on March 29, April 2 and 4, 2012. Prior to Mr. Mopas' arrival at the facility, Ms. Mendez provided us with a health and safety orientation. The orientation covered the hazards we could incur during the inspection. She also gave us an overview of the operation .. Mr. Mopas arrived during Ms. Mendez's presentation, and after she concluded the presentation, he granted us permission to conduct the inspection. I asked Mr. Mopas has the facility been cited by the AQMD for hydrocarbon emissions. He stated that the facility has not been cited for elevated hydrocarbon emissions. He stated that the facility has a CEMS (Continuous Emissions Monitoring System) unit which monitors for SOX, NOX and CO emissions. He stated that the after burner on the Blast Furnace burns any long chain organics, and the Reverberatory and Rotary Kiln Dryer burns short chained organics. He stated that the furnaces are fuelled by petroleum coke, coke breeze (srnaller petroleum coke) and natural gas. He stated that the after burner on the Blast Furnace eliminates volatiles generated from burning coke in the furnaces. I told Mr. Mopas that I received an e-mail from a co-worker stating that Exide is sending hazardous waste lead to Mexico for recycling. He stated that Exide is not sending hazardous waste lead to Mexico for recycling. He stated that Exide's consultant wrote in their closure plan, that if during closure their designated hazardous waste disposal facilities were unable to manage their hazardous waste, it's possible that Exide's hazardous waste could be sent to Mexico for disposal. We concluded the opening interview after this discussion and began the inspection of the Hazardous Waste Management units. We inspected the following Hazardous Waste Management units, but not in the order listed in the report. Also prior to inspecting the Reverberatory and Blast Furnaces and Containment building, Mr. Mopas took us to the newly enclosed areas which manage hazardous waste. I observed that the Battery Wrecker (photo 22), Mud Tank row (photo 23), the north end of RMPS (photos 24 and 25), and Bag House row (photo 26) were enclosed. A. Hazardous Waste Management Units and other Hazardous Waste Areas: Reverberatory and Blast Furnaces and Containment Building: The Reverberatory and Blast Furnaces are used to recover lead from lead acid batteries and other lead containing material and hazardous waste. Spent batteries are crushed in the battery wrecker and the material generated from crushing the batteries is stored in the Containment Building. The material is fed from the Containment Building into the Reverberatory Furnace to recover the lead. Primary slag is generated as a byproduct from smelting in the Reverberatory Furnace and contains a high content of lead. The primary slag as well as other lead material and lead hazardous waste are also placed into the Blast Furnace to recover lead. A secondary slag which coritains a low content of lead is generated from the Blast Furnace. The secondary slag is not recyclable due to its low lead content and is sent-off site for disposal. The Containment Building which is used to store the lead feed material before it is recycled in the Reverberatory and Blast furnaces is operated under negative pressure and appeared to be intact. No releases were observed. After we inspecte.d the Reverberatory and Blast Furnaces and Containment Building we went to Shipping and Receiving. Shipping and Receiving is not authorized to store hazardous waste, but during the walk-through I observed that the facility stored 60 drums of hazardous waste tin dross in this area (photo 27). The tin dross is generated inside the Reverberatory and Blast Furnaces during smelting. The tin dross is removed from inside the furnaces ahd is sent off-site for recycling. Mr. Mopas stated that the drums of tin dross were being stored in this area prior to being shipped off-site for recycling. Waste Water Treatment Plant (WWTP): Hazardous waste water that is generated on-site is treated at the Waste Water Treatment Plant before it is discharged into the Los Angeles County Sanitation District. The hazardous waste water is generated from the smelting operation, and from washing down the facility for emission control. The hazardous