South Coast

Air Quality Management District

21865 Copley Drive, Diamond Bar, CA 91765-4178

(909) 396-2000 www.aqmd.gov

January 27, 2012

Corey Vodvarka

Plant Manager

Exide Technologies

2700 South Indiana Street

Vernon, CA 90058

Reference: Application No. 530090

Approval of the Rule 1420.1 Compliance Plan for Facility II) # 124838

Dear Mr. Vodvarka:

The South Coast Air Quality Management District (AQMD) has received your Application No.

530090, submitted on December 16, 2011, for a Rule 1420.1 (Emission Standards for Lead-Acid

Battery Recycling Facilities) Compliance Plan, pursuant to Rule 1420.1(g), for your facility

located at 2700 South Indiana Street, Vernon, California 90058. AQMD staff has evaluated and

approved your Rule 1420.1 Compliance Plan subject to the following conditions.

CONDITIONS

1. Exide shall implement all lead mitigation measures described in the plan resubmitted by

Exide on January 20, 2012, unless otherwise specified below.

2. Exide shall install a minimum of six (6) boot wash stations at the exits of the total

containment buildings at this facility. The installation of the boot wash stations shall be

completed not later than June 30, 2012. Written notification shall be provided to the

AQMD when installation is complete.

3. Exide shall designate one or more forklifts to be exclusively used inside of the total

containment buildings so that the probability of tracking lead bearing materials outside of

the containment buildings is lowered when heavy moving equipment is operated at this

facility. The first forklift dedicated to indoor use only shall be implemented not later than

June 30, 2012. Written notification shall be provided to the AQMD when the new

forklift(s) are operational. For the purpose of this condition, any forklift operated inside

of a containment building shall be completely washed and decontaminated inside of a

total containment building so as to be visually free of all lead contamination prior to

transferring this forklift outside of the containment building for maintenance, repair, or

other purposes. A written record of equipment washing/decontamination shall be kept

with regards to each forklift transferred out of a total containment building for the

purposes stated in this condition and this record shall be signed by supervision or

management level staff and presented to AQMD personnel upon request.
Exide Technologies - 2 - January 27, 2012

4. On and after January 1, 2012, beginning with the 30-day period of January 1, 2012

through January 30, 2012, if monitored ambient lead concentrations exceed 0.15 ig/rn 3,

but no more than 0.23 jig/rn 3,on a rolling 30 day average at any AQMD or AQMD

approved ambient monitor, Exide shall implement the following mandatory daily process

curtailments:

A. Reduce the amount charged to the reverberatory furnace by 15% of the daily

average charged over the prior 90 days;

B. The mandatory curtailments contained within this condition shall begin within 48

hours of the time when Exide receives the sampling results (and in the case of an

AQMD monitor, the quality assurance and O&M data for the monitor). Exide

shall calculate the above-referenced averages based on the total materials charged

in the relevant time period above divided by the number of days when there were

materials charged and shall provide supporting documentation to the District to

justify the calculated averages prior to the required time of implementation.

These mandatory curtailments shall remain in effect until the monitoring results at

the affected monitoring station reflect 15 consecutive 30-calendar day averages of

less than 0.15 jig/rn 3.

5. On and after January 1, 2012, beginning with the 30-day period of January 1, 2012

through January 30, 2012, if monitored ambient lead concentrations exceed 0.23 jig/rn 3,

but no more than 0.30 jig/rn 3,on a rolling 30 day average at any AQMD or AQMD

approved ambient monitor. Exide shall implement the following mandatory daily process

curtailments:

A. Reduce the amount charged to the reverberatory furnace by 25% of the daily

average charged over the prior 90 days;

B. The mandatory curtailrnents contained within this condition shall begin within 48

hours of the time when Exide receives the sampling results (and in the case of an

AQMD monitor, the quality assurance and O&M data for the monitor). Exide

shall calculate the above-referenced averages based on the total materials charged

in the relevant time period above divided by the number of days when there were

materials charged and shall provide supporting documentation to the District to

justify the calculated averages prior to the required time of implementation.

These mandatory curtailments shall remain in effect until the monitoring results at

the affected monitoring station reflect 15 consecutive 30-calendar day averages of

less than 0.15 jig/rn 3.

6. On and after January 1, 2012, beginning with the 30-day period of January 1, 2012

through January 30, 2012, if monitored ambient lead concentrations exceed 0.30 jig/rn 3

on a rolling 30 day average at any AQMD or AQMD-approved ambient monitor, Exide

shall implement the following mandatory daily process curtailments:
Exide Technologies - 3 - January 27, 2012

A. Reduce the amount charged to the reverberatory furnace by 50% of the daily

average charged over the prior 90 days;

B. The mandatory curtailments contained within this condition shall begin within 48

hours of the time when Exide receives the sampling results (and in the case of an

AQMI) monitor, the quality assurance and O&M data for the monitor). Exide

shall calculate the above-referenced averages based on the total materials charged

V in the relevant time period above divided by the number of days when there were

materials charged and shall provide supporting documentation to the District to

justify the calculated averages prior to the required time of implementation.

These mandatory curtailments shall remain in effect until the monitoring results at

the affected monitoring station reflect 30 consecutive 30-calendar day averages of

less than 0.15 ig/m 3or the monitoring results at the affected monitoring station

reflect ten consecutive days below 0.12 tg/m 3and no other monitor causes a

violation of Rule 1420.1.

