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Department of Toxic Substances Control
Linda S. Adams
Secretary for
Environmental Protection

Maureen F. Gorsen, Director
1011 North Grandview Avenue
Glendale, California 91201

Arnold Schwarzenegger
Governor

CERTIFIED MAIL
August 3, 2006

Ms. Diane Kennedy
Compliance Manager
Exide Technologies
2700 South Indiana Street
Los Angeles, California 90023
Dear Ms. Kennedy:
On May 30 and June 2 and 5, 2006 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 90023. EPA ID Number CAD097854541. The enclosed report describes the
findings of this inspection.
You are required by section 25183 (c) (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 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 ten 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?

®

Printed on Recycled Paper

 Ms. Diane Kennedy
August 3, 2006
Page 2

•
•
•
•
•

To what extent is there knowledge of the information conveyed by the
photograph/document, by employees and others in your business?
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 concern you have with the inspection, the
report, the violations, or the proposed corrective action, please contact me at (818)
551-2908 or Ruth Williams-Morehead at (818) 551-2916.
Sincerely,

Mukul Agarwal—
Supervising Senior Hazardous Substances Scientist
Statewide Compliance Division
Southern California Branch
Enclosures
Certified Mail No.: 7005 3110 0002 0075 2960
Return Receipt Requested

 State o f California - California Environmental Protection Agency

Department o f 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 ID Number:

CAD097854541

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, two lead
smelting furnaces, their waste water treatment
unit and six 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, HSS
Brian Wu, HSS

Dates of Inspection:

May 30, 2006 and June 2 and 5, 2006

Type of Inspection:

CEIXX CME • O&M
Limited i Transporter

Facility Rep.:

Diane Kennedy, Environmental Health and
Safety Manager
Carlos Pena, Plant Manager
Rafael Perez, Material Manager

Type of Business:

Exide Technologies, Inc. is a secondary lead
smelter that recovers lead primarily from lead
acid batteries. The recycled lead is sold and
reused in manufacturing new batteries.

Focused

 Exide Technologies, Inc.
August 3, 2006
Page 2 o f 7

II.

CONSENT:
Consent to conduct an inspection that involves: taking photographs, reviewing and
copying records, questioning personnel and inspecting hazardous waste handling
areas.
Yes.
Consent given by:

III.

Diane Kennedy, Environmental Health
and Safety Manager

DOCUMENTS REVIEWED:
a.

Manifests, Bills of Lading, LDR's, Exception Reports:
No violations were observed during the document review.

b.

Contingency Plan:
The facility has an adequate contingency plan, and no violations were
observed during the document review.

c.

Training Plan and Records:
The facility has adequate training records, but during the record review it was
noted that not all of the hazardous waste management training given to their
employees were noted in their training records.

d.

Incident Report:
None reported.

e.

Waste Analysis Plan and Records:
The facility has an adequate waste analysis plan, and no violations were
observed during the document review.

f.

Operating Log:
The facility has an adequate operating log; however the operating log needs
to be updated to more efficiently track incoming and outgoing waste.

 •

•

Exide Technologies, Inc.
August 3, 2 0 0 6
Page 3 of 7

g.

Inspection Records:
The facility has adequate inspection records, however on a few of the
inspection records when discrepancies were found during an inspection, it
was not noted how the discrepancy was corrected.

h.

Tiered Permitting Applications and Authorization Letters:
N/A

I.

Annual/Biennial Reports:
The facility submitted the annual report for 2006, and no violations were
observed during the document review.

j.

SB 14 Plans:
N/A

k.

Closure Cost Estimates and Updates:
The financial responsibility review found
closure and post-closure cost.

that the facility has adequate

I.

Part A: An 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.

o.

Tank and/or Containment Certifications:
The facility has adequate tank certifications, and no violations were observed
during the document review.

 •

•

Exide Technologies, Inc.
August 3 , 2 0 0 6
Page 4 of 7

p.