waste water is contaminated with battery acid, lead and other heavy metals. Rainwater and wash water generated from emission control is collected in the Centralized sump or the Storm Water Retention Pond, and is also sent to the WWTP for treatment. During the walk-through of the WWTP I did not observe any leaks or spills, and the coating covering the floor of the secondary containment unit appeared to be intact. Trailer Staging Area: There were three forty feet trailers staged in this area. One of the trailers contained steel case batteries that are going to be shipped to Kinsbursky Brothers for processing, and the other two trailers contained lead acid batteries that will be recycled at Exide (photos 1 and 2). The steel case batteries will be cut opened at Kinsbursky Brothers and the lead plates will be removed and sent back to Exide for recycling. The trailers that contained the steel case batteries and lead acid batteries were marked with the appropriate labels that contained the date of receipt and I did not observe any leaks or spills. Storm Water Retention Pond: (Pond) The Storm Water Retention Pond is used to collect rainwater run-off and hazardous waste water that is generated from washing down the facility for emission control. (photos 3-8). The Pond also receives hazardous waste water from four 9,000 gallon Dropout Boxes, which receive hazardous waste water from the Centralized sump. Water generated from washing down the facility and other sources is collected in the Centralized sump and pumped into the Dropout Boxes, which filter out dirt, rock and other debris before the water is pumped into the Pond. During the site visit the Pond contained water and sludge. The sludge has been analyzed and is a hazardous waste because it contains lead and other heavy metals at concentrations above regulatory Ii'mits. I noticed that the level of the water in the Pond was low during the site inspection, and I also noticed that the facility has stenciled a volume scale on the liner that covers the west end of the Pond. The scale shows the volume of water in the Pond at different levels. Based on the scale the total volume of the Pond is 2,487,938 gallons. Hazardous Waste Battery Storage Area: Bins 103-108 Storage areas 103-105 (photos 12-14) were empty. Numerous pallets of batteries and drums containing hazardous waste lead dross were stored in storage areas 106-108 (photos 9-11). Prior to the inspection the facility received a load of drums from ATK/Ammunition Accessory; however twenty-eight of the drums that they received were marked with white labels, but were not marked with hazardous waste labels that contained the accompanying manifest number. I told Mr. Mopas that since the drums were not marked with a hazardous waste label that contains the accompanying manifest number, the location of the drums could not be crossreferenced to the operating log, and this is an oPerating log violation. However, Mr. Mopas was able to provide me with copies of the manifests that accompanied the twenty-eight drums. The manifest showed that the facility received thirty-five drums of lead dross, and thirty-two drums of lead dross on manifests 004372318FLE and 004372319FLE, respectively (attachment 2) , from ATK/Ammunition Accessories, Inc. The date on the manifests corresponds to the date of receipt written on the white labels that marked the drums. The drums were stored closed. No leaks or spills were noted, and no violation was cited. West Yard: The facility is prohibited from storing hazardous waste in the West Yard. The facility uses the West Yard to stage empty trailers and to store equipment (photos 18-20). During the walk-through, I observed that there were only empty trailers and equipment stored in the West Yard. The old Truck Wheel Wash (photo 17) which is located in the West Yard has been replaced with a new Truck Wheel Wash (photo 21 )which is also located in the West Yard. The old Truck Wheel Wash has been electronically disconnected and is going through closure. Railcar Spur: The facility operates a rail spur that is used to transport finished product (recycled elemental lead) by rail car to various customers. During the walk-through of this area there were three rail cars parked on the