annual compliance evaluation inspection report for exide, 2010

7/28/2019 Annual Compliance Evaluation Inspection Report for Exide, 2010

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Department of Toxic Substances ControlLinda S. AdamsSecretary forEnvironmental Protection

CERTIFIED MAILJune 14, 2010

Mr. Ed MopasEnvironmental ManagerExide Technologies2700 South Indiana StreetLos Angeles, California 90023Dear Mr. Mopas:

Maziar MovassaghiActing Director9211 Oakdale AvenueChatsworth, California 91311Arnold Schwarzenegger

Governor

On April 13, 15, 22, and 28, 2010, the California Environmental Protection Agency,Department of Toxic Substances Control (DTSC), conducted a Compliance EvaluationInspection of Exide Technologies located at 2700 South Indiana Street, Los Angeles,California 90023. EPA ID Number CAD097854541. The enclosed report describes thefindings of this inspection.However, subsequent to the inspection, additional violations were found. Therefore, asstated in the Summary of Violations issued to you on April 28, 2010, additionalviolations may be found after the site visit, and these will be identified in the Violation---sect lonof t lTe ins -p ec t ion tepo f t . -- - - - - -- - - -- - - - - -- - - -- - - - - -- - - - -- -You are required by section 25183 (c) (3) of the Health and Safety Code to submit awritten response to the Department within 30 days describing the corrective actions thatyou have taken or propose to take to bring your company into compliance. If youdispute the violation, you should explain your disagreement in this written response.The issuance of this letter and report does not preclude the Department from takingadministrative, civil or criminal action as a result of the violation noted in the report. Allpertinent information derived from the inspection, including documents and photographsare included as attachments to the report. The report will become a public document.


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Mr. Ed MopasExide TechnologiesJune 10, 2010Page 2 of 2You may request that any trade secret or facility security information be withheld frompublic disclosure. (See Health and Safety Code Section 25173)If you wish to assert the trade secret privilege, please provide DTSC specific writtenanswers to each of the following questions with 10 days of receipt of the inspectionreport.

To what extent is there knowledge of the information conveyed by thephotograph/document outside of your business? To what extent is there knowledge of the information conveyed by thephotograph/document, by employees and others in your business? To what extent have measures been taken to guard the secrecy of theinformation? Is the information valuable to competitors? If so, why? Has there been sUbstantial monetary expenditure in the development of theinformation? Could the information be easily and properly acquired or duplicated by others?

DTSC will review your response to these questions to determine if the informationshould 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 theDepartment to discuss any questions or concerns you have with the inspection, thereport,the violations, or the proposed corrective action, please contact me at(818) 717-6668 or Ruth Williams-Morehead at (818) 717-6578.Sincerely, ~ . ~ -

u AgarwalSupervising Sen or Hazardous ubstances ScientistEnforcement and Emergency Response ProgramChatsworth OfficeEnclosuresCertified Mail No.7008 1830 0003 5238 6389Return Receipt Requested


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INSPECTION REPORTI. GENERAL INFORMATION:

Company Name: Exide Technologies, Inc,Facility Address: 2700 South Indiana AvenueLos Angeles, California 90023Telephone Number: (323) 262-1101 ext. 259EPA 10 Number: CAD097854541Registration Number: 2157Facility Type: RCRA Hazardous Waste Treatment FacilityRegulated Units: The facility is currently operating under an ISO for theStorm Water Retention Pond, the Reverberatory andBlast smelting furnaces, the Waste Water TreatmentPlant and six Spent Lead-Acid Battery and Lead WasteStorage areas,Waste Streams: Lead acid batteries and other lead bearing waste,polypropylene waste, furnace slag, rubber and plasticcasing material, lead and acid contaminated wastewater, filter cake sludge, lead contaminated wipes,rags and trash, etc,Dates of Inspection: Ruth Williams-Morehead, HSS - 4/13, 15, 22, and 28,2010.... ---MicnaEWFIaynes, AirQualifyTnspectclf;-South CoastAir'-Quality Management District - 4/13/2010

Type of Inspection:

Facility Rep,:

Brian Wu, HSS - 4/13, 15,22, and 28, 2010CEI XX CME - O&M _ FocusedLimited _ TransporterEd Mopas, Environmental ManagerKen Copeland, Plant Manager


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Type of Business:

