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					Michigan Department of Environmental Quality
     Environmental Assistance Division




      John Engler, Governor w Russell J. Harding, Director
     For more information about the
Community Environmental Awareness Project,
            please contact:

            Michigan Department of
              Environmental Quality
                 ATTN: CEAP
        Environmental Assistance Division
                P.O. Box 30457
           Lansing, MI 48909-7957

         Environmental Assistance Center
             Phone: 800/662-9278

                 World Wide Web:
         http://www.deq.mi.us/ead/CEAP




                    AUTHORITY: PA 451 of 1994
                    TOTAL COPIES PRINTED: 250
                    COST PER COPY: $2.43
                    TOTAL COST: $607.72                        RECYCLED
                                                                 PAPER

  The Michigan Department of Environmental Quality (MDEQ) will not
  discriminate against any individual or group on the basis of race, sex,
  religion, age, national origin, color, marital status, disability, or political
  beliefs. Questions or concerns should be address to the MDEQ Office of
  Personnel Services, PO Box 30473, Lansing, MI 48909.
                                     TABLE OF CONTENTS

I. Introduction .................................................................................... 1
     Executive Summary ...................................................................................................... 2
     Sterling Heights Assembly Plant Overview .................................................................. 3

II. Environmental Information
         Introduction .............................................................................................................. 4
         Emergency Planning and Community Right-to-Know ............................................. 5
         Air Quality ............................................................................................................... 8
         Water Quality ........................................................................................................... 11
         Hazardous Waste ..................................................................................................... 15
         Storage Tanks .......................................................................................................... 17


III. Pollution Prevention ..................................................................... 19
IV. The Permitting Process and Public Participation ...................... 20


V.     Contact Information..................................................................... 22
VI. Appendices
         Appendix A: DaimlerChrysler Sterling Heights Assembly Plant Information ........ A-1
         (Prepared by DaimlerChrysler Corporation)

         Appendix B: SARA Title III .................................................................................... B-1
         Appendix C: Air Quality .......................................................................................... C-1
         Appendix D: Water Quality ..................................................................................... D-1
         Appendix E: Hazardous Waste ................................................................................ E-1

VII. Glossary of Terms and Abbreviations
                                      Community Environmental Awareness Project




                                            INTRODUCTION

T
        he Community Environmental Awareness                The Environmental Information section provides an
        Project, CEAP, is a Michigan Department of          overview of the laws, regulations and permits that
        Environmental Quality (DEQ) effort to develop       apply to SHAP. These laws, regulations and permits
an approach to improve the way environmental                address emergency planning and community right-to-
information is presented to the public. The DEQ is the      know, air quality, water quality, hazardous waste
state agency responsible for administering Michigan’s       management and storage tanks. This section also
environmental protection laws. The DEQ is also              reports on the performance of the facility relative to
delegated by the federal government to carry out            those requirements. This includes any violations of
environmental laws in Michigan. Through this project,       requirements, the relative importance or severity of a
the DEQ is seeking to improve the way it                    violation, the DEQ’s response and ultimate resolution.
communicates information about its environmental
programs to the public. The goal of the CEAP is to pilot    The Pollution Prevention section gives an overview of
an approach to improve the public’s access to and           the DEQ’s efforts to prevent pollution. This section
understanding of how auto assembly plants are               also highlights DaimlerChrysler Corporation’s
performing under environmental laws by presenting this      involvement in pollution prevention projects. The
information in a useful and meaningful context.             Permitting Process and Public Information section
                                                            describes both general and specific ways the local
The DaimlerChrysler Sterling Heights Assembly Plant         community can become involved in environmental
(SHAP) is the first automotive assembly plant to be         issues. Contacts for appropriate persons or offices for
profiled under this pilot project. This project is a        more information are listed for reference.
voluntary, cooperative effort between the agency and
industry to better communicate environmental                The appendices provide additional information and data
information. One of the objectives of the CEAP is to        about inspections and SHAP’s environmental
assess whether it is possible to develop similar profiles   performance. Appendix A, prepared by
of many other facilities throughout Michigan to be          DaimlerChrysler Corporation, gives DaimlerChrysler
available to the public on an ongoing basis.                an opportunity to present information about SHAP. This
                                                            includes information about the plant, its employees,
This document, prepared by the Michigan DEQ,                products and role in the community. This section also
provides environmental information and data about the       highlights DaimlerChrysler environmental policies and
DaimlerChrysler Sterling Heights Assembly Plant. It is      efforts the company has taken to reduce waste and
in a format and context intended to be understandable       pollution. Finally, a glossary provides definitions of
by, and meaningful to, the community surrounding            terms and abbreviations used in the document.
SHAP. The document is divided into several parts to
accomplish this.                                            NOTE: The term “violation,” when used in this
                                                            document means the DEQ believes environmental
                                                            requirements have been violated and has cited the
                                                            company for such. The citation is not proof that a
                                                            violation has actually occurred but rather an
                                                            allegation of non-compliance.




Please be aware that more recent compliance information than is presented in this profile may be available.
Please contact the DEQ for more information. A list of contacts can be found on page 22.


                                                                  Michigan Department of Environmental Quality        1
                                    Community Environmental Awareness Project



                                   EXECUTIVE SUMMARY

                T
                       he Sterling Heights Assembly Plant (SHAP) is regulated by federal, state
                       and local laws. The Michigan Department of Environmental Quality (DEQ)
                       is the agency that administers state environmental laws and by delegation,
                most federal environmental laws. These laws and regulations are numerous and
                have been put in place to protect human health and the environment.

                Federal and state laws require that SHAP obtain permits that restrict air emissions,
                water discharges, and waste handling and disposal activities. The SHAP facility has
                obtained these permits to operate. According to DEQ records, SHAP is in compli-
                ance with all permits and requirements pertaining to emergency planning and com-
                munity right-to-know, air quality, water quality, hazardous waste management and
                storage tanks. The following is a summary of SHAP’s performance, both current
                and historical. More detailed information can be found in the “Environmental Infor-
                mation” section of this document.


Emergency Planning and Community                            that was more than an allowable emission limit or
Right-to-Know                                               standard (in 1994 and 1996). Two violations were
The Emergency Planning and Community Right-to-              related to the improper design or operation of machin-
Know Act (EPCRA) of 1986 provides a means for               ery or equipment (in 1995 and 1996) and one violation
gathering certain information necessary for state and       was related to monitoring, testing, record keeping, or
local officials to develop plans to help protect the        reporting requirements (in 1995). A release or emission
community from hazardous chemicals at SHAP and              that is more than an allowable emission limit or stan-
other facilities. According to DEQ records, SHAP is in      dard is generally considered the more serious of the
compliance with the federal EPCRA. The company              violation types. The problems causing these violations
has provided information about hazardous chemicals on       were fixed in a timely manner.
site and the quantities of certain chemicals released to
the environment or transferred off site. Also, in accor-    Water Quality
dance with EPCRA, an emergency response plan is in          SHAP has water quality permits that allow the facility
place to protect the community from an accidental           to discharge wastewater to the City of Sterling Heights
release of hazardous chemicals.                             sewer system which leads to the City of Detroit
                                                            wastewater treatment plant. This discharge is currently
Air Quality                                                 controlled through a permit from the City of Detroit.
SHAP has air permits that specify air emission limits       According to the City of Detroit’s records, SHAP is in
and other requirements. The main sources of SHAP’s          compliance with this permit.
emissions are from the paint shop and powerhouse.
These include fumes from different paints used, smoke       Water Quality Performance History
and other emissions. According to DEQ records and           From 1993 to 1997, SHAP was cited twice for water
based on the last inspection in September 1998, SHAP        related violations. SHAP self-reported these violations
is meeting all air permits.                                 immediately to the City of Detroit and promptly came
                                                            back into compliance on both occasions. SHAP also
Air Quality Performance History                             reported three bypasses of the treatment system to the
From 1993 to 1997 there have been a total of five air       City of Detroit between 1995 and 1997. A bypass
quality related violations* at SHAP. Two of these           discharges wastewater directly to the sewer without
violations at SHAP resulted in a release or emission        treatment. SHAP notified the city of the three bypasses


* Refer to glossary

2    Michigan Department of Environmental Quality
                                       Community Environmental Awareness Project


at the time they occurred. The bypasses did not result          Hazardous Waste Management
in the City of Detroit violating its water quality limits for   Performance History
its discharge to the Detroit River; however, the third          From 1993 to 1997, there have been eleven cited
bypass resulted in a fine for SHAP.                             hazardous waste requirement violations, based on a
                                                                1997 DEQ inspection at SHAP. One violation related
SHAP also has a permit to discharge storm water to a            to record keeping requirements; one violation related to
local drain that leads to Plumbrook Creek. According to         air emission requirements; and nine violations were
DEQ records, SHAP is in compliance with this storm              related to waste storage requirements. These violations
water permit.                                                   did not result in a release to the environment and were
                                                                corrected in a timely manner.
Hazardous Waste Management
The SHAP facility is categorized as a “Fully Regulated          Storage Tanks
Generator” of hazardous waste because it generates a            The SHAP facility has one underground storage tank
certain quantity of waste per month through its manu-           (UST) that contains diesel fuel and 14 aboveground
facturing or other on-site processes. According to DEQ          storage tanks (AST’s) that contain diesel fuel, gasoline
records, SHAP is meeting all hazardous waste genera-            and solvents. Storage tanks are inspected before and
tor requirements.                                               after installation. According to DEQ records, SHAP is
                                                                meeting all the storage tank requirements.




      STERLING HEIGHTS ASSEMBLY PLANT OVERVIEW


S
       terling Heights, Michigan, is located about 15           The plant is located in the center of Sterling Heights on
       miles northwest of downtown Detroit in Macomb            310 acres with over 3.0 million square feet under roof.
       County. Sterling Heights has a population of             The plant employs more than 3,100 people. In 1997,
approximately 123,000 people (35,000 households)                the plant produced 227,000 vehicles on two shifts per
living within 36.8 square miles. The city is the third          day. The table below summarizes SHAP’s vehicle
largest in area and the sixth largest in population in the      production rates from 1993 to 1997.
state of Michigan.

Sterling Heights is a residential suburban Detroit                       SHAP Manufacturing Production
community but supports an important industrial base,                  1993    Data 1,995
                                                                             1994 (vehicles/year)
                                                                                              1996   1997
with more than ten large manufacturing facilities,                  229,557 84,874 205,535 232,767 227,277
including DaimlerChrysler, Ford Motor Company,
Mayco Plastics Inc., Curtis Metal Finishing Co. and
TRW Sterling Plant.

The Sterling Heights Assembly Plant (SHAP) makes
DaimlerChrysler’s mid-size sedans. The parts and                For more detailed information about the SHAP plant, its
materials that make up vehicles, such as engines, seats,        products and personnel, and its environmental policies,
doors, hoods, brakes, oils, and paints, are made at other       see Appendix A.
plants and delivered to SHAP. At SHAP, body parts
are welded together, cleaned and painted. Seats,
instrument panels, windshields, tires, and other parts are
installed as the body moves down the assembly line.
The vehicle is then ready for shipment.

                                                                      Michigan Department of Environmental Quality      3
                                      Community Environmental Awareness Project



                          ENVIRONMENTAL INFORMATION
Introduction to Laws and Regulations                        DaimlerChrysler’s Sterling Heights Assembly Plant


F
      ederal and state laws and regulations and local       (SHAP) is an assembly plant with painting operations
      ordinances regulate the activities of businesses,     and is extensively regulated under a number of environ-
      towns, institutions and individuals that impact the   mental laws. The DEQ has reviewed an analysis of
environment. Federal laws, which apply in all states,       environmental regulatory requirements affecting a
are usually carried out by delegated state agencies. The    typical automobile assembly plant. The analysis was
Michigan Department of Environmental Quality*               prepared by Horizon Environmental Corporation under
(DEQ) is delegated by the U.S. Environmental Protec-        contract by the former American Automobile
tion Agency* (EPA) to administer most federal envi-         Manufacturer’s Association. The analysis found that a
ronmental programs in Michigan.                             typical automobile assembly plant must comply with
                                                            about 900 specific environmental regulatory require-
States carry out environmental programs under the           ments. While not endorsing the study as being complete
authority of state law. Often, states pass additional       and accurate, the DEQ review found that this number
requirements for the added protection of their citizens     is a reasonable approximation of the number of regula-
and environment. Therefore state law may be stricter        tory requirements at a typical automobile assembly
than federal law. To operate under federal and state        plant.
law, businesses must obtain permits that regulate air
emissions, water discharges and waste disposal activi-
                                                            This section:
ties. These permits protect public health and the
                                                            • Summarizes Michigan’s environmental regulatory
environment.
                                                                system;
The automobile industry is a major industry in Michi-       • Gives an overview of the key laws and regulations
gan. The industrial processes that are involved in the          that protect public health and the environment and
manufacturing of automobiles have the potential to              the community’s right-to-know;
significantly impact the environment. For example, as       • Outlines Michigan’s permitting process in regards
an industrial sector, the Transportation Equipment              to air, water, waste and storage tanks and how the
industry (of which automobile manufacturing is in-              DEQ evaluates compliance;
cluded) ranks in the top five for total releases and        • Presents an overview of DaimlerChrysler SHAP’s
transfers of toxic chemicals under the federal Toxic            performance and compliance status relative to
Chemical Release Inventory (based on 1997 data).                permits and regulations; and
Examples of automobile manufacturing operations with        • Lists contacts to obtain further information.
potential to impact the environment
include foundry works, parts manufac-
turing, and coating and painting.                                                               Figure 1
Accordingly, the automobile industry is
heavily regulated under state and
federal law.

Figure 1 gives a general overview of
the laws and regulations that apply to
SHAP. These laws and regulations
will be discussed further in the follow-
ing sections.




* Refer to glossary

4    Michigan Department of Environmental Quality
                                      Community Environmental Awareness Project


               EMERGENCY PLANNING AND COMMUNITY
                RIGHT-TO-KNOW (SARA TITLE III)
Laws and regulations                                •   Submit an annual Toxic Chemical Release      The Emergency



T
        he Emergency Planning and                       Inventory* report to the DEQ and the         Planning and
        Community Right-to-Know Act of 1986,            U.S. Environmental Protection Agency.        Community
        also known as Title III of the Superfund        Facilities must provide information on an    Right-to-Know
                                                                                                     Act (SARA
Amendments and Reauthorization Act* (SARA               established list of toxic chemicals.
                                                                                                     Title III) is the
Title III) is the federal law that protects the                                                      federal law that
public and the environment from chemical            SHAP’s compliance with                           guarantees
hazards. This law also guarantees citizens the      SARA Title III requirements                      citizens the
right-to-know about chemical hazards in their       According to DEQ records:                        right-to-know
community.                                                                                           about chemical
                                                    √ SHAP has notified state and local officials    hazards in their
SARA Title III requirements                                                                          community.
                                                        that the facility stores extremely hazard-
All of the information reported under SARA              ous substances on site.
Title III is available to the public. SARA Title
III requires certain facilities to:                 √ SHAP has worked with local authorities to
                                                        develop a response plan for the plant. The
•   Notify the DEQ on behalf of the Michigan            plan ensures the safety of the surrounding
    State Emergency Planning and Community              community in case of a chemical emer-
    Right-to-Know Commission and local                  gency. To date, there have not been any
    officials of the presence of extremely              chemical emergencies at SHAP.
    hazardous substances on their property.
    Extremely hazardous substances are              √ There have not been any reportable
    capable of producing adverse physical               releases of hazardous chemicals at SHAP. All information
    effects like fire or explosion, or adverse                                                       that is reported
    health effects.                                 √ SHAP submits an annual “Emergency and          by SHAP under
                                                                                                     SARA Title III
                                                        Hazardous Chemical Inventory” to the
•   Work with local authorities to prepare an                                                        requirements
                                                        DEQ and local authorities which lists the
    “Emergency Response Plan” in case of a                                                           is available to
                                                        hazardous chemicals on site. SHAP also       the public.
    chemical emergency, such as a leak or spill.        provides material safety data sheets for
                                                        these chemicals. These chemicals are
•   Notify the DEQ and local officials of the           used in the automobile assembly process
    accidental release of hazardous chemicals.          and could pose a danger to the surround-
                                                        ing community if handled improperly. A
•   Submit an annual “Emergency and Hazard-             complete list of hazardous substances at
    ous Chemical Inventory” listing all hazard-         SHAP in 1997 is presented on page B-6.
    ous chemicals on site to the DEQ and local
    authorities. Facilities must also provide        √ SHAP submits an annual Toxic Chemical
    ‘material safety data sheets’ on these
                                                        Release Inventory (TRI) report to the
    chemicals. These data sheets contain
                                                        DEQ and the U.S. Environmental Protec-
    information about the chemical’s physical
                                                        tion Agency (EPA). SHAP reports the          A complete list
    properties, flammability, explosion hazard
                                                        quantities of TRI chemicals released to      of hazardous
    and health effects.
                                                        the environment (such as to air water or     substances at
                                                        land), transferred off-site, and managed     SHAP in 1997
                                                        through activities such as recycling or      is presented on
                                                        energy recovery.                             page B-6.