spur. One of the rail cars was opened and contained blocks (hogs of lead) of recycled elemental lead (photos 15 and 16). There were no violations cited in this area. B. Record Review I, Ruth Williams-Morehead and Ms. Tina Roberson-Holefield returned to the facility on April 2 and 4, 2012 to conduct the record review. Mr. Mopas gave us consent on both days to continue the inspection. During the record review one vfolation was found. The inspection logs that contain the results of the inspections conducted on the facility's emergency equipment showed that the inspections were not done at the frequency required by the regulations. Also during the record review I asked Mr. Mopas is Exide a registered hazardous waste hauler. Mr. Mopas stated that the only hazardous waste Exide hauls is lead acid batteries. I asked him if he could provide me with a copy of their Hazardous Waste Hauler Registration, a list of their trailers and tractors and a copy of their MCS-90 insurance document. Mr. Mopas provided me with a copy of their MCS-90, insurance document their Truck Fleet Roster, and their Hazardous Materials Registration License (attachment 3). However after further discussion, I learned that Exide is not required to register as a hazardous waste hauler because Exide only transports lead acid batteries. I told Mr. Mopas that because Exide only transports lead acid batteries and no other hazardous waste they are exempt from the hazardous waste transporter regulations that require them to be a registered hazardous waste hauler. V. VIOLATIONS: Violations Cited in the Summary of Violations issued on April 4, 2012 1. Health and Safety code, section 25202 Exide (the facility) violated Health and Safety Code section 25202, in that on or about March 29, 2012, the facility stored hazardous waste in an unauthorized area, to wit: the facility stored sixty 55-gallon drums of hazardous waste tin dross in shipping and receiving. Shipping and receiving is not authorized for hazardous waste storage. Corrective Action: Effective immediately the facility shall cease for storing all hazardous waste in Shipping and Receiving. 2. California Code of Regulations, title 22, section 66265.15 b (4) The facility violated California Code of Regulations, title 22, section 66265;15 b (4), in that on or about April 2, 2012, the inspections performed on their emergency equipment was not done at the required frequencies, to wit: The inspection logs that contain the results of inspections conducted on the facility's emergency equipment, showed that the inspections were not done at the required frequencies. Corrective Action: Effective immediately the facility shall perform inspections on their emergency equipment at the frequency which is required in the regulations. Additional Violations cited subsequent to the Inspection: 1. Health and Safety Code, section 25202 The facility violated Health and Safety Code section 25202, in that on or about March 29, 2012, the facility stored hazardous waste in an unauthorized area, to wit: During the walk-through of the facility I observed hazardous waste sludge stored in the Storm Water Retention Pond. The Storm Water Retention Pond is not authorized for storage. Corrective Action: This is a recurring violation and is currently being .addressed in Enforcement Order HWCA 2009-2208. 2. California Code of Regulations, title 22, section 66265.193 subdivision c (4) and Consent Order HWCA 97/98-3021 The facility violated California Code of Regulations, title 22, section 66265.193 subdivision c (4) and Consent Order HWCA 97/98-3021, in that on or about March 29,2012, the facility failed to remove sludge from the Storm Water Retention Pond within 24 hours or in as timely a manner as possible, to wit: During the walk-through, of the facility I observed hazardous waste sludge stored in the Storm Water Retention Pond. Corrective Action: This is a recurring violation and is currently being addressed in Enforcement Order HWCA 2009-2208. VI. CONCLUSION: We concluded the inspection on April 4,2012 and had an exit interview with Mr. Mopas. We discussed our findings and issued Mr. Mopas a Summary of Violations for two violations (attachment 4 ).1 also discussed the Areas of Concern noted in the' Summary of Violations with Mr. Mopas and after we concluded this discussion, we exited the facility. VII. 1. 