SCAQMD Rule 1420.1 Compliance Plan

For Exide Technologies (Vernon Plant)

Contents i

Contents

Page

1 Executive Summary 1

1.1 Rule Required Measures 1

1.2 Compliance Plan Early Action Measures 2

1.3 Compliance Plan Contingent and Future Measures 4

2 Introduction 5

2.1 Facility Location 5

2.2 Process Description 5

2.3 Rule 1420.1 Requirements 5

2.4 Ambient Air Quality Monitoring Results Error! Bookmark not defined.

3 Rule 1420.1 Required Measures 7

3.1 Total Enclosures Required by Rule 1420.1 7

3.2 Lead Point Source Emission Controls Required by Rule 1420.1 7

3.2.1 Lead Point Sources Vented to Emission Controls [Rule 1420.1(f)(1)] 8

3.2.2 Facility-Wide Emission Limits [Rule 1420.1(f)(2)] 9

3.2.3 Installation of Secondary Controls on Dryer [Rule 1420.1(f)(3)] 9

3.2.4 Installation of Secondary HEPA Controls [Rule 1420.1(f)(4)] 10

3.2.5 Installation of PTFE Filter Bags [Rule 1420.1(f)(5)] 10

3.2.6 Summary: Impact of Exide’s Rule-Required Measures 10

4 Ambient Air Quality Modeling 11

5 Additional Compliance Plan Lead Emission Reduction Measures 13

5.1 Compliance Plan Early Action Measures 13

5.1.1 “Baghouse Row” Permit Application and Installation 14

5.1.2 Additional Voluntary Fugitive Source Control Compliance Plan Early Action Measures 

Completed by June 2011 14

5.2 Compliance Plan Contingent and Future Measures 16

5.2.1 Additional Compliance Plan Contingent Measures to Achieve the Ambient Lead 

Concentration 16

5.2.2 Additional Compliance Plan Contingent Measures Housekeeping, Inspection, and 

Maintenance [Rule 1420.1(g)(2)(A)(i)] 16

5.2.3 Additional Compliance Plan Total Enclosure Measures [Rule 1420.1(g)(2)(A)(ii)] 17

5.2.4 Modifications to Lead Control Devices [Rule 1420.1(g)(2)(A)(iii)] 17

5.2.5 Installation of Multi-Stage Lead Control Devices [Rule 1420.1(g)(2)(A)(iv)] 17

5.2.5a Negotiated Potential Contingent and Future Measures 17

5.2.6 Process Changes, including Reduced Throughput Limits [Rule 1420.1(g)(2)(A)(v)] 17

5.2.7 Conditional Curtailments [Rule 1420.1(g)(2)(A)(vi)] 18

5.3 Implementation Schedule for All Additional Compliance Plan Lead Emission Reduction 

Measures (Early Action Measures and Contingent Measures) 211

6 Conclusion 222
SCAQMD Rule 1420.1 Compliance Plan

For Exide Technologies (Vernon Plant)

Contents (Continued)

Contents ii

List of Tables

Table 1. Total Enclosures at Exide 7

Table 2. Currently Permitted Control Equipment at Exide 8

Table 3. Current Facility-wide Pb Emission Rates 9

Table 5. Source Parameters of AERMOD Runs 11

Table 6. Lead Concentrations at the Monitors Predicted by AERMOD (μg/m3) 11

Table 7. Additional Early Pb Emission Reduction Measures 15

Table7a Additional Pending Pb Emission Reduction Measures 16

Table 8. Additional Pb Compliance Plan Contingent Measures 16

List of Figures

Figure 1. Site Vicinity Map

Figure 2. Site Plot Plan

Figure 3. Nearest Residential Receptors

Figure 4a. Charge: Reverb + Blast v. On-site N

Figure 4b. Charge: Reverb + Blast v. Concentration MID

Figure 4c. Charge: Reverb + Blast v. Concentration NE

Figure 4d. Charge: Reverb + Blast v. Concentration Rehrig

Figure 4e. Production: Reverb + Blast v. Concentration On-site N

Figure 4f. Production: Reverb + Blast v. Concentration MID

Figure 4g. Production: Reverb + Blast v. Concentration NE

Figure 4h. Production: Reverb + Blast v. Concentration Rehrig

Figure 5. Average Lead Concentration at On-Site N Monitor versus Production

List of Appendices

Appendix A. List of Compliance Plan Measures

Appendix B. December 1, 2011 Letter from the SCAQMD

Appendix C. Conditions

P:\E\Exide\1420.1-Compliance Plan-2011\_CompPlan\Exide 1420-1 Compliance Plan.docx
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Executive Summary 1

1 Executive Summary

Exide Technologies, Inc.’s (Exide) Rule 1420.1(g) Compliance Plan describes additional lead 

emission reduction and control measures to assure compliance with the National Ambient Air 

Quality Standard of 0.15 μg/m3 on a three-month rolling average and Rule 1420.1(d)(2) 

averaged over 30 consecutive days after January 1, 2012, if Exide does not demonstrate 

compliance with those standards.

Exide submitted its initial Compliance Plan in August 2011. On December 15, 2011, Exide 

submitted a revised Compliance Plan in order address the South Coast Air Quality Management 

District’s December 1, 2011 correspondence (correspondence attached hereto as Appendix B). 

Exide and the District thereafter engaged in further communication regarding measures to be 

implemented, and Exide now submits this second revised Compliance Plan at the District’s 

request. Exide has worked in good faith with the District throughout this process.

Exide has diligently undertaken lead emission reduction measures that fall into two general 

categories: (a) measures required by South Coast Air Quality Management District Rule 1420.1 

(“Rule-Required Measures”), and (b) Rule 1420.1(g) Compliance Plan additional lead emission 

reduction Measures (“Rule Compliance Plan Additional Lead Emission Reduction Measures”).

The Rule Compliance Plan Additional Lead Emission Reduction Measures can be further 

divided into two sub-categories: (i) additional lead emission reduction measures that Exide has 

already proactively implemented (“Compliance Plan Early Action Measures” or “Early Action 

Measures”), and (ii) additional lead emission reduction measures that Exide will implement if it 

does not satisfy the ambient standards beginning with and after January 2012 (“Compliance 

Plan Contingent Measures” or “Contingent Measures”).

Though many of these Rule-Required Measures and Compliance Plan Early Action Measures 

are complete (and have greatly reduced ambient air lead concentrations), several have only 

recently been implemented or are still in progress. Therefore, the full emissions-reduction 

impact of these measures is yet to come, and Exide is reasonably assured that it will comply 

with the ambient standards after January 1, 2012. Indeed, Exide is satisfying emissions 

standards as of the date of this January 2012 Compliance Plan submittal. If Exide does not 

satisfy the NAAQS standard in the future, Exide is prepared to implement the additional 

Compliance Plan Contingent measures to achieve compliance.

1.1 Rule Required Measures

Exide has worked diligently to implement all measures required by Rule 1420.1. These 

Rule-Required Measures include:

• Exide has completed construction of total enclosures of the battery breaking areas, the 

materials and storage and handling areas, the dryer and dryer areas, the smelting furnaces 

and furnace areas, the agglomerating furnace, and the refining and casting areas. [Rule 

1420.1(e)]

• Exide has completed work to vent its lead point sources, such as the reverb and blast 

furnace and lead refining kettles, to baghouses and other air pollution emissions controls. 

