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Exide Technologies - Compliance, Permitting and Toxic Hot Spots Information

Historical Permitting Activity - South Coast AQMD

On December 5, 2014, the South Coast AQMD adopted the Final Mitigated Negative Declaration (PDF, 12.6MB) dated December 2014, and approved the Title V Permit Revisions (PDF, 2.8MB), as well as the Final Risk Reduction Plan (PDF, 8.4MB) dated August 2014 for Exide Technologies authorizing the installation of new, and modification of existing, air pollution control equipment.  The new and modified air pollution control equipment implements the Revised Final Risk Reduction Plan submitted by Exide that proposed the measures to be taken at the facility to reduce toxic emissions and lower health risk to the neighboring communities.  During the permitting process, South Coast AQMD engineering staff thoroughly evaluated and discussed with Exide the proposed Risk Reduction Plan.  The evaluation and discussions resulted in the inclusion of additional improvements to air pollution control systems in Exide’s original proposal.  The new and modified equipment to be installed includes a new scrubber, two new regenerative thermal oxidizers (RTOs), a new baghouse and filtration systems, and the re-purposing of an existing baghouse and scrubber.  The existing scrubber system will now control emissions from one furnace only (Reverb Furnace) rather than its previous function of controlling emissions from two furnaces (Reverb and Blast/Cupola Furnaces), whereas the new scrubber will control emissions from the Blast/Cupola Furnace.  In addition, the modification includes changes to the facility ventilation systems to better ensure that all emissions are more effectively contained, collected, and controlled.  The draft Title V Permit revisions and Draft Mitigated Negative Declaration was released for public review and comments and the draft permit revision was also submitted to US EPA for review and comments.  No comments were received from the public or the US EPA during the comment period.  The South Coast AQMD also held a public meeting on November 25, 2014 to discuss the proposed actions and receive further public input.  

On October 16, 2014, a 30-day public notice period began for 18 permit applications submitted by Exide.  South Coast AQMD staff also sent the proposed Title V permit changes and engineering evaluation  to U.S. EPA on October 14th for their review.  The proposed changes improve the air pollution control equipment serving the cupola furnace and the rotary dryer and improve facility ventilation systems.  Changes include the addition of a new scrubber, two regenerative thermal oxidizers (RTOs), a cartridge-type dust collector, and the re-purposing of an existing baghouse. The existing scrubber system will control emissions from one furnace instead of two furnaces, and the new scrubber will control emissions from the other furnace.  In addition, the revision includes changes to the facility ventilation systems to better ensure that all emissions will be properly collected and controlled.  Written comments on the project are due by November 17, 2014.  The proposed permit, engineering evaluation, and Revised Final Risk Reduction Plan can be viewed at http://www3.aqmd.gov/webappl/publicnotices2/Search.aspx by entering the facility’s ID number (124838). 

 A Notice of Intent to Adopt a Mitigated Negative Declaration was issued on October 16, 2014.  The South Coast AQMD is the Lead Agency and has prepared a Draft Mitigated Negative Declaration (MND) for the proposed project identified below, in accordance with the California Environmental Quality Act (CEQA) per CEQA Guidelines §§ 15187 and 15189. Exide Technologies is proposing a project to reduce toxic emissions of arsenic, benzene and 1,3-butadiene to comply with the recent amendments made to South Coast AQMD Rule 1420.1 - Emission Standards for Lead and Other Toxic Air Contaminants from Large Lead-Acid Battery Recycling Facilities, as well as to assure compliance with requirements in South Coast AQMD Rule 1402 - Control of Toxic Air Contaminants from Existing Sources including the Proposed Revised Final Risk Reduction Plan.  Based on the analysis of the proposed project in the Draft MND, there would be no significant adverse impacts to any environmental area after mitigation implementation. The purpose of the Notice of Intent is to solicit comments on the environmental analysis contained in the Draft MND. The 30-day public comment period started October 16th.  Comments are due November 14, 2014.  For more information see: Notice of Intent to Adopt a Mitigated Negative Declaration - Toxic Air Contaminant Reduction for Compliance with SCAQMD Rules 1420.1 and 1402 at the Exide Technologies Facility in Vernon, California.