2. 3. 4. ATTACHMENTS: Photos, 1-27 Manifests and Purchase Order MCS-90, Hazardous Materials Transportation License, and Fleet Roster Summary of Violations dated April 4, 2012. ~ML R th Williams-Morehead, HSS <;AJJ&/~ at EXIDE TECHNOLOGIES MARCH 29. 2012 The trailer contains steel case batteries that will be shipped to Kinsbursky Brothers. The lead plates inside of the cases will be removed and sent back to Exide for smelting. 1 EXIDE TECHNOLOGIES MARCH 29. 2012 Crates of lead acid batteries received from off-site are staged in this trailer prior to being moved into one ofthe battery storage areas or processed in the Battery Wrecker. 2 V') UJ -<.!J o- I o Z I U ~ ""0 :::l III ""0 C ro .... UJ ....OJ UJ ""0 I- o X UJ ~ OJ c 'iii ..... c o u ""0 C o Cl. c o ',p c OJ ~ 0:: .... OJ ..... 3 E .... o ..... Vl OJ ~ V') U-I 19 0 .....J 0 Z I U U-I ~ U-I 0 X U-I CJ) Q.I) "0 ~ Vl "0 C ro .... CJ) +"' ro :s: "0 CJ) c ....roc a u "0 c a c.. c a :;::; c CJ) +"' CJ) c::: .... CJ) +"' ro :s: E .... a +"' Vl CJ) .r:: I- V') U-l (D N 'f"""I 0 --J 0 0 N I U N Z U-l lU-l 0 ->< U-l QJ b.O .... (j) I U e::: « ~ -a ~.•.... ::l Vl -a c . '" '- QJ ..... ~ -a QJ c 'ro t: 8 -a c o 0.. C o ~QJ ..... QJ cr:: '- QJ ..... 3 E 'o ..... Vl QJ ~ EXIDE TECHNOLOGIES MARCH-29, 2012 The Storm Water Retention pond cohtained water and sludge. V) UJ 19 0 .....J 0 Z I U OJ tlO "0 :::l Vi "0 C ro I- OJ "-' ro 3 UJ "0 OJ I- ro UJ -XCI UJ c "-' c 0 u "0 C 0 a. c 0 '.j:; c OJ "-' OJ c.:: I- OJ "-' ro 5: E I- 0 "-' Vl OJ ..c: I- EXIDE TECHNOLOGIES MARCH 29, 2012 The Storm Water Retention pond contained water and sludge. Based on the volume scale stenciled on the liner, the capacity of the pond is 2,487,938 gallons. 8 EXIDE TECHNOLOGIES MARCH 29, 2012 I if"'..'··. ~""" ,. Twenty-eight of the black drums that contained hazardous waste lead dross were marked with white labels but were not marked with a hazardous waste label. 9 EXIDE TECHNOLOGIES MARCH 29. 2012 L Twenty -eight of the black drums that contained hazardous ,Waste lead dross were marked with white labels but were not marked a with hazardous waste label. 10 EXIDE TECHNOLOGIES MARCH 29, 2012 .Y T. •'" . ~l,,::l ~''-''''''''';'-''_., __ .""~ __,,-,,, .. '-~ Twenty-eight of the black drums that contained hazardous waste lead dross were marked with white labels but were not marked a with hazardous waste label. 11 EXIDE TECHNOLOGIES MARCH 29 2012? I L. "a Batt?ry Storage area 105 is empty. 12 EXIDE TECHNOLOGIES 29 2012 '5 VI ?F?-mh I - . Battery Storage area 104 is empty. 13 EXIDE TECHNOLOGIES· MARCH 29, 2012 -~ -~~::..~-"--~~ Battery Storage areas 104 and 105 are empty. 14 EXIDE TECHNOLOGIES MARCH 29. 2012 Blocks (hogs) of recycled elemental lead will be shipped off site by rail car and reused in manufacturing new batteries. 15 EXIDE TECHNOLOGIES MARCH 29. 2012 Ii l 4- t " . .... (lJ :j:j rtl ..Q (lJ ..c ..... '0 (lJ .... :::l tJ') 0 uC l.LJ (V) N V') UJ - 19 0- I 0 Z I U UJ t- UJ 0 X UJ ~ 0 .... ..>:: c: ~ "'C :::l ~ b Q) .... :::l Vl 0 13 c: WJ V') UJ - N 0 .....J 0 N t9 Z I U ~ 0 ... (j) N I UJ U I- 0:: UJ -0X UJ « ~ "'C (]) Vl 0 uc (]) Vl ill) c "'C '::; ..a Vl c.. ~ IX: (]) ..c .... 4- 0 "'C C (]) ..c t 0 c (]) ..c I- LJ) N V') UJ -19 0 0 N ~ 0 .....J N Z (J) I U .... N I U I- 0::: UJ UJ 0 >< UJ « ~ . -c OJ V) 0 U t:: OJ .~ b.O t:: '0 :::J ..c Vl 0... 2: c:c: OJ ..c: ..... ....0 -c t:: OJ ..c: -e0 t:: OJ ..c: I- (jJ N V') L.U (,9 N ~ 0 a .....J N 0 0')' Z I U L.U 0 X L.U (J) Vl ::> 0 ::c b.O t'1l co N "tJ I U 0 u « >$ r- c:::: L.U ~ 0 .... ~ (J) Vl c (J) (J) c ...... t'1l "tJ (J) t'1l ...... Vl C b.O C 'w ..a Vl .... 0 0 "tJ $ (J) c « EXIDE TECHNOLOGIES MARCH 29. 2012 There were sixty drums of hazardous waste tin dross stored in shipping and receiving. Shipping and receiving is not an authorized area for storage of hazardous waste. 27 ATTACHMENT 2 ATK 2299 Snake River Avenue Lewiston, 10 83501 208-746-2351 ~ Debit Memo Invoice eelfSpeer Operations 7547 Number: ,~ Shipping Order:L FAX 208-746-8275 PURCHASED FROM: SHIP TO: EXIDE TECHNOLOGIES 2700 SOUTH INDIANA STREET LOS, ANGELES CA 90023 EXIDE TECHNOLOGIES 3900 E 26TH STREET LOS ANGELES CA 90023 CC: ENVIRO PO NumberlDate: Vendor Invoice Number/Date: l:-==--lL_._-_-" +-_____.