Questions and Answers

Previously submitted questions and their respective answers are included below.  The most recent responses are located at the top of the page.  New questions can be submitted via the form to the left (or to the bottom of your screen if viewing from a mobile device).


What is the latest update? We've noticed the lights on and woke up this morning to the "Exide" smell. Is there still work being done to remove this plant? I can't find any recent updates. 
Thank you. (submitted 2/17/16)

Answer: Exide continues to work cooperatively with the Texas Commission on Environmental Quality (TCEQ) and the City of Frisco to complete closure of the Exide facility in Frisco, Texas in accordance with applicable rules and regulations.  Manufacturing operations at the facility ceased on December 1, 2012 and the majority of the structures at the facility have been demolished.  Routine site management activities at the facility consist primarily of collection and treatment of wastewater (primarily stormwater), as required by regulations and Exide’s permits.  On occasion, the wastewater treatment process can give off a slight odor similar to an overheating car radiator; however, this odor is not normally observable beyond the immediate area of the wastewater treatment process.  There are currently no other ongoing activities that would result in odors emanating from the facility.  Please let us know if the odors you observed are something different than that described above.  Investigation activities required by the TCEQ are in the final stages and plans for the remaining demolition activities and site remediation are being prepared.  Exide maintains a presence at the facility and certain safety/security measures (hence the lights which were observed). 


Exide's actions in Frisco over the past few decades could very well be considered public nuisance, and if a proper settlement/agreement is to be reached, there must be considerations made for the health and properties of the public, which have been degraded by your malfeasance. What plans, if any, do you have to remediate the community? (submitted 9/21/15)

Answer: Our intent with this website is to provide accurate information to all interested persons about the Company's plans for the Frisco site, and to present that information in a clear, non-argumentative manner. Accordingly, we will respond to constructive questions about our plans for closure and corrective action at the site, including the schedules for its proposed and planned activities. We will not respond to accusations about the Company. Exide remains committed to complying with all of its legal obligations.



Can you please reschedule the next community meeting planned for Aug 22. This city is primarily working parents w/children. Frisco "meet the teacher night" is on Aug 22nd as well. Frisco citizens with children cannot be at both meetings. Please reschedule the " Exide community clean up" meeting? (submitted 8/7/2013)

Answer: The late summer meeting date was selected more than a month ago based on Exide's general commitment to the public, TCEQ and EPA to hold a public meeting regularly and to provide adequate notice of that meeting .  When Exide representatives checked the calendars posted by the City of Frisco and the Frisco Independent School District more than a month ago, when it was essential to select a date and prepare notice, and we did not see any events posted that conflicted with an August 22nd meeting date.  Any scheduling conflict was not intentional.  Notice for the “Exide Community Information Meeting” was posted on July 18, 2013 and professional calendars for Exide employees and Exide representatives who are essential to an informative meeting are now filled for other dates.  Accordingly, to meet our commitments, Exide needs to leave the meeting date as noticed for Thursday August 22, 2013 from 6:30 pm to 8:00 pm.  Information presented at the meeting will be posted on the website, and Exide will continue to respond to inquiries on the website.


In recently revealed studies, 29 out of 30 samples showed ARSENIC to be present and above the "safe" levels allowed by TCEQ. Now that Arsenic has been identified what is being done to test, identify and remediate arsenic on and off Exide's plant and buffer areas? - submitted on 7/21/2013

As noted, in July 2013 Exide published its Affected Property Assessment Report (APAR) for the Former Operating Plant, which included numerous samples analyzed for arsenic.  These include samples from within or in the vicinity of the former production area.  All arsenic concentrations in these samples were below the Texas Risk Reduction Program (TRRP) critical Protective Concentration Level (PCL) for arsenic used to identify areas for potential response actions for the Former Operating Plant.  Exide also has collected soil samples from the Undeveloped Buffer Properties and these too were analyzed for arsenic.  The data for these samples will be reported in the APAR for the Undeveloped Buffer Property, which is currently in preparation.