II. CONSENT:

Galindo Felix, Waste Water TreatmentUnit SupervisorVianey Mendez, Health and Safety ManagerAndy Enriques, Environmental Administrative Assistant.Exide Technologies, Inc, is a secondary lead smelterthat recovers lead by smelting lead from spent lead acidbatteries, lead bearing materials and hazardous waste,The recycled lead is sold and reused in. manufacturingnew batteries,

Consent to conduct an inspection that involves: taking photographs, reviewing andcopying records, questioning personnel and inspecting hazardous waste handlingareas,Consent given by: Ed Mopas, Environmental Manager,On April 22, 2010, Ed Mopas was not at the facility, but gave me consent to conductthe inspection when I contacted him by telephone to inform him that I had returnedto the facility to continue the inspection, We conducted the inspection with VianeyMendez, Health and Safety Manager and Andy Enriques, EnvironmentalAdministrative Assistant.

III. DOCUMENTS REVIEWED:a. Manifests, Bills of Lading, LOR's, Exception Reports:

During the inspection of the Manifest, no violations were found,b, Contingency Plan:

. -DUFingtmnnspecticfn-6ftne-C6ntingencypran, 1'10 violatianswere faDna,c. Training Plan and Records:

The facility has all the elements for a good training plan; however it needs tobe reorganized to better document that personnel that are directlyresponsible for handling hazardous waste are trained on hazardous wasterequirements that are directly related to their job descriptions,d. Incident Report:


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No incidents have occurred since the last inspection.e. Waste Analysis Plan and Records:

During the inspection of the Waste Analysis Plan, no violations were found.f. Operating Log:

During the inspection of the Operating Log, no violations were found.g. Inspection Records:

The inspection logs for the tanks, sumps, and the waste water treatment planthad only one word to describe the area for which the equipment is beinginspected. Also the logs did not have the time of the inspection.h. Tiered Permitting Applications and Authorization Letters:

N/Ai. Annual/Biennial Reports:

The facility filed the Annual Report for 2009.j SB 14 Plans:

N/Ak. Closure Cost Estimates and Updates:

No violations cited.I. Part A: An application was filed in 1981 by Gould, Inc. former owner ofGNB. Exide purchased GNB in 2000, but the facility has never been issued' -aHazardousWasteFadlity PermTfExide is-currentlyoperating-undeTElnInterim Status Document.m. Part B: Part B application is under review by the Southern CaliforniaPermitting and Corrective Action Division.n. POTW Compliance Data:

The facility has a perrnit to discharge treated wastewater into the LosAngeles County Sanitation District.


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o. Tank and/or Containment Certifications:During the walk-through of the facility, I did not observe any violationsassociated with the tank system.

p. Air Board Permits:Several of the facility's hazardous waste management units are equippedwith Air Monitoring Control Devices. All permits for these devices arecurrent.

q. Variances:The facility does not have any variances.

r. Recycling Records:N/A

s. Other:N/A

IV. NARRATIVE OF OBSERVATIONSIDISCUSSION WITH OPERATOR:On April 13, 2010, I, Ruth Williams-Morehead and Brian Wu, conducted aComprehensive Evaluation Inspection at Exide Technologies. We met with Mr. EdMopas, Environmental Manager and Mr. Ken Copeland, Plant Manager. We werealso joined by Michael Haynes from the South Coast Air Quality ManagementDistrict. Mr. Mopas gave us permission to conduct the inspection. I asked Mr.Mopas and Mr. Copeland if the there had been any changes in the hazardous wastemanagement operation since my last inspection. They both stated that theoperation has not changed, but to meet compliance with the Southcoast Air QualityManagement District's Proposed Rule 1420.1, they plan to enclose the RMPS,Battery Wrecker, Truck Wash area, Rotary Kiln and the hoods that pick up acid mistUiafls senno thescru5Eer.-- ------ -- --------- -- - - - -- -- -- - -- -- --They also stated that they re-asphalted a portion of the facility to create betterhouse keeping.I asked them if the Storm Water Retention Pond (Pond) contained hazardous wastewater or sludge, and they both stated yes, and that they would probably startcleaning out the pond in Mayor June.I asked them what is the capacity of the Pond and I was told that the Pond has acapacity of 3.3 - 3.6 million gallons. I told them that I spoke to some one at the Los


