Memorandum

Subject:		Teleconference with Exide Technologies

Location:		U.S. Environmental Protection Agency, RTP, NC
	
Date:			November 21, 2011

Participants:	 	Nathan Topham, EPA
			Steven Silverman, EPA
			Dean Rossi, Exide
			Jonathan Martel, Arnold and Porter representing Exide
            Russell Kemp, ENVIRON
			Donna Lazzari, ERG

The U.S. Environmental Protection Agency (EPA) met via telephone with representatives of Exide Technologies.  The meeting was held at Exide's request to discuss issues the company believes to be the most important to address when finalizing the NESHAP for Secondary Lead.  A brief summary of the key points that were discussed is outlined below.

   1. Exide stated its position that the proposed requirements for enclosures for secondary lead smelters were overly stringent and prescriptive. Specifically Exide recommends specifications for the in-draft velocity at enclosure openings be changed from a minimum of 300 feet per minute to a verification that there is in-draft at the openings. Exide noted that the recently published requirements for primary lead processing are less prescriptive than the proposed rules for secondary lead.

   2. Exide stated that the requirement to provide a battery back up on the negative pressure monitoring equipment for secondary lead enclosures is unnecessary and that multiple pressure monitors were not required for primary lead processing enclosures. 

   3. Exide also commented on several of the fugitive emissions work practices that they believed would not significantly reduce fugitive emissions and did not warrant the burden imposed. Specifically, the roof washing requirement and the wash water application rate for pavements were proposed with little or no justification.  

   4. Exide advised the EPA to revise the fugitive emission estimates based on comments received and encouraged the EPA to include in the preamble to the final rule a discussion of the fugitive emissions estimates. 

   5. Exide noted several errors that were contained in the risk assessment analysis. The company requested that these three issues be addressed by the EPA. 
         o  The Exide Frisco dioxin data in the risk analysis was based on estimates prior to receiving actual test data from Exide. The estimates in the risk analysis were much higher than actual.
         o The maximum Arsenic inhalation concentrations are at a receptor inside the facility fenceline at Exide Frisco.
         o The company objected to the addition of risk factors for receptors that are four miles apart.  


During the meeting the EPA inquired about the test data from the Exide Reading facility for dioxins and furans that Exide had previously indicated would be completed in September. Exide had previously stated that they would forward this information to EPA when it was available. Shortly after the meeting, Exide submitted this test data. 
         