At the last community meeting I spoke with the contractors who are in charge of the Class 2 landfill remediation. Samples that had been retreated with the FreeFlow mixture were continuing to come back too high in lead and/or cadmium. What is the current status of remediation of the open cells of the Class 2 landfill? What percentage of retreated samples are being tested? What is the failure rate of retreated samples?  - submitted on 7/12/2013

Answer: Exide completed the pilot activity under the Response Action Work Plan (RAWP) for the Class 2 landfill, which included excavation and retreatment of 20 containers of material from the landfill and evaluation of sampling results for the retreated material.  TCEQ is in the process of reviewing and considering the results of the pilot activity.  No activity under the RAWP beyond the pilot work has been or will be conducted by Exide until clearance is received from the TCEQ.   There were some initial inconsistencies in sample results, relating primarily to results from a lab that ran the samples without following proper sample preparation procedures.  However, subsequent re-tests at that lab along with a secondary lab that Exide utilized and testing done by TCEQ showed that 70 of 73 samples tested met Class 2 standards.  To avoid any question about the characterization of the materials,  Exide made the decision to manage any container of retreated material from the pilot program that had any sample result that exceeded Class 2 standard as a hazardous waste.  Accordingly, earlier this month Exide manifested and sent 11 of the 20 containers to an authorized facility for treatment and disposal (this number was 11 instead of 3 due to inclusion of the initial test results from the lab that did not follow proper sample preparation procedures and thus initially failed but passed on a follow-up analysis by the lab using proper procedures) to an authorized facility for treatment and disposal.


Regarding the “non-hazardous waste landfill”

  1. I understand that the re-treatment process for the improperly disposed hazardous waste was put on hold?  Is that correct? Why?
  2. Has the re-treatment of the hazardous waste been successful? In all cases?
  3. I can understand that only a portion of the landfill is being re-treated to determine if it contains hazardous waste.  Is that correct? Why isn’t the entire landfill subject to re-testing so we can know if the entire landfill contains hazardous waste?
  4. Will the landfill remain next to Downtown Frisco in perpetuity? Forever? Really?
  5. Is the landfill being tested for arsenic? If not, why not?  Wasn’t arsenic one of the contaminants from the battery smelting process?

Answer:

  1. That pilot involved the retreatment of 20 containers of excavated material.  The results of the pilot retreatment are currently being evaluated by both Exide and TCEQ.  Full scale remediation will not commence until the evaluation is complete.
  2. Overall, based on the preliminary review of the analytical results, Exide believes the retreatment of the material has been a success.
  3. Your question appears to misunderstand the purpose of the landfill remediation.  The purpose of the landfill remediation is to remove discrete areas of waste containing concentrations of lead and/or cadmium that exceed UTS and re-treat the excavated material in less than 90 day containers within the confines of the landfill until laboratory analysis indicates regulatory compliance (below the UTS), and collection of confirmation samples of the treated slag to ensure that excavation has removed all wastes that exceed the UTS.  The discrete areas of the landfill were identified as part of the active landfill investigation where in total 195 samples of the in-situ waste was collected and analyzed over a six-month period.  A summary of the investigation is provided in the “Results of the Class 2 Non-Hazardous Waste Landfill Investigation” dated March 13, 2012 and presented on the ExideFriscoClosure.com website.
  4. Following completion of the remediation, the landfill will resume operation for management of Class 2 non-hazardous waste generated on Exide’s property and will be closed later in accordance with applicable regulations.  It has always been the intent for the Class 2 landfill to provide a location for the permanent disposal of waste. Exide plans to continue to retain ownership of the land on which the landfill is located and to maintain it going forward. 
  5. Arsenic is an underlying constituent of the slag.  Of the total 197 samples collected and analyzed as part of the Landfill Investigation, 75 samples were analyzed for arsenic and arsenic was NOT identified as a chemical of concern.  Accordingly, at the moment, there is no remediation required for arsenic as part of the Response Action Work Plan.

The proposed Grand Park is directly downstream of Stewart Creek from the Exide site.  What has been done to ensure that the proposed Grand Park area is not contaminated from the contamination that has flowed historically from the Exide site?  What can be done to keep the contamination at the Exide site from continuing to contaminate the Grand Park area?