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Angeles Sanitation District and based on the information they gave me, I calculatedthat Exide can discharge a maximum of 424,000 gallons of treated water into thesewer each day. Mr. Copeland stated that they only pump between 80-100 gallonsof water a day from the pond to the waste water treatment plant. He stated that theamount of water they remove from the pond depends on "how hard they are runningthe smelting unit". He stated that the lead recycling operation interrupts the amountof water they can remove from the Pond and discharge into the sewer. Mr.Copeland stated that the water in the Pond never exceeds 2.5 million gallons ofwater.I told Mr. Copeland that during past inspections I noticed that the Pond alwayscontains sludge. I told him that I thought the Dropout Boxes were installed to filterout the sediment before it entered into the Pond. He stated that all of the watergenerated in the plant is sent to a 2,000 gallon centralized sump, and is pumpedfrom the sump into the Dropout boxes. He said that the four Dropout Boxes, whichare 9,000 gallons each, are designed to settle out dirt and rocks but not lead,although a small amount of lead is settled out.We concluded the opening interview, and I asked to conduct a walk-through andinspection of the facility's hazardous waste management units. I, Brian Wu, andMichael Haynes, conducted the walk of the hazardous waste management unitslisted below, and were accompanied by Mr. Copeland, Mr. Mopas, and Mr. GalindoFelix, Waste Water Treatment Unit Supervisor.Trailer Staging Area:This area is used to store incoming and outgoing trailers that contain hazardouswaste. The incoming trailers usually consist of lead acid batteries and other leadbearing waste that will be recycled at the facility. The outgoing trailers usuallycontain lead contaminated plastic that is generated by the facility from crushing leadacid batteries during the recycling process. The plastic is sent to KW Plastics inBakersfield, California for disposal.During the walk-through of the area I noticed that several forty foot trailers werestaged in the area. The trailers contained hazardous waste plastic and spent lead.... acidbatteries.-"fheirailerswhich-contained the lead-acid-batt eries-were-marked-with-the date the batteries arrived at the facility. The dates on the labels did not exceedten days.The trailers that contained hazardous waste plastic were marked with hazardouswaste labels that contained th.e start date of accumulation and the other appropriateinformation. 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 spillscoming from the trailers.


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Waste Water Treatment Plant:The waste water treatment plant treats hazardous waste water that iscontaminated with spent battery acid, lead and other heavy metals. The wastewater is generated from the facility's smelting operation, the wash down of thefacility, and from rainwater water that is collected in the Storm Water RetentionPond.During the walk-through of the waste water treatment plant I did not observe anyviolations. I need not observe any leaks coming from the treatment tanks, or tankaccessories. The coating covering the floor of the secondary containment, and thefloor and the wall that comprise the secondary containment were found intact.Storm Water Retention Pond:The Storm Water Retention Pond (photos 1-4) is used to collect rainwater, andhazardous waste water generated from washing down the facility. The Storm WaterRetention Pond also receives hazardous waste water from four 9,000 gallonDropout Boxes (photos 5-7). Hazardous waste water is collected in a centralizedsump and pumped into the Dropout Boxes to filter out dirt and rock from thehazardous waste water. The filtered water is pumped from the Dropout Boxes intoStorm Water Retention Pond.During the walkthrough, the Retention pond contained liquid and I also observedsludge on the bottom of the pond.Battery Storage Area - Bins 103-108:Numerous pallets of batteries and drums of lead shot were stored in bins 103-108(photos 8-16). Each pallet of batteries was marked with a label that contained thedate of receipt at the facility. The batteries were intact and I did not observe anyleaks or spills. The pallets are wrapped in plastic to enclose the batteries and tokeep the pallets intact, and I did not observe that each battery was placed into anindividual plastic bag. No violations were observed.

The fumaces recover lead from a material that is generated from crushing thebatteries called battery wrecker material. The plastic is separated from the batterywrecker material before it is stored in the containment building. The material is fedinto the reverberatory furnace to recover the lead. Primary slag is generated fromsmelting the battery wrecker material in the Reverberatory Furnace. The primaryslag contains a high percentage of lead and the slag is placed into the BlastFurnace to recover lead from the slag. A secondary slag is generated from theBlast Furnace, which is exhausted of much of its lead content and is sent off-site fordisposal.