On July 23, 2013, Exide received South Coast AQMD permits to improve two existing air pollution controls systems. The improvements include addition of High Efficiency Particulate Arrestor (HEPA) filters on the baghouse currently venting the cupola furnace feed room and installation of pre-filters to the HEPA of the current air pollution control system venting the battery crushing area.

South Coast AQMD staff revised Exide’s Title V permit on March 14, 2014 to add additional air pollution control systems and modify the feed system for the Reverberatory Furnace to allow Exide to better control their emissions. Permits to Construct were issued for installation of secondary control devices including addition of High Efficiency Particulate Arrestor (HEPA) filtration systems to the exhaust of two of their existing baghouses (the Hard Lead and Soft Lead Baghouses); addition of two new portable HEPA canister vacuums for general housekeeping; and for replacement of the two existing ram feeders with feed screw conveyors for the Reverberatory Furnace.

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Recent Compliance Activities

Latest Updates:

VERT Cleanup In 2022, DTSC’s Phase 1 of the cleanup was completed. South Coast AQMD enforcement staff has conducted approximately 20 on-site inspections this year and issued three Notices of Violation (NOV) to the Vernon Environmental Response Trust (VERT). The violations involved failing to maintain sufficient negative pressure within the full enclosure for a brief period of time and for failing to conduct real-time particulate matter (PM10) monitoring during deconstruction/demolition activities on specific days.  Additional details of the violations can be found below.  South Coast AQMD continues to closely follow the project and meets regularly with DTSC, EPA, and VERT to discuss future plans. 

Exide Residential Cleanup – In 2022, South Coast AQMD enforcement staff conducted approximately 60 on-site inspections relating to the Exide Residential Cleanup project. Although no violations were observed during any of those site visits, South Coast AQMD has periodically met with DTSC to discuss various cleanup sites. Staff will continue to conduct inspections as necessary until the project is completed.

Below is a listing of the most recent issuance of Notices of Violation at the Exide plant.

Exide Technologies, Inc.
Notices of Violation
May 13, 2015 - May 1, 2022

(Arranged Chronologically by Date of Violation)

NOV NO.

DATE OF VIOLATION

DATE OF ISSUANCE

VIOLATION DESCRIPTION

 P74764

 February 4, 2022

March 11, 2022 

Failure to operate a Title V facility in compliance with all terms, requirements, and conditions specified in the Title V permit: Failure to maintain a negative pressure of at least 0.011 inches of water column within the enclosure.

P74763 

 November 12, 2021

 March 11, 2022

Failure to operate a Title V facility in compliance with all terms, requirements, and conditions specified in the Title V permit: Failure to conduct real-time PM10 monitoring during deconstruction/demolition activity.

 P74762

October 25, 2021 

 March 11, 2022

Failure to operate a Title V facility in compliance with all terms, requirements, and conditions specified in the Title V permit: Failure to continuously collect Triboflow data, and to maintain negative pressure of at least 0.011 inches of water column within the enclosure.

P64600

 November 30, 2020

April 2, 2021

Failure to calculate lead and arsenic concentrations for samples collected on 11/30/2020 within 15 days end of month.  Failure to retain lead and arsenic samples for one year and provide upon request. Failure to comply with TV permit requirements.

P64592

May 24, 2020

June 25, 2020

Operating contrary to Rule 1420.1 Compliance Plan; Failure to Comply with R1420.1 Compliance Plan; Failure to Report Breakdown in a timely manner; Failure to comply with Title V Permit regarding breakdowns.

P64588

December 26, 2019 

December 27, 2019 

Failure to vent entire gas stream which may contain lead or arsenic to appropriate South Coast AQMD permitted control device; Failure to maintain negative pressure for total enclosure of at least 0.011 inches of H2O.

 P66712

February 17, 2019 

March 15, 2019 

Failure to vent entire gas stream which may contain lead or arsenic to appropriate South Coast AQMD permitted control device; Failure to maintain negative pressure for total enclosure of at least 0.011 inches of H2O.

 P63309

 April 16, 2018

May 31, 2018 

Failure to notify South Coast AQMD of cleaning of a vehicle outside of the truck wash station at least one hour prior to the cleaning.

P64561

June 23, 2016 

 October 15, 2016

Operating contrary to Rule 1420 Compliance Plan; Failure to contact South Coast AQMD within 4 hours of discovery or reasonable time of discovery of breakdown; Failure to continuously record wind speed and direction data during sampling periods using approved equipment.

