APPENDIX F

Contingency Measure Compliance

 Exide Technologies’ Contingency Measure Compliance Plans Report

 Exide Technologies’ Hi-Volume Air Inspection Form

 

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CONTINGENCY MEASURE COMPLIANCE PLANS 

Exide Technologies, Salina, Kansas

SUMMARY 

These compliance plans are being submitted by Exide Technologies (Exide) to the Kansas 

Department of Health and Environment (KDHE) as required by Section XI of Air Emission Source 

Construction Permit (Source ID No. 1690035) [the “permit”] issued on August 18, 2014. These 

plans, which propose contingency measures to reduce the impact of lead emissions from 

Exide’s battery manufacturing facility in Salina, Kansas, are to be implemented in accordance 

with Section XII of the permit in the event that data from KDHE’s ambient monitor, located just 

north of the facility, shows an exceedance of the 2008 National Ambient Air Quality Standards 

(NAAQS) for lead based on a rolling 3-month average for any 3-month period beginning after 

July 31, 2014. 

BACKGROUND 

In 2008, USEPA revised the NAAQS ambient standard for lead, reducing it from 1.5 ug/m3 to 

0.15 ug/m3. Subsequently, it was determined, based on monitoring data, that the area around 

Exide’s plant in Salina, Kansas was not attaining the new standard. KDHE, with the assistance of 

Exide, determined a set of emission-reducing countermeasures to be implemented by Exide to 

bring the area back into attainment. These changes consisted of replacing a baghouse, raising 

stacks, improving fugitive capture inside buildings, and paving a large section of roadway at the 

plant site. Dispersion modeling provided by Exide indicated that the area would be in 

attainment with the 2008 lead standard upon implementation of these modifications. These 

changes were completed as of July 31, 2014. 

On August 18, 2014 KDHE issued an Air Emission Source Construction Permit requiring Exide to 

develop compliance plans for contingency measures to be implemented in the event that the 

monitoring data shows nonattainment after the above-described changes have been made. As 

described in Section XI of the permit, these plans are to include: 

A. An analysis of site conditions and operations that potentially may impact, directly or 

indirectly, KDHE ambient air monitors. The analysis shall include, but not be limited to: a 

description of the site's root cause analysis and corrective/preventive action process as 

it relates to attaining and maintaining the 0.15 ug/m3

 standard; potential improvements 

to work practices or procedures; possible modifications to operating conditions or 

controls; ideas for optimization of plant logistics; possible improvements to 

startup/shutdown procedures and preventive maintenance; and any other 
 

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improvements that may become evident based on identified potential sources of lead 

emissions. Each measure identified in the analysis shall be assigned an implementation 

timeline and may be ranked with respect to ease of implementation, cost, and 

effectiveness. 

B. A fugitive dust control plan for the site that shall include an implementation timeline for 

each measure. The plan may include, but not be limited to, the following: new 

enclosures, total enclosures with negative pressure (not already existing) and/or 

improvements to existing negative pressure enclosures; regular, periodic inspections of 

plant buildings, material handling and storage areas, plant roadways, groundcover 

conditions, etc.; accidental release measures- preventive and corrective; roadway 

treatment- paving, cleaning; vehicular traffic -logistics, control; work practices for 

minimizing fugitive dust emissions during maintenance activities; and countermeasures 

during periods of adverse meteorological conditions and/or agricultural conditions and 

practices on grounds surrounding the plant that may affect fugitive dust impact on 

KDHE ambient air monitors. 

C. Identification and prioritization of measures, as developed per paragraphs A. and B. of 

this section, that shall be implemented immediately upon notification by KDHE of the 

first Lead NAAQS violation. Also included shall be a contingent list of measures (e.g., 

projects, procedures, etc.), as developed per paragraphs A. and B. of this section, that 

shall be implemented upon notification by KDHE of any subsequent Lead NAAQS 

violations. The contingent list of measures may be modified upon approval by KDHE of 

more effective measures identified by the root cause analysis conducted by Exide in 

accordance with Table II in Section XII of this permit. 

These requirements are addressed in the following sections. 