[Rule 1420.1(f)(1)]
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Executive Summary 2

• Exide has succeeded in reducing total facility mass lead emissions from all lead point 

sources to below 0.045 pounds of lead per hour. [Rule 1420.1(f)(2)]

• Exide has installed secondary emissions controls (a HEPA after-filter) on its existing rotary 

kiln dryer to reduce point source lead emissions. [Rule 1420.1(f)(3)]

• Exide has installed secondary HEPA after-filters between the North and South Torit 

baghouses outlet and the existing fan inlet. [Rule 1420.1(f)(4)]

• Exide has installed PTFE filter bags in the MAC baghouse. [Rule 1420.1(f)(5)].

These completed Rule-Required Measures have allowed Exide to significantly reduce ambient 

air concentrations to levels approaching the NAAQS standard. Because certain of the 

Rule-Required Measures have only just been completed, the full positive impact of these 

measures has yet to appear in Exide’s ambient monitoring results.

1.2 Compliance Plan Early Action Measures

In addition to 1420.1 Rule-Required Measures, Exide has voluntarily implemented several 

additional Compliance Plan Early Action Measures designed to achieve the NAAQS. Exide 

voluntarily undertook these Compliance Plan Early Action Measures (not all of which are 

complete, with the full positive impact still to come) in an abundance of caution even before it 

submitted the initial Compliance Plan in August 2011. Exide has diligently continued to work on 

these Compliance Plan Early Action Measures throughout 2011 and 2012, even as the 

Compliance Plan was being reviewed by the District. In other words, many of these Compliance 

Plan Early Action Measures have or already are being implemented proactively as “additional 

lead emission reduction measures” under Rule 1420.1(g).

These additional Compliance Plan Early Action Measures include:

• Exide has obtained the necessary permits and approvals to fully enclose its “Baghouse 

Row” (an area of nine baghouses between the furnace and feed prep building) which will 

be ventilated so as to provide the necessary in-draft velocity and negative pressure for the 

new enclosure. The design of this enclosure has been completed and the construction air 

permit received. Construction of the enclosure has commenced and is well underway. 

The enclosure, which is a major capital project designed to significantly reduce pointsource emissions, was initially expected to be complete by the end of 2011. However, due 

to unexpected delays in material delivery (i.e. steel for the enclosure), Exide now expects 

to complete the enclosure by March 31, 2012. Exide’s air modeling demonstrates that the 

Baghouse Row enclosure will succeed in achieving the NAAQS. 

• Exide has already diligently and voluntarily undertaken and/or implemented the following 

Compliance Plan Early Action Measures as proactive “additional lead emissions reduction 

measures”: 

1) Installed doors between the shipping and smelting building areas to enhance negative 

pressure in the smelting building.

2) Installed an automated door on the Southeast end of the feed corridor connecting the 

reverb and blast feed rooms to reduce the amount of time that door is open.

3) Installed a new vehicle wheel wash station in the west yard of the plant. 
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Executive Summary 3

4) Completely resurfaced the west yard of the facility to enhance the effectiveness of 

pavement cleaning activities.

5) Installed MERV 15 rated cartridge filters in the North and South Torit collectors

6) Upgrading Dry Sweepers to a combination hybrid dry sweeper / wet scrubbing ride-on 

pavement cleaning unit for use on plant yard paved areas to enhance pavement 

cleaning efforts. [Completed by October 2011]. Placed an order for a second 

scrubber/sweeper in December 2011.

7) Install ventilated negative pressure enclosure for “Baghouse Row” [to be completed by 

March 2012]

8) Modifying the railcar dock at the south end of the smelting building to allow the direct 

receipt of industrial battery plates into the blast furnace feed room. [to be completed by 

March 31, 2012]

9) Replacing strip curtains with doors on north and south end of RMPS building. 

[completed by December 31, 2011]

10) Installing a new vehicle and equipment decontamination and wash area at the north 

end of Baghouse Row as part of the Baghouse Row enclosure construction. 

[completed by December 31, 2011]

11) Discontinued use of the mobile equipment wash area at the south end of the plant in 

December. Closure to be completed pending DTSC Permitted Unit closure 

requirements.

12) Focused housekeeping on roofs and other horizontal surfaces in Baghouse Row. 

[ongoing during 2011-2012] A second contractor has been added to perform this 

service and other cleaning services related to fugitive dust control efforts.

In addition to those measures already implemented or in progress, Exide has agreed to 

implement the following (either by its own suggestion or at the District’s request):

13) Exide will be installing two backup diesel generators to supply sufficient electrical 

power to drive the exhaust fans for the two metallurgical furnace process off-gas 

baghouses and the two Torit collection systems in the event of a power outage. This will 

ensure that off-gases from the furnaces themselves continue to be drawn through fabric 

filtration during such outages. By continuing to drive the Torit fans suction can be 

maintained on the main smelting building enclosure during such upset events. Exide will 

submit any air permit applications necessary for installation of the diesel engines 

associated with these generators by May 2012. [voluntary work, to be completed by June 

2012]

14) Exide will install a minimum of six (6) boot wash stations at the exits of the total 

containment buildings [as requested by District, to be completed by June 30, 2012]

15) Exide will designate one or more forklifts to be used exclusively inside of total 

containment buildings [as requested by District, to be completed by June 30, 2012]
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Executive Summary 4

Exide’s diligent actions have already dramatically lowered ambient lead emission 

concentrations. By continuing its additional Compliance Plan Early Action Measures and 

completing the Baghouse Row enclosure, Exide reasonably expects to achieve and 

maintain the 0.15 μg/m3 ambient lead standard.

1.3 Compliance Plan Contingent and Future Measures

Exide’s diligent and aggressive voluntary Compliance Plan Early Action Measures are expected 

to reduce lead emissions to satisfy the NAAQS. Should it not achieve the NAAQS, Exide will be 

prepared to promptly implement additional compliance measures on a contingent basis to 

further reduce fugitive emissions. These measures include:

• Application of an elastomeric coating to the roof of the battery breaker building to enhance 

the maintainability of the roof and prevent the development of pinhole leaks over time.

Finally, pursuant to Rule 1420.1, Exide has considered other reduction options, including but not 

limited to whether process changes such as reduced throughput limits and conditional 

curtailments would assist in achieving NAAQS requirements. Exide has demonstrated that 

there is no relationship between throughput rates and ambient lead concentrations at its facility, 

such that reduced throughput (even on a conditional basis) would not be expected to further 

reduce emissions to achieve the NAAQS. [See Section 5.2.6, infra] Exide therefore does not 

believe it is appropriate to include throughput and conditional curtailments as self-implementing 

“additional lead emissions reductions measures” in this Compliance Plan. Nonetheless, Exide 

submitted a possible structure for conditional curtailments in its revised Compliance Plan 

(submitted December 2011), modeled to reflect the District Hearing Board’s preference (stated 

in its 2008 order) for reasonable and proportional curtailments. Exide and the District have 

continued to discuss potential curtailment options in December and January, and Exide has now 

in good faith agreed to the curtailment structure reflected in this second revised Compliance 

Plan.