Air Board Permits:
The facility's 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 May 30, 2006, I, Ruth Williams-Morehead and Brian Wu began my
Comprehensive Evaluation Inspection (CEI) at Exide Technologies (Exide). Exide is
located at 2700 South Indiana Street, Los Angeles, Ca. 90023. I met with Ms.
Diane Kennedy who is the new Environmental Health and Safety Manager at Exide.
I informed Ms. Kennedy of the purpose of my visit and asked for permission to
proceed with my inspection. Ms. Kennedy granted me permission to conduct the
inspection and I told her that I wanted to begin with a walk-through of the facility.
W e first visited the parking area that is used to stage trailers that contain hazardous

waste plastic that is generated from the smelting process and is eventually shipped
to KW Plastics in Bakersfield for disposal. Trailers that contained spent lead acid
batteries that were received from off-site were also staged in this area. The trailers
were stored closed and marked with labels that contained the dates the trailers were
received from off-site and the storage had not exceed the ten day time from allowed
under Health and Safety Code section 25200.19. (I asked facility personnel to
open the trailers and took photos, 22 and 23, of the batteries inside of the
trailers).
Next we visited the Strom Water Retention Pond (photos 1 -4). The pond contained
a large volume of water. Ms. Kennedy stated that the water inside of the retention
pond is being pumped to the waste water treatment unit for treatment prior to being
discharged into the sanitation district.

 Exide Technologies, Inc.
August 3, 2 0 0 6
Page 5 of 7

W e visited battery storage areas 106-108 (photos 16-21) and during the walk­
through of area 108 we observed that used batteries were being stored in pallets,
large metal bins and 110 gallon drums. The pallets, bins and drums were marked
with a label that contained that date the batteries were received on site for recycling.
Battery storage areas 106 and 107 were empty.
W e also visited battery storage areas 103-105. During the walk-through of areas
103 -105, we observed that numerous pallets of batteries were stored in these
locations. Two pallets of batteries in battery storage area 104 were not marked with
a label that contained the dates the pallets were received on site for storage, and
the there was inadequate aisle space between the pallets of batteries stored in
battery storage area 105. We did not observe any leaks or spills from the batteries
and before we exited battery storage area 104, labels had been placed on the two
pallets of batteries.
We noticed that the facility had 32 trailers (photos 5-15) parked in the west yard.
During the walk-through of the west yard we checked the contents of each trailer
and found that the trailers were empty.
Next we visited the new waste water treatment plant. The old waste water
treatment plant has been out of operation since 2000, but the tanks have not been
removed. During the walk-through of the waste water treatment plant I observed
that a leak was coming from a screw on the clarifier (photo 25) and that the sand
filter tank (photos 26 and 27) was leaking. The clarifier and the sand filter tank are
surrounded by secondary containment and the spill from the leak was controlled.
Ms. Kennedy contacted Rafael Perez who stated he would have the leaks repaired
immediately.
We completed the walk-through of the facility at this time and concluded the
inspection for the day. I told Ms. Kennedy that we would return and begin the
record review on June 2, 2006.
On June 2 and June 5, 2006,1 and Brian Wu returned to the facility and performed
the record review. On both days Ms. Kennedy granted us permission to conduct the
inspection. We reviewed the records and did not find any violations. On June 2,
2006,1 revisited battery storage area 105 and the waste water treatment plant, and
on June 5,2005 I only revisited the waste water treatment plant. The batteries that
were stored in battery storage area 105 on May 30, 2006 were removed and
recycled, and the storage area was empty (photos 32-34). Facility personnel had
painted yellow lines, two feet apart, on the floor of area 105 to outline where each
row of batteries should begin. At the waste water treatment plant on June 2,2006,
the leak from the clarifier was repaired but the sand filter tank continued to leak.

 Exide Technologies, Inc.
August 3 , 2 0 0 6
Page 6 of 7

However, on June 5, 2006, when I revisited the waste water treatment plant, the
leak from the sand feed tank was repaired.
V.