* Refer to glossary

                                                                   Michigan Department of Environmental Quality    5
                                     Community Environmental Awareness Project


    Community right-to-know                                                                  Average Daily Amount of Hazardous
    The following graphs in this section are derived                                                Chemicals at SHAP:
    from information reported by SHAP under commu-                                                 A Five-Year Summary
                                                                                      2,000,000
                                                                                                    1 ,720,900
    nity right-to-know requirements of EPCRA.
                                                                                      1 ,500,000                 1 ,300,1 00




                                                              Pounds/Day
                                                                                                                               1 ,1 90,050

    Hazardous chemicals at SHAP                                                       1 ,000,000
                                                                                                                                                         647,050
    Graph 1 shows the average daily amount of
                                                                                                                                             604,550
                                                                                       500,000
    hazardous chemicals on site at SHAP over the last
    five years. A complete list of hazardous substances                                       0

    at SHAP in 1997 is presented on page B-6.                                                          1993           1994        1995       1996        1997

                                                              Graph 1
                                                              Source: U.S. EPA Tier Two Emergency
    SHAP toxic chemical releases                              and Hazardous Chemical Inventory Form.
    Graph 2 presents the Toxic Chemical Release
    Inventory (TRI) data from SHAP for the last five                                               Total TRI Releases and Transfers:
    reporting years. TRI data can show trends of how                                                    A Five-Year Comparison
                                                                                      1,200,000
    TRI chemicals are released to the environment                                                         1,018,325
    (such as to air or water), transferred off-site or                                1,000,000

    managed.                                                        Pounds per Year     800,000
                                                                                                                                      630,523
                                                                                                                                                    691,062

                                                                                        600,000                         501,747                                    511,047
    There are several factors that can affect the
                                                                                        400,000
    quantities of TRI chemicals reported. For example,
                                                                                        200,000
    in 1994, SHAP was shut down for several months
    for a production model changeover. Since produc-                                               0
                                                                                                           1993          1994          1995            1996        1997
    tion rates are an important factor in evaluating TRI
    data, graph 3 shows TRI data on a per-vehicle             Graph 2
    basis. When the increase in production from 1994          Source: U.S. EPA Toxic Chemical Release
    to 1996 is taken into account, TRI chemicals              Inventory Reporting Form R.
    released or transferred off-site have remained
    constant or have been reduced since 1994.
                                                                                             Total TRI Releases and Tranfers
                                                                                           Per Vehicle: A Five-Year Comparison
    The TRI registry is a dynamic list of chemicals that                              7.00
                                                                                                                 5.91
    is always changing. The U.S. Environmental                                        6.00
                                                              Pounds/Vehicle




                                                                                                   4.44
    Protection Agency (EPA) periodically evaluates                                    5.00
                                                                                      4.00
    chemicals and adds them to the TRI registry when                                  3.00
                                                                                                                               3.07          2.97
                                                                                                                                                          2.25
    necessary. For example, in 1995 EPA added 286                                     2.00
    chemicals and chemical categories to the TRI                                      1.00
    registry. This added to SHAP’s list of reportable                                 0.00

    chemicals. EPA also removes or “delists”* chemi-                                               1993          1994          1995          1996         1997

    cals that have been reassessed and found to have          Graph 3
    minimal effect on human health and the environ-           Source: U.S. EPA Toxic Chemical Release
    ment.                                                     Inventory Reporting Form R.
                                                              Annual vehicle production figures provided by
                                                              DaimlerChrysler Corp.




* Refer to glossary

6    Michigan Department of Environmental Quality
                                                                                 Community Environmental Awareness Project

Waste management activities at SHAP                                                                    For more detailed information about materials SHAP re-
TRI data are also useful in assessing the amount of                                                    ports under TRI requirements and TRI data, please see
waste managed, which in turn is an indicator of waste                                                  Appendix B: SARA Title III Data.
reduction. Waste reduction includes activities that
reduce waste at the source through more efficient
production and material use. Waste reduction also
includes activities such as recycling, energy recovery
and treatment. Graph 4 summarizes waste manage-                                                            Contact information
ment activities at SHAP over the last five years.                                                          For more information about SARA Title III,
                                                                                                           contact:
                                               Total Waste Managed at SHAP:                                • SARA Title III Program, DEQ
                                                  A Five-Year Comparison                                       Environmental Assistance Division,
                   1,200,000                                                                                   Lansing Office, 517/373-8481.
                   1,000,000                       887,969                                                 • The Macomb County Local Emergency
 Pounds per Year




                                 800,000                                                                       Planning Committee*, 810/469-5270, can
                                 600,000
                                                             381,805
                                                                                                               provide more information about chemical
                                                                                 347,198
                                 400,000                                                   238,696             hazards in the community.
                                                                       169,373
                                 200,000                                                                   • The Emergency Planning and Community
                                               0                                                               Right-To-Know Hotline, operated by the
                                                    1993      1994      1995      1996      1997               U.S. EPA, provides up-to-date
                                                                                                               information on SARA Title III related
Graph 4                                                                                                        programs. The Hotline responds to factual
Source: Section 8, U.S. EPA Toxic Chemical Release Inventory                                                   questions and also to requests for related
Reporting Form R.
These activities include:                                                                                      documents. Call 1-800-535-0202,
Recycling: Toxic chemicals in wastes are generally recovered or                                                Monday-Friday, 8:30 a.m.-7:30 p.m. EST.
regenerated by a variety of methods.
Energy Recovery: Waste material is used as a source of fuel.                                               The DEQ publishes an annual TRI data
Treatment: Toxic chemicals in wastes are treated through a variety
                                                                                                           analysis for the state of Michigan. The public
of methods that destroy various amounts of the toxic chemical. In
some cases, the chemical is not destroyed but is prepared for                                              data release contains information on how
further waste management, such as contained disposal.                                                      facilities manage TRI chemicals. This
                                                                                                           information is available at local libraries and
                                                                                                           on the Internet at http://www.deq.state.mi.us/
Since production rates affect these totals, the following                                                  ead/sara/. Hard copy versions are available to
graph shows waste management activities on a per                                                           the public upon request.
vehicle basis.
                                                                                                           The 1997 TRI analysis will be completed in
                                                                                                           June 1999. TRI data from 1998 must be
                                         Total Waste Managed Per Vehicle at                                reported to the States and the Environmental
                                            SHAP: A Five-Year Comparison
                                                                                                           Protection Agency by July 1, 1999.
                                        6.00
                                                                                                           Please check the CEAP web site at
                                                             4.50
                   Pounds per Vehicle




                                        5.00
                                                   3.87                                                    http://www.deq.state.mi.us/ead/CEAP for
                                        4.00                                                               updates regarding TRI data.
                                        3.00
                                        2.00                                     1.49
                                                                       0.82                1.05
                                        1.00
                                        0.00
                                                   1993      1994      1995      1996      1997

Graph 5
Source: Section 8, U.S. EPA Toxic Chemical
Release Inventory Reporting Form R.
Annual vehicle production figures provided by
DaimlerChrysler Corp.                                                                                                                        * Refer to glossary

                                                                                                             Michigan Department of Environmental Quality     7
                                       Community Environmental Awareness Project




                                              AIR QUALITY

     Michigan has       Laws and regulations                            Michigan also has air requirements that are


                        T
more stringent air             he United States and Michigan have       more stringent than the federal law. For
requirements than               clean air programs to protect public    example, Michigan has strict laws for the
the federal law for             health and the environment. Federal     control of toxic air pollution through the
         the added      and Michigan laws set standards to prevent      construction permitting process and regula-
      protection of
                        and solve air pollution problems.               tions dealing with odor problems in the
        its citizens.
                                                                        community.
                        The federal Clean Air Act regulates air
                        emissions. This law:                            Air Quality in the region
                            • Sets national air quality standards       The DEQ Air Quality Division monitors air
                                for sulfur dioxide*, carbon             quality in southeastern Michigan. The air
                                monoxide*, nitrogen oxides*,            quality in this area is as good as or better than
                                particulate matter*, ozone* and         each of the national air quality standards.
                                lead*. The standards are set to
                                protect public health and welfare.      Air quality information is available through the
       The DEQ has          • Sets technology based emission            Air Quality Division’s Livonia District Office
            a “State            standards to make sure sources are      or the Air Quality Division’s Internet web
     Implementation             using the most advanced air             page at http://www.deq.state.mi.us/aqd/eval/
    Plan” to achieve            emission control equipment.             amu/amu.html. The Air Quality Division
      Clean Air Act         • Requires that any new or modified         issues an Air Quality Report every year that
      requirements.
                                major source of air emissions meet      summarizes statewide monitoring data.
                                special requirements that are made
                                part of a “new source review            SHAP’s air emissions permits
                                permit” issued before construction.     SHAP is authorized to emit air contaminants
                                Furthermore, each major source of       under state issued permits. SHAP has a total
                                air emissions must now have a           of 24 air use permits1, which specify a
                                “renewable operating permit,”           number of emissions limits and requirements.
                                which includes air emission control     SHAP has air use permits for the paint shop,
                                requirements for the entire facility.   powerhouse and various other processes at
                                                                        the plant.
      SHAP has air      The Michigan Department of Environmen-
   use permits that     tal Quality (DEQ) has a “State Implemen-        SHAP’s air emissions permit
           allow the    tation Plan” to achieve Clean Air Act           requirements
         emission of    requirements. The DEQ Air Quality               Permit requirements for SHAP include record
  air contaminates.     Division staff work to identify and reduce      keeping, periodic reporting of records to the
        The permits
                        existing outdoor air pollution problems and     DEQ and may require periodic testing and
specify a number of
      requirements,     prevent significant deterioration of the air    sampling of air emissions and/or materials.
  including record      quality. This is done through air emission      Permits also require that SHAP keep detailed
        keeping and     control programs, air monitoring, permit        records of paint shop operations. Typical
          sampling,     issuance and inspection of air emission         records would include the amount of paint
      among others.     sources.                                        used; the volatile organic compound (VOC)
                                                                        content of the paints; and calculations of the
                                                                        VOC emission rates.

                                                                        1
                                                                         Many, but not all of the regulatory requirements described
                        * Refer to glossary                             above are covered by the air use permits at the facility.

8    Michigan Department of Environmental Quality
                                     Community Environmental Awareness Project




Table 1 in Appendix C summarizes SHAP’s            A routine inspection may include:              DEQ staff monitor
air permits and requirements. Each year,               • Observation of stack exhausts for        SHAP on a regular
DaimlerChrysler must report SHAP’s actual                  visible emissions;                     basis and review
emissions of the following pollutants to the           • Sampling of paint and fuel;              reports submitted by
DEQ:                                                   • Review of company records and            SHAP to see if air
                                                                                                  permit requirements
     • Volatile organic compounds (VOC)                    emissions calculations;
                                                                                                  are being met.
     • Carbon monoxide (CO)                            • Evaluation of air pollution control
     • Nitrogen oxides (NOx)                               equipment for proper operation
     • Sulfur dioxide (SO2)                                and maintenance;
     • Particulate matter (PM)                         • Evaluation of ventilation and
     • Particulate matter less than                        exhaust systems for proper air
         10 microns (PM-10)                                pollutant capture and ducting to
     • Lead (Pb)                                           control devices; and
                                                       • Evaluation of process equipment
DEQ compliance evaluation                                  for proper design and operation
program for SHAP’s air emissions                           (e.g. paint applicators operating
permits                                                    per manufacturer’s specifications).
DEQ staff monitor SHAP on a regular basis
and review reports submitted by SHAP to            SHAP’s current performance                     According to DEQ
see if requirements are being met. If the          According to DEQ records and based on          records and the last
DEQ becomes aware of a violation of any            the last annual inspection, conducted in       inspection, SHAP is
requirement, DEQ staff contact the company         September 1998, SHAP is meeting all air        meeting all air
                                                   emission requirements. Table 2 in Appen-       emissions
to assure timely correction. Enforcement
                                                                                                  requirements.
actions taken by DEQ staff vary depending          dix C presents information about this
on the seriousness of the violation. Enforce-      inspection.
ment actions can include a phone call, a
written notice or even referral for a lawsuit.     SHAP’s performance history
                                                   From 1993 to 1997, there have been a
The Air Quality Division uses a number of          total of five air quality related violations
methods to evaluate compliance with air            at SHAP. Two of these violations re-
permit requirements and air quality regula-        sulted in a documented release or emis-
tions. The most common methods include:            sion that exceeded an allowable emission
    • Routine facility inspections;                limit or standard (in 1994 and 1996); two
    • Inspections as part of an investigation      violations related to the improper design
        of a citizen complaint. This type of       or operation of machinery or equipment
        investigation usually focuses on the       (in 1995 and 1996); and one violation
        process believed to be the source of the   related to inadequate monitoring, record
        complaint;                                 keeping or reporting (in 1995). An air
                                                                                                  From 1993 to 1997,
    • Review of performance testing done           emission violation is generally considered     there have been five
        by the company;                            the more serious type of violation. The        air quality related
    • Review of reports submitted by the           problems causing these violations were         violations at SHAP.
        company; and                               corrected in a timely manner. Table 2 in       These violations were
    • Voluntary disclosure resulting from          Appendix C provides detailed information       corrected in a timely
        company self audit/self reporting.         about these violations and the DEQ’s           manner.
                                                   actions.




                                                                     Michigan Department of Environmental Quality        9
                                    Community Environmental Awareness Project

SHAP’s air emissions                                                                              Five-Year Summary of SHAP’s VOC
Operations at the ‘paint shop’ and ‘powerhouse’ are the main                                           Emissions: Tons Per Year
sources of air emissions at SHAP. These sources have the most                      1200
                                                                                   1000
significant air permit requirements.




                                                                        Tons/year
                                                                                         800
                                                                                         600
                                                                                         400
The paint shop                                                                           200
The paint shop consists of car body priming and topcoat painting                          0

operations which emit volatile organic compounds (VOC), as                                                       1993          1994     1995    1996   1997
                                                                                                                            Volatile Organic Compounds
well as some compounds considered hazardous air pollutants.
VOC emission limitations depend on the painting operation               Graph 1
(prime, primer surfacer, topcoat and final repair). In order to
meet the VOC limits, the company uses a combination of low                                 Five-Year Summary of SHAP’s VOC
                                                                                             Emissions: Pounds Per Vehicle
VOC-containing paints, efficient application methods and                                 10
emission control equipment.




