Department of Toxic Substances Control Linda S. Adams Secretary for Environmental Protection Maziar Movassaghi Acting Director 9211 Oakdale Avenue Chatsworth, California 91311 ArnGld Schwarzenegger Governor CERTIFIED MAIL June 30, 2009 Mr. Edwin Mopas Environmental Manager Exide Technologies 2700 Indiana Street Vernon, Ca. 90023 Dear Mr. Mopas: On April29, 2009 and May 8 and 11, 2009; the California Environmehtal Protection Agency, Department of Toxic Substances Control (DTSC), conducted a Comprehensive Evaluation Inspection (CEI) at Exide Technologies, 2700 Indiana Street, Vernon, Ca 90023, EPA ID Number CAD 097854541. The enclosed report describes the findings of this inspection, including all violations and any actions that should be taken by the facility to correct the violations. You are required by 25183 © (s) of the Health and Safety Code to submit a written response to the Department with 30 days describing the corrective actions that you have taken or propose to take to bring you company into compliance. If you dispute the violation, you should explain your disagreement in this written respohse. The issuance of this letter and report does not preclude the Department fro 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 a 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 with 10 days of receipt of the inspection report: • • To what extent is there knowledge of the information conveyed by the photograph/document outside of your business? To what extent is there knowledge of the information conveyed by the photograph/document, by employees and others in your'business? @ Printed on R:::cyc1ed Paper. Mr. Edwin Mopas June 30, 2009 Page 2 • • • • To what extent have 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 any 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 the proposed corrective action, please contact me at (818) 7176668 or Ruth Williams-Morehead at (818) 717-6578. Sincerely, Jf //;1 ff' . . 1j/~;J?~ -'hIL Mukul Agarwal Supervising Hazardous Substances Scientist I Enforcement and Emergency Response Program Chatsworth Office Enclosures Certified Mail No. 700634500001 78190331 Return Receipt Requested State of California - 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 90023 Telephone Number: (213) 262-1101 ext. 259 EPA 10 Number: CAD097854541 Registration Number: 2157 Facility Type: RCRA Hazardous Waste Treatment Facility Regulated Units: The facility is currently operating under an ISO for their storm water retention pond, two lead smelting furnaces, their waste water treatment unit and six spent lead-acid battery and lead waste storage areas. Waste Streams: Lead acid batteries and other lead bearing waste, polypropylene waste, spent slag, rubber and plastic casing material, lead and acid contaminated waste water, filter cake sludge, lead contaminated wipes, rags and trash, etc. Dates of Inspection: Ruth Williams-Morehead, HSS - April 29, 2009 and May 8 and May 11 , 2009 Michael Haynes, Air Quality Inspector, South Coast Air Quality Management District- April 29, 2009 Brian Wu, HSS - May 8 and May 11,2009 Type of Inspection: CEI XX CME - O&M - Focused Limited _ Transporter Facility Rep.: Ed Mopas, Environmental Manager Ken Copeland, Plant Manager Rafael Perez Galindo Felix, Waste Water Treatment Unit Supervisor Vianey Mendez, Health and Safety Manager Marco Perez, Waste Water Treatment Operator Exide Technologies, Inc. Inspection Report June 30, 2009 Page 2 Type of Business: II. Exide Technologies, Inc. is a secondary lead smelter that recovers lead by smelting lead from spent lead acid batteries and other lead bearing hazardous waste. The recycled lead is sold and reused in manufacturing new batteries. CONSENT: Consent to conduct an inspection that involves: taking photographs, reviewing and copying records, questioning personnel and inspecting hazardous waste handling areas. Consent given by: III. Ed Mopas, Environmental Manager DOCUMENTS REVIEWED: a. Manifests, Bills of Lading, LOR's, Exception Reports: During the inspection of the manifests, no violation was cited. b. Contingency Plan: During the inspection of the contingency plan, no violation was cited. c. Training Plan and Records: The facility has an adequate training plan and training records, and no violation was observed. d. Incident Report: None reported. e. Waste Analysis Plan and Records: The facility did not have profile sheets for various waste streams detailing the parameters used to analyze hazardous waste received at the facility. The waste analysis plan did not provide the frequency or the action that would require the facility to review or repeat the analysis to ensure it's current and up to date. Exide Technologies, Inc. Inspection Report June 30, 2009 Page 3 f. Operating Log: The facility has an adequate operating log, and no violation was observed. g. Inspection Records: During the inspection of the inspection records, no violation was cited. h. Tiered Permitting Applications and Authorization Letters: N/A i. Annual/Biennial Reports: The facility submitted the annual report for 2008, and no violation was cited. j SB 14 Plans: N/A k. Closure Cost Estimates and Updates: The financial responsibility review found that the facility has adequate closure and post-closure cost. I. Part A: A Part A application was filed in 1981 by Gould, Inc. former owner of GNB. Exide