In summary, Exide has diligently completed Rule-Required Measures and has proactively and 

voluntarily undertaken other Compliance Plan Early Action Measures (some recently 

implemented, others not yet complete) designed to achieve the NAAQS and Rule 1420.1 (d)(2) 

ambient concentration limit after January 1, 2012. These actions have greatly reduced 

emissions (and Exide is currently in compliance with emissions standards), but their full effect is 

not yet known and will not be known until the end of April 2012. Exide has verified through air 

modeling that its completion of certain measures (especially full enclosures of all process areas) 

will result in ambient compliance. However, if Exide continues to exceed the ambient 

concentration limits in 2012, Exide is prepared to promptly implement additional Compliance 

Plan Contingent Measures to reduce emissions.

For ease of reference, a complete chart listing all Additional Compliance Plan Lead Emission 

Reduction Measures (both Early Action Measures and Contingent Measures) and their 

completion dates and implementation schedule can be found at Appendix A. Appendix A also 

includes graphics indicating the location of each activity. In addition, Appendix C sets forth the 

negotiated and District-approved conditions that Exide must satisfy.
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Introduction 5

2 Introduction

2.1 Facility Location

The Exide facility (SCAQMD ID # 124838) is located at 2700 South Indiana Street, Vernon, 

California. Exide is a secondary lead smelter that recycles lead batteries and other lead-bearing 

scrap materials. Figure 1 shows the facility and its vicinity. The land use in the immediate 

vicinity (up to 1.5 kilometers [km] radius) of the facility is industrial and the topography around 

the facility is primarily flat. The facility’s layout showing the locations of the various buildings 

and the stacks are presented on Figure 2. 

2.2 Process Description

Spent lead-acid batteries and other lead-bearing scrap materials are delivered to the facility by 

trucks, where the batteries and scraps are crushed, separated, and smelted to recover lead and 

propylene.

The spent lead-acid batteries and lead-bearing scrap are first broken apart and separated into 

the plastic, lead, and acid components. The plastic is recovered, and the acid is sent to a 

holding tank. The lead-containing components are transferred into one of the feed rooms, 

where they are then fed by conveyor to either the Reverbertory (Reverb) furnace (Device D119) 

or the Blast furnace (Device D128), which are each used to heat the lead until it reaches a 

molten state. 

The lead refining kettles are used to purify the hot, molten lead that is produced during the 

smelting process. Each kettle sits inside a brick-lined pit, housing natural gas-fired burners. 

The burners heat the air between the burners and the kettle, thereby heating the kettle. The 

kettles are continuously heated; however, there are usually only two or three kettles that contain 

material at any one time. The molten lead in the kettles is repeatedly heated, agitated with a 

mixer, and allowed to cool, with periodic stirring and additions of refining agents. 

The refined lead is then formed into ingots, which are subsequently transferred to the Finished 

Lead Storage Building.

2.3 Rule 1420.1 Requirements

On November 12, 2008, the United States EPA published the Final Rule in the Federal Register 

revising the NAAQS for lead from 1.5 μg/m3 to 0.15 μg/m3 measured on a three-month rolling 

average.

On November 5, 2010, the SCAQMD Governing Board adopted Rule 1420.1 (Emissions 

Standards for Lead from Large Lead-Acid Battery Recycling Facilities). Rule 1420.1(d)(2) 

prohibits a covered facility from discharging lead emissions exceeding 0.15 μg/m3 averaged 

over any 30 consecutive days. The Rule requires covered facilities to implement certain 

practices and emission control measures to attain the Lead NAAQS standard with the 30-day 

period starting January 1, 2012. 

Pursuant to Rule 1420.1(g), starting on July 1, 2011, if the facility discharges lead emissions 

that exceed 0.12 μg/m3 averaged over any 30 consecutive days, the facility shall submit a 
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Introduction 6

Compliance Plan that contains a description of additional lead emission reduction measures to 

achieve the ambient lead concentration of 0.15 μg/m3 averaged over any 30 consecutive days.
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Rule 1420.1 Required Measures 7

3 Rule 1420.1 Required Measures

Rule 1420.1 establishes several requirements intended to ensure compliance with the revised 

Lead ambient air quality standard of 0.15 μg/m3

. Rule 1420.1(e) specifies the requirements for 

Total Enclosures. Rule 1420.1(f) specifies the requirements for Lead Point Source Emission 

Controls.

Exide has complied with the mandatory provisions of Rule 1420.1, as set forth below. This work 

has significantly reduced both fugitive and point source lead emissions to levels approaching 

the NAAQS.

3.1 Total Enclosures Required by Rule 1420.1

Rule 1420.1(e) requires that the following areas be enclosed within a total enclosure as defined 

by Rule 1420.1(c)(25):

(A) Battery breaking areas;

(B) Materials storage and handling areas, excluding areas where unbroken lead-acid 

batteries and finished lead products are stored;

(C) Dryer and dryer areas including transition pieces, charging hoppers, chutes, and skip 

hoists conveying any lead-containing material;

(D) Smelting furnaces and smelting furnace areas charging any lead-containing material;

(E) Agglomerating furnaces and agglomerating furnace areas charging any lead-containing 

material; and

(F) Refining and casting areas.

As of July 1, 2011 Exide has enclosed all required areas. Table 1 summarizes this work.

Table 1. Total Enclosures at Exide

Control Device Description Equipment/Area Controlled

Total enclosure around RMPS area Fugitive emissions in RMPS area

Total enclosure around dryer Fugitive emissions from rotary dryer furnace (D115)

Total enclosure around smelting and refining 

processes

Fugitive emissions from smelting and refining processes

Total enclosure around South Corridor 

between Smelting and Refining building and 

Reverb Furnace Feed Room 

Fugitive emissions in South Corridor

Partial enclosure/tunnel for truck washing 

station

Minimize lead-contaminated water from spraying outside truck 

washing station

3.2 Lead Point Source Emission Controls Required by Rule 1420.1

Rule 1420.1(f) requires that each lead control device meet certain requirements. Exide’s 

compliance with these Rule requirements is summarized below.
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Rule 1420.1 Required Measures 8

3.2.1 Lead Point Sources Vented to Emission Controls [Rule 1420.1(f)(1)]

Exide currently employs multiple types of air pollution control (APC) equipment and other 

emission reduction measures in order to reduce the amount of process lead emissions. A list of 

the currently permitted, installed and fully operational control equipment (as of the date of this 

plan) is provided in Table 2.

Table 2. Currently Permitted Control Equipment at Exide

Control Device Description Equipment/Area Controlled

Baghouses/Dust Collectors/Scrubbers

C40 – baghouse;

C41 – baghouse;

Reverb furnace (D119)

C44 – afterburner;

C45 – baghouse

Blast furnace (D128)

C42 – venturi scrubber;

C43 – tray scrubber;

S139 – stack

APC 1 (C40, C41), APC 2 (C44, C45)

Hard Lead baghouse Lead refining kettles and dross hoppers (D7 – D20), Blast furnace 

tapping ports and launders (D129 – D134), rotary dryer furnace 

enclosure (C177)

Soft Lead baghouse Lead refining kettles and dross hoppers (D24 – D37), Reverb furnace 

feeders (D117, D118), Reverb furnace tapping ports and launders 

(D120 – D125), fugitive emissions from Quench Chamber cleanout 

door (D149)

Material Handling baghouse Central Vacuum System A (C159, C160), Central Vacuum System B 

(C162, C163), Blast Furnace feed hopper (D126)

C165 – packed bed scrubber;

C172 – HEPA filter;

S166 – stack

Raw Material Preparation System (RMPS) building (C175), 

Hammermill (D1), Hammermill feed conveyor (D2), Mud holding tanks 

(D3 – D5)

