Region 3 GPRA Baseline RCRA Corrective Action Facility


Exide Technologies (General Battery

Corporation)

Nolan Street and Spring Valley Road
Laureldale, PA 19603
Congressional District 6
EPA ID #: PAD990753089
Last Updated: 12/30/2005


Current Progress at the Site	

The Exide Technologies facility is located in Laureldale, PA and is approximately 45 acres in size. In
August 2000, the United States Environmental Protection Agency (EPA) issued the Administrative
Order on Consent (AOC) to Exide. As part of the AOC requirements, Exide will collect additional soil
samples in Laureldale Borough and Muhlenberg Township to assess the extent of soil lead
concentrations that are above EPA's screening level. Each property within the boundary of the
screening level will be sampled for lead in soil.  Properties that have an average lead exposure above
the determined lead clean-up levels will be cleaned-up. As an interim measure, the AOC requires
Exide to clean-up nineteen properties adjacent to the facility as directed by a Consent Order and
                                                                  Agre
                                                                  emen
                Figure 1  Exide Technologies, Laureldale, PA

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Environmental Protection (PADEP), which was issued on May 22, 2000. The clean-up of the nineteen
properties was completed in October 2000.  In early November 2000 and at EPA's request, Exide
voluntarily tested the soils of an approximately additional twenty properties in the northern proximity of
the facility. Four of the twenty-two properties require no further corrective action. The remaining 18
properties will be further evaluated pursuant to the AOC.

A public comment period was set from September 8 through October 23, 2000. A public meeting was
held on September 27, 2000 at the Muhlenberg Middle School, 801 E. Bellevue Street, Reading,
Pennsylvania, for the community and all other interested parties to hear a description of the AOC and
to ask questions. The meeting was attended by a total of 37 people, including representatives of EPA,
Pennsylvania Department of Environmental Protection (PADEP), the local government, and citizens.
This was an opportunity for the public to comment on the AOC and to present any issues and
concerns. Comments and oral testimony given at the meeting and comments received during the
comment period were considered and addressed by EPA in the Response to Comments and
summarized in the RTC fact sheet.

Recent Progress and Developments

(1st Qtr. 2001)

The AOC became effective March 2, 2001. Exide submitted the Draft Step 1 Environmental Sampling
Work Plan for EPA's review.  EPA had several comments on the work plan. Exide is currently revising
the work plan in response to EPA's comments.  Although the work plan requires some revisions, EPA
has approved the first step of the soil sampling event.

Exide began the investigation in mid-April. The first step entails collecting approximately
90 discrete supplemental soil samples in Laureldale Borough and Muhlenberg Township to refine the
boundaries of the study area. To properly oversee the work, EPA collected split soil samples with
Exide at various locations to ensure the validity of the soil  results.

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The soil samples were analyzed and soil lead concentration values were inserted into a
geostatistical model (Kriging) to identify areas that are not likely to exceed 400 parts per
million (ppm) for lead in soil. This defined the extent of contamination (i.e., study area)

(2nd Qtr. 2001)

EPA approved the Step 1 Environmental Sampling Work Plan. The Work Plan entails two phases of
soil sampling.  The first phase is to refine the boundaries of the study area. The second phase is to
determine the average lead concentration in soil for each property within the study area.

During the month of April and early May, Exide collected approximately 90 soil samples in Laureldale
Borough and Muhlenberg Township to refine the boundaries of the study area. The soil samples were
analyzed and soil lead results were used to identify areas that are not likely to exceed 400 parts per
million (ppm) for lead in soil. This defined the extent of the study area.  Properties within the study
area received a letter from Exide asking permission to conduct soil sampling. Residents that have
agreed to the soil sampling have had their property sampled or will be sampled shortly.  The purpose of
the soil sampling is to determine the average lead concentration for each property.  It is expected that
the property soil sampling will be completed by the end of the summer.  Property owners will receive
the results of the soil sampling in the Fall.

EPA, PADEP and Exide investigated Bernhart Park during the month of June. The assessment consists
of soil, sediment and surface water sampling.  EPA is currently reviewing the results of the sampling.
EPA will present the findings of the assessment at the public meeting in November 2001.