 P63305

 July 4, 2015

 July 22, 2015

Operating a digital differential pressure monitoring system serving the enclosure building that failed to measure and display the negative pressure in the range with a minimum increment of measurement.

P63305

July 4-7, 2015

July 22, 2015

Failure to measure and display the negative pressure in the range with a minimum increment of measurement of plus or minus 0.001 mmHg (0.0005 inches H2O) on the digital differential pressure monitoring system serving the Total Enclosure Building.

Failure to make readily accessible the recorded data from the digital differential pressure monitoring system serving the Total Enclosure Building equipped with an electronic recorder upon request of the South Coast AQMD Executive Officer.

P49175

June 11, 2015

July 22, 2015

Failing to vacuum lead pieces immediately after they were removed from kettles and prior to being removed from the Refinery building in accordance with Mitigation Plan Ex-101 submitted by Exide, reviewed and approved by the South Coast AQMD

P63301

April 28, 2015

June 18, 2015

Failure to comply with the January 14, 2015, Order for Abatement issued by South Coast AQMD Hearing Board by failing to comply with Condition nos. 2 and 3 of Permit to Operate no. G33129 and Mitigation Plan nos. 2 and Ex-72 while operating the lead abatement/HEPA dust collector.
Failure to comply with Mitigation Plan nos. 2 and Ex-72.

Failure to follow process described in Section 6b of the Risk Reduction Measures
Failure to vacuum work area (floors) with equipped and working HEPA filters in accordance with Mitigation Plan No. 2.
Failure to vacuum work area (floors) with equipped and working HEPA filter in accordance with Mitigation Plan Ex-72.

P63302

May 31, 2014

June 1, 2015

June 18, 2015

Failure to collect twenty-four (24) hour lead and arsenic samples at the Railyard Sampler.

Failure to report to 1-800-CUT-SMOG within two (2) hrs of knowing that a 24-hour, midnight-to-midnight, sample had not been collected due to malfunction / breakdown.
Failure to operate and maintain the Railyard Sampler in accordance with US-EPA reference methods

Failure to report the Railyard Sampler malfunction / breakdown to 1-800-CUT-SMOG

Failure to comply with Exide’s Rule 1420 Compliance Plan, Condition no. 22; 

Operating contrary to Condition no. 22 of Exide’s Rule 1420 Compliance Plan, Application no. 481923.

P63303

May 13-18, 2015

June 18, 2015

Failure to continuously record wind speed and direction data at all times using equipment approved by the Executive Officer of the South Coast AQMD.

Failure to comply with Condition no. 22 of Exide’s Rule 1420 Compliance Plan, Application no. 481923.

Failure to report to 1-800-CUT-SMOG within two (2) hrs of knowing that a malfunction / breakdown had occurred at the approved wind anemometer.

Operating contrary to Condition no. 22 of Exide’s Rule 1420 Compliance Plan, Application no. 481923



Residential Cleanup
Notices of Violation
February 25, 2020 - March 3, 2020

(Arranged Chronology by Date of Violation)

DATE OF VIOLATION

NOV
NO.

FACILITY
NAME

VIOLATION DESCRIPTION

July 29, 2020

P74318 

AMERICAN 
INTEGRATED
SERVICES, INC.

Failure to remove track out each day using a vacuum equipped with a filter(s) rated by the manufacturer to achieve a 99.97% capture efficiency for 0.3 micron particles, failure to remove all track out from an active operation at the conclusion of each day

July 29, 2020

P74317 

NATIONAL
ENGINEERING
CONSULTING
GROUP LLC

Failure to remove track out each day using a vacuum equipped with a filter(s) rated by the manufacturer to achieve a 99.97% capture efficiency for 0.3 micron particles, failure to remove all track out from an active operation at the conclusion of each day

March 3, 2020

P70276

NATIONAL
ENGINEERING
CONSULTING
GROUP LLC

Failure to adequately wet the job site and at frequencies to prevent fugitive dust emissions; failure to apply a dust suppressant prior to loading; fugitive dust crossing the property line; failure to implement BACM.

March 3, 2020

P70277

AMERICAN
INTEGRATED
SERVICES, INC.

Failure to adequately wet the job site and at frequencies to prevent fugitive dust emissions; failure to apply a dust suppressant prior to loading; fugitive dust crossing the property line; failure to implement BACM.