North Torit baghouse Fugitive emissions from the Smelting and Refining building, fugitive 

emissions from the pending Baghouse Row building

South Torit baghouse Fugitive emissions from the Smelting and Refining building, fugitive 

emissions from the pending Baghouse Row building

C143 – cyclone;

C144 – baghouse;

S145 – stack

Rotary dryer furnace (D115) and screw conveyors (D114, D116)

C156, C157 – MAC baghouses;

S158 - stack

RMPS building (C175), lead refining kettle burner stack emissions, 

rotary dryer hoppers (D109, D110) and conveyors (D111 – D113), 

South Corridor building (C182)

C159 – cyclone;

C160 – baghouse

Fugitive emissions in Blast Furnace Feed Room

C162 – cyclone;

C163 – baghouse

Fugitive emissions in Blast Furnace Feed Room
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Rule 1420.1 Required Measures 9

3.2.2 Facility-Wide Emission Limits [Rule 1420.1(f)(2)]

1420.1(f)(2) requires that the total facility mass lead emissions from all point sources shall not 

exceed 0.045 pounds of lead per hour, a level determined from District dispersion modeling at 

the time of promulgation of Rule 1420.1 as sufficient to maintain ambient concentration impacts 

from stack sources below one half the ambient limit. Exide has taken diligent actions to achieve 

(and even go substantially below) these limits.

As shown in Table 3, the facility-wide Pb emissions from all point sources at Exide are currently 

below the 0.045 lbs/hr limit.

Rule 1420.1(f)(2) also requires that no single source have lead emissions in excess of 0.01 

lbs/hr. As shown in Table 3, all individual sources have a lead emission rate that is less than 

0.01 lbs/hr and is in compliance with this section of the Rule.

Table 3. Current Facility-wide Pb Emission Rates

AQMD 

Device ID

Control Device 

Description Area Served Source Test 

Date

Source Test 

Measured 

(dscfm)

Pb Emissions

(lbs/hr)

C38 North Torit General 

Ventilation 9/2011 90,694 0.00374

C39 South Torit General 

Ventilation 8/23/2011 97,118 0.00321

C156/C157 MAC BHs

GV: RMPS, 

Kettle Burners, 

Reverb Feed

8/1-9/1/2011 90,727 0.00339

C48 Material Handling 

BH

GV: Material 

Handling & Blast 

Feed Room

10/12/2010 95,858 0.00115

C165/C172 RMPS MAPCO 

Demister / HEPA RMPS 11/10-12/2010 17,270 0.000358

C144/C143 Kiln Dryer BH / 

Cyclone

Kiln (Rotary 

Dryer) 9/2011 9,723 0.00202

C42/C43 Neptune-Venturi 

Scrubber

Blast & Reverb 

furnaces 9/8/2010 18,059 0.000175

C46 Hard Lead BH Hard Lead 10/4,5,7/2010 101,832 0.00102

C47 Soft Lead BH Soft Lead 10/2010 85,435 0.000851

Total 606,716 0.016

<0.045 limit

3.2.3 Installation of Secondary Controls on Dryer [Rule 1420.1(f)(3)]

On 12/3/2010 Exide submitted a permit application (A/N 516866) to install a HEPA after-filter 

between the existing rotary kiln dryer baghouse (C144) outlet and the existing fan inlet. Exide 

completed the HEPA installation by June 30, 2011. Exide therefore reasonably expects that this 

unit will comply with the requirements of Rule 1420.1(d)(3)(A) and will further reduce the point 

source lead emissions from the facility in 2011-2012.
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Rule 1420.1 Required Measures 10

3.2.4 Installation of Secondary HEPA Controls [Rule 1420.1(f)(4)]

On 5/13/2011 Exide submitted a permit application (A/N 520575 & A/N 50577) to install a HEPA 

after-filter between the existing North and South Torit baghouses (C38 &C39) outlet and the 

existing fan inlet. Exide completed the duct work and HEPA installation on August 9, 2011. 

Exide completed a source test on this unit by the end of the month. As with the secondary 

controls on the dryer (Section 3.2.3 above), Exide reasonably expects that this recent addition 

will further reduce lead emissions in 2011-2012.

3.2.5 Installation of PTFE Filter Bags [Rule 1420.1(f)(5)]

Exide submitted Permit applications (A/N’s 520478 & 520501) on 3/31/2011 to install upgraded 

polytetrafluoroethylene membrane-type (PTFE) filter bags on the MAC baghouses. Exide 

completed the upgrade and the baghouse leak tested in June 2011. Exide completed a source 

test on this unit in September 2011.

3.2.6 Summary: Impact of Exide’s Rule-Required Measures

Exide’s efforts to comply with the mandatory provisions of Rule 1420.1 have resulted in 

significant reductions of both fugitive and point source lead emissions, with stack emissions, for 

example, being reduced by approximately one half on a facility-wide basis since the 

promulgation of the Rule. Because Exide only recently completed several of the required 

measures, their full positive impact has yet to be fully realized. Thus, Exide expects to show 

even further emissions reductions and further improvement to ambient levels by the end of 2011 

and early 2012 and is expected to demonstrate and maintain compliance once the Baghouse 

Enclosure is complete.

Exide’s actions have significantly reduced ambient lead concentrations (see Table 4), and these 

reductions are expected to continue into the future. Exide reasonably expects that full 

compliance will be achieved once the Baghouse Row enclosure is complete.

Table 4. Ambient Air Monitoring Results (30-day Average)

Month Rail SE SW NE OSN MID

July 2011 0.06 0.06 0.08 0.68 0.55 0.21

August 2011 0.07 0.06 0.09 0.70 0.47 0.18

September 2011 0.03 0.06 0.08 0.23 0.25 0.14

October 2011 0.04 0.06 0.18 0.22 0.17 0.14

November 2011 0.03 0.08 0.16 0.18 0.19 0.26

December 2012 0.03 0.05 0.09 0.08 0.11 0.12

January 1-17, 2012 0.03 0.05 0.09 0.07 0.10 0.11
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Ambient Air Quality Modeling 11

4 Ambient Air Quality Modeling

US EPA’s AERMOD dispersion model was used to evaluate the impacts that the Pb reduction 

Rule-Required Measures and those Early Action Measures currently under construction would 

have on the ambient Pb concentrations measured at the monitors located at and around the 

fenceline of the Vernon facility. Inputs to AERMOD included:

• Pb emission rates (lbs/hr) from Point Sources using the rates measured from source tests 

conducted in late 2010 and early 2011 at the facility;

• Stack heights for the North Torit, South Torit, and MAC Baghouse were increased from 

79 feet to 120 feet for and the building parameters reflect the presence of the new 

Baghouse Row enclosure; and

• Roadway fugitive emissions from the 2007 ATIR were included in this dispersion modeling. 

Emissions from all other fugitive sources were set to zero to reflect the effect of the 

pending construction of the “Baghouse Row” enclosure is completed.

