The Exide Technologies battery recycling plant in Frisco, Texas, provides an unsettling example of how difficult it is to protect the public from industrial pollutants, like lead, and illustrates problems when the Texas Commission on Environmental Quality (TCEQ), the state’s environmental regulatory agency, concentrates efforts on air emissions only.
Exide Technologies is one of the world’s largest secondary lead recyclers. In November 2010, Exide Technologies and the city of Frisco garnered national attention as one of 16 locations in 11 states to be designated as a lead nonattainment area by the Environmental Protection Agency (EPA). This followed a revision to National Ambient Air Quality Standard (NAAQS) for lead, reducing the level from 1.5 to .15 micrograms per cubic meter. The EPA took action to tighten the standard as a means to further protect children, an at-risk group particularly vulnerable to lead effects.
City, state and citizen attention focused on Exide with demands for the plant to reduce its lead emissions. On June 22, TCEQ commissioners moved forward with a proposed agreed order detailing a timetable and methodology for Exide to invest nearly $20 million to upgrade its pollution abatement equipment and revise its processes to meet the federally mandated air standard for lead. The improvements will also reduce cadmium and other heavy metal pollutants released by the battery recycling operation. A public comment period for the proposed agreed order will run through August 8, 2011.
The NAAQS, as part of the Clean Air Act, sets the standard for air emissions only. Therein lies the problem. The agreed order, if enacted, will reduce future lead air emissions from Exide. It, however, does not fully address overall community exposure to lead from the Exide plant. For over 40 years, Exide operations introduced lead not only into the air, but into water and soil as well.
In December 2009, EPA conducted a compliance inspection of the Exide plant in Frisco. The report, recently made available to the public, details issues beyond air emissions. Storm water runoff, soil and groundwater contamination, and ill-maintained equipment are all areas covered in the comprehensive EPA documents.
The EPA inspection gave the Exide plant unsatisfactory marks in several evaluated areas. Of particular note, the report documented unauthorized storm water runoff from the facility into Stewart Creek. The EPA report states, “The facility appears to be having an ongoing unpermitted discharge of contact storm water from the process areas. A white crystallized substance was observed deposited in certain areas along one bank of Stewart Creek and on the concrete walls of the floodwall at the elevated pipe area. The crystallized substance is the dried remains of contact storm water seepage…..Analytical results show that this substance tested high for metals.”
The EPA found Exide discharged storm water under an expired permit. A recent check of TCEQ’s database shows Exide continues to operate under the expired storm water permit a year and half after the EPA inspection.
Exide also received an unsatisfactory rating for its operations and maintenance. The mix and filter tanks of Exide’s water treatment facility were found to be heavily corroded, and inspectors expressed concern about the tanks’ structural integrity.
Soil samples taken in early 2010 by the EPA found lead levels far in excess of the industrial standards of 800 parts per million (ppm). In one case, an analysis of white powder taken from the wall of a container storage area found lead concentrations of 5,610 ppm. Soil contamination is an ongoing issue with facility reports showing several areas with contaminated soil above 1000 ppm as far back as 1993.
No action appears to have been taken to remediate the contaminated soil. Even more surprising, Exide stopped monitoring potential soil contamination. The EPA report states “…from approximately 1993 until 2001, the facility collected soil samples annually from the perimeter of the property to follow trends of lead deposition. The sampling stopped when Exide filed for bankruptcy in 2001.”
It’s unknown whether the soil contamination has impacted the aquifer. Exide stopped monitoring groundwater in 2002 because it was not a requirement of Exide’s permit from TCEQ.
Perhaps the most alarming tidbit within the EPA report concerns potential contamination throughout Frisco. Exide’s Environmental Manager relayed to EPA inspectors that before the 1980’s regulations “… the City used battery casings from the plant as road base throughout the city.”
While actively monitoring air quality, TCEQ failed to assess potential contamination of groundwater, storm water or soil from the plant. The revelation that battery casings were used in some Frisco roadbeds expands the potential lead contamination to soil and water beyond Exide’s fence line.
The proposed agreed order would undoubtedly reduce future lead air emissions, but it will not fully address community exposure to lead and other battery recycling pollutants. A comprehensive examination and plan to remediate contaminated soil and water is critical for reducing overall community risk.
A full copy of EPA Region 6 multi-media inspection of Exide Technologies is available online on the community group Lead Free Frisco’s website at leadfreefrisco.com.
A copy of the proposed agreed order for reducing lead emissions at the Exide Technologies facility in Frisco can be found on TCEQ’s website at tceq.state.tx.us.
Sources and Websites:
TCEQ lead stakeholder group
EPA Region 6 Multi-media Inspection of Exide Technologies dated September 2010