Exide submitted the Step 2 Environmental and Human Health Sampling Work Plan, which is a follow-
up to the Step 1 Work Plan. The Step 2 Work Plan entails the Risk Assessment Sampling (i.e., soil,
dust, and tap water sampling and paint screening), Blood Lead Study, and Site-Specific Risk
Assessment. The Risk Assessment Sampling and Blood Lead Study will focus on the most vulnerable
residents (e.g., children under the age of 84 months, and pregnant women). The data will be
incorporated in the  Site-Specific Risk Assessment to determine the clean-up levels for lead in soil.
EPA is currently reviewing the Step 2 Work Plan.

(3rd Qtr. 2001)

EPA has received and is currently reviewing the Bernhart Park Assessment Report.  Exide continues
to conduct soil sampling of properties within the study area.  So far, approximately 350 properties have
been sampled.  The results of the soil sampling will be mailed to the property owners in the Fall.  In
addition to Bernhart Park, the review of the Step 2 Work Plan is ongoing. EPA anticipates to hold a
public meeting in November to present the progress of the investigation and to answer questions.

(4th Qtr. 2001)

A public meeting was held on November 27, 2001 at the Muhlenberg High School, Reading,

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Pennsylvania, to present the progress of the Exide Investigation.  The meeting was attended by
approximately 100 people, including representatives of EPA, PADEP, the local government, and
citizens.  EPA presented the progress of the investigation.  The presentation is summarized below and in
the Public Meeting Fact Sheet Handout and Map.

Soil Sampling of Individual Properties

Approximately 425 properties were sampled, which equate to about 10,000 sample locations. The
results of the soil sampling were used to determine the average soil lead concentration for each
property.  The soil  results were sent to the property owners in November and December. Based on the
soil results, the 425 properties were grouped into three distinct categories. These categories are
defined below:

1.  Properties that do not require clean-ups:

These properties contain soil lead concentrations of 500 mg/kg or less, which meet the Pennsylvania
Department of Environmental Protection (PADEP) Statewide Health Standard.  The properties do not
require soil clean-up and are not subject to further evaluation. This determination completes Exide's
investigation on these properties. One hundred six properties do not require clean-ups. .

2.  Properties that require clean-ups:

These properties contain soil lead concentrations of 1200 mg/kg or greater, a level that EPA has
determined requires clean-up to ensure long term protection for children. Forty-seven properties were
determined to have soil lead concentrations above 1200 mg/kg. Thirty-seven out of the forty-four
properties will be cleaned-up in Spring 2002. The remaining seven properties, which are either vacant,
do not have children residing on the property, or do not pose a high frequency of exposure, will be
addressed in subsequent clean-ups.  Because of the difficulties associated with soil excavation and the
low frequency of soil exposure during the winter months, Exide will implement the soil clean-up in
Spring 2002. Exide will contact the property owners in advance before any work begins.

3.  Properties that will be retained and re-evaluated:

These properties contain soil lead concentrations between 500 mg/kg and 1200 mg/kg.  The levels do
not present an immediate problem. These properties will be retained and re-evaluated for the second
phase study next year. The second phase study will determine the site-specific clean-up level.  The
properties will be re-evaluated based on this clean-up level. Properties with soil lead concentration
below the site-specific clean-up level do not pose a health risk and therefore, will not require soil clean-
ups.  Properties with soil lead concentration above the site-specific clean-up level will require soil
clean-ups.

Expansion of Study Area

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The original study area was expanded to fully define the extent of soil lead contamination.  The
expansion of the study area can be viewed in the Public Meeting Fact Sheet Handout and Map
webpage.  The expansion includes soil sampling of an additional 150 properties. The property owners
were contacted by Exide in October.  The properties were sampled in November or will be sampled
shortly. The results of the soil sampling will be mailed to the property owners in February 2002.

Bernhart Park Assessment

In addition to soil sampling of the individual properties, EPA , PADEP and Exide assessed Bernhart
Park this past summer. This assessment entailed soil, sediment, and surface water sampling.  Lead
levels detected in sediment and surface water in the reservoir do not pose a human health risk and
therefore, the reservoir do not require clean-up. EPA has identified ground areas in the park that will
require remediation. EPA is currently working with Exide and the City of Reading to put together a
proposal to clean-up these areas. Our goal is to begin soil clean-up at the park in Spring 2002 with the
anticipation of re-opening park in the Summer of 2002.

