# APPENDIX F

Contingency Measure Compliance

 Exide Technologies ’ Contingency Measure Compliance Plans Report

 Exide Technologies ’ Hi

- Volume Air Inspection FormSalina, KS October 17, 2014

1 

## 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 requ ired by Section XI of Air Emission Source Construction Permit (Source ID No. 1690035) [the “p ermit”] 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, K ansas, are to be implemented in accordance with Section XII of the permit in the event that da ta from KDHE’s ambient monitor, located just north of the facility, shows an exceedance of the 2 008 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 f or lead, reducing it from 1.5 ug/m 3 to 0.15 ug/m 3 . Subsequently, it was determined, based on monito ring data, that the area around Exide’s plant in Salina, Kansas was not attaining t he new standard. KDHE, with the assistance of Exide, determined a set of emission-reducing counte rmeasures 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 impleme ntation of these modifications. These changes were completed as of July 31, 2014.
On August 18, 2014 KDHE issued an Air Emission Sour ce Construction Permit requiring Exide to develop compliance plans for contingency measures t o 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 c orrective/preventive action process as it relates to attaining and maintaining the 0.15 ug /m 3 standard; potential improvements to work practices or procedures; possible modificat ions to operating conditions or controls; ideas for optimization of plant logistics ; possible improvements to startup/shutdown procedures and preventive maintena nce; and any otherSalina, KS October 17, 2014

2 improvements that may become evident based on ident ified 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 shal l include an implementation timeline for each measure. The plan may include, but not be limi ted to, the following: new enclosures, total enclosures with negative pressure (not already existing) and/or improvements to existing negative pressure enclosur es; regular, periodic inspections of plant buildings, material handling and storage area s, plant roadways, groundcover conditions, etc.; accidental release measures- prev entive and corrective; roadway treatment- paving, cleaning; vehicular traffic -log istics, control; work practices for minimizing fugitive dust emissions during maintenan ce 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 d eveloped 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 parag raphs A. and B. of this section, that shall be implemented upon notification by KDHE of a ny subsequent Lead NAAQS violations. The contingent list of measures may be modified upon approval by KDHE of more effective measures identified by the root caus e analysis conducted by Exide in accordance with Table II in Section XII of this per mit. These requirements are addressed in the following s ections.

**ANALYSIS OF SITE CONDITIONS AND OPERATIONS**
Upon completion of the previously agreed-upon modif ications, a thorough review of the plant site’s operations was performed to determine any re maining potential changes or work practices that could be implemented if the monitori ng indicates that additional reductions are needed. This review included analysis of the dispe rsion modeling that was submitted as part of KDHE’s nonattainment implementation plan. Specifi cally, the analysis included identifying the impact of the various sources at the plant on the h ighest-impacted receptor. Additionally, analysis of recent monitoring data along with accom panying 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 consul tant, ENVIRON International Corporation, toSalina, KS October 17, 2014

3 capture any previously unidentified potential sourc es and to discuss operations that might impact ambient lead concentrations.
Based on this analysis, several potential improveme nts were identified that could be implemented as supplemental measures. Some of thes e 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 t he permit deems them appropriate.
Measures to be implemented immediately
Air Inspection Program – Exide has implemented a formal procedure for inspec ting and recording information regarding lead emitting operations whenever a daily reading o f 0.12 ug/m 3 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. Speci fically, the air inspection will include recording wind speed and direction for the day(s) i n 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 measure s 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 fugit ive emissions from escaping the building through doorways and other openings. Exide current ly 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/m 3 . The doorway will be opened during this reading to simulate the worst case operating conditions.
Potential Measures for implementation in response t o 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 beli eved, the exhausts could be collectively routed to either an existing or new baghouse.
Enclose baghouse hoppersSalina, KS October 17, 2014

4 Maintenance of the baghouse hoppers and the dust tr ansporting equipment presents an opportunity for lead dust to be entrained and carri ed off-site. If the root-cause analysis indicates that this is a significant source, the ar ea 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 t hat 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 impleme nted immediately
Silt Load Sampling
As required by the permit, the silt load on the del ivery roads will be sampled and analyzed within 6 months of issuance of the permit. The res ults of these silt load measurements will be used to re-estimate the lead emissions from the roa dways 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 perfo rmed in response to an exceedance of the NAAQS.
Potential Measures that may be implemented in respo nse to root cause analysis Cover/enclose oxide delivery area
In addition to producing oxide in the Oxide Mill, E xide also receives some additional oxide by truck. Delivery trucks offload the oxide by hookin g up to one of the delivery ports to the south of the Ball Mill building. The oxide is then pneum atically 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 th ese areas. Road cleaning or wettingSalina, KS October 17, 2014

5 If the silt load sampling performed as required by the permit and the results of root-cause analyses indicate that the roadways are a significa nt contributor to the overall lead impact from the plant, Exide will study the various options ava ilable for implementing a program of regular and periodic road cleaning and/or wetting. Dependi ng on the results of this analysis and potential for reduced offsite impact, Exide may imp lement one or more of these options.

**IDENTIFICATION AND PRIORITIZATION OF MEASURES** The following table presents the proposed changes t hat could be implemented upon notification of a Lead NAAQS exceedance by KDHE. T his table also identifies their approximate timelines, relative ease of implementation, cost, a nd 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 wil l implement a root cause analysis in response to any nonattainment measurements at the state’s mo nitor. 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 exceedanc e. The following steps will be taken as part of the ro ot cause analysis:

1. Analyzing Air Inspection LogsheetsSalina, KS October 17, 2014

6 2. Identify likely sources and potential countermeasur es

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 KDHEYes 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 i n the event of a Hi-Vol result above 0.12 for any g iven sample day. This inspection shall be completed within 72 h ours of receiving lab results. The following items listed below shall be taken under consideration while perf orming the inspection. Inspection form shall be ke pt 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 be low)

Work being performed:

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

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

Other / Environmental Variable

Any other contributing factors:

Production / Operations Performance (Changes in pro cess, material, production goals, etc.) Ball Mill Building Negative Pressure Reading

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