                                                                        Pounds/Vehicle
                                                                                          8
                                                                                          6
Graphs 1 and 2 show SHAP’s VOC emissions in tons per year                                 4
and pounds per vehicle from 1993 to 1997. The “tons per year”                             2
graph shows that annual VOC emissions declined from 1993 to                               0
1994 and increased in 1995. This shows that the total VOC                                                     1993             1994     1995    1996    1997
emissions from the plant are largely affected by vehicle produc-                                                            Volatile Organic Com pounds

tion rates. To see the effect of control technologies (for ex-          Graph 2
ample, less solvent in paint) on emissions, it is helpful to see how
much VOC is emitted for each vehicle produced. The “pounds                                                                   Five-Year Summary of SHAP’s
                                                                                                                              Particulate Matter Emissions
per vehicle” graph shows that from year to year, emission rates                                                        40
per vehicle have remained about the same or have decreased                                                             30
                                                                                                                                                                           1993
                                                                                                           Tons/year


since 1993. Table 4 in Appendix C provides SHAP’s VOC
                                                                                                                                                                           1994
                                                                                                                       20                                                  1995

emission data.                                                                                                         10
                                                                                                                                                                           1996
                                                                                                                                                                           1997

                                                                                                                        0
                                                                                                                             Particulate Matter    Particulate Matter
                                                                                                                               (total)              (<10 microns)
The powerhouse
The powerhouse provides steam and heat for use within the                                       Graph 3
plant. The powerhouse consists of boilers fueled by natural gas
or fuel oil. Nitrogen oxides, sulfur dioxide, carbon monoxide,                                                                Five-Year Summary of SHAP’s
particulate matter and lead are mainly emitted by the power-                                                           60
                                                                                                                               Carbon Monoxide Emissions

house. Emission limits are specified for particulate matter, visible                                                   50
                                                                                                       Tons/year




emissions (smoke), nitrogen oxides and sulfur dioxides. Particu-                                                       40
                                                                                                                       30
late matter emissions, such as soot, are controlled by equipment                                                       20

in the boiler exhaust and disposed of in a proper manner. The
                                                                                                                       10
                                                                                                                        0
total annual emissions of these pollutants are affected by the                                                               1993      1994       1995     1996         1997

amount of time the powerhouse is operating to produce heat for                                                                            Carbon Monoxide

the plant and the type of fuel, such fuel oil or natural gas, that is                          Graph 4
used. Graphs 3 to 7 summarize the annual trends.
                                                                                                                            Five-Year Summary of SHAP’s Lead
                                                                                                                                        Emissions
                                                                                                                0.0070
                                                                                                                0.0060
                                                                                                                0.0050
                                                                                               Tons/year




                                                                                                                0.0040
                                                                                                                0.0030
Graphs 1-7                                                                                                      0.0020
Source: DEQ Air Quality Division                                                                                0.0010
                                                                                                                0.0000
                                                                                                                               1993       1994     1995      1996        1997
                                                                                                                                                   Lead

                                                                                          Graph 5
                                                                                          In 1997, lead emissions were negligible.

10   Michigan Department of Environmental Quality
                                                    Community Environmental Awareness Project

                    Five-Year Summary of SHAP’s                     Over the past several years, SHAP has burned natural gas, a
                      Nitrogen Oxide Emissions                      cleaner fuel, in the powerhouse boilers. Before 1995, two of
              150                                                   the three boilers at the powerhouse burned coal, a fuel, which
                                                                    causes high air emissions. Currently, these two boilers burn
  Tons/year

              100
                                                                    only natural gas, a much cleaner burning fuel. The third boiler
               50                                                   burns natural gas and fuel oil. The graphs show that the
                                                                    change to cleaner burning fuels has resulted in decreased
                0                                                   emissions of particulate matter, lead, carbon monoxide,
                    1993   1994 1995 1996         1997
                                                                    nitrogen oxides, sulfur dioxide. Tables 3 and 4 in Appendix C
                            Nitrogen Oxides
                                                                    present SHAP’s annual emissions data from 1993 to 1997.
Graph 6

                    Five-Year Summary of SHAP’s
                       Sulfur Dioxide Emissions
              300
              250                                                           Contact information
 Tons/yesr




              200
              150
                                                                            For further information about SHAP’s air
              100                                                           emissions contact:
               50                                                               • Air Quality Division, DEQ
                0                                                                   Southeastern Michigan District
                    1993   1994    1995    1996    1997
                              Sulfur Dioxide
                                                                                    Office, 734/953-1413.
Graph 7
In 1997, sulfur dioxide emissions were negligible.



                                                         WATER QUALITY
Laws and regulations                                                      The Clean Water Act requires a National Pollution


I
              ndustrial sites can affect water quality in four            Discharge Elimination System* (NPDES) permit to
              ways:                                                       discharge any waste to surface waters. The Michigan
              • Discharges of wastewater* to city sewage                  Department of Environmental Quality (DEQ) is autho-
                  treatment plants*;                                      rized to carry out the federal NPDES program under
              • Storm water runoff* from the site;                        the authority of state law, Part 31 of the Michigan
              • Direct discharges of treated wastewater                   Natural Resources and Environmental Protection
                  to surface waters (such as lakes, rivers                Act. Michigan state law requires a permit to discharge
                  or streams) and/or groundwater                          wastewater or storm water (runoff from when it rains
                  (water beneath the earth’s surface); and                or snows) to surface waters or groundwater (water
              • Spills to surface waters and/or groundwater.              beneath the earth’s surface). The NPDES permit
                                                                          program controls discharges to protect fishing and
The Clean Water Act of 1977 is the national law that                      swimming in surface waters such as lakes, rivers and
protects water quality. State and local laws and permits                  streams. The long-range goal is to stop the discharge of
also protect water quality. The Clean Water Act gives                     pollutants to surface waters through better treatment
the U.S. EPA the power to set wastewater discharge                        and control of wastes. The permits that the DEQ issues
standards on an industry basis. Wastewater is water                       contain discharge limits and other guidelines to assure
carrying wastes from homes, businesses and industries                     proper treatment methods are used and water quality
that is a mixture of water and dissolved or suspended                     standards are met. The NPDES permit for a city
solids. A discharge is a release of any waste into                        sewage treatment plant indirectly regulates all industrial
surface or groundwater from a point or known source,                      dischargers into the city’s sewer system. Spills of
such as a pipe. Michigan sets water quality standards                     polluting materials to surface waters are prohibited
for all substances that could harm surface waters.                        under the Michigan Natural Resources and Environ-
                                                                          mental Protection Act and a number of related federal
* Refer to glossary                                                       laws.

                                                                               Michigan Department of Environmental Quality     11
                                      Community Environmental Awareness Project

 SHAP discharges       SHAP’s discharge permits                       Cities that receive industrial wastewater are
    about 600,000      SHAP discharges its wastewater through         required by state and federal law to have these
         gallons of    Sterling Heights’ sewers to Detroit’s          programs. Industrial Pretreatment Programs
    wastewater and                                                    are designed to:
                       sewage treatment plant. SHAP’s dis-
  sewage per day to
                       charge is therefore regulated under the            • Protect the sewerage system. For
        the sewage
 treatment plant in    Industrial Pretreatment Program                         example, discharging a material like
         Detroit via   (discussed below). SHAP is also autho-                  gasoline, which is explosive, is
 Sterling Heights’     rized to discharge storm water to                       prohibited.
           sewers.     Plumbrook Creek and is regulated under a           • Protect the sewage treatment
                       state storm water discharge permit.                     plant. For example, especially
                       SHAP does not discharge any wastewa-                    corrosive or toxic chemicals can
                       ter directly to surface waters, storm                   damage equipment or destroy the
                       sewers or groundwater.                                  bacteria needed for treatment.
                                                                          • Protect water quality of the receiving
   SHAP’s permit to    Figure 2 shows SHAP’s wastewater and                    waters, such as the Detroit River.
          discharge    storm water discharges.                            • Protect the quality of the sludge or
   wastewater to the                                                           biosolids. Sludge is produced as a part of
     Detroit sewage    Discharges to city sewage                               treatment and need to be disposed of
 treatment plant has
        about thirty
                       treatment plants (in general)                           safely.
      requirements,    Industries generate wastewater in the
including sampling.    process of manufacturing their products.       It is the responsibility of the city that operates
                       The disposal of wastewater is regulated        the sewerage system (in this case, Detroit), to
                       by local, state and federal laws as neces-     administer an effective Industrial Pretreatment
                       sary to protect surface water and ground-      Program. The DEQ reviews and approves the
                       water. Some industrial facilities send their   local Industrial Pretreatment Program and
                       wastewater to city sewage treatment            evaluates the city sewage treatment plant at
                       plants, where that wastewater is treated       least once a year to make sure that all policies
                       along with sewage from local residents.        and regulations are being met.
                       The industry must have a permit from the
                       City allowing them to use the local            SHAP’s wastewater discharges to
                       sewage treatment plant.                        Sterling Heights and Detroit
                                                                      SHAP discharges treated process wastewater
Storm water runoff     In some cases, industry is required to         and sewage to the Sterling Heights sewer
      can also be a    treat its wastewater to remove suspended       system. Process wastewater is any water that
source of pollution    solids and other substances before             comes in contact with raw materials, products,
  and is covered by    sending it to the sewerage system. This        byproducts or wastes. The wastewater that
    SHAP’s storm       local permitting system is known as the        SHAP discharges to the Sterling Heights sewer
     water permit.     Industrial Pretreatment Program*.              is rinse water from metal cleaning, coating and
                                                                         painting. SHAP treats its wastewater to
                                                                         reduce the amounts of metals, oils and solids
                                                    Figure 2             in the water before it goes to the sewer
                                                                         system. SHAP also discharges cooling
                                                                         wastewater and other wastes to the sanitary
                                                                         sewer. The total wastewater discharge is
                                                                         about 600,000 gallons a day.

                                                                        The sewer system leads to the sewage
                                                                        treatment plant in Detroit. A sewer use
                                                                        ordinance and a permit from Detroit control
                                                                        the quality of wastewater discharged by
                                                                        SHAP.

                                                                                                     * Refer to glossary

12     Michigan Department of Environmental Quality
                                    Community Environmental Awareness Project

SHAP’s permit requirements to discharge                    SHAP’s current performance
wastewater to the sewage treatment plant                   According to Detroit records, SHAP is in compliance
SHAP is regulated under the Industrial Pretreatment        with all Industrial Pretreatment Program permit
Program. The permit has approximately thirty distinct      requirements.
requirements, such as sampling for a number of chemi-
cals. For example, wastewater must be sampled ten          SHAP’s performance history with the permit
times every three months for heavy metals such as lead     to discharge to sewage treatment plant
and copper.                                                From 1993 to 1997, there have been a total of five
                                                           wastewater discharge violations at SHAP. The facility
Some of the other important requirements of the            was cited for water-related violations that occurred on
wastewater discharge permit are to:                        September 21, 1993 and April 10, 1997. SHAP notified
   • Meet all the wastewater quality requirements;         the Detroit of these violations in a timely manner and
   • Report a limit violation within 24 hours;             promptly came back into compliance on both occasions.
   • Regularly sample to assure compliance. If
        there is a violation, take additional samples to   SHAP reported three bypasses of the treatment system
        demonstrate that the quality has returned to       to Detroit in the four-year period. A bypass discharges
        compliance;                                        wastewater directly to the sewer without treatment.
   • Report all discharge data and information every       Bypasses on March 3, 1995 and September 18, 1995
        six months;                                        were due to power outages at SHAP. The third bypass
   • Have a spill prevention and control plan; and         occurred on August 22, 1997. It was due to a plugged
   • Report any significant spill within one hour of       valve in the treatment system. The third bypass was
        awareness.                                         considered significant, and Detroit issued a Notice of
Table 1 in Appendix D summarizes the permit require-       Violation. SHAP paid a penalty of $1,237 on November
ments.                                                     10, 1997 in compliance with the Notice. SHAP notified
                                                           Detroit of all three bypasses at the time they occurred.
Detroit’s compliance evaluation program for                The bypasses did not result in Detroit violating its water
SHAP’s discharge to the sewage treatment                   quality limits for its discharge to the Detroit River. For
plant                                                      more detailed information about these violations, see
Detroit evaluates SHAP’s compliance through the            Table 2 in Appendix D.
review of sample data and reports, site inspections and
on-site sampling. SHAP is required to sample its           Storm water discharges (in general)
wastewater regularly. SHAP samples more frequently         When it rains or snows, water that does not soak into
than required. Wastewater samples are collected daily      the ground washes over roads, neighborhoods, industrial
to make sure the treatment is effective. The sampling      sites and other surfaces. This ‘runoff’ can pick up dirt,
reports are sent to Detroit every six months. Detroit      oil products and other pollutants. Since this can be a
reviews the sampling data and periodic reports that        serious source of pollution, industries that have raw
SHAP submits to them for compliance with the permit        material, products, waste materials or machinery
limits and conducts inspections at SHAP at least twice     exposed to storm water must meet storm water re-
a year. Detroit evaluates SHAP’s treatment system,         quirements, including obtaining a storm water permit.
sampling equipment, laboratory and spill control during    The DEQ issues a general storm water permit under
the inspections and samples SHAP’s wastewater to           which most industries are regulated. The goal of the
confirm that SHAP is within the permit limits.             storm water program is to improve the quality of storm
                                                           water that flows to surface waters.
Detroit advises SHAP in writing of any problems or
violations that are found during the evaluations or        SHAP’s storm water discharges
inspections. SHAP must respond to Detroit’s notice         SHAP has materials stored outside that are exposed to
and demonstrate that problems are corrected. If the        storm water and has obtained a general storm water
problems are not corrected, Detroit can fine SHAP,         permit from the DEQ. The permit authorizes and
enter into consent agreements with SHAP or file court      regulates SHAP’s storm water discharge to a local
actions. In accordance with program requirements,          drain that leads to Plumbrook Creek. Plumbrook Creek
Detroit publishes the names of companies that are not      is a tributary of the Clinton River.
consistently in compliance in the local newspaper every
year.

                                                                Michigan Department of Environmental Quality     13
                                    Community Environmental Awareness Project

SHAP’s storm water discharge permit                         Direct discharges to surface water and/or
requirements                                                groundwater
SHAP’s storm water permit has several requirements:         SHAP does not discharge any wastewater directly to
  • SHAP must have an on-site person trained and            surface waters, storm sewers or groundwater.
      certified by the DEQ to inspect and manage
      the storm water controls at the plant. Examples       Spills
      of storm water controls are a storm water             Surface and groundwater quality can also be affected
      collection pond and a dike around a storage           by accidental spills. Spills to the open environment are
      tank.                                                 prohibited under state law.
  • SHAP must maintain a Storm Water Pollution
      Prevention Plan, which describes how the              SHAP spill requirements
      plant will minimize the pollutants reaching           SHAP must report any spills of oil or other harmful
      surface waters.                                       materials under Michigan’s Oil and Polluting Mate-
                                                            rial Spill Prevention rules. State law requires facilities
DEQ compliance evaluation program for                       to have adequate plans to prevent and respond to spills
SHAP storm water discharge permit                           of oil and other polluting materials to surface and
The DEQ evaluates storm water permit applications to        groundwater. Facilities such as SHAP are required to:
determine if the rules apply and provides training and           • Develop a prevention plan that outlines what
certification to the facility storm water operators. The             measures will be taken to prevent an accident;
records and reports from the permit holders are re-              • Provide spill containment equipment and
viewed by the DEQ to confirm compliance. The DEQ                     adequate personnel at sites where polluting
inspects permit holders in response to complaints, at the            materials are transferred;
request of the facility or for other reasons. There have         • Provide adequate surveillance so that a spill
been no storm water inspections of SHAP to date.                     can be quickly detected;
                                                                 • Immediately dike or contain a spill if one is
SHAP’s current performance                                           detected; and
According to DEQ records, SHAP is in compliance                  • Report spills to the DEQ. Reports must outline
with the storm water permit requirements. SHAP has a                 the cause, discovery and actions taken to
trained person on site who inspects and takes care of                remove the spilled material from the water.
storm water controls at the plant to reduce the amount
of pollution in storm water. Some types of storm water      Spills are subject to enforcement actions, which are
controls are moving materials inside or building a storm    based on the severity and environmental impact.
water collection pond. SHAP has advised the DEQ
that they have a Storm Water Pollution Prevention           SHAP’s current performance
Plan, as required. This plan explains the storm water       According to DEQ records, there have not been any
controls the plant uses to minimize pollutants. For a       reported spills to surface waters or groundwater at
summary of SHAP’s storm water permit requirements           SHAP under Michigan’s Oil and Polluting Material
and compliance, see Table 3 in Appendix D.                  Spill Prevention rules. SHAP has developed a pollu-
                                                            tion prevention plan to address oil and solvents stored
                                                            on site.


          Contact information
          For more information about water discharges contact:
              • Sanitary sewer discharges, DEQ Southeastern Michigan District Office, 734/953-1433.
              • Storm water discharges, DEQ Southeastern Michigan District Office, 734/953-1440.
              • Spills and surface water discharges, DEQ Southeastern Michigan
                 District Office, 734/953-1431.

          For information about Detroit’s sanitary sewer permit, contact:
              • Detroit Industrial Waste Control at 313/297-5801.


