# APPENDIX B

Exide ’ s 2011 and 2013 Project Update DocumentsSalina Project Response 10/03/2013 Exide EHS

Date October 16, 2013 KDHE Onsite Visit Salina, KS

Statuses of all projects completed or in process ar e listed below. Each project includes the date(s) each project is finished or anticipated completed d ate. All of the baghouse dates are the actual start up dates and stack test dates. The diverter valves and ball mill dates are the dates the CER’s

were closed out.

Oxide Mill #7 – Completed on 01/30/11 (stack test d ate 03/17/11) Oxide Mill #8 – Completed on 02/03/11 (stack test d ate 05/05/11)

This capital project is designed to install two new Eagle/Linklater M1500 Oxide Reactors with automated controls for the oxide operations in Sali na, KS. This project is phase four of five with the replacement of existing oxide mills 7 & 8. Wit h the completion of phases one and two (oxide mills 1-4), we have seen a significant process impr ovement for lead in air. This is an EHScategory project required to improve our air qualit y in our oxide manufacturing process to help

reduce our lead in air to the Lowest Feasible Limit s (LFL).

Oxide Mill #9 – Completed on 03/24/11 (stack test d ate 05/06/11) Oxide Mill #10 – Completed on 03/24/11 (stack test date 05/05-06/11)

This capital project is designed to install two new Eagle/Linklater M1500 Oxide Reactors with automated controls for the oxide operations in Sali na, KS. This project is phase five of five with the replacement of existing oxide mills 9 & 10. The automatic controls & mechanical upgrades on reactors allows uniform control of both throughput & oxide particle classification (particle size). With the completion of all five phases, we have see n a significant process improvement for lead in air. This is an EHS-category project required t o improve our air quality in our oxide manufacturing process to help reduce our lead in ai r to the Lowest Feasible Limits (LFL).

Environmental baghouse #4 – Completed on 07/04/11 ( stack test date 08/10/11)

Project Summary Listed Below

This capital project is designed to replace our exi sting environmental baghouse #4 with a 120,000 ACFM Pulse-Jet Dust Collector system to ventilate s ix Pasting line stackers and four Oxide Mills in Salina, KS. This is an EHS-category project req uired to maintain air quality compliance required by recently released "National Emissions S tandards for Hazardous Air Pollutants (NESHAP)" standard for the Lead Acid Battery Manufa cturing industry and achieve compliance to the NAAQS level of .15 ug/m 3 effective January 1, 2010. The Salina facility co ntracted Bjerkan & Co. air ventilation engineers to determin e the best baghouse configuration and capacity requirements to adequately support the 4 O xide Mills & 6 pasting line stackers. They recommended installing a 120,000 ACFM Pulse-Jet sty le Dust Collector system. Installing a new baghouse will reduce overall lead emissions that we re modeled lead emissions in an effort to Project Summary Listed Below for Oxide Mills

Project Summary Listed BelowSalina Project Response 10/03/2013 Exide EHS

achieve compliance with the National Ambient Air Qu ality Standard (NAAQS) This is an EHScategory project required to maintain air quality c ompliance in light of the recently released

"National Emissions Standards for Hazardous Air Pol lutants (NESHAP)" standard for the Lead Acid Battery Manufacturing industry and achieve com pliance to the NAAQS level of .15 ug/m 3
effective January 1, 2010.

Environmental baghouse #5 – Completed on 05/25/12 ( stack test date 06/27/12)

Project Summary Listed Below

This capital project is designed to replace our exi sting environmental baghouse #5 with a 120,000 ACFM Pulse-Jet Dust Collector system to ventilate t he Metals, Past Mixing and 2 Assembly lines in Salina, KS. This is an EHS- category project re quired to maintain air quality compliance required by recently released "National Emissions S tandards for Hazardous Air Pollutants (NESHAP)" standard for the Lead Acid Battery Manufa cturing industry and achieve compliance to the NAAQS level of .15 ug/m3 effective January 1 , 2010.

The Salina facility contracted Bjerkan & Co. air ve ntilation engineers to determine the best Baghouse configuration and capacity requirements to adequately support the Metals, Past Mixing and 2 Assembly lines. They recommended installing a 120,000 ACFM Pulse-Jet style Dust Collector system. Installing a new baghouse will r educe overall lead emissions that were modeled lead emissions in an effort to achieve comp liance with the National Ambient Air Quality Standard (NAAQS) This is an EHS-category project r equired to maintain air quality compliance in light of the recently released "National Emissio ns Standards for Hazardous Air Pollutants (NESHAP)" standard for the Lead Acid Battery Manufa cturing industry and achieve compliance to the NAAQS level of .15 ug/m 3 effective January 1, 2010.

Relocation of oxide mill diverter valves – Complete d on 07/18/12

Project Summary Listed Below

This project is necessary to help the Salina Facili ty achieve the standards set forth in the

"National Emissions Standards for Hazardous Air Pol lutants (NESHAP)" standard for the Lead Acid Battery Manufacturing industry, achieve compli ance to the NAAQS level of .15 ug/m3 effective January 1, 2010 and was committed to the Kansas Department of Health and Environment in response to an escape issue that was experienced. With the completion of this project the Salina Faci lity will have a new Oxide delivery layout with an auxiliary set of valves installed in a parallel system along with making the building air tight in the areas where the highest potential of Oxide fugi tives escaping the Plant exist. This is one of 3 projects the Salina Facility has submitted to KDHE (Kansas Department of Health and Environment) as corrective action in order to help us stay in compliance with NAAQS level of .15 ug/m3 (the projects include the Ball Mill Venti lation and Bahouse #5 Replacement projects which are both approved.