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I observed that the Containment Building which houses the battery wreckermaterial, primary slag, and the Reverberatory and Blast furnaces is intact and undernegative pressure.West Yard:The facility is prohibited from storing hazardous waste in the West Yard. The facilityuses the west yard to store equipment. During the walk-through I observed thatthere were only empty trailers and equipment stored on the West Yard.After we finished the walk-through of the West Yard, I concluded the inspection forthe day.Record ReviewI, Ruth Williams-Morehead and Brian Wu returned to the facility on April 15,22,and 28, 2010 to conduct the record review. Mr. Mopas gave us consent on allthree days to continue the inspection. However on April 22, 2010, Mr. Mopaswas not at the facility during the inspection, and when I notified him viatelephone that I had returned to the facility to continue the record review hegave me consent to continue the inspection. During the record review only oneviolation was found. The daily inspection logs for the hazardous waste tanksand sumps did not have the time of the inspection, and the logs did not identifythe problems that are looked for during an inspection.

V. SUMMARY OF VIOLATIONS:Additional Violations:1. Health and Safety Code Section 25202Exide violated Health and Safety Code section 25202, in that on or about April 13,2010, the facility illegally stored hazardous waste lead contaminated sludge in anunauthorized unit, to wit: During the facility walk-through of the facility, I observedhazardous waste sludge and water stored in the Storm Water Retention Pond.Corrective Action: Effective immediately Exide shall cease fromillegally storing hazardous waste in the Storm Water Retention Pond.2. California Code of Regulations, title 22, section 66265.193 subdivision c (4) andConsent Order HWCA 97/98-3021Exide violated California Code of Regulations, title 22, section 66265.193subdivision c (4) and Consent Order HWCA 97/98-3021, in that on or aboutApril 13, 2010, the facility failed to remove sludge and precipitation fromthe Storm Water Retention Pond within 24 hours or in as timely a manner as


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possible, to wit: During the April 13.2010 CEI, the Storm Water Retention Pondcontained hazardous sludge and water.Corrective Action: Effective immediately Exide shall remove hazardous wastesludge and precipitation from the Storm Water Retention Pond within 24 hours or inas timely a manner as possible.Violation Cited in the Summary of Violations issued on April 28, 2010:Title 22, California Code of Regulations (CCR), section 66265.15 b (3) and dExide violated Title22, CCR, section 66265.15 b(3) and d, in that on or about April22, 2010, the facility did not completely identify the types of problems that arelooked for during an inspection, and the inspection logs did not have the time of theinspection, to wit: on the Daily Inspection Logs for Tanks, Sumps and the newWWT, there is only one word to describe the area of the equipment that is beinginspected, which does not identify the problems that are looked for when theequipment is being inspected.Corrective Action: Within 30 days of the inspection, Exide shall revise theinspection log and provide a more complete description of the area of theequipment that is being inspected and identify the problems that are looked forduring an inspection. Exide shall also place on the inspection logs the time of theinspection.

VI. EXIT INTERVIEW:After we completed the record review, we concluded the inspection, and I issued thefacility a Summary of Violations. I cited the facility for one minor violation and wediscussed the area of concern that was mentioned in the Summary of Violations.At the end of our discussion, we concluded the inspection and exited the facility atthe end of our discussion.

VII. ATT ACHEMNTS:1. Photos, 1-16

~ , I[ M..eRuth Williams-Morehead 0)4ao1 DDate


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Exide Technologies04/13/201

The Storm Water Retention Pond contains hazardous waste sludge and 1Water. The hazardous waste water in the pond is low.


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The Storm Water Retention Pond contains hazardous waste sludge andWater. The hazardous waste water in the pond is low. 2


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Exide Technologies

3


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Exide Technologies04/13/...,.,. "" .

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The Storm Water Retention Pond contains hazardous waste sludge andWater. The hazardous waste water in the pond is low. . 4


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Exide Technologies

Photo of the four Dropout Boxes. The Dropout Boxes are 9,000 gallons each.Hazardous Waste Water is collected in a centralized sump and pumped into theIDropout Boxes; and pumped from the Dropout Boxes into Storm Water 5Retention Pond.


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the four Dropout Boxes. The Dropout Boxes are ~ , O O O gallons each.Hazardous Waste Water is collected in a centralized sump! and pumped into theDropout Boxes; and pumped from the Dropout Boxes into Storm Water 6Retention Pond.