14    Michigan Department of Environmental Quality
                                   Community Environmental Awareness Project


                      HAZARDOUS WASTE MANAGEMENT
Laws and regulations                                •   Updates regulations so they are        The federal



H
        azardous wastes are wastes that                 in accordance with current state       Resource
        may, if improperly managed, pose a              and federal law;                       Conservation
        danger to human health and the              •   Conducts inspections and take          Recovery Act gives
                                                                                               Michigan the power
environment. The regulations defining                   steps to resolve non-compliance,
                                                                                               to regulate
“hazardous waste” are complex, and they                 with enforcement, if necessary;        hazardous waste
focus on whether the waste is:                      •   Processes manifests for the            from “cradle-to-
    • Toxic to humans,                                  tracking of hazardous waste from       grave.”
    • Easily ignited,                                   generation to disposal;
    • Corrosive* or                                 •   Issues construction permits and
    • Reactive.                                         operating licenses for certain
                                                        treatment, storage and disposal
The federal Resource Conservation Recov-                facilities; and
ery Act (RCRA) gave the U.S. Environmen-            •   Requires cleanup of contami-
tal Protection Agency and Michigan, by                  nated solid waste management
delegation, under the authority of state law,           units located at RCRA regulated
the power to regulate hazardous waste from              treatment, storage and disposal
“cradle-to-grave.” This includes the genera-            sites.
tion, transport, treatment, storage and dis-
posal of hazardous waste. RCRA also set         The Michigan Department of Environmen-         SHAP generates
forth a framework for the management of         tal Quality (DEQ) carries out a number of      more than 2,200
non-hazardous solid wastes. Michigan law        RCRA programs. The Hazardous Waste             pounds of hazardous
                                                Program of the DEQ Waste Management            waste each
(Part 111 and Part 121, respectively of the
                                                Division regulates both hazardous waste        month and is
Natural Resources and Environmental
                                                                                               regulated as a
Protection Act) regulates non-hazardous solid   and non-hazardous liquid industrial waste.
                                                                                               “Fully Regulated
and liquid industrial wastes.                   There are three general categories of          Generator.”
                                                facilities regulated under the hazardous
The Hazardous Waste Program of the DEQ          waste program: 1) treatment, storage, and
assures hazardous waste is managed in           disposal facilities; 2) transporters; and 3)
accordance with state and federal law. In       generators.
general, the program:
    • Inspects facilities;                      Waste generators (in general)
    • Reviews required submittals from          Facilities that generate waste through their
         facilities;                            manufacturing or other on-site processes
    • Reviews waste determinations. A           are regulated as “generators.”
         waste determination is when a
         hazardous waste generator must         There are three types of hazardous waste
         characterize and maintain              generators. “Fully Regulated Generators,”
         documentation indicating whether the   also known as “Large Quantity Genera-
         wastes it generates are hazardous,     tors,” produce more than 1,000 kilograms
         industrial wastes or non-hazardous;    (2,200 pounds) of waste per month. “Small
    • Reviews hazardous waste delisting         Quantity Generators” produce from 100 to
         petitions*;                            1,000 kilograms (220 to 2,200 pounds) of
    • Provides the public and regulated                                                        According to DEQ
                                                waste per month. “Conditionally Exempt
         industry with information about                                                       records, SHAP is
                                                Small Quantity Generators” produce less        in compliance
         waste recycling, reuse and proper      than 100 kilograms (220 pounds) of waste       with all Fully
         management requirements;               per month. Figure 1 on the following page      Regulated
                                                explains the types of hazardous waste          Generator
                                                generators.                                    requirements.
* Refer to glossary

                                                                Michigan Department of Environmental Quality      15
                                     Community Environmental Awareness Project


SHAP’s waste generator                             Figure 1: Hazardous Waste Quantity Categories
status
SHAP generates hazardous                  Key:      = 200 kilograms (440 pounds) of hazardous waste
waste and is regulated as a
generator. SHAP is a “Fully
Regulated Generator” because it           Conditionally Exempt Small Quantity Generator Limits:        Less than
generates more than 1,000                 In one month, you generate:
kilograms per month of hazard-               •   Less than 100 kilograms (220 pounds).
ous waste. SHAP is not a                     •   This is approximately equal to less than half a 55-gallon drum, or 25 gallonsw.
treatment, storage or disposal               •   AND you never accumulate 1,000 kilograms (2,200 pounds) or more at any
                                                 time.
facility, or a transporter.

SHAP requirements as a                    Small Quantity Generator Limits:         to Less than
hazardous waste generator                 In one month, you generate:
As a Fully Regulated Generator,               • From 100 kilograms (220 pounds) to less than 1,000 kilograms (2,200 pounds).
                                              • This is approximately equal to 1/2 to 5 drums, or 25 to 250 gallonsw.
SHAP must meet many record                    • AND you never accumulate 6,000 kilograms or more at any time.
keeping, storage and containment
requirements, among others.
                                          Fully Regulated Generator Limits:                               or more
Types of regulations that apply to
each type of hazardous waste              In one month, you generate:
                                              • 1,000 kilograms (2,200 pounds) or more.
generator are presented in Table              • This is approximately equal to 5 full drums or more, or 250 gallonsw.
1 of Appendix E.
                                          w Equivalent to a 55-gallon drum if the weight and volume of waste is equal to water.
DEQ compliance
evaluation process for
hazardous waste generators                                      1993 to 1997, SHAP has been notified of eleven
Compliance is checked by DEQ staff for all regulated            hazardous waste requirement violations. On July 29,
waste and areas of the facility. After a DEQ inspec-            1997, a DEQ inspection found the following violations:
tion, a letter is sent to the company noting the inspec-            • Air Emission - Certain requirements to assure
tion results. If the company is in compliance with all                  hazardous waste is handled in a manner to
requirements, the letter confirms that. If apparent                     not give off any air emissions were not met.
violations are found, they will be cited in a letter of                 This violation did not result in a release to the
warning. In that situation, the company’s response is                   environment.
tracked to assure timely correction of any violations. If
                                                                    • Waste Storage Requirement - Certain
the company fails to respond satisfactorily, or if there
                                                                        requirements for storage of hazardous waste
was a major violation, the DEQ may pursue escalated
                                                                        were not met. There were nine waste storage
enforcement action. This includes the entry of an order
                                                                        requirement violations. These violations did not
or litigation, if appropriate.
                                                                        result in a release to the environment.
                                                                    • Record Keeping Requirements - Certain record
SHAP’s current performance
                                                                        keeping requirements for hazardous waste
According to DEQ records, SHAP is meeting all
                                                                        were not met. This violation did not result in a
hazardous waste generator requirements.
                                                                        release to the environment.
SHAP’s performance history as a hazardous                       The DEQ issued a Letter of Warning, citing these
waste generator                                                 violations, on August 14, 1997. SHAP responded to
The DEQ has performed two inspections at SHAP                   that letter on September 4, 1997, and full compliance
within the past eight years. These inspections are              was achieved by March 1, 1998. All other hazardous
unannounced to assure proper management of hazard-              waste management requirements were met. See Table
ous and non-hazardous liquid industrial wastes. From            2 of Appendix E for a summary of inspections and
                                                                results.


16    Michigan Department of Environmental Quality
                                     Community Environmental Awareness Project

Waste generation at SHAP                                                       Five-Year Summary of Waste                   Graph 1
Graph 1 shows the total quantity of hazardous                                       Generation at SHAP                      Source: DEQ
and non-hazardous liquid industrial waste                             600000
                                                                                                                            Waste
generation at SHAP over a five-year period.                           500000                                                Management




                                                    Total kilograms
                                                                      400000                                                Division
    Contact information                                               300000

    For additional information about                                  200000

    hazardous and non-hazardous liquid                                100000

    industrial waste at SHAP, please                                      0
    contact:                                                                   1993     1994    1995   1996   1997

        • Hazardous Waste Program,                                                             Waste

             Waste Management Division,
             DEQ Southeastern Michigan
             District Office, 734/953-1448.




                                         STORAGE TANKS
Laws and regulations                               The DEQ Storage Tank Division:                                    An underground



E
       xcept in a few instances, federal regu-        • Regulates the design,                                        storage tank (UST)
       lations before 1984 did not address               construction, installation and                              is a tank and any
                                                         operation of regulated UST’s and                            underground piping
       underground storage tanks. In 1984,
                                                                                                                     connected to the
Congress passed the Hazardous and Solid                  AST’s for the purpose of
                                                                                                                     tank that has at
Waste Amendments to the Resource Conser-                 preventing releases of regulated                            least ten percent of
vation and Recovery Act. These amend-                    substances to the environment;                              its combined volume
ments included requirements for new tank              • Reviews plans for UST and AST                                underground. An
standards, record keeping and compliance                 installation;                                               aboveground
monitoring, among others. Other laws and              • Performs UST and AST                                         storage tank (AST)
amendments were later passed to address                  inspections;                                                is a tank and all
leaking tanks and financial responsibility for                                                                       related piping that
                                                      • Registers UST’s and AST’s;
actions, such as cleanups. Tanks are also                                                                            is above ground.
                                                      • Certifies AST’s and UST’s;
regulated under state law (Parts 211, 213 and
                                                      • Initiates and monitors corrective
215 of the Natural Resources and Environ-
                                                         and remedial action relating
mental Protection Act 1994 PA 451, as
                                                         to leaking UST’s; and
amended). Compliance with state law satisfies
                                                      • Reviews UST tank closure site
federal requirements.
                                                         assessment reports.
The DEQ Storage Tank Division regulates
                                                   In general, all registered tanks are
underground storage tanks* (UST’s) and
                                                   inspected by the DEQ Storage Tank
aboveground storage tanks* (AST’s). A UST
                                                   Division before being put into service.
is a tank and any underground piping con-
                                                   Inspections ensure proper installation and                        The DEQ Storage
nected to the tank that has at least ten percent
                                                   assure that all safety features work                              Tank Division
of its combined volume underground. An AST
                                                   properly. Safety features include double-                         inspects
is a tank and all related piping that is above                                                                       Underground Storage
                                                   walls, tank lining and leak detection
ground.                                                                                                              Tanks (USTs) and
                                                   devices to warn of potential leaks.
                                                                                                                     Aboveground Storage
The Storage Tank Division registers and                                                                              Tanks (ASTs) prior to
regulates storage tanks that contain com-                                                                            installation to assure
pressed gas, petroleum, or flammable or                                                                              safety.
combustible liquids above certain volumes.         * Refer to glossary

                                                                                      Michigan Department of Environmental Quality     17
                                        Community Environmental Awareness Project



      SHAP has one          SHAP storage tanks                          The Storage Tank Division assessed the
underground storage         There are both UST’s and AST’s at           release and SHAP removed the tank. SHAP
  tank that contains        SHAP.                                       has complied with all Storage Tank Division
         diesel fuel.                                                   reporting requirements.
                            SHAP underground storage tanks
                            SHAP has one registered 5,000 gallon        SHAP aboveground storage tanks
                            UST that contains diesel fuel. The UST      SHAP has 14 AST’s, of which seven are
                            at SHAP met all inspection require-         regulated by the Storage Tank Division. The
                            ments. After installation, tanks are        AST’s at SHAP vary in size from 250 to
                            inspected randomly or if a problem is       15,000 gallons and contain diesel fuel, gasoline
                            reported by the facility.                   and solvents. Before installation, the Techni-
                                                                        cal Review Unit of the Storage Tank Division
        SHAP has 14         SHAP is responsible for monitoring its      approved the plans for the tanks and the area
aboveground storage         UST, piping and dispensing equipment.       around the tanks.
   tanks that contain       SHAP must report any potential prob-
 diesel fuel, gasoline      lems to the DEQ.                            Currently, SHAP does not have any reporting
         and solvents.
                                                                        requirements. AST’s are inspected every
                            SHAP’s current performance                  three years. The Storage Tank Division
                            SHAP met all the conditions of the pre-     conducted an inspection in December 1996.
                            installation inspection and is in compli-   This inspection looked at the condition of
                            ance with all UST requirements, accord-     tanks, piping, spill and containment areas,
                            ing to DEQ records. SHAP was in-            among other requirements.
                            spected in January 1999 to verify that
                            the Storage Tank Division’s 1998 up-        SHAP’s current performance
                            grade requirements have been met.           SHAP met all the conditions of the last
                                                                        inspection and is in compliance with all AST
      According to DEQ                                                  requirements, according to DEQ records.
                            SHAP’s UST performance history
      records, SHAP is                                                  SHAP’s next AST inspection will be in
     in compliance with
                            In June 1998, SHAP had a confirmed
                            release from a UST. SHAP contacted          December 1999.
        all underground
       and aboveground      the DEQ, as required, when it found that
             storage tank   soil or water near the tank had been
          requirements.     contaminated with diesel from the tank.




                                              Contact information
                                              For more information about UST’s and AST’s, contact:
                                                  • DEQ Storage Tank Division, Southeast Michigan
                                                     District Office, 734/953-1450




18      Michigan Department of Environmental Quality
                                    Community Environmental Awareness Project



                               POLLUTION PREVENTION

P
       ollution prevention (P2) aims to          other materials of concern in the Auto          DaimlerChrysler
       eliminate and/or reduce the generation    Companies’ assembly and manufacturing           Corporation has
       of waste at its source where practi-      facilities. The final progress report for the   been an active
cable, environmentally acceptable and            Auto Project was released in November           participant in the
economically feasible. Wastes that cannot        1998. DaimlerChrysler reported that in          U.S. Automotive
                                                                                                 Pollution Prevention
reasonably be prevented at the source should     the U.S. it had reduced Toxic Chemical
                                                                                                 Project.
be reused or recycled in an environmentally      Release Inventory releases on a per
sound manner. Pollution prevention activities    vehicle basis by 61.8% from 1988 to
include process or procedure changes,            1995. The U.S. Auto Project is being
technology changes, input material and           replaced by a new Michigan auto project,
product changes, and good operating prac-        which will focus primarily on Michigan
tices.                                           companies.

The Michigan Department of Environmental         DaimlerChrysler has received national
Quality (DEQ) Pollution Prevention Strategy      recognition for its pollution prevention
states that waste and pollution should be        programs, including an award from the
prevented or minimized whenever possible.        U.S. Environmental Protection Agency
When wastes and pollution cannot be pre-         for its leadership in waste prevention
vented at its source, on-site and off-site       under its Waste Wise program.
recycling and other recovery methods should
be utilized.                                     As part of its many pollution prevention
                                                 efforts, DaimlerChrysler Corporation has
DaimlerChrysler was an active participant in     found alternative cleaning methods for
the U.S. Automotive Pollution Prevention         machinery used for painting. The new
Project (Auto Project), which recently ended.    methods eliminated 7.3 tons of VOC per
The U.S. Auto Project was a voluntary effort     year and eliminated the disposal of over
by DaimlerChrysler (formerly Chrysler),          22,000 gallons of hazardous material to
Ford, and General Motors (the Auto Compa-        waste treatment and the handling and
nies) to promote pollution prevention through-   disposal of over 400 55-gallon drums per
out their business operations, products and      year. DaimlerChrysler’s accomplishments
                                                                                                 DaimlerChrysler
practices. The project started in 1991 as a      have been highlighted in a DEQ case             has reduced Toxic
Great Lakes regional effort and expanded         study. Case studies and more information        Chemical Release
nationwide in September 1995. It has focused     about pollution prevention efforts in the       Inventory releases
on reductions in the use, generation and         auto industry can be found on the World         by 61.8% on a
release of persistent toxic substances and       Wide Web at http://www.deq.state.mi.us/         per vehicle basis
                                                 ead/p2sect/auto/.                               from 1988 to 1995.



                                     Contact information
                                     For more information about pollution
                                     prevention, contact:
                                        Environmental Assistance Division
                                                  (800) 662-9278




                                                                  Michigan Department of Environmental Quality    19
                                      Community Environmental Awareness Project




                             THE PERMITTING PROCESS
                             AND PUBLIC PARTICIPATION


T
       he state of Michigan is responsible for assuring a public participation process on significant pending
       permitting decisions. The Department of Environmental Quality assures public participation on proposed
       projects that might impact air quality, water quality and waste management.

The flow chart below gives a basic overview of the permitting process for significant permits. This outline is not
all-inclusive; some permits may require additional procedures. In general, the permitting process for significant
permits takes about 180 days.