__ Return Authorization: i-----~(---: ~ __~,:~tity __. ! I I 24,042 LBS _____J .J (LT-_ON_y_ _ _ _ _ f Description RETURNING FOR CREDIT SCRAP FOR RECYCLING 7,551 LBS Reference w/?'s: Date: (D. RomeSiJUf9~1~1120121 Unit Price Dollar Amount ---=-:=.:..='-+~:.::: 1 I ! Lead dross (0008 Mat'l) Manifest #004372318FLE ·1 25,022 gross - 980 tare 35 bxs , 25,022 x (.9644 x 85%) 25,022 x .8197 - .32 (8100099) 6,210 LBS J Mixed lead scrap (8100093) 6,585 gross - 375 tare 12 bxs 6,585 x (.9644 x 85%) 6,585 x .8197 - .32 .49997 $12,013.79 .499971, $3,103.14 I .4997 Mixed lead scrap (8100094) 7,932 gross - 381 tare 3 bxs 7,932 x (.9644 x 85%) 7,932 x .81'97 - .32 $3,773.23 $0.00 $0.00 TOTAL: $18,890.16 Shipping Order-Slmlghl 6111 01 Ladlng-Sho~ Form Orlginal-Nol NegoUable RECEIVED Subjecllo the closslncallons and la~ffs In el'feol on the dole althe Isslie 01 Ihi. 6111 ot Lading Ihe properlY de~crlbed below, In ~pparenl good order, e~cepl "S noled (contents and condition of contanls Df packages, unknown,) marKed, con5igned ~nd des lined as IndlG~led belew, which .ald ~amer (the word ""mer o"lng understood throughoulthls centrad as moaning any person or corpora!!on In posse5slon ollila property unuer Ihe conlracl) agroes 10 carry 10 lis usual place of delivery "I said des!lnallon, If on II~ roule, alharwise 10 deliver 10 anolher Qarrler on Ihe route 10 Sold desllnallon. Ills mUlually agreed, as 10 ellch camer 01 all or any said property formed hereunder shall be subject to ailihe terms and condilions of Ihe Uniform Dome~llc Siraighl Bill of Lading sel forlh (I) In Orrlclal, Soulhern, Weslem and mlnols Fral;tht C!assl~callons In effed on Iha (ale heroD!, If (his Is a r.1I or rail waler shlpmenl, Of (2) In Ihe applicable molor currier clas~lncatlan or lariff IIIMis Is a molar carrier shlpm~nl. Shipper hereby c~rlJn"S thai he Is famillarwilh all the larms and conditions of !he said bill olladlng,l~cludlng Ihase on Ihe b80~ Ihereof. sel fodh In the ciasstncalfan Dr tariff which gO\lems Ihe Iranspnr1,Uon of Ihls shlpmenl, and IhB said 16rm'; and cond~iQns era hereby agreed 10 by Ihe shipper and accepted for himself and his assigns. Account #: 1800000210/80135580 Carrier's Signature: iii of Pkgi:.I--=:'-~iYPioii'""'·~le ~-=~ ~ }1- ~ !__,i:I_____ ~_.&.'f£_LQfill:u........... ,~..llill-''-- Q~ 1..'d-_~~-",~~ t--r::f;OML' (6M3 1--1'£_::)16 :'J_~.:.: ~ 14:(1_ U';A~ SQI.3.f'---fj.LOD{) '-/ I '7 93 rJ- I 1 Collect l__ ---.--l------.-- --·------·---------k------! .__ L'r-ffiJfiSe>.. n:'JR _____.___-+lO...J~ __---'-T.:..:.otal Weight I/.fO 7.s-oi Vl Dest Value: Ship Via: _!_~J jPAFFILE Date Shipped This is to certify that the above"namsd material is properly classified, desc;rlbsd, packaged, marked and IEbaled End Is in proper condition for IransportEtion to the applicable regulations of the Department of Transportation, ~----------------, I· I Original: Vendor Copies: 2-Accounting, 1-Purchasing, i-Shipping, 1-Carrier, 1-Packing List -J Please print Of type (Form designed for use on elite (12-pitch) typewriter) UNIFORM HAZARDOUS 11. Gen,e~to~_ID NlJmber Form Approved OMB No 2050-0039 , ~ _ ~. - I jJ 09:ll<1~~$l'ie':l WASTE MANIFEST Q ) , ,J 723'1 I _ OOil' ' ", Generator's Site Address (if different than mailing address) 'lljl,14S·2J5'1 5. Generator's Name and Mailing Address ~T'!( t"ll.1HllnlUtlli ' I; t: IJ:!lfHIM PC) Box 856, Le'i'.!l,-"~~g,H~N C~!}:.Ftir~Ut~r~ R!\Il>f A¥~(ml)" lflw!si-rV ~ f-yo\ ¢' .[0:\ .1 13. Waste Codes 4. 14. Special Handling Instructions and Additionaltnformafjon [/IM'!"vj'\ iE.An m'lOS$ .- i,i!li!, Tl'ilUp,l "10 lU; RECY{;Uzl.)l ---. UIIJ( u+..-~) II I ---\-- 15. GENERATOR'S{OFFEROR'S CERTIFICATION: I hereby declare thai the contents of this consignmant are fully 81ld accurately described above by the proper shipping name, and are classified, packaged, marked and labeled/placarded, and are in all respects in proper condition for transport according to a·;plicable Inlemational and national governmental regulations. If export shipment and I am the Primary Exporter, I certify that the cOiltents of this consignment conform to the terms of the attached EPAAcknowledgment of Conserlt. I certify that the waste minimization statemerlt identified in 40 CFR 262.27(a) (if I am a large quarltity ~enerator) or (b}QU 'l9}b~01Jl.