7. Exide shall complete construction of the baghouse area Total Containment Building no

later than March 31, 2012. Exide shall notify the Executive Officer of the AQMD in

iting within 48 hours of completion ofthe construction.

8. On or after completion of construction of the baghouse area Total Containment Building,

but no later than March 31, 2012, if monitored ambient lead concentrations exceed 0.15

.ig!m 3on a rolling 30 day average at any AQMD or AQMD-approved ambient nionitor,

the specific lead emission mitigation measures

listed below in this condition. Each of these mitigation measures may be implemented

individually or in any combination based on the specific situation and information

available at the time. Within 15 days of each occurrence, Exide shall submit to the

AQMD for approval the selected measure(s) to be implemented along with a description

ofthe specific situation and available information that justifies the specific selection. An

implementation timeline shall also be included and shall be established based on Eide’s

betëff6rt for iml5iemeñtatioh ThëIëëtëd ëasuie(häll be implemented as

by the AQMD. T1isspecffic individual mitigation measures are as follows:

A. Install an additional room ventilation baghouse or dust collector equipped with a

second stage high efficiency particulate air (HEPA) filter, with sufficient blower

capacity to move a minimum of 50,000 CFM of air from one or more of the

following locations:

a. The battery crusher room in the north end of the RMPS building.

b. The truck loading and unloading dock on the south end of the RMPS

building.

c. The furnace room in the smelter building.

d. The cupola feed room in the south end ofthe smelter building.
Exide Technologies - 4 - January 27, 2012

As an alternative to adding additional ventilation with individual baghouses or

dust collectors, Exide may install a single larger air pollution control system with

at least 200,000 CFM of blower capacity to cover all four ofthese locations.

B. Install second stage HEPA filters on one or more of the following air pollution

control systems:

a. The hard lead refinery baghouse (device C47).

b. The soft lead refinery baghouse (device C46).

c. The MAC baghouses venting the RMPS building (devices C156, C157).

d. The cupola furnace feed room baghouse (device C48).

C. All new HEPA filter installations performed pursuant to parts A and B ofthis

condition shall comply with the following requirements:

a. The HEPA filters used in this equipment shall be certified, in writing, by

the manufacturer to have a minimum control efficiency of 99.97 percent

on 0.3 micron particles.

b. Copies of the HEPA filter certifications shall be kept and maintained on

file for a minimum of 5 years and shall be provided to District personnel

upon request.

D. Following completion of all required mitigation measures listed in parts A and B

of this condition, Exide shall evaluate the following additional mitigation

measures:

Install an additional total or partial enclosure(s) of one or more ofthe following

locations:

a. Reverberatory furnace A-pipe.

b. Cupola furnace A-pipe.

c. Additional area enclosure(s) to be determined.

E. The mitigation measures listed in part D of this condition shall not be used to

fulfill the requirements of the first paragraph of this condition unless all

mitigation measures in parts A and B of this condition have first been

implemented. However, Exide may voluntarily implement the measures in part D

of this condition as additional voluntary measures prior to exhausting all required

measures listed in parts A and B of this condition. An exception to this

requirement may be made in special cases where the AQMD, upon examining all

available information, has determined that an A-pipe, or other piece of equipment

as applicable, is the cause for an ambient lead concentration limit exceedance. In

all cases, Exide shall obtain written permission from the AQMD, and written
Exide Technologies - 5 - January 27, 2012

Permits to Construct, where applicable, prior to the commencement of

construction ofsuch enclosure(s) listed in part D ofthis condition.

9. Prior to implementing parts A and B of Condition No. 8, Exide shall first submit the

required permit applications, additional information and associated fees to the AQMD

and obtain the required written Permits to Construct required prior to commencement of

construction.

10. For the purpose of compliance with the incremental mitigation measures in Condition No.

8, when one requirement is triggered by a violation of the 0.15 jig/rn 3rolling 30 day

average lead concentration limit, a second and subsequent mitigation measure may not be

required for additional violations of the 0.15 jig/rn 3 rolling 30 day average lead

concentration limit, until after the ongoing mitigation measure has been implemented.

Exide shall notify the AQIvII) in writing within 48 hours of completion of each mitigation

measure in Condition No. 8.

11. The specific selection and implementation of any required mitigation measure described

in these conditions is subject to written approval from the AQMD. Written approval

from the AQMD shall take into consideration the nature and location from each

monitoring station of any event determined to be associated, or apparently associated

(based on available data) with (an) ambient lead concentration exceedance(s) triggering

the implementation of a required mitigation measure.

In addition to compliance with the mitigation measures described in the submitted compliance

plan, and the modified mitigation measures described in the conditions of this plan approval

letter, Exide Technologies shall comply with all applicable requirements of Rule 1420.1, 40 CFR

63 Subpart X, all applicable AQMI) Rules and Regulations, and all laws, ordinances, and

regulations of other governmental agencies which are applicable to the operation of this facility.

This plan approval letter has been incorporated into Section I of your Title V facility permit and

any changes to the plan shall be done in accordance with Title V permit revision requirements

pursuant to Regulation XXX.

Should you have any questions regarding this plan approval, please contact Mr. Marco Polo at

(909) 396-2633.

Very truly yours,

Jy Chen, P.E.

JC/CT/TGLIMAP Senior Engineering Manager

Engineering and Compliance

cc: Mohsen Nazemi

Jill Whynot

Nancy Feldman

Ed Pupka

Application File

Exidel 05e8doc