                  Permit Application                        DEQ reviews permit the application for completeness
                      Received                              and accuracy and notifies applicant of status. The
                                                            applicant may need to provide additional information.

                     Draft Permit                           DEQ develops a draft permit based on the application
                     Development                            and any additional information required to be provided
                                                            by the applicant.

                     Public Notice                          A draft permit is placed on public notice, with a public
                                                            comment period of at least 30 days. Public notices
                                                            appear in the legal or classified sections of a local
                                                            newspaper. This information can also be obtained
                                                            through the DEQ Calendar, which is published every
                                                            two weeks, on alternate Mondays.

                                                            At the same time, the draft permit is sent to the
                                                            applicant, the district, adjacent property owners listed
                                                            in the permit (if applicable) and any names included
                                                            on the mailing list for public notice.

                                                            DEQ addresses concerns raised during public notice
                                                            period.
                                                            w Based on comments received, the draft permit may
                                                            require extensive revision.
                                                            w If there is controversy regarding the project, a public
                                                            hearing or meeting may be required. This provides
                                                            another opportunity for the public to participate in the
                                                            decision making process.
                                                            w If the permit is changed significantly, re-public notice
                                                            may be required.


                    Permit Issuance                         DEQ issues or denies permit. An applicant or other
                                                            person may appeal a permit decision through an
                                                            administrative contested case hearing.


20    Michigan Department of Environmental Quality
                                        Community Environmental Awareness Project
Why is public participation important?                            improperly denied or issued, may appeal a permit decision
Public participation assures that the community’s voice is        through an administrative contested case hearing. Follow-
heard regarding proposed significant permits for an               ing the final action after a hearing, the decision can be
industry or business. The permit may allow for a new or           appealed to the Circuit Court.
increased release or discharge of pollutants, wastewater
or other materials to the environment. In these situations,       What are some other ways for community members
it is important for the public to be knowledgeable about          to become involved?
new environmental issues in their community. Public               One of the most effective ways to become involved in
participation allows the public to comment on proposals           community environmental issues is to actively participate
and share their views.                                            in community organizations and public interest groups.
                                                                  Academic organizations, business associations, neighbor-
How can the public participate?                                   hood groups, environmental interest groups and city
After a public notice has been posted, the public has             government provide participation opportunities for citi-
several opportunities to participate. Citizens can request        zens.
more information regarding the specific permit applica-
tion, submit written comments, request a public meeting           Permit appeals
or public hearing, or request an informal meeting with            The processes for formal administrative appeals of permit
DEQ staff. A public meeting or public hearing is usually          decisions are set forth in statutes and rules relating to the
held when there is considerable public interest or contro-        various permitting programs. In general, if a person is
versy regarding a proposed project.                               aggrieved by an agency decision, that person has the right
                                                                  to file a formal request for a contested case hearing. At the
All information regarding a permit application and relating       hearing, evidence is presented and an administrative
correspondence, staff analysis, reports and recommenda-           hearing officer will develop formal findings of fact and
tions are available to the public upon request. There may         proposal for decision. The director or designated represen-
be some specific technical information in the application         tative will make the final agency decision following the
that is proprietary business information (trade secrets)          hearing. That decision may be appealed in court.
that may be held confidential, but all information regard-
ing releases or discharges to the environment is available        Federal oversight
to the public.                                                    Many of the permitting programs administered by the
                                                                  DEQ satisfy permit requirements of federal law (Clean Air
How are public comment and feedback considered?                   Act, Clean Water Act, Resource Conservation and Recov-
Public comment and feedback are taken very seriously              ery Act) and are administered under authority delegated by
by the DEQ. All issues raised are reviewed and must be            the U.S. Environmental Protection Agency (EPA). Under
adequately addressed. The public comment process does             the delegation agreements, the EPA oversees the programs
impact the permitting decision. Often, permits will be            and has the authority to object to significant proposed
modified or issuance delayed so that public concerns can          permit actions if they are not consistent with the delega-
be addressed. An applicant or any other person dissatis-          tion agreement. It is extremely rare for the EPA to object
fied with permit conditions or who believes a permit was          to a proposed permit in Michigan.

   Contact information
   •    Contact the City of Sterling Heights Community Relations Department at 810/446-CITY for more information about
        community organizations. A calendar of city government meetings can be found on the Sterling Heights web site at
        http://www.ci.sterling-heights.mi.us.
   •    To receive the DEQ Calendar, send a request to: DEQ Calendar, Michigan Department of Environmental Quality,
        P.O. Box 30473, Lansing, MI 48909-7973 or call 517/335-3153. The calendar can also be accessed on the Internet at
        http://www.deq.state.mi.us/cal/.

   For more information about permits, contact the DEQ Environmental Assistance Center (EAC) at 800/662-9278. The EAC
   provides direct access to DEQ environmental programs, answers to environmental questions, referrals to DEQ technical
   staff and quick response. Questions on any items listed in the DEQ Calendar as well as other requests can be referred to
   the EAC.

   The public is encouraged to report pollution emergencies or suspected pollution incidents to the Pollution Emergency
   Alert System at a toll free number (1-800-292-4706). Pollution emergencies include emission events, spills, illegal activities
   or other complaints regarding any type of pollution. DEQ staff investigate and respond to emergency occurrences and
   coordinate actions with other agencies.

                                                                         Michigan Department of Environmental Quality          21
                                  Community Environmental Awareness Project



                              CONTACT INFORMATION
The following resources can provide more detailed information. Many reports submitted to government
agencies are on the Internet and available to the community.

Michigan Department of Environmental Quality
              SE MI District Office                                                38980 7 Mile Road
                                                                                   Livonia, MI 48152-1006
                                                                                   (734) 953-8905
Environmental Assistance Division ................................................ 1-800-662-9278
Air Quality Division, SE MI District Office ................................... (734) 953-1413
Land & Water Management Division, SE MI District Office ....... (734) 953-1488
SARA Title III Program, Lansing Office ...................................... (517) 373-8481
Storage Tank Division, SE MI District Office ............................... (734) 953-1450
Surface Water Quality Division, SE MI District Office ................ (734) 953-1451
Waste Management Division, SE MI District Office .................... (734) 953-1448
Pollution Emergency Alert System ................................................ 1-800-292-4706


Michigan Department of Community Health ......................... (517) 335-3500
National Response Center* ...................................................... 1-800-424-8802


DaimlerChrysler Corporation
DaimlerChrysler Environmental Public Relations .......................... (248) 512-2987


Internet
Michigan DEQ, Community Environmental Awareness Project, http://www.deq.state.mi.us/ead/ceap
DaimlerChrysler Corporation, http://www.daimlerchrysler.com


Local agencies with general environmental information
Sterling Heights Fire Department .................................................. (810) 446-2950
Sterling Heights Engineer .............................................................. (810) 446-CITY
Macomb County Local Emergency Planning Committee .............. (810) 469-5270
Macomb County Health Department ............................................ (810) 446-5236
Macomb County Department of Public Works ............................. (810) 446-2440

Other Resources:
Public Interest Groups/Non-Governmental Organizations: Contact the Environmental Assistance Center:
1-800-662-9278 for contacts in the area.



22      Michigan Department of Environmental Quality
Appendix A is a DaimlerChrysler Corporation
document prepared by and authored by
DaimlerChrysler personnel. It is included for
informational purposes.
                                       Community Environmental Awareness Project



                          APPENDIX A: PLANT INFORMATION
                     (PREPARED BY DAIMLERCHRYSLER CORPORATION)

          In 1997, the     DaimlerChrysler Sterling Heights
    Sterling Heights       Assembly Plant
     Assembly Plant:
                           The Sterling Heights Assembly Plant
    • Employed more
                           (SHAP) was originally constructed as a jet
  than 3,100 people,
                           engine plant in 1953. In 1980 it was con-
        • Worked two
                           verted to an automobile assembly plant by
   shifts per day, and
                           Volkswagen. DaimlerChrysler Corporation
  • Built an average
                           purchased the facility in 1983. Today the
      of 985 vehicles
               per day.    facility produces DaimlerChrysler’s mid-size
                           sedans: the Dodge Stratus, Chrysler Cirrus
                           and Plymouth Breeze. The facility is located
                           in the heart of the City of Sterling Heights on
                           310 acres with over 3.0 million square feet
                           under roof. In 1997, the plant produced                           Site Location
                           227,000 vehicles on two shifts per day.                              (No Scale)

                                                                                     Sterling Heights Assembly Plant
                                                                                              38111 Van Dyke
                           Manufacturing process                                        Sterling Heights, MI 48312
                           Building the vehicle
                           The parts and materials that make up a
                           vehicle come from a number of different
                           sources. Engines, seats, doors, hoods, brakes,
                           transmissions, oils, paints, etc., are all made
                           at other facilities. They are often delivered to
                           the plant on a daily or “Just-in-Time” basis.
                           Other DaimlerChrysler plants make some
                           parts while some are from vendors.

                           Vehicles are manufactured in three basic
                           steps. First, the vehicle skeleton is created by
                           welding together body parts, known as the
At SHAP, body parts        “body-in-white.” Next, the vehicle body is
 are welded together,      cleaned, coated with rust protection materials
 cleaned and painted.                                                              The Plymouth Breeze (shown here),
                           and painted. Painting includes a primecoat, a           Dodge Stratus and Chrysler Cirrus
    Seats, instrument      primer surfacer, a colored basecoat and a
 panels, windshields,                                                              are all manufactured at the Sterling
                           protective clearcoat. Finally, vehicle compo-           Heights Assembly Plant.
tires and other parts
                           nents such as the powertrain, interior trim
  are installed as the
body moves down the        (seats, instrument panel, etc.), windshield,
   assembly line. The      tires and exterior trim are installed as the
 process results in a      body moves down the assembly line. The
     complete vehicle      vehicle is then driven off the 16-mile long line
  ready for shipment.      and is ready for shipment.




                                                                          Prepared by DaimlerChrysler Corporation      A-1
                                         Community Environmental Awareness Project



        Waste outputs                                                  Once the vehicle is built and sold to the con-
        There are different sources of waste through-                  sumer, gasoline is consumed and there are
        out the manufacturing process. Raw materials                   tailpipe emissions. Automobiles must meet
        are sent in crates, pallets and containers.                    government standards for these emissions
        Disposal of this packaging is generally avoided                before they are sold. The efficiency of the
        by using returnable containers and recycling                   automobile’s engine, as well as the occasional
        programs. Waste byproducts from painting                       disposal of used oil, fluids, batteries, tires, etc.,
        processes are recycled or blended into a fuel                  are the responsibility of the owner.
        mixture for other industrial use. Some volatile
        organic compounds* (VOCs) from the painting                    At the end of the useful life of the automobile,
        processes are emitted into the air and some                    75% of it can be recycled. Material that cannot
        residuals go to landfill. Other wastes from                    be recycled is generally landfilled.
        assembly operations are recycled or sent out
        for disposal.



                         Automobile Manufacturing

      Inputs                                                    Material Recycling

  Raw                                                                                                 Part Recycling
 Materials
 • Metal (steel /
    aluminum)
                                                                                          Product
 • Plastics                                                                               Outputs
 • Components
   (electronics,
   engine,
   transmission,
    windshields,                                                                         System /                      End of
    mirrors,                  Body           Paint               Vehicle
    batteries,                Shop           Shop               Assembly                 Vehicle                        Life
    seats, etc.                                                                            Use
 • Paints, oils,
    fluids, etc.
 • Packaging
                         Waste Outputs
    (cardboard,         Metal and          Paint, thinners              Packaging          Exhaust /            95% of all vehicles
     wood, etc.)        plastic scrap;     and cleaners, water,         materials          tail pipe            in the US are
 • Energy               Mostly             paint residues, volatile     scrap;             emissions;           recycled. More than
 • Water                recycled.          organic compounds            mostly             fuel/energy use      75% of the vehicle
                                           (VOCs); mostly               recycled,                               material is recycled;
                                           recycled or fuel             some refuse                             the balance, which is
                                           blended, some VOC air        goes to                                 foam, seat material,
                                           emissions, some              landfill.                               instrument panel, etc.
                                           residuals are landfilled.                                            is mostly disposed of
                                                                                                                in landfills.




                              SHAP Manufacturing Production Data (vehicles/year)

               1993                   1994                      1995                     1996                  1997
              229,557                84,874                    205,535                  232,767               227,277

        * Refer to glossary

A-2    Prepared by DaimlerChrysler Corporation
                                    Community Environmental Awareness Project



Wastes generated at SHAP are sent to several different companies in
Michigan:
   • Non-hazardous wastes are sent to City Environmental, Inc. in Detroit.
   • Hazardous cleaning solvent, which is flammable, is returned to Gage
       Chemical Products in Ferndale for reclamation.
   • Other hazardous flammable liquid and solid wastes are sent to Phillips
       Environmental in Detroit for fuel blending.
   • Used lights are sent to Cleanlites Recycling in Mason for recycling.
   • Hazardous waste from primer paint operations is sent to the USL City
       Environmental, Inc., a treatment facility in Detroit.                        Two SHAP employees assemble
                                                                                    vehicle bumpers.
SHAP does not treat hazardous wastes on site. DaimlerChrysler personnel
periodically inspect all facilities that take hazardous waste. Records are
checked for regulatory compliance and the site is inspected for material
handling operations.

Employment
Approximately 3,100 people are currently employed at the plant. More than
2,900 are represented by United Auto Workers Locals #1700, 889 and 412.

Employees and the community
SHAP management and employees are very active in the surrounding
community. In 1998 the DaimlerChrysler facility was recognized with a “Spirit       An employee puts the finishing
Award” from the City of Sterling Heights. This award is for corporate citizen-      touches on a vehicle door.
ship and contributions to the community.

Employees donate to the United Way, hold an annual food and clothing drive,
and are involved with a “School to Work” program. During the holidays, they
organize a Christmas party for underprivileged children and the plant choir
carols at local hospitals. The plant also works with the Sterling Heights Cham-
ber of Commerce on various projects.




                Sterling Heights Assembly employees are involved
                in a variety of charitable and community programs.

                                                                     Prepared by DaimlerChrysler Corporation    A-3
                                   Community Environmental Awareness Project



The Sterling Heights Assembly Plant strives to           SHAP dedicates a considerable amount of staff and
operate in an environmentally responsible manner         resources to assure environmental compliance. SHAP
and to continually improve the environmental             has an environmental staff that includes:
performance of processes and products.                       • Two environmental coordinators;
DaimlerChrysler has both corporate and manufac-              • Three wastewater treatment operators;
turing environmental policies. In addition, SHAP             • Twelve powerhouse operators/engineers;
has adopted its own environmental policy specific            • An emergency response coordinator
to its own location. It is the policy of the Plant:              (Incident Commander);
     • To be committed to the integration of sound           • Fire, Safety and Industrial Hygiene staff
         environmental practices into all aspects of             around the clock;
         the manufacturing and assembly processes;           • A paint and energy specialist that concentrates
     • To strongly support operational actions to                on paint shop environmental only; and
         preserve and protect the environment;               • Other plant and corporate staff available for
     • To continue to cooperate and work                         assistance when needed.
         with government to develop environmen-
         tally responsible laws and regulations; and     The environmental staff work closely with production
     • To communicate to the public about                personnel to assure compliance with environmental
         on-going environmental activities at the        regulations. The staff also seeks out new and innova-
         plant.                                          tive ways to operate the plant and reduce impacts to
                                                         the environment.
Environmental regulations
SHAP must comply with a great number of local,           To better communicate with the public,
state and federal environmental regulations. A           DaimlerChrysler Corporation distributes an “Environ-
study commissioned by the former American                mental Newsletter” to the local community surrounding
Automobile Manufacturer’s Association (com-              SHAP. The newsletter is published twice a year as a
pleted by Horizon Environmental Corporation)             means to provide SHAP’s neighbors with information
reviewed environmental regulations that affect the       about the plant, its operations, and environmental issues
typical automobile assembly plant in Michigan.           of interest to the community. Questions or comments
                                                         can be sent to:
Federal, state and local environmental regulations                SHAP Environmental Newsletter
were considered. The study found that a typical                   DaimlerChrysler Corporation
automotive assembly plant must comply with about                  38111 Van Dyke
884 environmental regulations over the course of                  Sterling Heights, MI 48312
one year. The typical plant must comply with the
following requirements:
     • 86 wastewater;                                    Environmental, health and safety training
     • 14 storm water;                                   Employees receive a variety of training designed to
     • 133 air quality;                                  protect their health and safety. Those involved in
     • 562 hazardous materials management;               managing hazardous materials regularly receive training
     • 47 federal Emergency Planning and                 on proper handling of these materials. All employees
        Community Right-to-Know;                         receive basic instruction on how to respond in the event
     • 12 Toxic Substances Control Act; and              of an emergency. Others receive more detailed training
     • 30 relating to ozone depleting substances.        to prepare them to lead the response to environmental,
                                                         health or safety emergencies.