Answer: Exide is in the process of conducting an Affected Property Site Assessment (APAR) for the Undeveloped Buffer Property and the Former Operating Plant.  The APAR and Response Action Plan, or RAP, will be proposed simultaneously for the Undeveloped Buffer Property, identifying remedial objectives, response actions, and confirmatory sampling for this tract.  After the APAR for the Former Operating Plant is approved, a RAP will be developed specifically for this area.  The RAP will address among other things, any appropriate action with respect to contaminant pathways identified in the APAR, including for example, any pathway related to Stewart Creek and any required post-closure care.  The community will have the opportunity to review and comment on the APARs and RAPs prior to TCEQ approval.


Why didn't Exide allow for public comment on its landfill remediation plan before submitting it to the state for approval? - submitted on 12/11/2012

Answer: Exide followed the appropriate process. The public may comment on the landfill work plan by providing comments to Exide via the website until January 22, 2013. Submission to and approval by the TCEQ does not foreclose public comment on, nor does it preclude Exide from proposing modifications to the approved plan. The plan does not address closing of the landfill and is not related to the cessation of operations. Rather, the plan is part of resolving an issue noted in TCEQ’s Notice of Enforcement resulting from TCEQ’s inspection report.


What does Exide plan to do about historic “waste piles” on the site?  Are they being tested?  Is so, what are the results?  Will they be allowed to remain onsite, as the landfill is proposed to allowed to remain?  Forever? What about the berms? What about other areas with buried waste?

Answer:  All historic waste piles will be addressed in the forthcoming Affected Property Assessment Report (APAR) for the Former Operating Plant which the community will have the opportunity to review and comment on prior to  TCEQ approval.

We assume by “berms” you are referring to the shooting berm.  The shooting berm located along the west side of the south disposal area will be removed and disposed of at an authorized facility as required under the Agreed Order we entered into with TCEQ.

We assume by “other areas with buried waste,” you are referring to the on-site landfills. These landfills are, and always have been, intended to provide a location for the permanent disposal of waste. Exide plans to continue to retain ownership of the land on which the landfills are located and to maintain them going forward. 


Existing contamination on what city is purchasing?  How many tests (soil borings) are being drilled per acre?  I understand only 1.4 samples per acre, is this true?  How many groundwater test wells are being drilled and where?

Answer:  This comment will be addressed in the forthcoming APAR for the Undeveloped Buffer Property which the community will have the opportunity to review and comment on prior to final TCEQ approval. 


How many days have there been exceedances of air contamination since the demolition has began?  No, not the three-month rolling average for lead, per day?  Are you testing for lead, cadmium and arsenic?  If not, why not?

Answer:  This question assumes that there is an applicable daily limit for air contamination that has been exceeded during demolition.  That assumption is incorrect. Per the Perimeter Monitoring Plan for the both Decontamination and Demolition and the Landfill Remedial Action Work Plan, there have been no exceedences of  Exide specific “Take Action” or “Stop Work” levels for lead or cadmium.  Lead and cadmium are the primary contaminants of concern (COCs).  Based on  the Phase 1 RCRA Facility Investigation report for the Exide Frisco plant, and the subsequent eight-step process for COC identification outlined in Texas Risk Reduction Program guidance, arsenic has not been identified as a COC for the Exide Frisco operation. 

 


A newly released Environmental Site Assessment (Phase I) was posted on the Exide website within the last week that shows numerous new issues on the land the city is proposing to purchase.  Please discuss what is being done to tell the people of Frisco about those issues.  What is being done to investigate these new issues?

Answer:  The Phase I report was posted on the website on April 30, 2013.  Use of the website is central to keeping the public informed about new information related to the Exide site investigations.  During the APAR process, the “Recognized Environmental Conditions” (RECs) and potential environmental concerns noted in the Phase I ESA prepared by Southwest Geoscience have all been investigated by both Exide and City consultants.  The results of the investigations will be presented and addressed in the forthcoming APAR for the Undeveloped Buffer Property.  The APAR will be posted on the Exide website and likely the agency website as well.  The community will have the opportunity to review and comment on that APAR prior to TCEQ approval. 