ANALYSIS OF SITE CONDITIONS AND OPERATIONS 

Upon completion of the previously agreed-upon modifications, a thorough review of the plant 

site’s operations was performed to determine any remaining potential changes or work 

practices that could be implemented if the monitoring indicates that additional reductions are 

needed. This review included analysis of the dispersion modeling that was submitted as part of 

KDHE’s nonattainment implementation plan. Specifically, the analysis included identifying the 

impact of the various sources at the plant on the highest-impacted receptor. Additionally, 

analysis of recent monitoring data along with accompanying meteorological data was 

performed to ascertain the areas of the plant most likely creating the largest impacts. Finally, a 

site visit and inspection was performed by a consultant, ENVIRON International Corporation, to 
 

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capture any previously unidentified potential sources and to discuss operations that might 

impact ambient lead concentrations. 

Based on this analysis, several potential improvements were identified that could be 

implemented as supplemental measures. Some of these changes will be implemented 

immediately, while others will be implemented upon notification by KDHE of a Lead NAAQS 

violation, if the root cause analysis required by the permit deems them appropriate. 

Measures to be implemented immediately 

Air Inspection Program – 

Exide has implemented a formal procedure for inspecting and recording information regarding 

lead emitting operations whenever a daily reading of 0.12 ug/m3 or greater is recorded at either 

of Exide’s voluntary ambient lead monitors. A copy of a sample logsheet that will be used for 

this purpose is attached. This logsheet will allow Exide to more effectively determine the root 

cause of any such elevated monitor readings. Specifically, the air inspection will include 

recording wind speed and direction for the day(s) in question, as well as recording any unusual 

maintenance or upset conditions at the site. 

Ball Mill Negative Pressure Measurements 

The Ball Mill building has a manometer that measures the differential pressure between the 

interior and exterior of the building. This allows Exide to verify that the Ball Mill building is 

under sufficient negative pressure to prevent fugitive emissions from escaping the building 

through doorways and other openings. Exide currently takes readings of the pressure on a 

regular basis when the doorway to the Ball Mill is open. However, additional measurements 

will be taken as part of the Air Inspection Program mentioned above in response to any lead 

monitor readings in excess of 0.12 ug/m3

. The doorway will be opened during this reading to 

simulate the worst case operating conditions. 

Potential Measures for implementation in response to root cause analysis 

Route melt pot combustion stacks to a baghouse 

The gases from these stacks do not normally contain lead because the melt pots are indirectly 

fired. However, there is some potential for minor amounts of lead to enter these exhaust 

streams as a result of a malfunction. If the root-cause analysis indicates that these types of 

malfunctions are more prevalent than initially believed, the exhausts could be collectively 

routed to either an existing or new baghouse. 

Enclose baghouse hoppers 
 

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Maintenance of the baghouse hoppers and the dust transporting equipment presents an 

opportunity for lead dust to be entrained and carried off-site. If the root-cause analysis 

indicates that this is a significant source, the area around the hoppers could be enclosed to 

prevent this. 

Additional ventilation of Ball Mill 

If the root-cause analysis indicates that dust may be leaking from the buildingwhen doors are 

left open, additional ventilation could be provided to increase the inward velocity at all 

openings. This additional ventilation could be in the form of ducting to an existing baghouse or 

the installation of a new baghouse. 

FUGITIVE DUST CONTROL PLAN 

This fugitive dust control plan includes measures that will be taken immediately, as well as 

other potential measures that can be considered in the event of a future NAAQS exceedance. 

Fugitive Dust Control Measures that will be implemented immediately 

Silt Load Sampling 

As required by the permit, the silt load on the delivery roads will be sampled and analyzed 

within 6 months of issuance of the permit. The results of these silt load measurements will be 

used to re-estimate the lead emissions from the roadways and compared with the original 

analysis used in the SIP demonstration model. The results of this comparison will be taken into 

account during any future root cause analysis performed in response to an exceedance of the 

NAAQS. 

Potential Measures that may be implemented in response to root cause analysis 

Cover/enclose oxide delivery area 

In addition to producing oxide in the Oxide Mill, Exide also receives some additional oxide by 

truck. Delivery trucks offload the oxide by hooking up to one of the delivery ports to the south 

of the Ball Mill building. The oxide is then pneumatically conveyed into the building where it is 

stored. This area could be covered or enclosed to restrict the potential for entrainment of 

fugitive lead released during deliveries. 