A-4     Prepared by DaimlerChrysler Corporation
                                    Community Environmental Awareness Project


Environmental protection efforts                               •   The Great Lakes Persistent Toxic Substances.
                                                                   The goal is to reduce the production and
SHAP strives for continuous improvement in pollution
                                                                   release of regulated substances that affect
prevention and waste reduction.
                                                                   water quality of the Great Lakes.
                                                               •   Binational Toxics Substances Strategy. The
Voluntary programs and recognition                                 goal is to eliminate high level regulated
SHAP was designated a Clean Corporate Citizen by                   materials from products throughout the U.S.
the DEQ on October 10, 1997. This prestigious desig-               and Canada.
nation is awarded to Michigan facilities that have             •   TRI/NPRI reduction and elimination of
demonstrated a high standard of environmental ethics,              regulated chemicals program. The goal is to
regulatory compliance and stewardship. SHAP is the                 reduce/eliminate the use and release of listed
first automotive assembly plant to receive this designa-           chemicals annually reported in the U.S. and
tion.                                                              Canada.
The Clean Corporate Citizen program requires perfor-
                                                           Teams
mance in three important areas.
                                                           SHAP has a “Pollution Prevention Team.” They focus
• Environmental Management: The                            on reducing process waste and reformulating materials
   company must have a strong and effective                to reduce or eliminate regulated chemicals. This team is
   environmental management system (EMS). This             made up of various plant personnel and led by the
   EMS includes:                                           plant’s environmental coordinator. They meet on a
       • Identification of environmental impacts;          regular basis to discuss ways that pollution prevention
       • Self-initiated compliance audits;                 can be practiced at the facility.
       • Public communication;
       • A clear statement of the company’s                A United Auto Workers Product Quality Improvement
          commitment to environmental excellence           (PQI) team at the plant seeks and implements waste
          and continued improvement; and                   elimination and waste recycling/re-use ideas. A mem-
       • Environmental training for employees.             ber of the plant PQI team serves on the
                                                           DaimlerChrysler National PQI team. DaimlerChrysler
•   Pollution Prevention: The company must adopt a         assembly plant PQI teams hold a “Sharing Meeting”
    pollution prevention policy and waste program to       about once a month to share ideas with other sites. In
    reduce waste at the source and by taking actions       1997, the PQI team’s efforts resulted in over 380 tons
    to:                                                    (780,000 pounds) of waste being recycled versus
        • Identify pollution prevention opportunities;     landfilled.
        • Establish goals to address these
           opportunities;                                  SHAP, along with all DaimlerChrysler facilities, trans-
                                                           fers pollution prevention ideas and technology through
        • Report on accomplishments; and
                                                           the DaimlerChrysler Corporate Office of Pollution
        • Participate in information and technical
                                                           Prevention. This office serves as a clearinghouse for
           exchange programs.
                                                           pollution prevention information and coordinates
                                                           programs with individual sites. Pollution prevention
•   Environmental Compliance: The company must             specialists coordinate technology transfer through site
    demonstrate consistent compliance with all             and corporate teams, sharing meetings, an environmen-
    applicable environmental requirements and have no      tal computer bulletin board and the CHEER
    outstanding unresolved violations.                     (DaimlerChrysler “Continuously Honors Environmental
                                                           Excellence with Recognition”) Award Program.
DaimlerChrysler Corporation is also a participant in
several pollution prevention projects. These projects
include:
     • The U.S. Automotive Pollution Prevention
         Project. The goal was to promote pollution
         prevention throughout business operations,
         products and practices.


                                                                    Prepared by DaimlerChrysler Corporation   A-5
                                     Community Environmental Awareness Project

Accomplishments - Recent and on-going activities to prevent waste
These activities include:                                  Some of SHAP’s pollution prevention achievements
Reduction                                                  associated with the U.S. Automotive Pollution Pre-
   • In the amount of paints and solvents used for         vention Project include:
        vehicle painting as a result of the installation       • Screening of non-production materials to
        and use of more efficient application                      eliminate substances of concern before they
        equipment.                                                 are supplied to the plant;
                                                               • Mercury* reduction program;
Reformulation of                                               • Polychlorinated Biphenyl (PCB)* elimination
   • Primers, paints, adhesives, sealers and cleaning              program; and
      compounds to eliminate and/or reduce                     · Surface coating regulated chemicals reduction
      regulated chemicals.                                         program in painting operations.
   • Powder anti-chip coating, with a zero-volatile
      organic compound.                                                                         Bulk hazardous
                                                                                                materials, such
Replacement of                                                                                  as gasoline, oils
   • Refrigerants such as Freon 12 that contain                                                 and solvents, are
       chlorofluorocarbons* (CFCs) with those that                                              stored in above
       do not contain CFCs,                                                                     ground tanks
   • Solvent*-borne basecoats with water-borne                                                  inside curbed
       basecoats that contain fewer regulated                                                   concrete storage
                                                                                                areas.
       chemicals for use in the paint shop.

Recycling of                                               SHAP and its suppliers have minimized the hazards of
   • Steel drums and totes.                                the materials stored and used in manufacturing. They
   • Certain plastic and rubber wastes.                    accomplished this through pollution prevention initia-
   • Cardboard, wood and other packaging                   tives. For example:
       materials.                                              • Locations where oils and chemicals are
   • Oils and solvents.                                             delivered and stored are protected through the
   • Laundering cloth wipe rags from the Body,                      use of spill containment structures, devices and
       Trim and Paint Shops for re-use at other                     inspection procedures;
       facilities.                                             • Monitoring devices and alarm systems are in
                                                                    place to assure any problems are immediately
                                                                    detected; and
                                                               • Wherever possible, the inventory of materials
                                                                    stored on-site is minimized through the practice
                                                                    of “Just-in-Time” delivery.


                                                                                                  Response to fire,
                                                                                                  disaster and
                                                                                                  environmental
                                                                                                  emergencies is
                                                                                                  outlined in the
Automotive component protective plastic                                                           facility “Episode
caps and packaging are collected for reuse                                                        Plan.” The “Episode
and recycling.                                                                                    Plan” is reviewed
                                                                                                  and updated by the
                                                                                                  staff on a regular
                                                                                                  basis.

* Refer to glossary



A-6     Prepared by DaimlerChrysler Corporation
Appendices B, C, D and E have been prepared by the
Department of Environmental Quality and represent
DEQ information and data.
                                    Community Environmental Awareness Project



                         Appendix B: SARA TITLE III

T
        he federal Emergency Planning and                                                             Total TRI Releases and Transfers:
        Community Right-to-Know Act of 1986 is part                                                        A Five-Year Comparison
        of Title III of the Superfund Amendments and
                                                                                                1,200,000
Reauthorization Act (SARA Title III). SARA Title III




                                                                              Pounds per Year
                                                                                                1,000,000
requires certain businesses and federal facilities to
                                                                                                 800,000
report certain information on hazardous chemicals
under their control. These chemicals are considered                                              600,000

hazardous because they have known physical or health                                             400,000

hazard characteristics.                                                                          200,000
                                                                                                       0
                                                                                                               1993     1994      1995      1996     1997
This appendix provides general information on the
amounts of hazardous chemicals stored, released,                                                Graph 1:
treated, and shipped off-site by the DaimlerChrysler                                            Source: U.S. EPA Toxic Chemical Release Inventory
Sterling Heights Assembly Plant. It also includes use,                                          Reporting Form R.
physical hazard and health hazard informa-
tion associated with reported chemicals.
                                                                                                         SHAP TRI Data:
                                                                                                     A Five-Year Comparison
Hazardous chemical reporting                                        600,000
                                                  Pounds per Year




Hazardous chemicals stored at SHAP in                               500,000                                                                                 1 993
1997, along with their average and maxi-        400,000                                                                                                     1 994
                                                300,000
mum daily amounts, are listed in Table 5 at                                                                                                                 1 995
                                                200,000                                                                                                     1 996
the end of this section. These chemicals                                                                                                                    1 997
                                                100,000
must be properly managed in accordance
                                                      0
with federal, state and local regulations.                                                  Air Releases          Discharges to           Off-site
Safe guards must be in effect to ensure the                                                                           POTW               Transfers
public’s health and safety. For example,
SHAP has developed a facility emergency response                                                Graph 2:
                                                                                                Source: U.S. EPA Toxic Chemical Release
plan to prepare for a chemical emergency.
                                                                                                Inventory Reporting Form R.
                                                                                                POTW = Publicly Owned Treatment Works, or wastewater
Toxic chemical release inventory reporting                                                      treatment plant (Detroit)
One of the most important reporting requirements
under SARA Title III is the reporting done under the                                                   Total TRI Releases and Transfers
Toxic Release Inventory or TRI. Under TRI, compa-                                                                   in 1997
nies that manufacture or process more than 25,000
                                                                                                        Off-site
pounds, or use more than 10,000 pounds per year of a                                                   Transf ers
listed chemical must report to the DEQ the amount of                                                     37%
                                                                                                                                               Total Air
                                                                                                                                               Releases
that chemical that is released, treated, managed or
                                                                                                                                                 52%
transported to a licensed hazardous waste treatment
facility.
                                                                                                            Discharge
The following graphs present SHAP TRI data from                                                              to POTW
1993 to 1997. Graph 1 shows total TRI releases and                                                             11%
transfers over five years. Graph 2 breaks down the
total releases into environmental releases and off-site                                         Graph 3:
transfers. Graph 3 shows total environmental releases                                           Source: U.S. EPA Toxic Chemical Release Inventory
and off-site transfers for 1997. Data are presented in                                          Reporting Form R.
Table 1.                                                                                        POTW = Publicly Owned Treatment Works, or wastewater
                                                                                                treatment plant (Detroit)


                                                                                                Michigan Department of Environmental Quality                B-1
                                         Community Environmental Awareness Project

  The following table provides information on the hazardous substances reported by SHAP under TRI, including
  the amounts of hazardous chemicals released, treated, managed and transported to a licensed hazardous waste
  treatment facility over the last five years.

  Table 1: A Five-Year Summary of SHAP’s TRI Data
          Categories                1993                 1994               1995                 1996                 1997
                               229,557 vehicles     84,874 vehicles    205,535 vehicles     232,767 vehicles     227,277 vehicles
                                  produced             produced           produced             produced             produced
                                 lbs.   lbs./  lbs.  lbs./    lbs.   lbs./  lbs.                       lbs./       lbs.     lbs./
                                       vehicle      vehicle         vehicle                           vehicle              vehicle
  Release to Air On-site       438,587 1.91 142,571  1.68   442,623 2.15 379,269                       1.63     291,671     1.28
  Discharge to Water On-site      0         0         0         0         0         0         0          0          0         0
  Release to Land On-site         0         0         0         0         0         0         0          0          0         0
  Underground Injection           0         0         0         0         0         0         0          0          0         0
  On-site
  POTW                          37,290    0.16     19,625     0.23      48,850    0.24     63,671      0.27      62,620      0.28
  On-site Recycling               0         0         0         0         0         0         0          0          0         0
  Off-site Recycling           450,631    1.96    207,745     2.45      81,958    0.40    281,087      1.21     137,013      0.60
  On-site Energy Recovery         0         0        0         0          0        0          0          0         0           0
  Off-site Energy Recovery      72,165    0.31    117,290     1.38      34,480    0.17     11,666      0.05      11,936      0.05
  On-site Treatment            310,700    1.35     22,680     0.27      64,008    0.31     58,626      0.25      27,249      0.12
  Off-site Treatment            54,473    0.24     34,090     0.40      52,935    0.26     64,819      0.28      62,498      0.27
  Source: U.S. EPA Toxic Chemical Release Inventory Reporting Form R.
  Annual vehicle production figures provided by DaimlerChrysler Corp.

  Definitions
  Release to Air: Chemicals are released to the air through confined air streams, such as stacks or vents, or through unconfined
  air streams, such as leaks.
  Discharge to Water: Chemicals are discharged to bodies of water.
  Release to Land On-Site: Disposal of chemicals in landfills or other on-site land disposal methods.
  POTW: Wastewater from the facility is transferred through pipes or sewers to a public owned treatment works (POTW).
  Recycling: Chemicals in wastes are generally recovered or regenerated by a variety of methods.
  Energy Recovery: Waste material is used as a source of fuel.
  Treatment: Chemicals in wastes are treated through a variety of methods that destroy various amounts of the toxic chemical. In some
  cases, the chemical is not destroyed but is prepared for further waste management, such as contained disposal.
  Underground Injection: A contained release of a fluid via a subsurface well for the purpose of waste disposal.


  Chemical usage, physical properties and health effects
  The following provides general chemical use and                     effects. It also explains how the chemicals are used,
  health effect information associated with the TRI                   produced or processed at SHAP. This section high-
  chemicals reported by SHAP.                                         lights how the TRI chemicals are mainly used in the
                                                                      plant; however, these chemicals may also be used in
  The relative risk and health effects of a chemi-                    other ways within the facility. The following presenta-
  cal depend on many factors, such as the con-                        tion on how these chemicals are used at SHAP is
  centration, quantity and exposure to the chemi-                     based on information provided by DaimlerChrysler
  cal. In most cases, the chemicals used at SHAP                      Corporation.
  are components, or part of mixtures, and are not
  in highly concentrated forms.                                       The products or uses in which these chemicals are
                                                                      found fit into three categories:
  Most of the TRI chemicals that SHAP reports are                             • bulk fluids (gasoline, radiator fluid)
  ingredients of products. This section includes a                            • paints and cleaners
  general description of the chemicals and chemical                           • miscellaneous uses (welding, wastewater
  mixtures, their physical properties and health                                   treatment).



B-2   Michigan Department of Environmental Quality
                                      Community Environmental Awareness Project

Gasoline                                                         ingested or absorbed through the skin. For example,
Gasoline that is added to the new vehicles before they           exposure to ethylene glycol vapors over an extended
leave SHAP is stored in bulk storage tanks according             period of time can cause adverse health effects.
to federal and state laws. Gasoline can easily change
from a liquid to a gaseous or vapor state. When this             Wastewater Treatment Process
happens, gasoline may release its ingredients: benzene,          Sodium nitrate is used in some manufacturing pro-
toluene, xylene, 1,2,4-trimethylbenzene, ethylbenzene            cesses and is also used during the wastewater treat-
and methyl tert-butyl ether. Gasoline is a dangerous             ment process at SHAP. Sodium nitrate poses no fire
substance and should be handled with care. It is                 hazard but can cause other materials to ignite. Sodium
extremely flammable and explosive. Gasoline can be               nitrate can be harmful if inhaled, ingested in high
harmful to health if it is swallowed, comes in contact           amounts or if it comes in contact with skin or eyes.
with skin, or if the gasoline fumes are inhaled. For
example, benzene, one of the many ingredients in                 Welding Process
gasoline, is considered to be a human carcinogen if              Manganese compounds and nickel compounds are both
exposure is high.                                                used in the welding process at SHAP. Manganese dust
                                                                 is flammable. Nickel compounds have been found to
Paints and Cleaners                                              cause cancer if inhaled or ingested in high amounts.
All new cars are painted. The painting process is one
of the key activities at an assembly plant. Sprays from          For more information on the physical properties and
the painting operations must be captured by equipment            health effects of the above TRI chemicals, please refer
required to protect worker safety and the environment.           to one of the Internet sources cited below or call the
The paint fumes are volatile organic compounds that              SARA Title III Program office at 517/373-8481.
contain chemicals such as formaldehyde and glycol                    • Environmental Health Center, Chemical
ethers, which can be dangerous to people and animals                     Backgrounder Index:
at high concentrations. The release of paint fumes from                  http://www.nsc.org/ehc/ew/chemical.htm
the plant is strictly regulated to protect the public                • U.S. Environmental Protection Agency:
health. (See Appendix B – Air Quality). Paint itself is                  http://www.epa.gov
flammable and can be a health hazard if inhaled,                     • Vermont Safety Information on the Internet,
ingested or absorbed through the skin. Environmental                     MSDS (Material Safety Data Sheet) Database:
regulations establish strict controls on the release of                  http://siri.org/msds/index.html
paint fumes from assembly plants and the disposal of
waste paint.
                                      Table 2: TRI Chemicals and Uses at SHAP (Paints and Cleaners)
Table 2 lists reported TRI chemi- Ingredient                   Part of     Manufacturing   Ancillary                  Byproduct
                                                           Vehicle Product     Aid       and other uses
cal ingredients of paints and
                                   Formaldehyde                                 X
cleaners used at SHAP. The table Glycol ethers                                  X              X
also shows how the chemicals are Manganese compounds              X
used, processed or produced. The Methanol                         X             X
cleaners used to prepare vehicles Methyl isobutyl ketone                        X              X
                                   Methyl tert-butyl ether
for painting also contain volatile
                                   Nickel compounds               X
organic compounds, which are       Nitrate compounds                            X                                          X
dangerous and therefore strictly   N-methyl-2-pyrrolidone                       X              X
regulated.                         Phosphoric acid                              X              X
                                      Toluene                             X                 X                 X
Radiator Fluid                         Xylene                             X                 X                 X
                                      Zinc compounds                      X                 X                 X
Radiator fluid that is added to all
                                      Part of vehicle product: The chemical becomes part of the vehicle.
new vehicles is stored in bulk        Manufacturing aid: The chemical aids the manufacturing process but does not become part
storage tanks and handled at the      of the product.
facility in accordance with federal   Ancillary or other uses: The chemical is used at a facility for purposes other than
and state laws. Radiator fluid is a   manufacturing as described above.
                                      Produced as a byproduct: The chemical is produced during the manufacture, processing,
mixture of water and antifreeze
                                      otherwise use, or disposal of another chemical substance or mixture and, following its
(or ethylene glycol). Antifreeze      production, is separated from that other chemical substance or mixture. Chemicals produced
can be a health hazard if inhaled,    as a result of waste management are also considered byproducts.