 


I heard your Vernon, California plant was shut down – that it had its permit revoked.  Why? Please explain why the California regulators said the air emissions from that plant posed a terrible risk to over 100,000 people, especially because of arsenic.  Was there any real difference between what was emitted here in Frisco and what was emitted in Vernon?

 I heard Exide recently had been sued, alleging that the shareholders have been mislead regarding the environmental issues at the company.  Is this true?  Please explain.

I understand that Exide has hired experts in “restructuring.”  Is Exide contemplating filing for bankruptcy?  What happens if that happens?  Didn’t Exide file for bankruptcy a little over 10 years ago? 

Answer:  Thank you for question and concern.  Exide has established this website for community input concerning the Frisco Site Projects and to receive and respond to questions and comments that are directly about the Frisco Site Projects and the activities that will be and have been initiated in conjunction with the cessation of recycling operations at the Frisco plant, including the Undeveloped Buffer Property remediation.  This question does not meet this criteria.


Can you please disclose the amount of arsenic that has been released into our environment by the smelting process? Need measurable amounts. I noticed that the metrics only measure lead and cadmium- but what about the cancer causing arsenic levels? - submitted 5/6/2013

What levels of arsenic have been tested in the SOIL both on Exide's property and surrounding community soil. Air to land fallout? - submitted 5/6/2013

How much arsenic is in the Exide land (not landfill) and surrounding areas. - submitted 5/9/2013

How many soil samples will be or have tested for arsenic on Exide plant facilities & why is arsenic not on the protocol for testing? - submitted 5/9/2013

How much arsenic is in the soil from years of air to land contamination? I was told by several of Exide paid consultants that arsenic was not a toxin of concern and was not being measured. Can you please test and report soil sample results for this cancer causing carcinogen-Arsenic? - submitted 5/14/2013

How much arsenic has accumulated due to air land emissions?  I understand from the open house that arsenic is NOT a toxin of concern.  Why not?  It is a by product of the smelter process.  It has been measured in your Vernon, CA facility and deemed harmful levels.  I have found documents that indicate that the levels in Frisco are MUCH higher than Vernon, CA.  Please release the ARSENIC data to the public.  It can be measured in the soil samples just like lead and cadmium. - submitted 5/13/2013

Answer: Exide has two types of information that document arsenic associated with facility operations-- (1) TRI and other air emissions data that show measured arsenic emissions and (2) soil sampling results from Exide’s property. 

Annual TRI data and air emission and stack test reports are publicly available and can be obtained from the EPA and TCEQ, respectively. 

Exide is currently conducting a site assessment that includes surface soil sampling.  Although lead and cadmium are the primary chemicals of concern (COC), some soil samples have also been tested for arsenic.  Based on current sampling plans, Exide anticipates that approximately 45 soil samples have been or will be analyzed for arsenic.  Only 1/3 of the samples collected and tested for arsenic to date have been verified, but so far, there have been no exceedances of TCEQ’s protective concentration level (PCL) for arsenic.  The complete results of the soil sampling analyses will be included in the APAR, which will be provided for public review and comment.  See schedule posted on website for expected date of publication.

Arsenic is in fact a regulated substance, but, as noted, based on  the Phase 1 RCRA Facility Investigation report for the Exide Frisco plant, and the subsequent eight-step process for COC identification outlined in Texas Risk Reduction Program guidance, arsenic has not been identified as a COC for the Exide Frisco operation.  Concerning the documents mentioned in the last comment above, we have asked the commenter for additional information on the records referenced so that we can better understand and respond to this comment.

To respond to public interest in information concerning arsenic at the Frisco former operating site, Exide is preparing a fact sheet on this topic and will post the fact sheet on this website.  The fact sheet will be finalized following receipt of results for the soil samples that were analyzed for arsenic.


Can you tell me how much arsenic has been buried in Frisco Landfills?  What is being done to remediate arsenic and to what levels will the clean up be performed for arsenic? - submitted on 3/24/2013

Answer: Your question appears to misunderstand the potential for the presence of arsenic in the Frisco Class 2 landfill and mistakenly assumes that arsenic has been identified as a chemical of concern in the landfills and needs to be remediated.