Ongoing and Future Activities

As we look ahead to the future, we anticipate to complete the following goals in the up-coming years:

   Complete the delineation of the study area by December 2001.
•  Clean-up 37 properties in Spring  2002 with the 7 properties to follow.
•  Clean-up Bernhart Park and re-open the park for recreational use in Summer 2002.
   Collect data for the second phase study in Summer 2002 to determine the site-specific clean-up
   level.
   Complete the second phase study in  Spring 2003.
•  Re-evaluate properties with soil lead concentrations greater than 500 mg/kg but less than 1200
   mg/kg. Commence clean-ups of properties with soil lead concentrations above the site-specific
   clean-up level in Spring 2003.

(1st Qtr. 2002)

Exide completed additional soil sampling in the expanded areas.  A revised study area was delineated
from the additional soil results. Properties that were recently sampled in the expanded areas should
receive their results by the  end of May 2002. Thus far, EPA has identified seventy-one (71) properties
that require soil clean-ups.  Nineteen (19) of the seventy-one (71) properties were cleaned up in Fall
2000. The remaining fifty-two (52) properties will be cleaned up this summer.  The property owners
have been notified of the soil clean up.  Exide is expected to begin the soil clean up by mid-June.  The
soil clean up is expected to be completed by October 2002.  In addition, EPA has identified a total of
two hundred fourteen (214) properties that have an average soil lead concentration equal to or less than
the Pennsylvania Department of Environmental Protection (PADEP) Statewide Health Standard of 500
mg/kg.  These properties will not require soil clean up.  The remaining properties, which are
approximately 300 properties, have soil lead concentrations greater than 500 mg/kg but less than 1200

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mg/kg.  These levels do not present an immediate problem.  However, these properties will be retained
and re-evaluated for the second phase study to be completed by next year.

EPA is currently working with Exide and the City of Reading to finalize the work plan  to clean-up
Bernhart Park. Our goal is to begin soil clean-up in Spring 2002 with the anticipation of re-opening
park in the Summer of 2002.

(2nd Qtr. 2002)

Given Exide's present financial difficulties, the company filed for Chapter 11 Bankruptcy, which entails
reorganization of the company. By enlarge, the bankruptcy will not impede the progress of the soil
investigation and clean ups. Exide is committed  to the clean- up of the fifty-two (52) residential
properties this summer. Exide will begin the residential  soil clean-up in June.  The soil clean up is
expected to be completed by October 2002. As presented in the previous public meeting in Nov.
2001, Exide will initiate the second phase study to determine the site-specific clean up level this
summer. This work is proceeding accordingly. EPA plans to schedule a public meeting later this
summer to present the progress of the residential  clean ups and the second phase study.  The residents
and interested parties will be informed of the public meeting in advance.

Because of the bankruptcy and the limited funds  available, the clean up of Bernhart Park may be
delayed. EPA is working with Exide and the City of Reading to establish a feasible time frame for the
clean up of the park.

(3rd Qtr. 2002)

Since the last public meeting, one additional property was added to the list of properties to be cleaned
up. This makes the total of 53 occupied residential properties with elevated soil lead concentrations of
1200 parts per million (ppm) or greater that will require soil clean up. These soil lead levels pose a
significant health risk, particularly to children six years old and younger. Exide began the soil clean ups
of the properties in June 2002. The clean ups consist of an initial landscape survey of the properties,
with an approximate 6 to  12 inches of excavation, depending on the magnitude of contamination.
Confirmatory soil samples are collected and analyzed after excavation to ensure that the cleans up meet
regulatory requirements.  The properties are than backfilled with clean soil  and restored to their original
conditions. The  clean ups of the 53 properties are expected to be completed by the end of October
2002.

On August 8, 2001 EPA held a public meeting at the Muhlenberg Middle School,  Reading,
Pennsylvania, to present the progress of the Exide investigation and remediation.  The meeting was
attended by approximately 50 people, including representatives of EPA, PADEP, local government,
and citizens. EPA and Exide presented the progress of the investigation, residential clean ups and
upcoming activities. The outline of the public meeting is summarized in the August 8, 2002 Public
Meeting Handouts.