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Exide Technologies

Photo of the four Dropout Boxes. The Dropout Boxes are 9,000 gallons each.Hazardous Waste Water is collected in a centralized sump and pumped into theDropout Boxes; and pumped from the Dropout Boxes into Storm Water 7Retention Pond.


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Lead shot bought by Exide. The lead shot will be recvcled 10


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Pallets of batteries are wrapped in plastic; not each irldividual battery. 11


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Exide Technologies201

Pallets of batteries are wrapped in plastic; not each individual battery. 12


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Pallets of batteries are wrapped in plastic; not each individual battery.I 13


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Exide Technologies !04/13/2010

Pallets of batteries are wrapped in plastic; not each ind 14


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... --''];Pallets of batteries are wrapped in plastic; not each ind 15


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Exide Technologies010,-

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Pallets of batteries are wrapped in plastic; not each i n ~ i v i d u a l battery.! 16


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Department of Toxic Substances ControlMaziar Movassaghi, Acting Director

linda S. Adams 9211 Oakdale Avenuesecretary for Chatsworth California 913111.-1__ _U_M_M_A_R_Y_O_F_V_I_O_L_A_T_IO_N_S__ -- !

Arnold SchwarzeneGovernor

On April 13, 15,22, and 28,2010, the Department of Toxic Substances Control(DTSC), California Environmental Protection Agency, conducted an inspection at:Facility Name: Exide TechnologiesFacility Address: 2700 .Indiana Street.. Los Angeles, California 90023EPA 10 Number: CAD 097854541 County: Los AngelesAs a result of this inspection, violations of hazardous waste laws, regulations, andrequirements 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 youdisagree with any of the violations or proposed corrective actions listed in this Summary ofViolations, 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.DlSC will provide you a complete inspection report within 65 days of the date of thisinspection. You may request a meeting with DTSC to discuss the inspection, inspectionreport, or the Summary of Violations. The issuance of this Summary of Violations does notpreclude DTSC from taking administrative, civil, or criminal action as a result of the violationsnoted in the Summary of Violations or violations that have not been corrected within the timeprovided. A false statement that compliance has been achieved is a violation of the law andpunishable by a fine of not less than $2,000 or more than $25,000 for each occurrence.DTSC many re-inspect this facility at any time.Company Representative Accepting Summary DTSC Representative- - - - - - - - -Signature 4 ; i L ~ ~ 9 d . . - - __

Title Hazardous Substance ScientistDate 7 ( Date Al2ril 28, 2010


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Department of Toxic Substances Control9211 Oakdale AvenueChatsworth, California 91311

SUMMARY OF VIOLATIONSFacility Name: Exide Technologies Date: April 28, 2010SECTION II: MINOR VIOLATIONS I NOTICE TO COMPLY(Minor Violations not corrected at the time of the inspection)You must correct the following violation(s) within the specified time frame for each violation.Within five working days of achieving compliance, you are required to sign the certificationbelow, and return it to DTSC at the above address.

1. Title 22, California Code of Regulations (CCR), section 66265.15 b(3) and dExide Technologies violated Title 22, CCR, section 66265.15 b(3) and d , in that on orabout April 22, 2010, the facility did not completely identify the types of problems thatare looked during an inspection and the inspection logs did not have the time of theinspection, to wit; on the Daily Inspection log for Tanks, Sumps and new WWT, there isonly a word to describe the equipment that you are inspecting, but it does identify theproblems that are looked for when you are inspecting the equipment.

I certify under penalty of law that the corrective actions listed in SECTION II of thisdocument have been taken and the violations have been corrected. I am aware that thereare significant penalties for submitting false information.Signature __________________ Date_____Name ____________ Title____________


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Department of Toxic Substances Control9211 Oakdale AvenueChatsworth, California 91311

SUMMARY OF VIOLATIONSFacility Name: Exide Technologies Date: April 28, 2010SECTION IV: OTHER ISSUES/CONCERNSThe following issues/concernswere identified during this inspection. Further research mayidentify additional violations. Any new violations, with the required corrective action andcompliance schedule, will be identified in the Violation section of the inspection report.The facility has all the elements for a good training plan; however it needs to be reorganizedto better document that personnel that are directly responsible for handling hazardous wasteare trained on hazardous waste requirements that are directly linked to their job descriptions.

annual compliance evaluation inspection report for exide, 2010

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