First, treated slag and other Class 2 materials have been disposed of in the Class 2 landfills.  Arsenic is an underlying constituent of the slag.  Exide took 75 samples of the treated waste material in the open Class 2 landfill during the landfill investigation; those samples were tested for arsenic and arsenic was NOT identified as a chemical of concern.  Accordingly, at the moment, there is no remediation required for arsenic as part of the Response Action Work Plan.

However, additional soil samples have been and will be collected as part of the Affected Property Assessment Report for the Former Operating Plant, and those samples have been or will be evaluated for metals, including arsenic, and those results will be available to the public.  The state has adopted residential and industrial assessment standards for arsenic, as well as groundwater protection limits.  A specific clean up level for arsenic on the Former Operating Plant has yet been selected, but will be proposed if necessary in the Response Action Work Plan.






Isn’t your landfill leaking arsenic and selenium per the EPA? - submitted on 2/27/2013

 

Answer: EPA’s comment indicates “EPA collected a sample in April 2009 of leachate from the closed portion of the north landfill…”. This statement appears to be incorrect as there is no record of a sample being collected at that time. However, EPA did collect a sample on April 1, 2010 from a storage tank near the landfill, which receives leachate from both active and closed portions of the landfill that collect in a sump within the Class 2 landfill and also receives stormwater from within the tank containment area. Assuming the April 1, 2010 sample is the sample being referred to, the leachate present in the tank that was sampled was collected inside the lined landfill system and the sample results are not evidence of any leakage from the landfill. Further, there is not enough information to determine whether the liquids in the tank would be representative of a sample of leachate collected from the landfill sump, nor whether the liquids would be representative of leachate from the closed cells of the landfill. The tank from which the sample was taken collected liquids over a period of time before the accumulated liquids were sent to the on-site waste water treatment plant. During the accumulation period, constituents found in the liquid could have become concentrated due to evaporative or other loss of water during storage, or from disproportionate distribution of constituents in the tank during transfer or during the sampling process (i.e., the material in the tank may not have been a homogenous mixture representative of the leachate collected in the landfill sump even if the only materials in the tank were these liquids). Because of the detection of elevated levels of arsenic and selenium in the tank that holds liquids collected from within the landfill, Exide has agreed with TCEQ that Exide will include arsenic and selenium in the sampling parameters for the groundwater monitoring plan for the Class 2 Landfill that Exide is developing under the TCEQ Agreed Order.


Did you stop groundwater monitoring of the landfills in 2002? - submitted on 2/27/2013

Answer: Groundwater monitoring of the Class 2 Landfill continued until 2005.


Future plans for groundwater monitoring around landfill; old disposal areas? - submitted on 2/27/2013

Answer: In accordance with Ordering Provision 3.b.ii of TCEQ Agreed Order Docket No. 2011-1712-IHW-E, Exide is currently preparing a groundwater monitoring plan for the on-site active landfill to be submitted to the TCEQ for approval and which we hope to begin implementing during the second quarter of 2013. Additionally, groundwater testing has been performed as part of site investigation activities and additional groundwater testing is being performed as part of the Affected Property Assessment that is currently underway. The report for that assessment is expected to be available late this summer. All sampling results will posted on the Exide Frisco website.


Don’t the pre-2002 results show leaking and exceedances? - submitted on 2/27/2013

Answer: The pre-2002 groundwater data for the Class 2 Landfill do not indicate leaking. The pre-2002 data indicate two detections of lead slightly above drinking water standards - one in 1998 and one in 2000. However, over a dozen subsequent samples from the same well documented conditions were below those standards. In addition, data from the well used to document background levels showed three slight exceedances of these contaminants over the same period of data collection. There were no additional exceedances of drinking water standards indicated in the post-2002 groundwater data for the Class 2 Landfill.


Are two of the four landfills in the floodplain? - submitted on 2/27/2013

Answer: No, the Class 2 Landfill, South Disposal Area and the Slag Landfill are entirely outside the 100-year base floodplain. Based on available maps showing the 2009 100-year base floodplain boundary and the boundary of the North Disposal Area, it appears that there potentially could be a very small overlap along an approximately 200-foot portion of the northern edge of the North Disposal Area and the southern edge of the 100-year base floodplain.