                                                                      Michigan Department of Environmental Quality             B-3
                                          Community Environmental Awareness Project

Chemical specific information reported under SARA Title III
The various chemicals that SHAP reported under TRI are listed in the next table. Table 3 is a listing of the
amounts of the various chemicals reported under TRI being released or transferred off-site for further treatment.


   Table 3: Total Waste Generationw of TRI Chemicals at SHAP in 1997 (in Pounds)
    Chemicals                 Fugitive Air Stack Air                 Water        Injection       Land         POTW        Off-site
                                 (lbs.)      (lbs.)                  (lbs.)         (lbs.)        (lbs.)        (lbs.)      (lbs.)
    Formaldehyde                     3,300      29,000                        0            0               0          0            54
    Methanol                         2,200           59                       0            0               0          0             0
    Ethylene Glycol                     91          750                       0            0               0        380             0
    Ethylbenzene                     1,900      17,000                        0            0               0          0       13,000
    1,2,4-Trimethylbenzene           1,100       9,500                        0            0               0          0        8,700
    Methyl Isobutyl Ketone           8,000      72,000                        0            0               0          0       54,000
    Toluene                          1,700          480                       0            0               0          0             0
    Xylene (Mixed Isomers)           9,600      85,000                        0            0               0          0       63,000
    Phosphoric Acid                      0          470                       0            0               0          0             0
    Sodium Nitrite                       0            0                       0            0               0          0             0
    N-Methyl-2-Pyrrolidone           1,600      14,000                        0            0               0          0             0
    Glycol Ethers                    4,200      33,000                        0            0               0     24,000          200
    Nickel Compounds                     0            0                       0            0               0        370        1,100
    Manganese Compounds                  0            0                       0            0               0        410        2,000
    Nitrate Compounds                    0          410                       0            0               0     37,000             4
    Zinc Compounds                       7            2                       0            0               0        460       11,000
    Methyl Tert-Butyl Etherww            0            0                       0            0               0          0             0
    Benzeneww                            0            0                       0            0               0          0             0
   Source: U.S. EPA Toxic Chemical Release Inventory Reporting Forms R and A.
   w Total Waste Generation is calculated from sections 5, 6, and 7 of the Toxic Chemical Release Inventory Reporting Form R and is
   equal to the total amount of TRI chemicals released to the air, water, land or injected underground and the amount of TRI chemicals
   transferred off-site (to a Publicly Owned Treatment Works and other locations).
   ww Methyl tert-butyl ether and benzene release and transfer data are from the Toxic Chemical Release Inventory Reporting Form
   A, a simplified reporting form.



Total amount of TRI chemicals
managed at SHAP                                                      Total Amount of TRI Chemicals Managed at
Under TRI, SHAP also reported the amount                                           SHAP in 1997
of chemicals that were recovered for energy
                                                                                        Of f-site
and recycled. When combined with amounts                                               Treatment
                                                                          On-site
released and transferred, this gives the total                                           12%
                                                                         Treatment
amount of TRI chemicals handled or man-                                     5%
                                                                                                                  Total Released
                                                                                                                        56%
aged in some fashion at SHAP. It does not
include a discussion on how TRI chemicals                                Of f-site
in raw materials and products are stored.                               Recycling
                                                                          26%         Off -site
This total distribution of TRI chemicals                                              Energy
                                                                                     Recovery
managed is shown in Graph 4 and listed on a                                             1%
chemical by chemical basis in Table 4. Graph
5 shows how TRI chemicals were managed                    Graph 4:
at SHAP from 1993 to 1997 on a per vehicle                Source: U.S. EPA Toxic Chemical Release Inventory Reporting Form R.
basis.




B-4     Michigan Department of Environmental Quality
                                         Community Environmental Awareness Project

Table 4: Total Amount of TRI Chemicals Managedw by SHAP in 1997 (in Pounds)
Chemicals                   Totalww On-site Off-site On-site      Off-site   On-site    Off-site    Total
                            Releases Energy Energy Recycling Recycling Treatment Treatment Amount
                              (lbs.) Recovery Recovery   (lbs.)    (lbs.)     (lbs.)     (lbs.)    Managed
                                      (lbs.)   (lbs.)                                               (lbs.)
Formaldehyde                  32,000       NA      680        NA          90     4,600           1   37,371
Methanol                        2,200      NA       NA        NA        NA         NA           68    2,268
Ethylene Glycol                   840      NA         10      NA           1         69       380      1,300
Ethylbenzene                  19,000       NA       NA        NA     13,000        NA         NA     32,000
1,2,4-Trimethylbenzene        11,000       NA    8,700        NA        NA         NA         890    20,590
Methyl Isobutyl Ketone        80,000       NA         26      NA     54,000        170        NA 134,196
Toluene                         2,200      NA       NA        NA        NA         NA           80    2,280
Xylene (Mixed Isomers)        94,000       NA    1,900        NA     63,000        190          79 159,169
Phosphoric Acid                   470      NA       NA        NA        NA       4,400        NA      4,870
Sodium Nitrite                      0      NA       NA        NA        NA       6,700           0    6,700
N-Methyl-2-Pyrrolidone        16,000       NA      220        NA           1       120        NA     16,341
Glycol Ethers                 37,000       NA      400        NA          21    11,000     24,000    72,421
Nickel Compounds                1,500      NA       NA        NA      1,400        NA         NA      2,900
Manganese Compounds             2,400      NA       NA        NA      2,600        NA         NA      5,000
Nitrate Compounds                 410      NA       NA        NA        NA         NA      37,000    37,410
Zinc Compounds                12,000       NA       NA        NA      2,900        NA         NA     14,900
Methyl Tert-Butyl Ether www         0        0         0        0          0          0          0         0
Benzenewww                          0        0         0        0          0          0          0         0
Total                        311,020         0  11,936          0  137,013      27,249     62,498 549,716
Source: U.S. EPA Toxic Chemical Release Inventory Reporting Form R.
w Total Amount of TRI Chemicals Managed is calculated from section 8 of the Toxic Chemical Release Inventory Reporting Form R,
and is equal to the sum of the total amount of TRI chemicals released and recovered for energy, recycled and treated (both on and off-
site).
ww Total Releases includes on-site discharges of toxic chemicals including emissions to the air, discharges to bodies of
surface water, releases at the facility land and contained disposal into underground injection wells as well as releases of
toxic chemicals during off-site treatment activities.
www Methyl tert-butyl ether and benzene release and transfer data are from the Toxic Chemical Release Inventory Reporting Form
A, a simplified reporting form.




                                                              Five-Year Comparison of TRI Chemicals
                                                            Managed at SHAP on a Per-Vehicle Basis
      Graph 5:                                       2.50
      Source: U.S. EPA Toxic
                                                     2.00
      Chemical Release Inventory                                                                                              1993
      Reporting Form R.                                                                                                       1994
                                                     1.50
                                                                                                                              1995
      Annual vehicle production                      1.00                                                                     1996
      figures provided by
                                                                                                                              1997
      DaimlerChrysler Corp.                          0.50

                                                     0.00
                                                                Total         Energy         Recycling       Treatment
                                                              Releases       Recovery




                                                                           Michigan Department of Environmental Quality              B-5
                                      Community Environmental Awareness Project

SHAP hazardous chemical inventory
Under SARA Title III, SHAP must report all the hazardous materials handled on site to ensure that the fire
department and other emergency planning responders have a complete listing of this information in case of an
accident. The hazardous materials reported by SHAP to be at the plant are listed in Table 5.

Table 5: SHAP’s 1997 Hazardous Chemical Inventory Report (Tier II)
Material                                    EHS NAMEw         Average Amount of Maximum Amount
                                                               Material On Site of Material On Site
PAINT ENAMEL EXT. CLEAR COAT 0                             550 lbs.              55,000 lbs.
PAINT ENAMEL EXTERIOR - RFU 04        FORMALDEHYDE         550 lbs.              55,000 lbs.
PAINT FLAT BLACK MS PEA-3 0412                             550 lbs.              55,000 lbs.
SEALER LIGHTWEIGHT 04696240                                550 lbs.              550,000 lbs.
UNDERCOAT FLUID DEADNER 046584                             550 lbs.              550,000 lbs.
PAINT ENAMEL EXT - RFU AY111 0        FORMALDEHYDE         550 lbs.              55,000 lbs.
PAINT ENAMEL EXT-RFU AY11 0464        FORMALDEHYDE         550 lbs.              55,000 lbs.
SEALER -ANTI-CHIP PUMPABLE 046        N-METHYL PYRROLIDONE 550 lbs.              550,000 lbs.
PAINT ENAMEL EXT. RFU WATE 046        FORMALDEHYDE         550 lbs.              55,000 lbs.
PAINT ENAMEL EXT. RFU RED 0464        FORMALDEHYDE         550 lbs.              55,000 lbs.
PAINT ENAMEL EXT - RFU WATE 04        FORMALDEHYDE         550 lbs.              55,000 lbs.
PAINT ENAMEL EXT.- CLEAR COAT         FORMALDEHYDE         550 lbs.              55,000 lbs.
WATER BORNE BASECOAT HWB 04640        FORMALDEHYDE         550 lbs.              55,000 lbs.
ALCOHOL-ISOPROPYL CONC.MS 1125                             550 lbs.              55,000 lbs.
OIL ENGINE 5W-30 ILSAC 0465433                             5,500 lbs.            550,000 lbs.
PAINT ENAMEL EXT -RFU 04889145        FORMALDEHYDE         550 lbs.              55,000 lbs.
PHOSPHATE - ANTI CORR CHEMF 04                             550 lbs.              550,000 lbs.
LUBRICANT - MANUEL TRANS FL 04                             5,500 lbs.            550,000 lbs.
REFRIGERANT A/C (R134A) 045960                             5,500 lbs.            550,000 lbs.
ADHESIVE-HIGH VICOSITY 0418736                             550 lbs.              550,000 lbs.
ANTIFREEZE - GLYCOL TYPE - IN                              5,500 lbs.            550,000 lbs.
SOLVENT WATER COMPATIBLE 04123                             550 lbs.              550,000 lbs.
FLUD-A/TRANS MS 716 04105369                               5,500 lbs.            550,000 lbs.
FLUID - HYDRAULIC STEERING 040                             5,500 lbs.            550,000 lbs.
GASOLINE - MS 5393 03870401                                5,500 lbs.            550,000 lbs.
FLUID - HVD MS 4574 02863965                               550 lbs.              550,000 lbs.
SOLUTION-W/SHLD WASHER 0212089                             550 lbs.              550,000 lbs.
GRIT STEEL 020980760                                       5,500 lbs.            550,000 lbs.
PAINT ENAMEL EXT-HWB AY-11 046        FORMALDEHYDE         550 lbs.              55,000 lbs.
CLEANER PAINT EQUIPMENT 122750                             550 lbs.              550,000 lbs.
CLEANER METAL HEAT EXCHAN 1227        NITRIC ACID          550 lbs.              55,000 lbs.
CLEANER METAL CHEMFIL 12270279        HYDROCHLORIC ACID    550, 000 lbs.         550,000 lbs.         Source: U.S. EPA
ACID MURIATIC NPKX-108 1205017        HYDROCHLORIC ACID    5,500 lbs.            55,000 lbs.          Emergency and
ACID SULFURIC NPKX-106 1205026        SULFURIC ACID        5,500 lbs.            5,500,000 lbs.       Hazardous Chemical
ACID MURIATIC 20 DEGREE 120501        HYDROCHLORIC ACID    55,000 lbs.           550,000 lbs.         Inventory Report,
OIL FUEL DIESEL #MS-633 318001                             55,000 lbs.           550,000 lbs.
                                                                                                      Section 312 EPCRA.
GASOLINE MS-5393 UNLEADED 3160                             55,000 lbs.           550,000 lbs.
GAS FUEL PROPANE COMMER. 31450                             55,000 lbs.           550,000 lbs.         w Extremely
GAS ARGON BULK 124500415                                   5,500,000 lbs.        35,000,000 lbs.      Hazardous Substance
GAS ACETYLENE 124500100                                    5,500 lbs.            5,500,000 lbs.       Name. A blank entry
COATING REMOVABLE BOOTH 123002                             5,500 lbs.            550,000 lbs.         means the chemical is
COATING REMOVABLE SPRAY 123002                             550 lbs.              550,000 lbs.
                                                                                                      not categorized as an
PAINT ENAMEL EXTERIOR RFU 0488        FORMALDEHYDE         550 lbs.              550,000 lbs.
CLEANER PAINT EQUIPMENT 122753                             550 lbs.              550,000 lbs.         Extremely Hazardous
PAINT ENAMEL EXT.-RFU 04889142        FORMALDEHYDE         550 lbs.              550,000 lbs.         Substance. Note that
SODA CAUSTIC NPKX-1148 1222563                             55,000 lbs.           5,500,000 lbs.       these substances are
LIME SLACK HYDRATED 90% 122254                             55,000 lbs.           5,500,000 lbs.       components of the
PAINT PAY-AS-BUILT 04889000 TU        FORMALDEHYDE         550 lbs.              55,000 lbs.
                                                                                                      material. Amounts
PAINT PAY-AS-BUILT 04889162AA         FORMALDEHYDE         550 lbs.              55,000 lbs.
PAINT PAY-AS-BUILT 04889161 AA        FORMALDEHYDE         550 lbs.              55,000 lbs.          listed here are for the
PAINT PAY-AS-BUILT 04889160 AA        FORMALDEHYDE         550 lbs.              55,000 lbs.          material and not for
PAINT PAY AS BUILT 04889159 AA        FORMALDEHYDE         550 lbs.              55,000 lbs.          the EHS listed.
PAINT PAY-AS-BUILT 04889158AA         FORMALDEHYDE         550 lbs.              55,000 lbs.
PAINT PAY-AS-BUILT 04889093AA         FORMALDEHYDE         550 lbs.              55,000 lbs.
                                                                                                      For more information,
PAINT PAY-AS-BUILT 04889064 SW        FORMALDEHYDE         550 lbs.              55,000 lbs.
PAINT PAY-AS-BUILT SGG 0488901        FORMALDEHYDE         550 lbs.              5,500 lbs.           contact the SARA
PAINT PAY-AS-BUILT TCN 0488901        FORMALDEHYDE         550 lbs.              550,000 lbs.         Title III Program at
WATER TREATMENT CALGON CO. 129        ALIPHATIC POLYAMINE  550 lbs.              550,000 lbs.         517/373-8481.
CLEANER PHOSPHATE EQUIP. 12277                             550,000 lbs.          550,000 lbs.