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Exide is currently collecting additional data as part of the Step 2 Investigation. The Step 2
Investigation will determine the site-specific soil clean up levels that will be protective of human health
and the environment.  The Investigation targets residences with children six years old and younger and
consists of additional environmental sampling (e.g., tap water, house dust, lead-based paint screening)
and a blood lead study.  Exide will complete the Step 2 Investigation by spring 2003. The results of the
Investigation will determine the site-specific soil clean up levels that will be apply to the remaining
properties. Properties with soil lead concentrations greater than the site-specific soil clean up levels will
require clean up. Properties with soil lead concentrations less than the site-specific soil clean up levels
will not require soil clean up.

(4th Qtr. 2002)

Exide completed the clean ups of the 53 residential properties on November 24, 2002.  Furthermore,
Exide conducted soil sampling for approximately 20 additional properties within the Study Area. The
property owners should receive their results by March of next year.

The Step 2 Investigation is ongoing. Exide completed the supplementary data collection and is
progress of reviewing the data. The Step 2 Investigation should be completed by spring/summer 2003.
The results of the investigation will determine the site-specific soil clean up levels that will be applied to
the remaining properties. Properties with soil lead concentrations greater than the  site-specific soil
clean up levels will require clean up.  Properties with soil lead concentrations less than the site-specific
soil clean up levels will not require soil clean up.

(1st Qtr. 2003)

As reported in the previous quarter, the Step 2 Investigation is ongoing. We anticipate that the Step 2
Investigation will be completed this year.  The results of the investigation will determine the site-specific
soil cleanup levels that will be applied to the remaining properties.

Properties that were sampled for soil lead concentrations during the fall and winter of 2002 will receive
their results this quarter. Properties with soil lead concentration below the Pennsylvania Department of
Environmental Protection (PADEP) Statewide Health Standard of 500 parts per million (mg/kg) will
receive a letter from EPA stating that their properties do not require soil clean-up and are not subject to
further evaluation.  All the other remaining properties will be retained and reevaluated as part of the
Step 2  Investigation.

(2nd Qtr. 2003)

The Step 2 Investigation is ongoing. Additional data analysis is required to determine the site-specific
soil cleanup levels that will be applied to the remaining properties. EPA anticipates that the Step 2
Investigation will be completed this summer. EPA expects to hold a public meeting later this year to
present the findings of the Step 2 Investigation.

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(3rd Qtr. 2003)

Exide and EPA are progressing with the Step 2 Investigation.  There have been several delays with the
analysis of the data. EPA anticipates that the Step 2 Investigation will be completed by the end of the
year.

(4th Qtr. 2003)

Exide has submitted the Risk Assessment, which is the final submission to the Step 2 Investigation.  The
national EPA Technical Review Workgroup for Lead (TRW) is currently reviewing the Risk
Assessment to ensure that the Step 2 Investigation is implemented properly.  The final approval of the
Risk Assessment will determine the site-specific soil lead cleanup levels for the study area. A public
meeting will be held in the new year to present the results of the Step 2 Investigation. EPA anticipates
that the next round of residential cleanups will take place during the next construction period, which
normally begins in April or May 2004, weather permitting.

(1st Qtr. 2004)

The completion of the Risk Assessment have been delayed due to inadequate information. Exide is
preparing to  submit the additional information. EPA will re- evaluating the Risk Assessment to ensure
that all supporting information will meet the requirement of the Risk Assessment. At the completion of
the Risk Assessment and the determination of the site-specific soil lead cleanup levels EPA will
schedule a public meeting to present the results of the Risk Assessment and initial the residential clean
up process.