Why use 1992 1.05 for employees and air when standard is .015? - submitted on 2/19/2013

Answer: The 1.05 µg/m3 standard is the Stop Work level for lead concentrations under the Perimeter Air Monitoring Plans, not the standard for employees. Instead, "personnel exposure monitoring" and related "take action" levels are described in Section 8.0 of the Site Safety and Health Plans for the work to be performed. Personnel exposure monitoring "take action" levels and response actions are established by applicable Occupational Safety and Health Administration regulations. With respect to the 1.05 µg/m3 Stop Work level for lead concentrations described in the Perimeter Air Monitoring Plans as such standard relates to the lead National Ambient Air Quality Standard (NAAQS) value of 0.15 µg/m3, compliance with the NAAQS is based on a rolling 3-month average of measured readings, not 8 hour averages as will be utilized for metals sampling in this instance to determine "Take Action" and "Stop Work" levels. Therefore, Exide utilized Appendix D, "Averaging Period Concentration Estimates" in EPA-454/R-92-024 "Workbook of Screening Techniques for Assessing Impacts of Toxic Air Pollutants (Revised)" to determine the appropriate factor to convert three-month averages to an appropriate concentration for the 8-hour average period. In other words, the presently-applicable NAAQS (0.15 µg/m3) was used, but reference to a NAAQS only has meaning in the context of the associated averaging period. So an appropriate adjustment was made using methodology described in a 1992 EPA technical document to establish the 1.05 µg/m3 Stop Work level for lead concentrations.


Why is total removal from Frisco not an option? I'm assuming cost but at the possible long term risk and expense shouldn't this be considered again? - submitted on 2/19/2013

Answer: Thank you for your comment. We assume by “total removal,” you are referring to the Class 2 on-site landfill. Removal of the Class 2 landfill from the Frisco site is not feasible. From an environmental risk perspective, removal and associated material handling is not a better alternative so long as this landfill is properly inspected and maintained. The expense, which is prohibitive, is also a factor but feasibility and consideration of environmental risk are equally important considerations. This landfill is, and always has been, intended to provide a location for the permanent disposal of Class 2 waste. For example, it is outside the floodplain, and is carefully lined with both a synthetic and clay barrier. In addition to conducting the response action required under the Agreed Order we entered into with TCEQ, Exide also will implement groundwater monitoring around the Class 2 landfill. Exide plans to continue to retain ownership of the land on which the Class 2 landfill is located and to inspect and maintain the landfill and implement the landfill and site groundwater monitoring as required by law.


Why not sample with the dust suppression after work hours (high winds at night)? - submitted on 2/19/2013

Answer: Sampling after work hours is not planned because the purpose of the air monitoring program is to evaluate and avoid the potential for lead and cadmium off-site effects from impacted materials. Because there will not be disturbance of materials at night and the staging piles will be covered with poly sheeting and weighted down by sandbags, impacted materials will not be exposed to high winds at night.


What groundwater testing is planned for the site? When will groundwater test results be available? Will the public have access to those results? - submitted on 2/15/2013

Answer: In accordance with Ordering Provision 3.b.ii of TCEQ Agreed Order Docket No. 2011-1712-IHW-E, Exide is currently preparing a groundwater monitoring plan for the onsite active landfill to be submitted to the TCEQ for approval and which we hope to begin implementing during the second quarter of 2013. Additionally, groundwater testing has been performed as part of site investigation activities and additional groundwater testing is being performed as part of the Affected Property Assessment that is currently underway. The report for that assessment is expected to be available late this summer. All sampling results will posted on the Exide Frisco website.