purchased GNB in 2000, but the facility has never been issued a Hazardous Waste Facility Permit. Exide is currently operating under an Interim Status Document. m. Part B: Part B application is under review by the Southern California Permitting and Corrective Action Division. n. POTW Compliance Data: The facility has a permit to discharge treated wastewater into the Los Angeles County Sanitation District. Exide Technologies, Inc. Inspection Report June 30, 2009 Page 4 o. Tank and/or Containment Certifications: At the waste water treatment plant a clarifier was leaking and created a large puddle on the floor of the secondary containment. p. Air Board Permits: The Air Board Permits are current. q. Variances: Not currently operating under a variance. r. Recycling Records: N/A s. Other: N/A IV. NARRATIVE OF OBSERVATIONS/DISCUSSION WITH OPERATOR: On April 29, 2009, I began the Comprehensive Evaluation Inspection (CEI) at Exide Technologies. I arrived at the facility at 0800. Michael Haynes from the South Coast Air Quality Management District also joined the inspection. Mr. Haynes arrived at the facility at 0830. We met with Mr. Mopas, Environmental Manager and I told him the purpose of my inspection was to review the hazardous waste management documents and inspect the hazardous waste management units. During the opening interview, Mr. Haynes mainly discussed withMr. Mopas that additional high volume samplers may need to be installed due to the high readings measured on the samplers that are presently installed. After the discussion we began the inspection of the hazardous waste management units, but not in the order listed below. We began the walk-through at the Waste Water Treatment Plant, and then we went to the battery storage areas. Before we completed the walk-through of the battery storage area ,Mr. Haynes and Mr. Mopas left and went to inspect another area of the facility. Exide Technologies, Inc. Inspection Report June 30, 2009 Page 5 Rafael Perez escorted me to the remaining hazardous waste management units. Also during the walk-through, Mr. Perez said that the tanks from the old waste treatment unit have been removed. He showed me the vacant areas where the tanks had been removed. Trailer Staging Area: This area is used to store incoming and outgoing forty foot trailers that contain hazardous waste. The incoming trailers usually consist of lead acid batteries and other lead bearing waste that will be recycled at the facility. The outgoing trailers usually contain lead contaminated plastic that is generated by the facility from crushing lead acid batteries, during the recycling process. The plastic is sent to KW Plastics in Bakersfield, California for disposal. During the walk-through of the area I noticed that six forty foot trailers were staged in the area. Three of the trailers contained hazardous waste plastic and three of the trailers contained batteries. The trailers which contained the lead acid batteries were marked with the date the facility arrived at the facility. The dates on the labels did not exceed ten days. The trailers that contained hazardous waste plastic were marked with hazardous waste labels that contained the start date of accumulation and the other appropriate information. The dates on the labels did not exceed 10 days. I also observed that the trailers were closed and I did not notice any leaks or spills. Waste Water Treatment Plant: The waste water treatment plant treats hazardous waste water that is contaminated with spent battery acid, lead and other heavy metals. The waste water is generated from the facility's smelting operation, wash down and maintenance of the facility, and from rainwater water that is collected in the Storm Water Retention Pond. During the walk-through of the waste water treatment plant I noticed that the equalization tank was empty and that the crossovers on the equalization and reaction tanks that were leaking during the last inspection were repaired. The footing on the acid tank that contained cracks on the last inspection was also repaired. The footing on the equalization tank was being repaired. Storm Water Retention Pond: The Storm Water Retention Pond is used to collect rainwater and water generated Exide Technologies, Inc. Inspection Report June 30, 2009 Page 6 from washing down the facility. During the walkthrough, the Retention pond contained liquid and I also observed sludge on the bottom of the pond. Mr. Mopas stated that the water in the pond should be pumped out in the next few months and that the sludge is going to be sent to the Reverberatory furnace for recycling. Battery Storage Area· Bins 103·108: Three pallets of batteries were stored in bin 106. Numerous ballets of batteries were stored in bins 103, 104, 105, 107 and 108. Each pallet of batteries was marked with a label that contained the date of receipt at the facility. The batteries were intact and I did not observe any leaks or spills. Reverberatory and Blast Furnaces and Containment Buildings: The furnaces are used to recover lead from material that is generated from crushing the batteries. The plastic is separated from the battery wrecker material before it is stored in the containment building. The material is either feed into the reverberatory furnace or into the blast furnace. During the walk-through I observed that the buildings that