~ ~'!.-ll,~~Y g,e9-~atoI1l,Hw1~ "l',,",.\;, ,··· .."lr- t:: 18b. Alternate Facility (or Generator) U.S. EPA 10 Number -' <3 c:: I Facility's Phone: 0 LIJ 18c. Signature of Alternate Facility (or Generator) ivlol1th ~ 13 z '" 1. u; Day 13.~ Year 1/.2 19. Hazardous Waste Report ManagemenUviethod Codes (I.e., codes for hazardous waste treatment, disposal, and recycling systems) LIJ 0 /JO/6 [' [3 14 20. Designated Facility OWner or Operator: Certification of receipt of hazardous materials covered by the manifest except as noted In Item 18a Sign 1 printedTDhm~ (! d r yJ i2ll1e r EPA Form 8700-22 (Rev. 3-05) Previous editions are obsolete. I '~')f ~ . "'. ..Jc', Monlh Day .Year I 3 I ~~II';'J DESJ/;NATED FACILITY TO GENERATOR STATE (IF REQUIRED) , -,\ft) PI~pmii:'t'i?type. (Form designed for use on elite (12 ~ "'.' PI''''~' '''~~'''.''.'''' ;_Ji"'Jr.,~ n ~~'.' ""~"" '''/' ~,n:;; 11"~'",1',~' ~~",--..H";'i':;:;~ ?!nO $1-1>i,1~.h !nd~.:1n~J :~H'r:t~f.'t 1 C'" ,~\~H,~~,i,r,:,.s Ci~ U.S, EPA 10 Number ..;,;·nfO~,:1 I Facility's Phone: 9b. U,S, DOT Description (Including Proper Ship~ing Name, Hazard Class, 10 Number, and Packing Group (if any)) 9a. HM fu'it '.: ~1' ",'-110. '" ¥ Generator's Site Address (if different than mailing address) 5. Generator's Name and Mailing Address 10. Containers No. 11. Total Quantity Type 12. Unit WtNol. I . 3, 13. Wasle Codes ---1- --- -,-It . 4, ---- 14. Special Handling Instructio~s and Addilionallnformation 15. GENERATOR'S/OFFEROR'S CERTIFICATION: 1hereby declare that the contents of this,conjlignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labeled/placarded, and are in all respects in proper condition f?r transpo~ acc~r~~Ag to applicable international and na~ional governmental regulations. If export shipment and I am the Primary Exporter, I certify that the contents of this consignment conform to the term,s of-the -attached EPA Acknowledgment of Consent, I certify that the waste minimization statement identified in 40 CFR 262.27(01) (if I am a large quantliy generator) or (b) (if I am a small quantity generator) is true. -l ~ 0 16. International Shipments 0 ImporttoU,S. Export from U.S, Portofentry/exit: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Transporter signature (for exports only): ffi l:2 Da'te leaving U,S.: 17. Transporter Acknowledgment of Receipt of Materials Transporter 1 PrintedfTyped Name IVlonth Signature ,. O,y Year I ",i"'j"_ ,"'" I I;: ,': I f .. ~ ",,==,~i"';':""'7'==="i"~"~V___-~'_________________""=='-_-'-_-'-'-"-"-'-'--------------'r:f±-'--"'::,--'-i;:,;0-j O ~ 1· Transporter 2 Printedrryped Name 1 r, 18,. Olecrepeeey 'cdlce"" Space ,D Quantity o I D Residue Type Dey Month I 18. Discrepancy I ~~ "Ii., Signature ~ r ",I ,I' .' ' .• I o D Partial Rejection :~ Year I Full Rejection Manifest Reference Number: ~ 18b. Alternate Facnity (or Generator) ::J U ;t U,So EPA 10 Number I Facilitv's Phone: @~1~8~C.~S~'9~c~at~u~re~o"fA~'~'e~rn~a~'e'F-a'd"tityC7(o~r"G-ec-e~ra~'o~rl;------------------------------.L----------;,~'o-ct~h--"O~ay"---Cycea~r-j ~~~~~~~~~~~~~~~~~~~~~~_______________L-I_L-I_L-I~ g [j f719~.~H=az=a=rd=O="=W::::"="::.cR='P=O='I=M=,=ce=g~e=rn=ec='=M='='h=Od::.;:C~Od='='=(I=.e=.,=,o=d=e='=fo=rh=,=,=ar=dO=u='=w=a="='='r=ea~'m=e=c=t,=d=,,~po~,=a=l,=ac=d="='2y=cI=in""'Y='='e=m='I'-_ _ _ _ _ _T7_ _ _ _ _ _ _ _ _ _ _ _ _ _ _-I Cl 1. 12, 13 14 /:/,'IJ I 1 20. Designated Facility Owner or Operator: Certification of receipt of hazardous materials covered by the manifest except as noted in Item 18a PrintedlJ.xped Name S'lgn.ature /) 1 ._ ,.",.7 ()f.J}"t (} If f'EM(Cr' -EPA Form 8700-22 (Rev. 3-05) PrevIous editions are obsolete. ! aii'~l~ I Month Day Year 13 12J. II." DESIGNATED FACiLlTY'S COPY ATTACHMENT 3 • •••• ~.s. ~epartment ENDORSEMENT FOR MOTOR CARRIER POLICIES OF INSURANCE FOR PUBLIC LIABILITY UNDER SECTIONS 29 AND 30 OF THE MOTOR CARRIER ACT OF 19BO (If Transportation Fedetal Motor Carrlsr S/lifety MmlnlstraH:o" I~.ued to 13000 DEERFIELD PARKWAY BlllLDTNG 200. MILTON. GA 30004 day of JULY _20_1_1_ _ EXIDETECHNOLOG~ of ......b_u_rg"',c..ll_U_'n_o_is_ _ _ _ _ _ this 1ST Dated at --=:SC:.h:..:.::UID Amending Policy No, _B_AP_8_9_78.:..5_9_2_-1_5_ _ _ _ _ _ _ _ Elleclive Dete Name of Insurance Company July 01, 2011 Zurich American Insurance Company. Counlerslgned by -.