SUMMARY OF VIOLATIONS:
1. Title 22, California Code of Regulations (CCR), section 66265.35
The facility violated Title 22, CCR section 66265.35 in that on or about May 30,
2006, the facility failed to provide adequate aisle space between rows of pallets
of batteries that were stored in battery storage area 105.
This violation was corrected by June 2, 2006. The batteries that were stored in
battery storage area 105 on May 30, 2006 were removed and recycled, and the
storage area was empty. Facility personnel had painted yellow lines, two feet
apart, on the floor of area 105 to outline where each row of batteries should
begin (photos 32-34).

2.

Title 22, CCR, section 66266.81 (a) (7) (D)
The facility violated Title, CCR section 66266.81 (a) (7) (D) in that on or about May
30,2006, the facility failed to mark two pallets of batteries stored in battery storage
area 104 with a label that contained the date the batteries were received on site for
storage.
This violation was corrected on May 30, 2006. The two pallets of batteries were
marked with a label that contained the date that they were received on-site for
storage before the DTSC inspectors exited the area.

3.

Title 22, CCR section 66265.31
The facility violated Title, CCR section 66265.31 in that on or about May 30,2006, a
screw on the clarifier leaked process water; and clear water leaked from the sand
feed tank. Both the clarifier and the sand feed tank are located at the waste water
treatment plant which is surrounded by secondary containment.
The leak from the clarifier was repaired by June 2, 2006 (photos 28 and 29), but
the sand feed tank continued to leak (photos 30 and 31). The leak from the
sand feed tank was repaired by June 5, 2006 (photos 37 and 38).

VI.

EXIT INTERVIEW INSPECTION REPORT:
On June 2 and June 5,2006,1 toured the facility and verified that the violations cited
above had been corrected. I issued Ms. Kennedy a Summary of Violation

 #
Exide Technologies, Inc.
August 3, 2006
Page 7 of 7

(attachment 2), and noted that each violation I cited had been corrected. I also told
Ms. Kenney and noted my comments in the Summary of Violations that I had
addressed two areas of concern. During the record review it was noted that the
person(s) who is/are responsible for conducting the inspections of the hazardous
waste management units, did not record in the inspection log how discrepancy
found on an inspection are corrected Also on a few of the training records for
personnel who are involved in the management of hazardous waste, the hazardous
waste training they received was not noted in their training records.
VII.

ATTACHMENTS:
1. Photos, 1-38
2. Summary of Violation

Date
Hazardous Substances Scientist

 S t a t e d California - California Environmenta

Department of Toxic Substances Control

SUMMARY OF VIOLATIONS
On 'SI SO. b / j i - U f c j M 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. Los Angeles CA 90023

EPA ID Number:
County Name:

CAD 097 854 541
Los Angeles County

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 III: Minor Violations, within
days. Within five working days of achieving compliance, you must sign
the statement certifying compliance at the bottom of Section III and return it to DTSC at
the address 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 violation. DTSC may reinspect this facility at any time.
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 or the
findings of the report. 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 that have not been corrected within the time
provided in the Notice to comply.
Company Representative Accepting Summary

Department Representative

Name
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Date 6

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Title Hazardous Substances Scientist

State of California - California Environmental Protection Agency

Facility Name:

Department of Toxic Substances Control

Exide Technologies

Date:_

SECTION IV: MINOR VIOLATIONS CORRECTED AT THE TIME OF THE
INSPECTION

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Facility Name:

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Department of Toxic Substances Control

Date:_

Continuation Sheet for SECTION IV: MINOR VIOLATIONS
CORRECTED AT THE TIME OF THE INSPECTION
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Spte of.CaJifornia - California Environmental Protection Agency

Department of Toxic Substances Control

SUMMARY OF VIOLATIONS
Facility Name:

Exide Technologies

Date:

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SECTION III: MINOR VIOLATIONS I NOTICE TO COMPLY
(Minor Violation not corrected at the time of the inspection)
You must correct the following violation(s) within / 5 days. Within five working days of
achieving compliance, you are required to sign the certification below, and return it to
DTSC at the following address: l o i t /V ; Q^i r *Jo
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I certify under penalty of law that the corrective actions listed in SECTION III of this
document have been taken and the violations have been corrected. I am aware that
there are significant penalties for submitting false information.
Signature

Date

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DTSC

(7/05)

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