March 3, 2020

P70278 

PARSONS
CORPORATION

Track-out observed at this site that extended beyond 25 feet of the property line, and which was also in excess of 25 cumulative feet.

March 3, 2020

P70279

INNOVATIVE
CONSTRUCTION
SOLUTIONS

Track-out observed at this site that extended beyond 25 feet of the property line, and which was also in excess of 25 cumulative feet.

March 3, 2020

P70280

NRC
ENVIRONMENTAL
SERVICES INC

Track-out observed at this site that extended beyond 25 feet of the property line, and which was also in excess of 25 cumulative feet.

February 25, 2020

P70274

NATIONAL
ENGINEERING
CONSULTING
GROUP LLC

Allowing fugitive dust to cross the property line; allowing Track-out in excess of 25 cumulative feet; failure to implement BACM, listed in Table 1 of South Coast AQMD Rule 403.

February 25, 2020

P70275

AMERICAN
INTEGRATED
SERVICES, INC.

Allowing fugitive dust to cross the property line; allowing Track-out in excess of 25 cumulative feet; and failure to implement BACM, listed in Table 1 of South Coast AQMD Rule 403.

February 25, 2020

P70287

NATIONAL
ENGINEERING
CONSULTING
GROUP LLC

Track-out observed at this site that extended beyond 25 feet of the property line; allowing Track-out at this site to extend more than 25 feet in cumulative length.

February 25, 2020

P70288

AMERICAN
INTEGRATED
SERVICES, INC.

Track-out observed at this site that extended beyond 25 feet of the property line; allowing Track-out at this site to extend more than 25 feet in cumulative length.

To see a listing of NOVs issued to Exide prior to these dates: Prior NOVs

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Historical Compliance Information

Exide, on August 30, 2013, notified South Coast AQMD of a breakdown involving the shutdown of the Blast Furnace due to a water leak.  An inspector was on-site at the time of the breakdown and conducted an immediate investigation.  Emissions from that  building are vented to baghouses, which were in operation during the breakdown.

On August 25, 2013 Exide notified South Coast AQMD of a breakdown involving the shutdown of the Kiln baghouse blower motor for fifteen (15) minutes for replacement of the blower motor guard.  The Kiln is the dryer for the feed for the Reverberatory Furnace.  An inspector was dispatched to investigate the breakdown. Exide had ceased feeding materials to the Kiln dryer while the blower motor guard was replaced.  The Kiln baghouse blower motor was down for approximately twenty-five (25) minutes.

On August 9, 2013 Exide notified South Coast AQMD of a breakdown involving the shutdown of the blower motor for the East MAC baghouse for one (1) to two (2) hours for repair.  The East MAC baghouse controls emissions from the Reverberatory Furnace feed storage room, the Raw Materials Processing System (RMPS) room and the refining kettle burner chambers.  An inspector was dispatched to investigate the breakdown and determined that the blower motor was down for repairs for approximately 1½ hours.  Emissions from these operations were collected by the South and North Torit baghouses that ventilate the storage room, RMPS room and kettle burner chambers. 

Exide notified South Coast AQMD that on August 3, 2013 the facility had started the reheat process of the Blast Furnace which was previously shut down on July 23, 2013.  

Exide notified South Coast AQMD on August 1, 2013 that the facility had started the reheat process of the Reverberatory Furnace which was previously shut down on July 23, 2013. 

Exide notified South Coast AQMD that on July 29, 2013 a faulty solenoid in a blower motor resulted in the shutdown of a dust collector, which resumed operation in about 45 minutes.  This equipment collects air from the smelting building and provides negative pressure to the building.  No smelting or refining activities were occurring during this breakdown.  An inspector was dispatched to investigate.

Exide notified South Coast AQMD on July 23, 2013 that two furnaces and associated refining pots were shut down because they were close to the permit requirement that limits carbon monoxide emissions in each 30-day period.  Limited operations resumed on August 1, 2013.  South Coast AQMD inspectors continue to monitor the facility frequently.

On Sunday, July 7, 2013 at 7:33 am, Exide staff notified South Coast AQMD by phone that they were “taking the North MAC Baghouse down for repairs”. The North MAC Baghouse (also known as the West MAC Baghouse) and the associated East MAC Baghouse reduce emissions from the reverberatory furnace feed rooms, the interconnecting corridor between the reverberatory and blast furnace feed rooms, and refining kettle burner ventilation.

