Corrective Action

Overview

DTSC provides oversight to the corrective action activities for the clean-up of the identified Solid Waste Management Units (SWMUs) at Exide. Corrective Action activities being overseen by DTSC are listed below and are an on-going process.

RCRA Facility Investigation Phase I (Soil and Sediment Sampling in the adjoining Drainage Channel)

On May 20, 2004, DTSC sent a letter requiring Exide to submit for review and approval, a field sampling and analysis plan (FSAP) for collecting soil and sediment in the adjoining Open Drainage Channel that runs from north to south of the Exide Facility. On June 25, 2004, DTSC approved the FSAP which was implemented on August 4, 2004. Soil and sediment sampling analyses came back with concentrations of lead above acceptable levels. DTSC required Exide to immediately address the cleanup of the channel. Under DTSC’s oversight, approximately 20 cubic yards of contaminated soil was removed from a 100,000 square foot of surface area which included the concrete floor and banks of the open drainage channel.

RCRA Facility Investigation Phase 2 (SWMU -1, SWMU-6, and SWMU-11)

The workplan focused on investigating the extent of known releases from SWMU-1 (Old Slag Landfill), SWMU-6 (Earthen Acid Pit), and SWMU-11 (former Old Mixed Metal Extrusion Building Area). The investigation was completed in 2006 and additional investigations to delineate the nature and extent of off-site contamination for the Old Slag Landfill and Earthen Acid Pit are being conducted under Phase 3 investigation. In addition, elevated concentrations of volatile organic compounds (VOCs) were detected within the area of the Old Mixed Metal Extrusion Building. DTSC required Exide to submit a workplan to remove VOCs contamination and so minimize potential vapor intrusion and groundwater infiltration. Current planned activities include the collection and analyses of additional soil vapor samples at specific targeted areas prior to construction and operation of the soil vapor extraction system (SVE).

RCRA Facility Investigation Phase 3 (Off-site Extent of Old Slag Landfill and Establishing Better Hydrologic Control at Acid Waste Disposal Pit and Downgradient of Facility).

The Phase 3 investigation was intended to: (a) determine the extent of off-site subsurface contamination related to historical slag and acid waste disposal by the facility, (b) to establish better hydrologic control in the vicinity of Acid Waste Disposal Pit, and (c) to establish better downgradient hydrologic control along Bandini Boulevard. Work began in 2007 but because of access agreement issues, the final well was installed in 2011. Six (6) soil borings and two wells were installed. DTSC is currently reviewing the phase 3 RCRA Facility Investigation (RFI) Report.

RCRA Facility Investigation Phase 4 (Combined Sampling at Closing HWMUs and Most Remaining SWMUs)

DTSC is currently reviewing the Phase 4 RFI Workplan which is a combined closure and RFI activities for the former Wastewater Treatment Tanks System areas, Baghouse Row Tanks, and RMPS Building Area Tanks.

Interim Measure Workplan – SWMU-11

Significant trichloroethene (TCE) contamination was encountered in shallow ground water at the southeastern corner of the facility. This roughly corresponds to the former location of the Old Mixed Metals Extrusion Building (SWMU-11). Gas-phase TCE was confirmed in the vadose zone (soil and deeper unsaturated materials) during the Phase 2 RFI. DTSC required an interim measures (IM) workplan together with specific approval conditions from February 25, 2009 through May 30, 2009 and subsequently approved the workplan on June 30, 2010 for implementation. The IM is to construct and operate a soil vapor extraction (SVE) system to remove TCE from the vadose zone. However, in response to the approval conditions for the IM, Exide requested a delay in implementation in order to submit a supplemental workplan to provide baseline soil gas information. This workplan proposed four soil gas locations instead of the more extensive base-line network in the IM approval conditions. DTSC is currently reviewing the supplemental workplan.

RCRA Facility Investigation Phase 5 (Los Angeles River Sediment Sampling)

Lead-bearing slag and lead dust were found in the concrete-lined storm water channel that crosses the site from north to south and discharges into the Los Angeles River. A workplan was required to evaluate whether or not there was evidence of direct releases of lead from facility operations into the Los Angeles River. The sampling will be from the confluence of the cross-site drainage channel and the Los Angeles River downstream to the South Atlantic Boulevard overpass. DTSC conditionally approved the revised Workplan on September 9, 2011 and required that work begin by mid-October 2011.

Interim Measures for Emergency Clean-up of Off-site Airborne Deposition/Accumulation

This was an emergency cleanup required to address the discovery of off-site airborne/deposition of lead particulates emitted by Exide in areas where the public was subject to exposure. The effort was primarily directed at abating the lead contamination on the roof and parking lot at the neighboring Rehrig Pacific Facility and within specified sections of the rights-of-way for East 26th Street, South Indiana Street and Bandini Blvd. Although, the work at Rehrig Pacific Facility was finished on February 2, 2010, portions of the roof still appear to have lead embedded in the roofing at hazardous waste concentrations. The embedded lead is not a threat to human health and the environment.

RCRA Facility Investigation Phase 6 – Area-wide Airborne Deposition/Accumulation

DTSC has reviewed the Phase 6 Workplan which expands the area investigation of airborne lead deposition/accumulation on a number of additional private parcels being planned for evaluation, including building roofs and off-site public right-of-ways. This is an expansion of the 2009 Emergency Interim Corrective Measures Cleanup for Off-site/Soil/Dirt. The workplan has been reviewed by DTSC.