Table 5. Source Parameters of AERMOD Runs

Source ID

UTM Coordinates (m) Emission 

Rate (g/s)

Release 

Height

(m)

Temp

(K)

Velocity

(m/s)

Stack 

Diameter

X Y (m)

MAPCO 389705.7 3763538 8.05E-05 19.35 299.48 4.55 1.09

MAT_STOR 389722.7 3763488 1.18E-03 34.14 300.93 14.14 2.13

SOFTLEAD 389750.0 3763554 8.38E-04 34.14 318.15 14.10 2.03

HARDLEAD 389729.9 3763505 8.35E-04 34.14 311.76 17.17 2.03

DRYER_BH 389769.8 3763525 1.32E-03 36.60 375.22 7.47 0.91

NEPTUNE 389751.4 3763527 2.20E-05 34.14 332.89 8.27 1.16

NOR_CART 389790.5 3763550 3.60E-04 36.60 298.50 11.29 2.13

SOU_CART 389789.3 3763547 5.29E-04 36.60 298.89 15.29 2.13

MAC_BH 389740.1 3763479 2.36E-04 36.60 307.44 18.06 1.82

0.0054 g/s

0.043 lbs/hr

The modeling results are summarized in Table 6 below.

Table 6. Lead Concentrations at the Monitors Predicted by AERMOD (μg/m3)

SW_Monitor SE_Monitor NE_Monitor On-Site N REHRIG Railway CP_Monitor

0.00765 0.00338 0.0437 0.02403 0.04657 0.01339 0.0071

For these modeling runs, the emission rates were based on source tests from late 2010 through 

early 2011. Additional source testing has been in progress as part of the update for the AB2588 

HRA. The emission rates that were used in this modeling did not reflect the improvements due 

to the recent modifications to the air pollution control equipment. The total facility-wide emission 

rate for all stationary sources used in the modeling was 0.043 lbs/hr. This is greater than the 

0.016 lbs/hr facility-wide rate when the most recent source tests are taken into account, but it is 

still less than the 0.045 lbs/hr limit set by the rule – indicating that the 0.045 lbs/hr facility-wide 

point source limit established in the Rule is adequate to insure compliance with the ambient 

standards.
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Ambient Air Quality Modeling 12

Thus, the modeling results presented in this Plan reflect a worst case scenario when the Vernon 

plant is emitting lead at a rate just below the Rule limit. As the actual facility-wide emission rate 

is even less than the modeled rate, the ambient impacts would be less than what is reported 

here. Figure 3 shows the location of the nearest residential receptors, with the nearest receptor 

over 0.5 miles from the Vernon fenceline.

The modeling results show that once all enclosures have been constructed and fugitive 

emissions become insignificant; the ambient Pb concentrations at the monitors will be well 

below the limit of 0.15 μg/m3 established by the Rule. In particular, the above results show that 

stack emission impacts are well below the 0.15 μg/m3 target concentration. Should the 

measures already planned and underway for completion by the end of 2011 fail to achieve the 

0.15 μg/m3 lead concentration at the monitors on a 30-day average after January 1, 2012, this 

modeling makes it clear that the issue is not with impacts from stack emissions, but rather 

fugitive emissions. Any contingent measures (including curtailments) implemented in response 

to exceedances after January 1, 2012 should, therefore, be directed to fugitive sources.
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Additional Compliance Plan Lead Emission

Reduction Measures 13

5 Additional Compliance Plan Lead Emission

Reduction Measures

Rule 1420.1(g)(2) requires that the Compliance Plan include the following elements:

(A) A description of additional lead emission reduction measures to achieve the ambient 

lead concentration including, but not limited to, requirements for the following:

(i) Housekeeping, inspection, and maintenance activities;

(ii) Additional total enclosures;

(iii) Modifications to lead control devices;

(iv) Installation of multi-stage lead control devices;

(v) Process changes including reduced throughput limits; and

(vi) Conditional curtailments including, at a minimum, information specifying the 

curtailed processes, process amounts, and length of curtailment.

(B) The locations within the facility and method(s) of implementation for each lead reduction 

measure of subparagraph (g)(2)(A); and

(C) An implementation schedule for each lead emission reduction measure of subparagraph 

(g)(2)(A) to be implemented if lead emissions discharged from the facility contribute to 

ambient air concentrations of lead that exceed 0.15 μg/m3 averaged over any 

30 consecutive days measured at any monitor pursuant to subdivision (j) or at any 

District-installed monitor. The schedule shall also include a list of the lead reduction 

measures of subparagraph (g)(2)(A) that can be implemented immediately prior to plan 

approval.

As previously explained Exide has undertaken various Compliance Plan Early Action Measures 

(Section 5.1, et. seq.) and also proposes Compliance Plan Contingent Measures (Section 5.2, 

et. seq.) to be implemented if Exide has not satisfied the NAAQS beginning in January 2012. 

A complete list of all Exide’s Compliance Plan Lead Emission Reduction Measures is set forth at 

Appendix A.

5.1 Compliance Plan Early Action Measures

In addition to the control measures required by Rule 1420.1, Exide has proactively undertaken 

certain additional Compliance Plan Measures that will reduce fugitive lead emissions, which are 

the primary source of measured concentrations. Exide diligently undertook these measures in 

an abundance of caution before it formally submitted this Compliance Plan. Exide’s Early 

Action Measures are, in effect, pre-qualified and self-implemented “additional lead emission 

reduction measures” under Rule 1420.1(g).

Exide has not completed all of these measures, and implementation of others began recently. 

Exide has therefore not yet realized the full emissions-reducing impact of these voluntary 

measures. Thus, the exceedance of the 0.12 μg/m3 level triggering this Compliance Plan does 

not reflect the expected lower lead concentrations to be achieved in 2012. Exide reasonably 

expects that continued implementation of these Compliance Plan Early Action Measures will 
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Additional Compliance Plan Lead Emission

Reduction Measures 14

result in compliance with the ambient standards upon completion of the baghouse enclosure, 

making implementation of any additional Compliance Plan Contingent Measures unnecessary.

5.1.1 “Baghouse Row” Permit Application and Installation

On March 31, 2011, Exide submitted several permit applications (A/Ns 520468, 520577, 

520575, 520501, 520478, 520477, & 522622) to enclose the area at the facility known as 

“Baghouse Row”. Exide operates 9 baghouses in this area, which is between the smelting 

furnace building and feed prep building. Construction permits have been issued as a result of 

these applications, design completed, and construction of the enclosure has commenced. The 

enclosure was previously scheduled to be completed before the end of 2011.

Due to unanticipated material supply delays outside Exide’s control, the Baghouse enclosure 

will not be complete until March 31, 2012. Exide will work diligently to ensure completion by this 

date or sooner if possible.

Exide has established an additional budget of $250K to fund 30 hours/week of additional OT for 

the next 15 weeks (from December 10, 2011 through March 31, 2012) to accelerate the 

completion of the Baghouse Row Enclosure and mitigate any risk from weather delays.

The nine baghouses are represented in Exide’s Title V permit as devices C40 and C41 (Reverb 

Furnace baghouses), C45 (Blast Furnace baghouse), C46 (Hard Lead baghouse), C47 (Soft 

Lead baghouse), C48 (Material Handling baghouse), C144 (Rotary Dryer baghouse), and C156

and C157 (MAC baghouses). These baghouses control emissions from various parts of Exide’s 

processes, such as the raw material handling, refining, and smelting processes.

The area where the baghouses are located is currently open to the atmosphere. Exide is 

planning on building an enclosure around the baghouses in order to reduce fugitive lead 

emissions. The air inside the enclosure will be vented to existing air pollution control devices 

which consists of Torit cartridge collectors C38 and C39, respectively. The existing ventilation 

capacity is expected to be adequate to provide the necessary in-draft velocity and negative 

pressure for the new enclosure.