=======""'_____________ AulhOtized ~fl'j Rqlfe5e(l1alfYe The policy 10 which this endorsement i. attached provides primary or excess insurance, as indlcaled by "18l", for the limils shown: I8l o .,'•... This insurance is pnmary and the company shall not be liable for amounts In excess of $ 5,000,000 for each accident. This insurance is excess and the oompany shall not be liable for amounw in excess of In excess of the underlying limit of $ for each acelden!. $ for each 'accident ----- Whanover required by the Federal Mol« Garrier Safely Admlnlslratlon (FMCSA). the COOlpany agrees to fumlsh the FMCSA a duplloate of said pdie)! and .11 Its endorsements. The ccmpany also agrees, upon lelephooe requesl by an aulhalzad represenfative 01 the FMCSA, fa Vlnalloo thereof,. ne""ssary m"'u,"s talien'lo mininilm· ... nii'gaW damage "10" human . . .'W . . BODIL.Y INJURY msans Injury 10 the body, sIckness, or d~ea.., to any health, the natural envirooinen~ nsh. stmnllsh, and wikllili),." ..' " .". . . per$OO, Including dea!h resulting rrom any of th.... PUBUC UABIUTY means liability Ie< bOd"y injury, property damage, and . ," '. PROPERTY DAMA.GE means damage 10 or loss 01 use of tangible en\'ironmental restoration. '., proparty. Tile Insurance polley 10 whim !hIs endorooment Is allached provides shan relieve the company from lIablily or from the payment of any final auklmobile liability iI1surance· and Is amended to assure compliance by jlJdgment, within the limils of liability hereIn descrIbed, In'aspeclWe of Ill. Ihe Insured, withIn the limits stabld horeln, as a molar carrier of property, financial condtllon, Ins_ncy or bankrupt described herein, any ~na1 judgment rscovored provisions of the polley except for the agreement oonlalned in Ih!o endorsement. "IIaln'l the Insu",d lor public lIablllty ","ulUng from negilgence In the operalion, malnlEinaflC8 or use of motor vahides subject to the financial reSPOOslblilly requiremen!S S.cIlons 29 end 30 of the Molor Carrier Aot It Is furlher undareload and agreed that, upon failure of the COOlpany 10 of 1980 regardless of whether or not each motor veIllcie I. spacifically pay any final judgment recovered again the Insured as provided herein, described In the polley and ""ether or nolsuell negligence occurs on any the Juc:tgment credl!or may main lain an action In BIlY court of compa!F.lot or In any lerlitory aulholized 10 be served by Ihe Insured or jurisdiction against Ihe company 10 rompel sUCh payment. elsewhere. Such Insurance os Is afforded, for public Iiablllly, does not apply 10 Injury to or death of the Insured'. employees while engaged In the The limits of the company's nobility for Ill. amounts prescribed In this endorsement apply separately 10 each accJdenl and any payment LInder course of their employmenl, or property transporled by the Insured, deelgnaled as cargo. It is understood and agreed thal no condillOll, Iho policy because of anyone accident shall not operate 10 reduce the liabIlIty of the company for the payment of final judgmef\ts """,J6Ag from provision, stlpulallon, or limitation conlalned In the pOlicy, this any other accident endorsement or any other endorsement thereon. Of' violation !hereof, "i""" 0' route THE SCHEDULE OF L.lMITS SHOWN ON THE NEXT PAGE OOES NOT PROVIDE COVERAGE. The Umlls shown In the schedule are lor Informallon pUrpose$onty. Form MCS-90 (page 1 of 2) • , ~ STATE OF CALIFORNIA DEPARlMENr OF CAI.!FQRNIA HIGHWAY PAIROL HAZARDOUS MATERIALS TRANSPORTATION LICENSE (only if differenf from helow) EXIDE TIOCHNOlOGTES UGe!SE NUMBER 199186 55594 CHP CARRIER NUM6ER lOCATiO" fSSUEOATE 412512011 GA 14389 \EFFECTIVEOATI? \ EXPlRAllQNDATE o Duplicate o Initial o 9130/2012 Replacement ~ Renewal The original valfd uc:elnso mtlst be kept alllia ffi:!!Ilsee's placa of business C!S mOlca[ad on 1h!1 rlCll'nSB and a Isgltlacopy mustba carried In any vehicle orromblnallon tlanSportl01I ha1..ard"au5 malerial5 and must be presen!ad.