Recent Permitting Activity - SCAQMD
On December 5, 2014, the SCAQMD 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, SCAQMD 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 SCAQMD 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. SCAQMD 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 SCAQMD 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 SCAQMD 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 SCAQMD 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 SCAQMD 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.
SCAQMD 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
Exide notified SCAQMD 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 SCAQMD issued Permits to Construct to Exide on March 14, 2014.)
On March 29, 2014, SCAQMD 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 SCAQMD 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, SCAQMD staff responded (PDF, 252kb) to the Maintenance Mitigation Plan and also addressed a proposed requested change to their refining operations. SCAQMD 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.
Below is a listing of the most recent issuance of Notices of Violation at the Exide plant.
Exide Technologies, Inc.
C U R R E N T A C T I O N S
May 13 through July 22, 2015
(Arranged Chronology by Date of Violation)
NOTICE OF VIOLATION NO.
DATE OF VIOLATION
DATE OF ISSUANCE
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 SCAQMD Executive Officer.
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 SCAQMD
April 28, 2015
June 18, 2015
Failure to comply with the January 14, 2015, Order for Abatement issued by SCAQMD 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.
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.
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 SCAQMD.
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
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 SCAQMD 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 SCAQMD 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 SCAQMD 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 SCAQMD 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 SCAQMD 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 SCAQMD 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 SCAQMD 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. SCAQMD inspectors continue to monitor the facility frequently.
On Sunday, July 7, 2013 at 7:33 am, Exide staff notified SCAQMD 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 SCAQMD inspector arrived on scene at 10:45 am to initiate an investigation. SCAQMD 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. SCAQMD permit conditions require that both of these baghouses be in operation when the equipment they serve is in use. SCAQMD 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.
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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). The SCAQMD 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 SCAQMD 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 SCAQMD Rule 1402, and staff reviewed. Rule 1402(g)(1) provides up to three (3) months for the SCAQMD staff to review and approve (or reject) the draft Risk Reduction Plan. Due to community interest, the SCAQMD staff has made the draft Risk Reduction Plan available and can be accessed through the link below. On October 24, 2013, SCAQMD 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 SCAQMD responded in a letter dated February 12, 2014.
Exide submitted their Final Risk Reduction Plan on March 4, 2104 to address SCAQMD staff comments. The latest revised plan was reviewed and approved by SCAQMD staff on March 19, 2014.
- SCAQMD Staff's Approval of Final Risk Reduction Plan, March 19, 2014 (PDF, 447kb)
- Exide's Final Risk Reduction Plan, March 4, 2014 (PDF, 8MB)
- SCAQMD's Response to Exide's Amended Revised Risk Reduction Plan, February 12, 2014 (PDF, 460kb)
- Exide Amended Revised Risk Reduction Plan, January 2014 (PDF, 8MB)
- SCAQMD Rejection of Exide's Risk Reduction Plan - October 24, 2013 (PDF, 533kb)
- Exide Draft Risk Reduction Plan (PDF, 9MB)
- SCAQMD Letter to Exide, May 17, 2013 (PDF, 252kb)
- SCAQMD Approval of HRA, March 1, 2013 (PDF, 5MB)
- Exide HRA (PDF, 12MB)
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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