The height of the new enclosure will be 79 feet. In order to conform to current building codes, 

the height of the stacks for C144 (Rotary Dryer), C156 and C157 (MAC Baghouses), C38 (North 

Torit), and C39 (South Torit) must be increased to 120 feet, which will minimize the effects of 

building downwash while still meeting stack height rule limits. Exide will also install a differential 

pressure monitoring system on the new enclosure in compliance with Rule 1420.1. Overall, the 

voluntary modification to enclose “Baghouse Row” is expected to significantly reduce emissions.

Indeed, Section 4 outlined Exide’s ambient air modeling, demonstrating that ambient lead 

concentrations at all monitors will be less than 0.15 μg/m3 once all enclosures are 

fully-operational.

5.1.2 Additional Voluntary Fugitive Source Control Compliance Plan Early Action 

Measures Completed by June 2011

Exide undertook additional Compliance Plan Early Action Measures to reduce fugitive emissions 

from other locations at the Vernon plant, as summarized in Table 7 below. These measures 

were underway by July 2011 and will all be completed prior to January 1, 2012 (with the 
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Additional Compliance Plan Lead Emission

Reduction Measures 15

exception of the Baghouse Row enclosure and related actions). As previously stated, these are 

“additional lead emissions reductions measures” under Rule 1420.1(g) that Exide has 

proactively and voluntarily initiated on an early action basis before submitting this formal 

Compliance Plan.

Table 7. Additional Early Pb Emission Reduction Measures

Action Completion 

Date

1 Install door(s) between shipping and smelting to enhances negative pressure in 

refining/smelting and reduce draft from shipping. Oct 2010

2 Install an automated door on the southeast end of the corridor to reduce the amount of 

time that the door is open Nov 2010

3 Install a new vehicle wheel wash station in the west yard of the plant Jun 2011

4 Completely resurface the west yard of the facility to enhance the effectiveness of 

pavement cleaning activities Jul 2011

5 Installed MERV 15 rated cartridge filters in the North and South Torit collectors July 2011

6 Upgraded ride-on yard sweeper to a combination dry sweeper / wet scrubbing unit for 

cleaning of plant yard pavement. Added additional sweeper/scrubber.

Oct-Dec. 

2011

7 Install ventilated negative pressure enclosure for “Baghouse Row” March/April, 

2012

8 Modify railcar dock at the south end of the smelting building to allow receiving of industrial 

plates and dedicated inside and outside forklifts. Dec 2011

9 Replace strip curtains with doors at north and south end of RMPS building Dec 2011

10 Install new vehicle and equipment decontamination and wash area at the north end of 

baghouse row as part of the baghouse row enclosure construction Dec 2011

11 Discontinued use of mobile equipment wash area at south of plant. Final closure pending 

DTSC approval.

pending 

DTSC 

approval

12 Focused housekeeping and other horizontal surfaces in Baghouse Row, pending 

completion of enclosure of area. Secured services of second contractor

Nov 2010-

Dec 2011

Certain of the measures were only recently implemented, and their positive effect on emissions 

is expected to increase as Exide continues to improve its procedures (i.e. improved 

housekeeping on roofs and horizontal surfaces). With these voluntary fugitive reduction 

Compliance Plan Early Action Measures, along with the required Rule-Required Measures and 

the pending “Baghouse Row” enclosure, Exide has seen emission reductions during the second 

half of 2011 and expects further reductions upon completion of these pending measures.

In addition to the items listed in Table 7, Exide has agreed to implement the following items in 

the near future, either of its own volition or as part of discussions with the District that took place 

after Exide submitted its revised Compliance Plan on December 15, 2011:
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Additional Compliance Plan Lead Emission

Reduction Measures 16

Table 7a Additional Pending Pb Emission Reduction Measures

Action Completion 

Date

13. [Voluntary Measure] Exide will be installing two backup diesel generators to supply 

sufficient electrical power to drive the exhaust fans for the two metallurgical furnace 

process offgas baghouses and the two Torit collection systems in the event of a power 

outage. This will ensure that off-gases from the furnaces themselves continue to be 

drawn through fabric filtration during such outages and by continuing to drive the Torit 

fans suction can be maintained on the main smelting building enclosure during such 

upset events. Exide will submit the air permit applications necessary for the installation 

of the diesel engines associated with these generators by May 2012 and expects to 

complete installation of these systems by June 2012.

Jun 2012

14. [District-Required Measure] Exide will install a minimum of six (6) boot wash stations 

at the exits of the total containment buildings. Jun 2012

15. [District-Required Measure] Exide will designate one or more forklifts to be used 

exclusively inside of total containment buildings. This Measure relates to and expands 

upon Measure No. 8 in Table 7.

Jun 2012

5.2 Compliance Plan Contingent and Future Measures

Exide reasonably believes that various measures already completed or underway will allow it to 

achieve the NAAQS and Rule 1420.1(d)(2) ambient limit. However, if Exide continues to 

exceed these standards after January 2012, it will undertake further additional “lead reduction 

measures” (Compliance Plan Contingent Measures) as set forth in this Section.

5.2.1 Additional Compliance Plan Contingent Measures to Achieve the Ambient 

Lead Concentration

Additional lead emission reduction Compliance Plan Contingent Measures evaluated and 

proposed to achieve the ambient lead concentration as required by Rule 1420.1(g)(2)(A) are 

described below.

5.2.2 Additional Compliance Plan Contingent Measures Housekeeping, 

Inspection, and Maintenance [Rule 1420.1(g)(2)(A)(i)]

In addition to continuing and increasing those already-implemented measures set forth in 

Table 7, if Exide has not satisfied the ambient standards it will perform the additional 

maintenance activities actions summarized in Table 8 below. 

Table 8. Additional Pb Compliance Plan Contingent Measures

Action Completion Date Emission 

Source

1

Apply elastomeric coating to the roof and sidewalls of the battery 

breaker building to enhance maintainability of the roof and prevent 

development of pinhole leaks over time.

June 2012 Fugitive
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Additional Compliance Plan Lead Emission

Reduction Measures 17

5.2.3 Additional Compliance Plan Total Enclosure Measures [Rule 

1420.1(g)(2)(A)(ii)]

Once Exide installs the total enclosure for “Baghouse Row” as described in Section 5.1.1, all 

lead point sources at the Vernon plant will be operating inside total enclosures that will be 

vented to existing lead control devices.

In addition, a significant portion of the plant property will also be contained within total 

enclosures. Any fugitive dust generated on these operating areas will be contained and vented 

to existing lead control devices.

As a result, Exide does not envision that any additional total enclosures (beyond that already 

described for the enclosure of “Baghouse Row”) will be available to be enclosed that would 

reduce Pb emissions.

5.2.4 Modifications to Lead Control Devices [Rule 1420.1(g)(2)(A)(iii)]

5.2.5 Installation of Multi-Stage Lead Control Devices [Rule 1420.1(g)(2)(A)(iv)]

The secondary HEPA filters were not yet installed on the North and South Torits by July 1, 2011 

so their emission reduction benefits were not being fully felt at the ambient monitors when the 

original Compliance Plan was submitted. The installation was completed by the end of July with 

subsequent source tests being performed approximately one month later.

Section 4 outlined the ambient modeling Exide performed demonstrating that ambient Pb 

concentrations at all monitors will be less than 0.15 μg/m3 once all enclosures are fully 

operational. As a result, installation of additional multi-stage lead control devices will not be 

needed to meet the ambient Pb concentration.

