Department of Toxic Substances Control Winston H, Hickox Agency Secretary California Environmental Protection Agency Edwin F, Lowry, Director 1011 N, Grandview Avenue Glendale, California 9120 1 Gray Davis Governor Exide Technologies, Inc, 2700 South Indiana Street Los Angeles, Califomia 90023 Dear Mr. Wideman: On April 28, and 29, and May I, 6, 9, and 12,2003, the California Environmental Protection Agency, Department of Toxic Substances Control, conducted an iuspection of Exide Technologies, Inc, located 2700 South Indiana Street, Los Angeles, Califomia 90023 , The enclosed report desclibes the findings oftms inspection, including all violations observed and any actions that should be taken Exide Technologies, Inc, to correct the vio lations, All perti nent infol111ation derived from the inspection, including documents, photographs, aud sampling results, are included as attaclU11ents to the report, except copies of documents provided by your facility at the time of the inspection, In order to reduce copying and mailing costs, these have not been retul11ed to you with the rep0l1; copies will be provided if you request them. This report will become a public doclllnent; you may request that any trade secret or facility security infonnation be withheld fi'om public disclosme, (See Health and Safety Code Section 25173) If you have any questions regarding this letter, or if you wish to meet with the Department to discuss any questions or concems you have with the inspection, the repmi, or the violation s, please call Ruth Williams-Morehead at (8 18) 551-2916, Sincere~1t !!d!I?~{t~~ rJ'-r"'''''/ Mukul Agarwal Unit Chief Statewide Com pliance Division Southem Califol11ia Region Enclosme Certified Mai l Retum Receipt Request The energy challenge facing California is real. Every Califomian needs to take immediate action to reduce energy consumption. For a fist of simple ways you can reduce demand and cut YOLirimergy costs, see our Web-site at www.dtsc.ca .gov. @ Printed on P.ecycled Paper Sta te of Ca li fornia~California Environmental Protection Agency Department of Toxic Subs tances Control INSPECTION REPORT I. GENERAL INFORMATION: Company Name: Exide Technologies, Inc. Facility Address: 2700 South Indiana Avenue Vernon, California 90023 Telephone Number: (213) 262-1101 ext. 259 EPA ID Number: CAD 097 854 541 Registration Number: 2157 Facility Type : RCRA Hazardous Waste Treatment Facility Regulated Units: The facility is currently operating under an ISD for their storm water retention pond, lead smelter, wastewater treatment unit and four spent lead-acid battery and lead waste storage areas. Waste Streams : Polypropylene waste, furnace slag, rubber and plastic casing material , wastewater, filter cake sludge, lead contaminated wipes and rags, etc. Inspected by: Ruth Williams-Morehead Dates of Inspection: April 28,29 , 2003 and May 1, 6, 9, 12, 2003 Type of Inspection: CEI XX CME . O&M . Focused Limited . Transporter Facility Rep.: Thomas Wideman,Environmental Health and Safety Manager Type of Business: GNB is a secondary lead smelter which produces pure lead and lead alloy from mainly lead acid batteries and other lead bearing waste. The lead hogs and pigs produce from smelting are sold to battery manufacturers . Inspection Report Exide Technologies, Inc. Page 2 II. CONSENT: Consent to conduct inspection that involves: taking photographs , reviewing and copying records, questioning personnel and inspecting hazardous waste handling areas. Yes. Consent given by: Thomas Wideman, Environmental Health and Safety Manager III. DOCUMENTS REVIEWED: a. Manifests, Bills of Lading, LOR's, Exception Reports: The State Oversight and Enforcement Branch, Rita Hypnarowski, cited the facility for the following manifest violations: Title 22, California Code of Regulations, section 66262.70, in that Exide inaccurately represented the amount of hazardous waste generated on 53 manifest records dated July 10, 2002 through December 10, 2002 as cubic yards instead of pounds; failed to indicate the number of containers used to ship hazardous waste as required on over one hundred manifest; and failed to indicate the number of units generated on seven manifest. Health and Safety Code section 25163, and Title 22, California Code of Regulations , section 66263.17 (a) and section 66266.81 (a) (5), in that Exide on nine manifest since December 1, 1998 transported hazardous with an expired transporter registration. b. Contingency Plan : The facility need to amend their contingency plan to reflect a change in the emergency coordinator. The facility need to include Tom Wideman as their emergency coordinator. c. Training Plan and Records: The facility has update their training records to include adequate training records. The training presently include a job title for each position with a description and how it relates to hazardous waste management, a written job Inspection Report Exide Technologies, Inc. Page 3 description and written description of the type and amount of both introductory and continuing training. N/A e. Waste Analysis Plan and Records: The facility has an adequate waste analysis plan. f. Operating Log: The facility has an adequate operating record. g. Inspection Records: The facility has updated their inspection logs to include how repairs or remedial actions are taken when discovering a discrepancy on inspections. h. Tiered Permitting Applications and Authorization Letters: N/A I. Annual/Biennial Reports: No violations noted. j. 5B 14 Plans: No violations noted. k. Closure Cost Estimates and Updates: No violations noted. I. Part A: A Part A application was filed in 1981 by Gould, Inc. former owner of GNB. GNB was purchased by Exide in 2002 , and is currently operating under Interim Status. Inspection Report Exide Technologies, Inc. Page 4 m. Part B: The part B has been submitted to Facility Permitting Branch and is currently under review. n. POTW Compliance Data: The facility has a permit to discharge treated waste water into the Los Angeles County Sanitation District. o. Tank and/or Containment Certifications: The facility has installed the new waste water treatment plant. The treatment plant is comprised of tanks and is surrounded by secondary containment and each tank has certification. The old wastewater