Has a Phase I ESA or Phase II ESA been performed at the Exide Plant in Frisco, TX, or the properties surrounding the Exide Plant in Frisco, TX? If so what were the results? Have soil samples been taken and analyzed for Lead or other Hazardous Materials at the Exide Plant property in Frisco? Have soil samples been taken and analyzed for Lead or other Hazardous Materials at the properties surrounding the Exide Plant property in Frisco? If so what were the results of the testing? - submitted on 12/15/2012

Answer: Since 1998, three Phase I ESAs have been performed or are in the process of being performed for all or certain portions of the property owned by Exide. The latest Phase 1 ESA is being performed by the City of Frisco for that portion of the Exide property being acquired by the City. The Phase I ESA being performed by the City is currently in the process of being completed. These three Phase 1 ESAs include discussions of lead concentrations detected in certain soil samples collected as part of the ongoing investigation of the facility, several soil mounds and fill areas of unknown origin, a former shooting range berm, the onsite landfills, and several offsite issues related to operations of entities other than Exide. Exide has not performed Phase I ESAs for properties surrounding those owned by Exide. Over the years, numerous phases of soil investigations have been performed on Exide-owned properties and soil samples collected have been analyzed for lead and other constituents. All of these investigations have been performed under the oversight of the TCEQ or EPA and the reports documenting the results are in TCEQ and/or EPA files. Analytical results indicate concentrations of lead and certain other constituents exceed Texas Risk Reduction Program Protective Concentration Levels (PCLs) for soil standards at certain locations on Exide-owned property. Over the years, Exide has also performed soil sampling on certain properties in the vicinity of Exide-owned properties. Analytical results for some of these samples have exceeded default residential TCEQ soil. Those locations outside of Exide-owned property where residential soil standards were exceeded have been remediated.


Thank you for setting up the first meeting yesterday evening. For the next meeting, could we have someone from the corporate office present and also a representatitve from the remediation company who may be answer some questions regarding the process? I would also like to see some education on what the measurements means. - submitted on 12/13/2012

Answer: Thank you for your question. We are in fact planning to have representation from our contractor, consultant and the company’s corporate headquarters at our next public meeting. We have suggested dates and are waiting to see which works best for all. We anticipate the meeting will take place toward the end of January. Once the date and time have been finalized we will post a formal notification. I believe this group of people should be able to provide responses and explanations to the questions you have. Also, please note that we are in the process of updating our website to include more details, monitoring information, etc. to continually keep the public informed.


When is the next public meeting for public input and recommendations? - submitted on 12/13/2012

Answer: We are currently coordinating a time for the next meeting. The meeting will take place in January and we hope to announce the exact date and time late this week/early next week. A notification for the meeting will be sent out through the website and other channels. Input and recommendations are welcome anytime by posting on the website.


I thought the plant shut down operations on Nov 30th. I see your plans (already approved) to bring even more lead slag and cadmium into the city of Frisco to be buried in the landfills. Is this true? Didn't burying lead and cadmium in a class II non hazardous landfill get your company in trouble in the first place? What exactly is the stabilization process and how is it different than what got you in trouble with EPA and TCEQ? - submitted on 12/12/2012

Answer: Not true. Our intent with this website is to provide accurate information to all interested persons about the Company's plans for the Frisco site, and to present that information in a clear, non-argumentative manner. Accordingly, we will respond to constructive questions about our plans for demolition, decommissioning, closure and corrective action at the site, including the schedules for its proposed and planned activities. We will not respond to accusations about the Company, the pending enforcement action including the matters alleged by Downwinders at Risk and Frisco Unleaded (of which you are a member) in their Notice of Citizen Suit. Exide did indeed shut down operations (ceased its recycling operations) at the Frisco site on November 30, 2012. Your apparent understanding of our plan is incorrect. There are no plans to bring in any lead slag, cadmium or other material from outside the Exide property for disposal in the landfill. Future site activities consist of site decommissioning, decontamination, corrective action and closure activities. Use of the landfill in conjunction with these future site activities will be according to the applicable treatment standards with confirmation sampling to ensure compliance with the standards.


When was the decision made by Exide to hold a public meeting during the holiday season? - submitted on 12/11/2012

Answer: Exide did not host the first public meeting after demolition had already started. Certain decommissioning and decontamination activities, for example removal of objects from inside the buildings, are underway, but demolition activities have not started, but will likely begin around the end of the year. The date of the public meeting was established in conjunction with the cessation of recycling operations at the facility on November 30, not the holidays. 