5.2.5a Negotiated Potential Contingent and Future Measures

Though Exide maintains that such measures may not be necessary or appropriate (as set forth 

in sections 5.2.3 – 5.2.5), after discussion with the District, Exide has nonetheless agreed to 

certain potential contingent measures that may be implemented in the event of a future 

exceedance. These potential contingent future measures are governed by Conditions 8-11 in 

Appendix C.

5.2.6 Process Changes, including Reduced Throughput Limits [Rule 

1420.1(g)(2)(A)(v)]

Upon careful consideration, Exide has not identified any issues with its basic processes or lead 

processing equipment and technologies that are hindering achieving the ambient standard. 

Fundamental process changes are not, therefore, proposed as Contingent Measures. However, 

as highlighted elsewhere in this Plan, Exide has proposed additional enclosures of those 

processes and equipment which Exide has modeled to be effective in achieving the NAAQS. 

With these enclosures (as well as Exide’s other required and voluntary actions under 1420.1), 

Exide does not expect throughput limits to be necessary.

In order to assess whether process changes or throughput reductions may be necessary or 

effective, Exide plotted the daily ambient air measurements since 2010 from the specified 

monitors against the corresponding throughput rates for that day (Figure 4). For this exercise, 
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Additional Compliance Plan Lead Emission

Reduction Measures 18

throughput is taken as the sum of the reverberatory furnace and blast furnace charging rates. 

Figure 5 is a bar chart that shows the average daily ambient air measurement for different 

ranges of daily production rates (tons/day).

All graphs clearly show that, for the plant configurations that existed during the time period 

represented by these charts, there is no correlation between throughput rate and the 

measurements taken from the various ambient monitors. At relatively low production rates 

(< 200 tons/day), the average reading from the indicated monitors is essentially the same as the 

readings at higher production rates (> 200 tons/day).

As Exide has demonstrated in the past, baghouses and other mechanical filtration devices are 

constant outlet concentration devices, not constant control efficiency devices. Their emission 

rates are determined by the concentration of contaminants bleeding through the filtration media 

which, once the filter media is “loaded” on the inlet side, remains relatively constant and 

independent of variations of inlet concentrations to the collector. Thus, emissions from such 

collectors also do not vary with the underlying process rates giving rise to those inlet 

concentration loadings. Therefore, if the ventilation fan serving a given baghouse is on, 

emissions are relatively constant and independent of process rates.

Given the demonstrated lack of any relationship between throughput rates and ambient monitor 

results at this facility, and the underlying principles of operation of the lead emission control 

devices at this facility, we believe that reduced throughput limits will not reduce lead 

concentrations at ambient monitors and are not an appropriate element for inclusion as a 

Compliance Plan measure. 

Nonetheless, in its December 2011 revised Compliance Plan Exide suggested an approach that 

would have reduced throughput limits on a conditional basis. Exide has since negotiated certain 

conditional curtailments with the District, which are set forth in Section 5.2.7.

5.2.7 Conditional Curtailments [Rule 1420.1(g)(2)(A)(vi)]

As stated in Section 3.1 and elsewhere in this Plan, once Exide completes the installation of the 

total enclosures, emissions from fugitive sources are not expected to be a major contributor to 

lead concentrations.

Installation of upgrades at the point sources will ensure compliance with the emission limit 

established by Rule 1420.1(f)(2). As was stated in Section 3.2.2, the facility-wide Pb emission 

rate from all point sources from the most recent source tests is much less than the 0.045 lbs/hr 

limit established by the rule.

Reductions in process throughput will not reduce the lead concentration measured at ambient 

monitors as was described in section 5.2.6.

Reduction in emissions will be accomplished through the significant reduction in fugitive 

emissions, the installation of total enclosures and upgrades to the point sources. For the same 

reasons that “reduced throughput limits” are not an appropriate measure for reducing ambient 

impacts from this facility, neither are “conditional curtailments” involving processing or 
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Additional Compliance Plan Lead Emission

Reduction Measures 19

production rates or activities Exide has demonstrated repeatedly using actual data from this 

facility that ambient monitor concentrations have no relationship to process throughput rates.

As stated above in Section 4, dispersion modeling indicates that stack emissions would not be 

the cause should 30-day ambient concentrations exceed 0.15 μg/m3 after completion of the 

Baghouse Row enclosure. Accordingly, should any activities at the site be conditionally 

curtailed in response to such an occurrence, the curtailed activities should only be those 

associated with the potential generation of fugitive emissions rather than process activities that 

are enclosed and ventilated to point sources.

However, Exide recognizes that the District has requested additional process/throughput 

curtailment options. Therefore, in order to address the issues raised in the District’s December 

1, 2011 correspondence, and in the spirit of good faith cooperation with the District, Exide 

proposed a structure for conditional curtailments in its December 2011 revised Compliance 

Plan, to be implemented in the event that ambient concentrations exceed the 0.15 μg/m3

standard measured over 30 consecutive days. Exide continues to maintain that, if implemented, 

a curtailment structure must be reasonable and proportional, must conform to the Hearing 

Board’s 2008 Order (3151-18) and other Hearing Board precedent, and must allow Exide a 

reasonable due process opportunity to identify and correct episodic causes for potential ambient 

exceedances without submitting to curtailment.

After its December 2011 submittal, Exide and the District continued to engage in discussions 

regarding conditional curtailments. In the spirit of good faith, Exide has agreed to implement the 

following (set forth in Appendix C):

1. 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 μg/m3

, 

but no more than 0.23 μg/m3

, on a rolling 30 day average at any AQMD or AQMDapproved 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 μg/m3

.
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Additional Compliance Plan Lead Emission

Reduction Measures 20

2. 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 μg/m3

, 

but no more than 0.30 μg/m3

, on a rolling 30 day average at any AQMD or AQMDapproved 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 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 μg/m3

.

3. 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 μg/m3

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 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 

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 30 consecutive 30-calendar day averages of less than 0.15 

μg/m3 or the monitoring results at the affected monitoring station reflect ten 

consecutive days below 0.12 μg/m3 and no other monitor causes a violation of Rule 

1420.1.

4. Exide may avoid the mandatory curtailments set forth in Conditions 1 through 3 by 

seeking a waiver from the Executive Officer. Such request for waiver must be supported 

by substantial and credible evidence that Exide is not the cause of the exceedance or 

that Exide has definitely identified and corrected the cause of the exceedance. The 

foregoing shall not prevent Exide from seeking relief from these requirements upon 

application to the Hearing Board.
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Additional Compliance Plan Lead Emission

Reduction Measures 21

5.3 Implementation Schedule for All Additional Compliance Plan Lead Emission 

Reduction Measures (Early Action Measures and Contingent Measures)

For ease of reference, a complete chart listing all Additional Compliance Plan Lead Emission 

Reduction Measures (both Early Action Measures and Contingent Measures) and their 

completion dates and implementation schedule can be found at Appendix A. Appendix A also 

includes graphics indicating the location of each activity. In addition, Appendix C sets forth the 

negotiated and District-approved conditions that Exide must satisfy.
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Conclusion 22

6 Conclusion

The Plan described herein demonstrates that the combination of measures already undertaken 

(both Rule Required and voluntary Compliance Plan Early Action Measures) at the Exide 

Vernon facility and measures for which applications have already been submitted will be 

sufficient to assure future compliance with the ambient standard of 0.15 μg/m3 established in 

Rule 1420.1. The primary elements of the Plan are the installation of secondary filtration on 

selected sources (the kiln dryer baghouse and the Torit cartridge collectors) and, most 

significantly, the construction of an additional large enclosure to house the facility’s baghouse 

operational area. Completion of the pending enclosure will occur by the end of March 2012. 