house the furnaces and containment building were intact and under negative pressure. West Yard: The facility is prohibited from storing hazardous waste in the West Yard. The facility uses the west yard to store equipment. During the walk-through I observed that there were empty trailers parked on the West Yard. After we completed the walkthrough I completed the inspection for the day. Record Review I and Brian Wu returned to the facility on May 8 and 11, 2009 to conduct the record review. Mr. Mopas gave us consent on both days to continue the inspection. During the record review only one violation was found. The facility's profile sheets for some of their waste streams did not detail the parameters used to analyze the samples of hazardous waste received a t the facility. The waste analysis plan did not provide the frequency or the action that would require the facility to review or repeat the analysis to ensure it's current and up to date. V. SUMMARY OF VIOLATIONS: 1. Title 22, California Code of Regulations (CCR), section 66265.13 (b) (1-4) Exide Technologies violated Title 22, CCR, section 66265.13 (b) (1-4), in that on or about May 8, 2009, the facility's profile sheets for some of their waste Exide Technologies, Inc. Inspection Report June 30, 2009 Page 7 streams did not detail the parameters used to analyze the samples of hazardous waste received at the facility. The waste analysis plan did not provide the frequency or the action that would require the facility to review or repeafthe analysis to ensure it's current and up to date. 2. Title 22, GGR, section 66265.31 . Exide Technologies violated Title 22, GGR, section 66265.31 in that on or about April 29, 2009, the facility failed to maintain and operate the waste water treatment plant to in a manner to minimize the possibility of a release. At the waste water treatment plant a clarifier was leaking and created a large puddle on the floor of the secondary containment. VI. EXIT INTERVIEW INSPECTION REPORT: After we completed the record review, we concluded the inspection. I cited the facility for two minor violations and issued the facility the Summary of Violation. I told Mr. Mopas that the waste analysis plan needs to be revised in the next 30 days and that the leaking clarifier needs to be repaired immediately. We concluded the inspection at this time and exited the facility. VII. ATTACHMENTS: Photos 1-28 Summary of Violation 0~1 D e Exide Technologies 4/29/2009· Equalization tank is not in operation. The tank has been drained and the footing needs to be coated with epoxy material to prevent corrosion. 1 m >< -c. ...... ..j:::..CO 0) ......... --f ::J 7\ I\.) 0) (J) I\.)::J"" 0CD CD O::J 00 ::J CD "0 0). m 0. N CO ~(") ::J" <.0 I 0 c.c -co (J) Exide Technologies 4/29/2009 Photo shows that the crossover from the reaction tank is not leaking. 3 Exide Technologies 4/29/2009 Photo of the inside of the equalization tank which has been drained for repair. 4 Exide TechnOIOQies 4/29/2009 Photo l??king clarifi-er pump at fireatmeh?tblahf. Exide Technologies 4/29/2009 Photo shows leaking clarifier pump at the waste water treatment plant. 6 Exide Technologies 4/29/2009 Photo shows leaking clarifier pump at the waste water treatment plant. 7 -I o "0 <. ~ :J C'D 0. ru_. ::J m C 0CD N -I C'D 0. C'D ..0 ru _. ~ O· ::J >< -. CD (") ::r :::J o o CO -. 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Exide TechnolOgies Sludge and liquid contained in the Storm Water Retention Pond. 13 Exide Technologies 4/29/2009 Sludge and liquid contained in the Storm Water Retention Pond. 14 Exide Technologies tr pe lai 'tris ah th lead bearing hazardous wa?te. 15 Exide Technologies 4/29/2009 Storage area (107) used to store spent lead-acid batteries and other lead bearing hazardous waste. 16 Exide Technologies .- a (18) u. se led-aid teirs a ohr 17 lead bearing hazardous waste. ..., 3 -I CD Q) 0 < ::l A (J) CD ..... ?-a 3 ....... :::r CD m _. >< 0 0. ~ Q) (J) ....... CD ~ Q. ..(:::.CD i\3-1 c.oCD ....... ...... 0 -I 0 0 Q) CD ..., (j) ~ 3 CD ::l ....... ""0 Q) ::l ....... :::r Q) < CD 0- CD CD ::l I\.):::::r ::J 0 c.o -0 _. CO CD CJ) Exide Technologies 4/29/2009 Tanks from the old Waste Water Treatment Plant have b!een removed. 19 Exide Technologies 4/29/2009 Storage area (103) used to store spent lead-acid batteries and other lead bearing hazardous waste. 20 Exide Technologies 4/29/2009 Storage area (104) used to store spent lead-acid batteries and other lead bearing hazardous waste. 21 Exide Technologies 5 Storage are (1_04)se to stor spent lead-aid bries and other lead bearing hazardous waste. 22 Exide Technologies 4/29/2009 , , f -••. Storage area (105) used to store spent lead-acid batteries and other lead bearing hazardous waste. 23 Exide Technologies 4/29/2009 Storage area (105) used to store spent lead-acid batteri lead bearing hazardous waste. 24 OJ ~ CD -< ..., (") c (J) :::r CD ..., m >< -. a. ~CD ""'-.., NCD ~() N::r 0::::::1 00 COo -. CD < . -0- CD '-..., "...,c J\.) ::J"" 0- ru .-.. .-.. -< CJ) ::rCD ..., ~CO J\.)CO ~(') O::l 00 (()o CO -. CO en Exide Technologies 4/29/2009 Enclosed conveyer used to take crushed batteries to the sink float tank. 27 Exide Technologies 4/29/2009 i Plastic chips generated from crushing batteries are bldwn into a trailer for storage prior to being shipped off-site for recycling. 28 Global in Sto.lX.'