Will the comp any post its closure plan for the smelter before submitting it to the state or EPA? - submitted on 12/11/2012

Answer: Regarding the formal regulatory “closure plan,” Exide plans to implement the closure plan in its permit. (Regulations required that a Closure Plan be submitted and approved by the TCEQ as part of applying for the current permit for the facility. This Closure Plan only addresses the regulated hazardous waste units at the facility (i.e., the battery storage area and feed material storage building). When the current permit was issued, the Closure Plan in the application for that permit was deemed approved. That Closure Plan is in effect and in force.) Areas other than the permitted hazardous waste units will also be addressed in compliance with applicable laws and regulations. Remediation plans will be developed after the ongoing work to investigate environmental conditions is completed. Development of the remediation plans for the operating portion of the site has not yet begun. As part of the development process, Exide will provide for continued public participation. These remediation plans will be posted for public comment; however, it has not yet been discussed at this point whether they would be posted before or after submittal to the TCEQ or EPA.


Was EPA informed of the decision to hold a public meeting on December 12th before it was announced? -submitted on 12/11/2012

Answer: Although there is no regulatory requirement to hold any public meetings regarding the demolition, Exide recognizes there is significant public interest in demolition and remediation of the Exide facility and is voluntarily holding public meetings as one avenue for the public to better understand our proposed plans.. For instance, although submittal and approval of a Demolition Plan is not required by the environmental regulations, The Demolition Plan was provided to the EPA for review.. Similarly, as discussed at the first public information meeting, Exide is providing opportunity for the public to comment on the demolition plan.


When did Exide apply for the city permits necessary for demolition and when were those permits granted? -submitted on 12/11/2012

Answer: Exide applied for the demolition permits October 29th, and they were issued November 23rd.



Knowing the closure schedule for the smelter, why is the company holding a public meeting on its demolition plans after demolition has already started instead of before? - submitted on 12/11/2012

Answer: Exide did not host the first public meeting after demolition had already started. Certain decommissioning and decontamination activities, for example removal of objects from inside the buildings, are underway, but demolition activities have not started, but will likely begin around the end of the year. The date of the public meeting was established in conjunction with the cessation of recycling operations at the facility on November 30, not the holidays.


Is it Exide's intent to permanently leave a lead waste landfill in the middle of central Frisco? - submitted on 12/11/2012

Answer: Again, Exide intends to respond on the website to constructive questions. The term "lead waste landfill" is misleading and not correct. There is a Class 2 non-hazardous waste landfill on the portion of the property that will continue to be owned by Exide following the sale to the City. This Class 2 non-hazardous landfill will be closed as a Class 2 non-hazardous waste landfill in accordance with all regulatory requirements. As noted, Exide will continue to own this industrial property.


When was the decision made by Exide to hold a public meeting during the holiday season? - submitted on 12/11/2012

Answer: Exide did not host the first public meeting after demolition had already started. Certain decommissioning and decontamination activities, for example removal of objects from inside the buildings, are underway, but demolition activities have not started, but will likely begin around the end of the year. The date of the public meeting was established in conjunction with the cessation of recycling operations at the facility on November 30, not the holidays.


Is Exide committed to cleaning up the site to at least 250 ppm? - submitted on 12/11/2012

Answer: Exide agreed with the City to remediate the property being sold to the City to a lead in soils concentration of 250 ppm although this level is one-half of the current TCEQ default standard for residential properties. Exide will not be applying this level to property retained by Exide; rather, Exide will be applying the appropriate industrial levels consistent with applicable regulations, as will be outlined in the development of the overall remedy.


Did Exide send EPA a copy of its landfill remediation plan? If so, was there any EPA comment on it? -submitted on 12/11/2012

Answer: TCEQ is the regulatory agency with responsibility for reviewing and evaluating the landfill plan, and it has done so. In its oversight capacity over the TCEQ, EPA has been provided a copy of the landfill remediation plan and as of the writing of this response,, EPA has not provided formal comments.


Does the company have a plan to deal with any off-site contamination from its smelter that might be found in Frisco in the coming years? - submitted on 12/11/2012

Answer: Exide will evaluate any incidences of off-site contamination allegedly attributable to materials from the facility and address as appropriate. Exide is committed to complying with all of its legal obligations.