Dispersion modeling indicates that with the completion of these projects, Exide will comply with 

the ambient standards (both federal and Rule 1420.1). If Exide continues to exceed the NAAQS 

in 2012, Exide is prepared to promptly implement additional voluntary Contingent Measures to 

reduce emissions.
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Figures
y = -0.0007x + 0.8512

R2 = 0.0244

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

0 100 200 300 400 500 600 700 800

Lead Conc. @ Exide Monitors (μg/m3)

Reverb + Blast

Figure 4a - Charge: Reverb + Blast v. On-site N
y = -0.0004x + 0.4403

R2 = 0.0555

0.00

0.20

0.40

0.60

0.80

1.00

1.20

1.40

1.60

1.80

0 100 200 300 400 500 600 700 800

Lead Conc. @ Exide Monitors (μg/m3)

Reverb + Blast

Figure 4b - Charge: Reverb + Blast v. Concentration MID
y = 6E-05x + 0.391

R2 = 0.0003

0.00

0.50

1.00

1.50

2.00

2.50

3.00

0 100 200 300 400 500 600 700 800

Lead Conc. @ Exide Monitors (μg/m3)

Reverb + Blast

Figure 4c - Charge: Reverb + Blast v. Concentration NE
y = 0.0002x + 0.2339

R2 = 0.0046

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

0 100 200 300 400 500 600 700 800

Lead Concentration at AQMD Monitors (μg/m3)

Reverb + Blast

Figure 4d - Charge: Reverb + Blast v. Concentration Rehrig
y = -0.0009x + 0.8679

R2 = 0.0217

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

0 50 100 150 200 250 300 350 400 450 500

Lead Conc. @ Exide Monitors (μg/m3)

Reverb + Blast

Figure 4e - Production: Reverb + Blast v. Concentration On-site N
y = -0.0006x + 0.4582

R2 = 0.0565

0.00

0.20

0.40

0.60

0.80

1.00

1.20

1.40

1.60

1.80

0 50 100 150 200 250 300 350 400 450 500

Lead Conc. @ Exide Monitors (μg/m3)

Reverb + Blast

Figure 4f - Production: Reverb + Blast v. Concentration MID
y = 6E-06x + 0.4115

R2 = 2E-06

0.00

0.50

1.00

1.50

2.00

2.50

3.00

0 50 100 150 200 250 300 350 400 450 500

Lead Conc. @ Exide Monitors (μg/m3)

Reverb + Blast

Figure 4g - Production: Reverb + Blast v. Concentration NE
y = 0.0002x + 0.2543

R2 = 0.0018

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

0 50 100 150 200 250 300 350 400 450 500

Lead Concentration at AQMD Monitors (μg/m3)

Reverb + Blast

Figure 4h - Production: Reverb + Blast v. Concentration Rehrig
0.00

0.20

0.40

0.60

0.80

1.00

1.20

1.40

0 - 99 100 - 199 200 - 299 300 - 399 400+

Average Lead Concentration (μg/m3)

Reverb + Blast Production Rate (tons/day)

Figure 5 - Average Pb Concentration at On-Site N Monitor vs Production (Jan 2010 - Jan 2012)
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Appendix A

List of Compliance Plan Measures
Appendix A – List of Compliance Plan Measures (1-20-2012)

Action Completion Date

1 Install door(s) between shipping and smelting to enhances negative 

pressure in refining/smelting and reduce draft from shipping. Oct 2010

2

Install an automated door on the southeast end of the corridor 

connecting the reverb and blast feed rooms to reduce the amount of 

time that the door is open

Nov 2010

3 Install a new vehicle wheel wash station in the west yard of the plant Jun 2011

4 Completely resurface the west yard of the facility to enhance the 

effectiveness of pavement cleaning activities Jul 2011

5 Installed MERV 15 rated cartridge filters in the North and South Torit 

collectors Jul 2011

6 Upgraded ride-on yard sweeper to a wet scrubbing unit for cleaning of 

plant yard pavement Oct 2011

7 Install ventilated negative pressure enclosure for “Baghouse Row” March/April 2012

8 Modify railcar dock at the south end of the smelting building to allow 

receiving of industrial plates and dedicated inside and outside forklifts. Jun 2012

9 Replace strip curtains with doors at north and south end of RMPS 

building Dec 2011

10

Install new vehicle and equipment decon and wash area at the north 

end of baghouse row as part of the baghouse row enclosure 

construction

Dec 2011

11 Eliminate and close mobile equipment wash area at south of plant

ASAP (Notify 

DTSC, pending 

DTSC approval)

12 Focused housekeeping and other horizontal surfaces in Baghouse 

Row, pending completion of enclosure of area

Nov 2010- Dec 

2011

13

Install two backup diesel generators to supply electrical power to drive 

the fans serving the two process furnace exhaust baghouses and the 

two Torit collectors during power outages

Jun 2012

14 Install at least six (6) boot wash stations at exist of total containment 

buildings June 2012

15 Designate one or more forklifts for exclusive use inside total 

containment buildings June 2012

16

Apply elastomeric coating to the roof as well as vertical and horizontal 

surfaces of the battery breaker building to enhance the maintainability 

of the roof and prevent the development of pinhole leaks over time

Contingent 

Measure, per 5.2.2
Appendix A – List of Compliance Plan Measures (1-20-2012)

Action Completion Date

17 Curtailment of specific activities

Contingent. Per 

5.2.7 and Appendix 

C Conditions 4-6

18 Potential Contingent Measures

Contingent. Per 

Appendix C, 

Conditions 8-11
SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Appendix B

December 1, 2011 Letter from the SCAQMD


SCAQMD Rule 1420.1 Revised Compliance Plan

For Exide Technologies (Vernon Plant)

Appendix C

Conditions
1

APPENDIX C

CONDITIONS

1. Exide shall implement all lead mitigation measures described in the Compliance Plan

resubmitted by Exide in January 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.

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 μg/m3

, 

but no more than 0.23 μg/m3

, on a rolling 30 day average at any AQMD or AQMDapproved 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 μg/m3

.
2

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 μg/m3, 

but no more than 0.30 μg/m3

, on a rolling 30 day average at any AQMD or AQMDapproved 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 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 μg/m3.

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 μg/m3

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 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 

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 30 consecutive 30-calendar day averages of 

less than 0.15 μg/m3 or the monitoring results at the affected monitoring station 

reflect ten consecutive days below 0.12 μg/m3 and 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 

writing within 48 hours of completion of the construction.
3

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

μg/m3 on a rolling 30 day average at any AQMD or AQMD-approved ambient monitor, 

Exide shall commence implementing 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 

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

implementation timeline shall also be included and shall be established based on Exide's 

best effort for implementation. The selected measure(s) shall be implemented as 

approved by the AQMD. These specific 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 of the smelter building.

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.
4

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 written 

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

construction of such enclosure(s) listed in part D of this 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 μg/m3 rolling 30 day 

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

required for additional violations of the 0.15 μg/m3 rolling 30 day average lead 

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

Exide shall notify the AQMD 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.
5

12. Exide retains the right to seek relief from these Conditions via application to the Hearing 

Board, as appropriate.