# 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 PlantManager Exide Technologies 2700 South Indiana Street Vernon, CA 90058 Reference: ApplicationNo. 530090 Approval oftheRule 1420.1 Compliance PlanforFacilityII) # 124838 DearMr. Vodvarka: The South Coast Air Quality Management District (AQMD) has received your Application No. 530090, submitted onDecember 16, 2011, for aRule 1420.1 (Emission Standards forLead-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 staffhas evaluated and approved yourRule 1420.1 Compliance Plan subjecttothe following conditions. CONDITIONS 1. Exide shall implement all lead mitigation measures described in the plan resubmitted by Exide onJanuary 20, 2012, unless otherwise specifiedbelow. 2. Exide shall install a minimum of six (6) boot wash stations at the exits ofthe total containment buildings at this facility. The installation ofthe boot wash stations shall be completed not later than June 30, 2012. Written notification shall be provided to the AQMD wheninstallationis complete. 3. Exide shall designate one or more forklifts to be exclusively used inside ofthe total containmentbuildings so thatthe probability oftracking lead bearingmaterials outside of the containment buildings is lowered when heavy moving equipment is operated at this facility. The firstforkliftdedicatedto indooruse only shallbe implementednotlaterthan June 30, 2012. Written notification shall be provided to the AQMD when the new forklift(s) are operational. For the purpose ofthis 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 ofthe containment building for maintenance, repair, or other purposes. A written record ofequipment 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 staffandpresented 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

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A. Reduce the amount charged to the reverberatory furnace by 50% ofthe daily averagecharged overtheprior90 days; B. The mandatory curtailments containedwithinthis condition shallbeginwithin 48 hours ofthe time whenExide receives the sampling results (and inthe case ofan AQMI) monitor, the quality assurance and O&M data for the monitor). Exide shall calculatethe above-referenced averages based onthe total materials charged

V in the relevanttimeperiod above divided bythe numberofdays whenthere 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 shallremainin effectuntilthemonitoringresults at the affected monitoring stationreflect 30 consecutive 30-calendarday averages of less than 0.15 ig/m 3 or the monitoring results at the affected monitoring station reflect ten consecutive days below 0.12 tg/m 3 and no other monitor causes a violationofRule 1420.1. 7. Exide shall complete construction ofthe baghouse area Total Containment Building no later than March 31, 2012. Exide shall notify the Executive Officer ofthe AQMD in iting within48 hours ofcompletionofthe construction. 8. On or aftercompletion ofconstruction ofthe baghouse area Total Containment Building, but no later than March 31, 2012, ifmonitored ambient lead concentrations exceed 0.15 .ig!m 3 on 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 ofthese 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 adescription ofthe specific situation and available informationthatjustifies the specific selection. An implementationtimeline shall also be included and shall be establishedbased onEide’s betëff6rt for iml5iemeñtatioh ThëIëëtëd ëasuie(häll be implemented as bytheAQMD. T1isspecffic individualmitigationmeasures are as follows: A. Install an additional room ventilationbaghouse or dustcollector 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 ofthe followinglocations:

a. ThebatterycrusherroominthenorthendoftheRMPS building. b. The truck loading and unloading dock on the south end ofthe RMPS building. c. Thefurnaceroominthe smelterbuilding. d. The cupolafeedroominthe southend ofthe smelterbuilding.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 of these 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 of this 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 of the 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 writtenExide Technologies

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Permits to Construct, where applicable, prior to the commencement of constructionofsuch enclosure(s) listedinpartD ofthis condition. 9. Prior to implementing parts A and B ofCondition 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 Constructrequired prior to commencement of construction. 10. Forthepurpose ofcompliance withthe incrementalmitigationmeasures in ConditionNo. 8, when one requirement is triggered by a violation ofthe 0.15 jig/rn 3 rolling 30 day average leadconcentrationlimit, a second and subsequentmitigationmeasure maynotbe 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 notifytheAQIvII) inwritingwithin48 hours ofcompletionofeachmitigation measure in ConditionNo. 8. 11. The specific selection and implementation ofanyrequired 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 ofarequiredmitigationmeasure. In addition to compliance with the mitigation measures described in the submitted compliance plan, and the modified mitigation measures described in the conditions ofthis plan approval letter, Exide Technologies shall complywithall applicablerequirements ofRule 1420.1, 40 CFR 63 Subpart X, all applicable AQMI) Rules and Regulations, and all laws, ordinances, and regulations ofother governmental agencies which are applicable to the operation ofthis facility. This plan approval letterhas been incorporated into SectionI ofyourTitle V facilitypermit and any changes to the plan shall be done in accordance with Title V permit revision requirements pursuantto RegulationXXX. Should you have any questions regarding this plan approval, please contact Mr. Marco Polo at (909) 396-2633. Verytrulyyours,
Jy Chen, P.E. JC/CT/TGLIMAP SeniorEngineeringManager Engineering and Compliance cc: MohsenNazemi Jill Whynot NancyFeldman Ed Pupka ApplicationFile Exidel05e8doc