An South Coast AQMD inspector arrived on scene at 10:45 am to initiate an investigation. South Coast AQMD staff’s inspection of the interior of the West MAC Baghouse established that a majority of the bags were damaged due to excessive heat. The East MAC Baghouse was not in operation.  Exide temporarily shut down portions of their operation that vented to these baghouses but resumed operations of the East MAC baghouse on the morning of July 8th. South Coast AQMD permit conditions require that both of these baghouses be in operation when the equipment they serve is in use.  South Coast AQMD issued a Notice of Violation to Exide on July 9th for failing to comply with the requirements of this permit condition when they resumed operations with only the East MAC Baghouse in operation.  On July 9th, Exide shut down operations until the baghouse was repaired.  Once repaired and tested, operations resumed at Exide and they were in full operation by the morning of July 15th.

Exide notified South Coast AQMD and others about major planned maintenance activities that will last approximately 3 weeks, beginning March 14, 2014. Work will be done on the reverb and blast furnaces, baghouses, and the battery breaker system, and will include shutting down various equipment and the associated air pollution control systems. Exide reports that this work is being done to ensure continued regulatory compliance and reliable operations. The work includes approximately 10 hours of plant-wide power outage during the day on March 27, 2014. (Also during the shutdown period, Exide intends to add the secondary control HEPA filtration systems to the Hard and Soft Lead Baghouses, add the two new HEPA canister vacuums and replace the two ram feeders with feed screw conveyors on the Reverberatory Furnace, for which South Coast AQMD issued Permits to Construct to Exide on March 14, 2014.)

On March 29, 2014, South Coast AQMD staff sent a letter to Exide (PDF, 178kb) to put Exide on notice regarding recent multiple days violations of Rule 1420.1 for high ambient lead levels measured around Exide due to Exide's activities.

Exide submitted a Maintenance Mitigation Plan (PDF, 1MB) to South Coast AQMD staff on April 10, 2014 that described the remaining and additional maintenance activities that would occur at the facility and measures that Exide would put in place to reduce emissions. On April 12, 2014, South Coast AQMD staff responded (PDF, 252kb) to the Maintenance Mitigation Plan and also addressed a proposed requested change to their refining operations. South Coast AQMD staff informed Exide that the mitigation monitoring measures proposed were insufficient and that because there have been repeated, consecutive, exceedances of the ambient lead monitoring limit in Rule 1420.1 (d)(2), that any daily readings of lead above 0.15 mg/m3 that contribute to a violation of the 30-day rolling average ambient lead limit would be considered knowing, willful and intentional violations. Exide has decided to temporarily suspend maintenance activities at this time and will submit a revised mitigation plan.

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Toxic Hot Spots Activities

Health Risk Assessment and Risk Reduction Plan

The facility was required to prepare a health risk assessment (HRA) per the requirements of Air Toxics “Hot Spots” Information and Assessment Act (or AB 2588)Link to external website.. The South Coast AQMD approved Exide’s HRA on March 1, 2013 and the facility is subject to the public notification requirements of AB 2588 and the risk reduction requirements of South Coast AQMD Rule 1402 (PDF). Links to documents related to the HRA are below.

Exide submitted a draft Risk Reduction Plan on August 28, 2013 to comply with South Coast AQMD Rule 1402, and staff reviewed.  Rule 1402(g)(1) provides up to three (3) months for the South Coast AQMD staff to review and approve (or reject) the draft Risk Reduction Plan.  Due to community interest, the South Coast AQMD staff has made the draft Risk Reduction Plan available and can be accessed through the link below. On October 24, 2013, South Coast AQMD rejected Exide's submitted Risk Reduction Plan as being inadequate to ensure the required risk reductions.  Exide submitted an Amended Revised Risk Reduction Plan on January 17, 2014 and the South Coast AQMD responded in a letter dated February 12, 2014.

Exide submitted their Final Risk Reduction Plan on March 4, 2104 to address South Coast AQMD staff comments. The latest revised plan was reviewed and approved by South Coast AQMD staff on March 19, 2014.

Nine community meetings were held in late May and June. See Prior Meetings for meeting details, copies of presentations, and other information.

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