Upgrade ball mill ventilation – Completed on 11/18/ 11

Project Summary Listed Below for Ball-Mill

The purpose of this Capital project is to help remo ve excessive heat that builds up in our Ball Mill manufacturing room. Currently the Ball Mill is unde r ventilated thus allowing the heat generated by the production and equipment in the mill to rais e the ambient temperature to a level intolerable by personnel, equipment and controls. The Ball Mill room has several exterior doors that could be opened to allow fresh cooler air into the mill howe ver we are not able to open them due to theSalina Project Response 10/03/2013 Exide EHS

possibility of lead Oxide escaping into the atmosph ere. This project will allow us to bring fresh

air in our Ball Mill room and evacuate some of the heat without any concerns of Oxide fugitives escaping the room. This project will also allow us to create a safer working environment for our employees.



### October 03, 2013 Response

Statuses of all projects completed or in process ar e listed below. Each project includes the date(s) each project is finished or anticipated completed date.

Project Title Action Anticipated or Completed Date(s) Baghouse (BH1) Replace baghouse and increase height to 80 feet per Salina’s

attainment demonstrated SIP plan 07/01/2013 – 02/15/2014

Baghouse (BH11- BH15), ball

mill stacks Increase stack heights by 37 feet demonstrated per Salina’s

attainment demonstrated SIP plan 07/08/2013 – 07/19/2013

Oxide Mill (OM1- OM10),

oxide mill stacks Manifold to new stack, 65 feet from ground level demonstrated per Salina’s

attainment demonstrated SIP plan 07/08/2013 – 10/01/2013

In-plant roadways Pave all internal roadways and parking lots subject to

vehicular traffic on the North West section per Salina’s

attainment demonstrated SIP plan. (Total area to be paved 15220 SQ. Yards). 07/01/2013 – 03/31/2014

Plant process fugitive control Establish negative pressure building ventilation and

maintain local exhaust ventilation at process points 09/21/2011

COMPLETED

Roadways:

Traffic on-site follows two primary routes which ha ve been designated the Delivery Route and the Shipping Route. Most delivery vehicles check in at the security building at the southwest corner of the property and proceed clockwise around the facility to drop off or pick up their delivery. This route is designated Delivery Route ( see Figure 2-1c). Trucks picking up batteries check in with security then proceed along Berg Road which is the southern boundary of the facility to the Eastern Distribution Center (DC) th en return along a similar route along Berg Road. This route is designated Shipping Route in th e model and is depicted on Figure 2-1d. Vehicular fugitive emissions were modeled as ground level adjacent volume sources. Volume source input parameters were calculated using the U SEPA’s recommended approach in Table 3-1 of USEPA 2004a and according to the guidance pr ovided in the USEPA’s Haul RoadSalina Project Response 10/03/2013 Exide EHS

Workgroup Final Report (USEPA, 2012b). Road fugitiv e volume sources were calculated using a vehicle height of 3 meters above grade level and a vehicle width of 3 meters. Sections passing along Berg Road along the southern boundary of the site were modeled using a twolane approach

with a road width of 6 meters. The model used a tot al of 144 volume sources on the Delivery Route and 82 volume sources on the Shipping Route. Delivery Route sources were included in source groups DELRD1, DELRD2, and volum e sources on the Shipping Route were included in model source groups called SHPRD1, SHPR D2, SHPRD3, and SHPRD4.

Several groups have been assigned to each route to separate two-lane from one-lane segments. Traffic fugitive emissions were quantified using th e Paved Roads section of Chapter 13.2.1 from AP-42 (USEPA 2011). The equations in AP-42 require site specific data including the fleet average vehicle weight and a silt loading value for Paved Roads. Site-specific silt and lead content sampling were completed for the Salina faci lity in 2012. A representative sample of silt and lead content from an area free from off-pavemen t dust tracking was used for these

parameters.

In order to achieve attainment, it is expected that lead-in-roadway silt loading will need to decrease. It is further expected that paving all un paved road sections would be an appropriate method of achieving the reduced silt load. The meas ures are aimed at reducing the silt load and

lead content to the levels similar to the dust load ing and lead content currently measured on the South WDC roadway (see Fig 2-1c). This area is cons idered representative of paved roadways with adequate silt control strategies in place. To capture the impact of the proposed changes, all roadways in this modeling exercise were modeled as paved (using AP-42 emission factors for Paved Roads) and assuming the silt load and the lea d content of the samples collected from South WDC. The currently projected implementation timing for this proposed change is provided in the

Table listed above.

The fleet average weight and vehicle activity (path length, and number of passes / year) were used to estimate annual emissions of TSP, and then the percentage of particulate measured to be

lead was used to estimate the annual lead emissions from each roadway segment. The total annual lead emissions were distributed evenly throughout t he day, and amongst each of the volumes representing the line source associated with each s egment of roadway. Details of the calculations are provided as attachment 1 in Salina’s Air Qualit y Dispersion Modeling Report for SIP

Attainment Demonstration listed below.

Air Quality Dispersion Modeling Report for SIP Atta inment Demonstration



### Salina SIP Demonstration Full Report 20AUG13.pdf

Salina Paved Parking Map 7000-2013-PLP



### 7000-2013-PLP.pdf