\p any CHP allicerupon requesl ThiS!1CEI1SIJ15 NON-TRANSFERABLE and must be ljurrendl:!red to \hE! CHP upon demand ['I( as tuqutred by l;nv. Amalmily c:hanllll In ownlm;~ip QfCtlnlrol of the !k:ensed aclivity shall requllll d new rlCensa-. ThIs flcense may til'! renewed by submnllng an appllcalion and appropriate !'tie 10 IhB CHP. Persons whose licen;;:e;;: have:.tlXplred or am Q!Ire!Wr~e 110 longer valid mustlmmedfatflly cease !lIe acUvity tequlrlng a license, nlERE IS NO GRACE PERIOD. For licensing infonnaUon ccn!2tt GHP, Gomme.reial VehIcle Seelinn at (9:15j 843-3400, This carner is 011 the spedal routihg/safe ,s!opplng place mailfng !Isis as indrcaled below: liCENSEE NAME AND MAIliNG ADDRESS EXlDE TECHNOLOGIES 13000 DEERFIELD PARKWAY #ZDO ALPHARETTA GA 30004 ATTIONTION: DARRELL JOHNSON I ERIC MURRAY o (HMX) ExplosNes sublecllo Division 14, Cal~omla Vehicle Code (CVe). meteria~ in b"ik packagings subiecllo Polson InhalaUon Hazard Io (HMPIH) Division 14.3. eve. o 1 1 t COHTROL NUMBER PROPERTY OF THE CALIFORNIA HIGHWAY PATROL (CHP) CHP 360H (REV. 1100) OPI 062 llCIONSEE NAME AND PHYSICAL ADDRESS • '} (HRCQ) Highway Route ConlroHed Quanity radloaGllve ma(enals sub/set to DivIsion 14.5, CVC. Any J.1eI$on who{/urnps. spillS, (lr causes !he release 01 hazaroOlJS- materials of haz:a.r;::lovs was!"" upon any highway shall immedJal!!Jy notify Iha- CHP t;Jf!he ag.ency havingJurisdiclion for {hal highway. The minimum fine (lirfaIJure ID make 111(/ appropriate nonrroe!fon Is $: 2,000.00. {CVe Sar:[!on 231125; • FLEET ROSTER L.A, HAULAGE DMSION Updated June 15.2009 , • ~ . -', SHUTTLE TRAILERS: UNIT # 402 405 407 409 413 416 417 421 305 306 307 308 2810 5001 1012 4955 30412 YEAR MAKE STATE V1N NUMBER DESCRIPTION 1979 1981 1981 1981 1985 1988 1989 1993 1994 1994 1994 1994 1995 1993 1979 1986 1995 FRUEHAUF TRLMOBILE TRLMOBILE TRLMOBILE HOBBS HOBBS TRLMOBILE MONON TRLMOBILE TRLMOBILE TRLMOBILE TRLMOBILE TRLMOBILE GRTDN BUDDCO TRLMOBILE GRTDN CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA MEV648501 1PT011AJ6C9001051 1PT011AJ8C9001035 1PT011 AJOC9001 045 1H5V04529FM012702 1H2V04823JC023413 1PT011AJ8K9006114 1NNVA4820PM175188 1PTF71TJ5R9009060 1PTF71TJOR9009063 1PTF71TJ9R9009062 1PTF71TJ7R9009061 1PT01 JAHOT900281 0 1GRAA9625PB015001 YS2S420C62 1PT02DAH8G9004955 1GRAA9622SB116215 45'VAN 45'VAN 45'VAN 45'VAN 45'VAN 4S'VAN 45'VAN 48'VAN FLATBED FLATBED FLATBED FLATBED 45'VAN 42'VAN VAN VAN VAN STORAGE TRAILERS ONLY: 705 6045 449171B 459055 Flatbed 1 PLATE # EXPIRES (Maine) 1462447 212812014 (Maine) 1462448 212812014 (Maine) 1462449 212812014 (Maine) 1462450 212812014 (Maine) 1462451 212812014 (Oregon) HP 10398 PERM Questionable (Maine) 1462452 2/28/2014 (Maine) 1462453 212812014 (Maine) 1462454 212812014 (California) 4JI"4633 PERM re-registration on 10/31/12 (Maine) 1462457 212812014 (Maine) 1462455 212812014 (Maine) 1462456 212812014 (California) 4KG4793 1213112016 (Wisconsin) OK 41320 Questionable (California) 1VY8776 1/31/2017 (Maine) 1462446 212812014 (Oregon) HP 06171 (California) BT 27768 No Plates (California) VR 8437 '1 ATTACHMENT 4 Department of Toxic Substances Control Matthew Rodriquez Secretary for Environmental Protection Deborah O. Raphael, Director 9211 Oakdale Avenue Chatsworth, California 91311-6505 Edmund G. Brown Jr. Governor SUMMARY OF VIOLATIONS On March 29, April 2 and April 4, 2012, the Department of Toxic Substances Control (DTSC), California Environmental Protection Agency, conducted an inspection at: Facility Name: Exide Technologies Facility Address: 2700 South Indiana Street EPA ID Number: CAD097854541 County: Los Angeles As a result of this inspection, violations of hazardous waste laws, regulations, and requirements Iist.ed 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 Ihese will be identified in the Violation section of the inspection report. DTSC will provide you a complete inspection report within 65. days of the date of this inspection. You may 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 preclude DTSC 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. A false 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 Summary DTSC Representative Name Name ~Vt/1& tVI' jIt; (A /11·(--(1&V:~Iz(L",/~ Signature Title -""-"""'-''-'-''':.f..J..t;A''''·:...J:I..I..O:l-.L-.-''-''''''''''''.I'-'-e''-'''-,r_ Date -J-"70c....L.t'-"h""'o/'-":2"------ J~ a/k!tL~t;Jh~7 Title _....:.qf,L._l::....)_ _ _ _'---_ __ L(-I-/I~I\l. l. .