(2nd Qtr. 2004 - Present)

Exide submitted the additional information to complete the Risk Assessment. The EPA Technical
Review Workgroup (TRW), which consists of EPA national experts , is  currently reviewing the Risk
Assessment.   EPA anticipates that the review of the Risk Assessment will be completed shortly.  EPA
will announce its' conclusion and decision on the Risk Assessment later this  year. Following the
announcement, EPA will schedule a public meeting to present and discuss the results of the Risk
Assessment.
Site Description
The Exide Technologies Site occupies approximately 50 acres of land and is located in Laureldale
Borough and Muhlenberg Township, just northeast of Reading, PA. The Facility began operating as a
battery manufacturing plant in the mid-1930s under the ownership of the Bowers Battery Company.
General Battery Corporation purchased the facility in 1958, and was itself acquired by Exide in 1987.
The Facility currently recycles lead batteries. Spent lead-acid batteries are sent to a battery breaker

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unit where lead, plastic and acid are separated.  The recycled lead is smelted and cast into lead-alloy
bars to make new battery plates. As a result of approximately 35 years of lead smelter operation prior
to the installation of air pollution controls and the advent of the Clean Air Act of 1970, Exide
contributed to lead contamination in soil of the surrounding areas of the Facility. Currently, the Exide
plant operates in compliance with air permits issued by the Pennsylvania Bureau of Air Quality.
Site  Responsibility
Off-site investigation and remediation for lead in soil are being implemented in accordance with the
7003 Administrative Order on Consent that became effective March 2001. On-site RCRA Corrective
Action activities at the Exide facility are conducted in accordance with the federal RCRA Corrective
Action Permit that was issued on November 7, 1988 and was renewed September 1999.
Institutional Controls	
Institutional controls are not required at this time.

Contaminants
Off-site contaminants of concern include lead contamination in soil and the potential of indoor lead dust
contamination.  On-site concerns are antimony, arsenic, cadmium and lead in soil and groundwater.
Community Interaction
The community has been vocal about their concerns with Exide's operations. EPA has interacted with
the public in numerous occasions through public meetings, responding to controlled correspondence
and answering phone calls.

There will be future opportunities for the public to review the Risk Assessment and Remediation Work
Plans with respect to the off-site investigation and remediation.  The work plans will be available for
review at the Muhlenberg Community Library and the EPA Region III Office. A public meeting will be
held to present the content of the work plans and to respond to any questions that the public may have.

Lead Blood Sampling

Residents who wish to be tested for lead blood levels can go to the Omega Medical Laboratories. The

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service is free of charge to the public. Please specify that the lead blood test is under the Exide
program in order to receive this free service. The facility is located at:

Omega Medical Laboratories
Fairgrounds Square Mall
Reading, PA 19605
(610)921-0305

Lead Poisoning Prevention

There are several ways in which you can minimize your exposures and risks to lead from any source.
The EPA website  http://www.epa.gov/opptintr/lead/index.html contains valuable information to reduce
your exposure and protect you and your family from these lead sources.
Government Contacts
Mr. Khai M. Dao
EPA Project Manager
U.S. Environmental Protection Agency - Region III
1650 Arch Street
Mail code: 3WC22
Philadelphia, PA 19103-2029
Phone: 1-800-352-1973 ext. 45467
Fax: (215)814-3113
Email: dao.khai@epa.gov

Mr. Manuel NZambi
Pennsylvania Department of Environmental Protection
Southcentral Region
909 Elmerton Ave.
Harrisburg, PA17110
Phone: (717) 705-4839
Fax: (717) 705-4830
Email: mnzambi@state.pa.us
Facility Contact
Mr. Matthew A. Love
Exide Technologies

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3000 Montrose Avenue
Reading, PA 19605
Phone: (610) 921-4054
Fax: (610)921-4062
Email: Dshank@exideworld.com
Information Repositories
An information repository containing documents related to the site is maintained at the following
locations:

U.S. EPA Region III
1650 Arch Street,
Philadelphia, PA 19103
Phone: (215) 814-5467

Muhlenberg Community Library
3612KutztownRoad
Laureldale, PA 19605
Hours: Mon & Thurs: 9:00 AM - 5:00 PM
      Tues & Wed: 12:00 PM - 8:00 PM
      Fri: 11:00 AM - 5:00 PM
      Sat: 9:00  AM - 4:00 PM
Contact: Annette Pendleton
Phone: (610) 929-0589

For more information about EPA's corrective action webpage, including Environmental Indicators,
please visit our site at:  www.epa.gov/reg3wcmd/correctiveaction.htm

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