treatment is out-of-service, but the tanks have not been removed. Mr.Wideman stated a closure plan was submitted for the dismantling of this unit, but DTSC has not approved the plan. p. Air Board Permits: No violations found . q. Variances: Not currently operating under a variance . r. Recycling Records: N/A s. Other: N/A IV. NARRATIVE OF OBSERVATIONS/DISCUSSION WITH OPERATOR: I, Ruth Williams-Morehead, met with Mr. Tom Wideman , Environmental Managerfor Exide Technologies, Inc. on April 28, 2003. The purpose of our meeting was to conduct a Comprehensive Evaluation Inspection (CEI). Mr. Wideman granted me permission to conduct the CEI , and I began the interview with asking for an Inspection Report Exide Technologies, Inc. Page 5 overview of the facility's hazardous waste operations. Mr. Wideman stated that the process has not changed since my last CEI. He stated that the facility receives used lead-acid batteries and other lead scrap from off-site. The lead from the batteries and scrap is recycled on site and sold to be used in the manufacturing of new batteries. Mr.Wideman stated that the new waste water treatment unit has been installed and is in operation, but that the old . A Consent Agreement issued in May 1999, have been implemented . He stated that the corridor project and drop-out box project have been completed and that the facility has installed the new waste water treatment tanks. He stated that the old wastewater treatment unit is no longer in operation , but that the tanks have not been removed. He stated that in accordance with the Consent Agreement, Exide submitted a decommissioning sampling plan for the wastewater treatment tanks to DTSC, but have not received any comments from the Department. I asked Mr. Wideman have the activities at the facility changed in the past year, and he stated no, that the operation has not changed. Due to the lateness of the hour , I stopped the inspection atthis time, and returned on April 29, 2003 to continue the inspection . On April 29, 2003, I returned to Exide to continue the inspection. I received permission from Mr. Wideman to continue the inspection and spent the day reviewing the operating log. Due to the number of truck loads of batteries and other lead bearing material the facility receives on a daily basis, the entries into the operating log and the operating log its self is immense. During the review I noted one violation . The operating log noted that batteries were being received in battery storage bin 108, when the batteries were actually being shipped to Kinsbursky Brothers. Exide receives steel case batteries that contain lead plates but cannot be processed on site due to the steel casing. The batteries are shipped to Kinsbursky Brothers to have their steel cases cut open and removed, and the plates are shipped back to Exide for smelting. In some cases the steel batteries are purchased and sent directly Kinsbursky Brothers, but the purchase will be recorded in the operating as batteries received. This is done through the facilities purchasing office. I informed Mr. Wideman that that the operating log is fortracking hazardous waste received on-site, and that the purchasing office should not record batteries as on-site, when the batteries are being sent to Kinsbursky Brothers . Mr. Wideman stated that he would discuss my concerns with purchasing and would Inspection Report Exide Technologies, Inc. Page 6 have the violation corrected immediately. I concluded the inspection for the day and returned to the facility on May 1 and May 6, 2003 , to continue the record review. I noted one violation. The facility did not amend the contingency plan to reflect a change of emergency coordinators. The contingency plan needs to be updated to include Tom Wideman as the new emergency coordinator. On May 9, 2003, I returned to the facility, I conducted a walk-through of the facility . I received permission from Mr. Wideman to continue the inspection. The new waste water treatment system is in operation, and the old system has not been removed. Mr. Wideman stated that he submitted a closure plan to the DTSC in 2000, but at this time Exide has not received any response from the Department. During the wa lk-through I noticed two violations. The facility failed to mark approximately 16 pallets of batteries stored in bins 103 and 104 with the dates the pallets were received at Exide, and the facility failed to mark three drums co ntaining lead waste in storage bin 7 with the start accumulation date . Two of the drums contained a hazardous waste label, and one drum contained no label. Facility personnel corrected this violation before the conclusion of the facility walk-through. I concluded the inspection after the walk-through, and due to the lateness of they day returned on May 12,2003, to conduct the exit interview. EXIT INTERVIEW: On May 12, 2003, I met with Mr. Wideman , and conducted the exit interview. I gave him a summary of all the violations I found during the inspection , and asked Mr. Wideman if he had any questions. He stated "no" and I concluded the inspection at this time. 4k.~~b(j;d Hazardous Substances Scientist SUl"Lm.i!!:Y cf Violations State of California - California Environmenta l Protection Agency Department of Toxic Substances Control SUMMARY OF VIOLATIONS '-Ill's &In 11l On i ~ '1 <;/1 ~<,/(, ,,,)1 ': the Department of Toxic Substances Control (DTSC), 1 California nviromnental Protection Agency , conducted an inspection at: Facility Name: Facility Address: ~'f....I · GI c-- T..e'--~V\Dl o~ye,>, Q:JO\) S' -::fhd A CA VI ('-= -y:,hL $,/vf'e.-.:f= EPA 10 Number: County Name: As a result of that inspection , the 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. If you disagree with any of the violations listed in Section I, you must give the inspector who issued the Notice to Comply a written notice of disagreement. You must correct the violations listed in Section 1: Minor Violations, Within-J./...; ,.R..- filfLb 11ri'.l Ifh.-" ,b I rxJf' .L!k'£~ Cut!t ~YI1l "- f_.prJVlJ /"' ~'J9 q. (i11Yt.f, ~f71 /Yd m,A."", ( ei-~"" ' '''J lec.-z/ w",k. ' '1 011' '-D7 (,A/ ,/.0 ~ !d-v ve C4A. ~,.£. .r?-'- ~S. :J.. oLHe.1vlAn-.s t.V1~1;-"Y1-e,J.. l ti'~J ___ ~L ~c.U-''''\Jh OTSC (31951 t... n wr1 00<-< 0'..... k r f~"'\ifY',..v( 'v..{e/ / ( ·(/vu..