Add groundcover and/or other landscaping to unpaved areas 

Exide will consider the addition of groundcover in unpaved areas where there is no traffic. This 

will reduce the potential for fugitive dust from these areas. 

Road cleaning or wetting 
 

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If the silt load sampling performed as required by the permit and the results of root-cause 

analyses indicate that the roadways are a significant contributor to the overall lead impact from 

the plant, Exide will study the various options available for implementing a program of regular 

and periodic road cleaning and/or wetting. Depending on the results of this analysis and 

potential for reduced offsite impact, Exide may implement one or more of these options. 

IDENTIFICATION AND PRIORITIZATION OF MEASURES 

The following table presents the proposed changes that could be implemented upon 

notification of a Lead NAAQS exceedance by KDHE. This table also identifies their approximate 

timelines, relative ease of implementation, cost, and effectiveness. 

Potential Measure 

Implementation 

Timeline 

Ease of 

Implementation Relative Cost Effectiveness 

Reroute Oxide 

combustion stacks to 

designated baghouse. If 

available CFM or 

additional baghouse may 

be required

18 months to 3 

years

Difficult (requires 

some downtime 

along with KDHE 

Permitting)

High Medium/High

Enclose baghouse 

hoppers 18 to 24 months Medium difficulty High Medium/High

Additional ventilation of 

Ball Mill/Oxide Mill bldgs

18 months to 3 

years

Difficult (requires 

some downtime 

along with KDHE 

Permitting)

High Medium/High

Truck enclosure for oxide 

delivery/unload area

18 months to 3 

years

Difficult (requires 

some downtime 

along with KDHE 

Permitting)

High Medium/High

Add ground cover and 

landscaping 12 to 18 months Relatively easy Medium Low

Evaluation depending on 

silt sampling to determine 

cleaning. The evaluation 

will be made within 6 

months of the completed 

paved project. 

12 to 18 months Relatively easy Medium Low/Medium

As required by Section XII of the permit, Exide will implement a root cause analysis in response 

to any nonattainment measurements at the state’s monitor. Depending on the results of this 

analysis, the supplemental measures described above will be considered based on their 

potential to target the root cause of the exceedance. 

The following steps will be taken as part of the root cause analysis: 

1. Analyzing Air Inspection Logsheets 
 

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2. Identify likely sources and potential countermeasures 

3. Estimate the effect of countermeasures on emissions and rerun dispersion model with 

proposed changes, if appropriate 

4. Provide results of root cause analysis and proposed measures to KDHE 
Yes No

inwc

Yes No

Yes No

Yes No

Yes No

EXIDE 

Technologies 

Salina, Kansas Facility

Hi-Volume Air Inspection Form ENV 161

Approved by: EHS Manager Issued by: EHS Manager 8/14/2014 Revision: Two 10/15/14 Page (1 of 1)

Instructions: This inspection form shall be used in the event of a Hi-Vol result above 0.12 for any given sample 

day. This inspection shall be completed within 72 hours of receiving lab results. The following items listed 

below shall be taken under consideration while performing the inspection. Inspection form shall be kept on site 

for a minimum of two years.

Name: Date:

Weather Data (weatherunderground.com) Data Data

Wind Direction Wind Maximum Gust

Wind Speed Average Temperature

Wind Maximum Speed Average Barometric Pressure

Weather Variables (Rain Snow):

Facility Doors / Environmental Variable 

Facility Doors to outside open? (If yes which ones? Readings?)

Open Doors and Readings:

Maintenance Work / Environmental Variable 

Maintenance work outside? (If yes explain who, what, when, where, why)

Work being performed:

Oxide Delivery

Facility Projects / Environmental Variable 

Facility events being performed? (If yes explain below)

Work being performed:

Was oxide delivered by truck? (If yes explain below)

Describe delivery schedule and note if there were any mishaps (spills)

Other / Environmental Variable 

Any other contributing factors:

Production / Operations Performance (Changes in process, material, production goals, etc.)

Ball Mill Building Negative Pressure Reading

Comments:

Ball Mill manometer reading at West dock door with door open
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