B-6        Michigan Department of Environmental Quality
                                                Community Environmental Awareness Project



                                       Appendix C: Air QUALITY
The following table summarizes the number of air permit requirements, total allowable emission rates (pounds per
hour and tons per year) and other key permit requirements, such as paint usage limits and vehicle production limits.

         Table 1: Summary of Permit Requirements
              Operation     No. of Permits    No. of Permit   Total Allowable                    Examples of Other Key
                                               Conditions/    Emission Rates                      Permit Requirements
                                                                          1
                                              Requirements     (tons/year)
             Paint Shop           15               87          VOC - 2484           Topcoat process shall not operate more than 5,760
                                                                                       hour/year or coat more than 76 cars/hour.
                                                                         2
             Powerhouse           2                22          SO2 - 64.7       No. 2 Fuel oil usage, in #1 Boiler shall not exceed 253,130
                                                               NOx - 128.52                            gallons/month.

             Other                7                34           VOC – 74.5      Shall not process more than 2,400 tons/year of dried sludge
                                                                                                   in the sludge dryer.
         Source: DEQ Air Quality Division
         1
           The numbers listed in this column are a summation of those permits that include allowable annual (tons/year)
         emission rates. The plant-wide emissions allowed for an air pollutant may be higher than listed in this table because
         some permits may not specify an allowable annual emission rate.
         2
           SO2 and NOx are emitted from three boilers. The allowable emission rates have been significantly reduced in recent
         years to reflect conversions from use of coal and oil to primarily natural gas.


The following table summarizes SHAP’s air quality performance from 1994 to 1998. It provides information relative to
the types of violations that the agency has cited and the company’s responses. Table 2 also includes information about
annual inspections.
   Table 2: Summary of SHAP Compliance with Air Quality Regulations
    Date of    Type of Compliance          Cited       Documented     Date Agency Date of Date Problem                                   Date all
    Agency         Evaluation           Violation       Impact on Problem Action Citation Causing the                                     Issues
   Compliance                             Typew        Environment     was                     Violation                                 Resolved
   Evaluation                                                      Corrected                   Occurred
                                                                                              rd
    12/21/94 Review of VOC Quarterly Air Emission          Yes       1/06/95 L.O.V. 12/21/94 3 Quarter of                                 1/19/95
                 Emissions Report                                                                 1994
    09/25/96   Review of Stack Test    Air Emission        Yes      10/09/98 L.O.V. 10/09/96     8/20/96                                 01/03/97
                Report (of 8/20/96)
    09/14/94          Annual                NA             NA          NA     NA      NA           NA                                         NA
                    Inspection
    03/03/95   Review of Incinerator Process/Control       No       07/24/95 L.O.V. 03/21/95    02/23/95                                 03/29/96
                Malfunction Report   Operational Issue                                                                                    (AO)

    07/06/95         Review of compliance           Monitoring/           No         07/24/95 L.O.V. 07/06/95             02/23/95       03/29/96
                     status with L.O.V. of        Record keeping/
                            3/21/95               Reporting Issue
    04/25/95           Annual Inspection                NA                NA           NA             NA                    NA             NA
    02/08/96           Annual Inspection           Process/Control        No         04/19/97 L.O.V 04/11/96              02/08/96       09/11/97
                                                  Operational Issue
    03/17/97              Annual Inspection             NA                NA             NA         NA        NA             NA               NA
    09/02/98              Annual Inspection             NA                NA             NA         NA        NA             NA               NA
   Source: DEQ Air Quality Division
                  Cited Violation Type                                                  Agency Action
                  Air Emission                                                          L.O.V = Letter of Violation
                  Process/Control Operational Issue                                     N.O.V. = Notice of Violation
                  Monitoring/Record keeping/Reporting Issue                             AO = Administrative Order
                  Administrative Issue                                                  Lit = Litigation
                                                                                        CO = Court Order
                  w The agency believes environmental requirements have been violated and has cited the company for such.
                  The citation is not proof that a violation has actually occurred but rather an allegation of non-compliance.

                                                                                 Michigan Department of Environmental Quality                      C-1
                                       Community Environmental Awareness Project

SHAP air emissions data
SHAP is authorized to emit air contaminants under state issued permits. The emission limits in these permits are
set to assure public health and the environment are protected. The permits also assure that SHAP is using the
appropriate control technology. The following table summarizes SHAP’s actual emissions from 1993 to 1997. The
amount of each air contaminant emitted is based on the annual report of emissions submitted by SHAP to the
DEQ.

            Table 3: Five-Year Overview of SHAP Annual Emissions
            Year      Volatile      Particulate        Particulate    Lead      Carbon     Nitrogen   Sulfur
                      Organic         Matter             Matter                Monoxide     Oxides    Dioxide
                     Compounds        (total)         (<10 microns)
                       (VOC)
                        (tons)         (tons)              (tons)     (tons)      (tons)    (tons)    (tons)
              1993      1026               28                  6      0.01         52        146       262
              1994       366               25                  5      0.01         48        135       237
              1995       627               32                  7      0.01         57        146       297
              1996       767                9                  4      0.002        25        64         73
              1997       733                2                  2      0.00         17        56        0.38

            Source: DEQ Air Quality Division



The following table shows VOC emissions in tons per year and pounds per vehicle for each of the last five years.

            Table 4: Five-Year Overview of VOC Emissions
            in Tons and on a Per-Vehicle Basis
            Year       No. of           Volatile
                      Vehicles          Organic
                      Produced         Compounds
                                     tons       lbs./vehicle
              1993     229,557      1026           8.94
              1994     84,874        366           8.62
              1995     205,535       627           6.10
              1996     232,767       767           6.59
              1997     227,277       733           6.45

            Source: DEQ Air Quality Division
            Annual vehicle production figures provided by DaimlerChrysler Corp.




C-2     Michigan Department of Environmental Quality
                                                 Community Environmental Awareness Project



                               Appendix D: Water QUALITY
Table 1 summarizes SHAP’s permit requirements for discharging wastewater to the City of Detroit sanitary
sewer.
             Table 1: Summary of Sanitary Sewer Discharge Permit (No. 151-002) Requirements
               Wastewater No. of Permit              Major Requirements                       Chemicals Controlled
                 Type     Requirements
              Treated metal            31          Sample frequently             acidity      lead                    PCB - total
                finishing,                         Meet limits                   arsenic      mercury                 phosphorus
               Rinse water                         Report results                cadmium      nickel                  phenolics
               and Cleaner                         Report violations             chromium     oils                    silver
                                                   Report all problems           copper       organics - total        solids
                                                   Keep records                  cyanide      oxygen demand           zinc
                                                   Maintain equipment            iron         PCB - arochlor 1260
                                                   Prevent and control spills
              Source: City of Detroit - Department of Water and Sewerage

Table 2 provides information about SHAP’s wastewater discharge and performance from 1993 to 1997. The table
also provides information on the regulatory actions taken by the Detroit Department of Water and Sewerage.

Table 2: Summary of SHAP Compliance with the Sanitary Sewer Discharge Permit
   Date of      Type of Compliance            Cited Violation      Documented        Date         Date       Agency       Date of     Date All
  Agency            Evaluation                    Typew             Impact on      Problem      Problem      Action       Citation      Issues
 Compliance                                                        Environment     Occurred     Corrected                            Resolved ww
 Evaluation                                                        or Sewerage
                                                                      System
  3/18/93           Inspection
    6/93           Data review
  11/22/93      Company notification            Discharge              No           9/21/93      9/22/93      N.O.V       11/22/93    12/21/93
    1/94           Data review
  3/29/94           Inspection
    6/94           Data review
    1/95           Data review
   3/3/95       Company notification        Discharge-Operation      No - No        3/3/95        3/3/95
  5/11/95           Inspection
    6/95           Data review
  9/18/95       Company notification            Operation              No           9/18/95      9/18/95
    1/96           Data review
   2/8/96           Inspection
    6/96           Data review                  Monitoring             No                         8/96        L.O.W        8/7/96      8/30/96
  10/15/96          Inspection
    1/97           Data review
  2/19/97           Inspection
  5/30/97       Company notification                                   No           4/10/97      4/11/97
    6/97           Data review
  8/22/97       Company notification        Discharge-Operation      No - No        8/22/97      8/23/97      N.O.V        9/30/97    11/10/97
  11/14/97          Inspection
Source: City of Detroit - Department of Water and Sewerage

Cited Violation Typew                                                                             Agency Action
Discharge – Discharge to local sewer system exceeded requirement                                  L.O.W. = Letter of Warning
Process Control/Operational Issue                                                                 N.O.V = Notice of Violation
Monitoring/Record keeping/Reporting Issue                                                         AO = Administrative Order
Administrative Issue                                                                              Lit = Litigation
                                                                                                  CO = Court Order

w The agency believes environmental requirements have been violated and has cited the company for such. The citation is not proof that a
violation has actually occurred but rather an allegation of non-compliance.
wwDate all issues resolved: The date by which all re-inspection and paperwork issues have been resolved.

                                                                                    Michigan Department of Environmental Quality             D-1
                                      Community Environmental Awareness Project


Table 3 below summarizes SHAP’s storm water permit requirements and performance.


           Table 3: Summary of SHAP Storm Water Permit Requirements and SHAP Compliance
             Certificate of Coverage No.                              MIR11D361
             Issuing Authority                                        Michigan Dept. of Environmental Quality
             Permit Type                                              General Storm water
             Issuance Date                                            September 30, 1996
             Receiving Stream                                         Plumbrook via Moore-Ledwidge Drain

             Certificate of Coverage REQUIREMENT:                     COMPLIANCE (Yes, No or Pending) :
             Annual Fee of $200                                                        Yes
             Certified Operator by 9/30/97                                             Yes
             Storm Water Pollution Prevention Plan by 3/30/98                          Yes
             Requirements for non-storm water discharges by 9/30/97                     Yes
             Non-structural controls implemented by 9/30/98                          Pending *
             Structural controls implemented by 9/30/99                              Pending *
           Source: DEQ Surface Water Quality Division

           * DEQ verifying compliance status




D-2      Michigan Department of Environmental Quality
                                        Community Environmental Awareness Project



     Appendix E: HAZARDOUS WASTE MANAGEMENT
Hazardous waste generator requirements
As a fully regulated hazardous waste generator, SHAP must meet many requirements. Groups of requirements
that apply to each category of generator are summarized in the following chart.
       Table 1: Requirements for Hazardous Waste Generators
        Regulatory Category           Fully Regulated              Small Quantity               Conditionally Exempt
                                        Generator                    Generator               Small Quantity Generator
                                     (>1000 kg/month)           (100-1000 kg/month)               (<100 kg/month)
        Waste determinations                Yes                         Yes                               Yes
        Transportation                      Yes                         Yes                               Yes
        Manifesting                         Yes                         Yes                   Industrial waste (Part 121)
        Waste Storage                Yes (<90 day limit)        Yes (<180 day limit)                      Yes
        Contingency plan                    Yes                   Yes (Abbreviated)                       No
        Personnel training                  Yes                          No                               No
        Record keeping                      Yes                          No                               No
        Air emissions                       Yes                          No                               No
        Treatment                           Yes                          No                               No
      Regulatory Categories defined:
      Waste determinations - A generator must characterize and maintain documentation indicating whether the wastes it
      generates are hazardous, industrial wastes, or non-hazardous.
      Transportation - The U.S. Department of Transportation requires that certain containers, labels and packaging be used for
      wastes. State Hazardous and Liquid Industrial waste regulations require, in most cases, that a licensed transporter be used.
      Manifesting - The movement of all Hazardous and Liquid industrial wastes are tracked from generation to disposal. These
      records are maintained by the generator, transporter and treatment, storage and disposal facility.
      Waste Storage - Hazardous waste has specified accumulation time limits, containment and labeling requirements.
      Contingency plan - This plan reviews general safety standards to prevent and prepare for an emergency. It describes what
      facility personnel will do in case of a fire, explosion, and/or release of hazardous waste. Small Quantity Generators are not
      required to have a contingency plan but must have a list of emergency contact personnel and agency numbers by the phone.
      Personnel training - Generators must train personnel in the contingency plan and emergency procedures.
      Record keeping - Records must include records of release, facility in-house inspections and biennial reporting when required.
      Air emissions - Generators must comply with applicable portions of the federal Resource Conservation and Recovery Act.
      Treatment - Generators may treat their own waste on-site if they follow specific requirements.

The following table summarizes SHAP’s environmental performance and the DEQ regulatory actions.
     Table 2: Summary of SHAP Compliance with the Hazardous Waste Requirements
        Type of         Date of Regulatory              Violation         Agency      Agency       Company         Compliance
       Inspection      Agency   Categoryw              Resulted in        Action      Action       Response         Achieved
                      Inspection    and               Actual Release                   Date         (Date
                                Number of                 to the                                   Received)
                                 Violations           Environment
           G         7/29/97       AE - 1                   No            L.O.W.      8/14/97        9/4/97          3/13/98
           G         7/29/97       SR - 9                   No            L.O.W.      8/14/97        9/4/97          3/13/98
           G         7/29/97       RR - 1                   No            L.O.W.      8/14/97        9/4/97          3/13/98
     Source: DEQ Waste Management Division
     Type of Inspection                    Agency Action                                          Regulatory Categoryw
     G = General inspection                L.O.W. = Letter of Warning                             WD = Waste Determination
     FUP = Follow-up                       L.O.W.2 = second Letter of Warning                     CP = Contingency Plan
     C = Complaint investigation           10 = 10-day Letter                                     MR = Manifesting Requirement
     CD = Case development                 N.O.V = Notice of Violation                            SR = Waste Storage Requirement
     RR = Record reviews                   CO = Consent Order                                     PT = Personnel Training
     SV = Site visit                       CJ or JO = Litigation (Judicial Order)                 RR = Record keeping
     CON = Construction activities                                                                AE = Air Emission
     CL = Closure plan activities          Note: No date indicates an action is pending.          TE = Treatment
     w This cited violation category means the agency believes environmental requirements have been violated and has cited the company
     for such. This citation is not proof that a violation actually occurred but rather an allegation of non-compliance.


                                                                         Michigan Department of Environmental Quality             E-1
                                            Community Environmental Awareness Project



                 GLOSSARY OF TERMS AND ABBREVIATIONS
aboveground storage tank (AST) — A tank or combination of               oxides (NOx), therefore, controlling VOC and/or NO emissions low-
tanks, including the pipes connected to the tank(s) or ancillary        ers levels of ozone.
equipment, which is used to contain an accumulation of liquids          particulate matter — Liquid or solid particles such as dust, smoke,
and has less than ten percent of its volume, including the volume       mist, or smog found in air emissions.
of the underground pipes that are connected to the tank(s), be-         polychlorinated biphenyls (PCB) — A group of toxic, persistent
neath the surface of the ground.                                        chemicals used in electrical transformers and capacitors for insulat-
carbon monoxide (CO) — A colorless, odorless, poisonous gas             ing purposes, and in gas pipeline systems as a lubricant. The sale
produced by incomplete fossil fuel combustion.                          and new use of PCBs were banned by law in 1979.
chlorofluorocarbons (CFC) — Any of various compounds con-               SARA Title III — The Emergency Planning and Community Right-
sisting of carbon, hydrogen, chlorine, and fluorine, once widely        To-Know Act, also known as Title III of the Superfund Amend-
used as aerosol propellants and refrigerants.                           ments and Reauthorization Act (SARA Title III), is the national
corrosive — A substance that eats or wears away materials gradu-        legislation designated to help local communities protect public
ally by chemical action.                                                health, safety, and the environment from chemical hazards.
delisting petition — Use of the petition process (1) to have a          sewage treatment plant — A facility that receives wastewater (and
chemical’s toxic designation rescinded; (2) to remove a site from       sometimes runoff) from community and/or industrial sources. The
the National Priority List; or (3) to exclude a particular waste from   plant contains a series of tanks, screens, filters and other processes
regulation even though it is a listed                                   that remove pollutants from water.
hazardous waste.                                                        SHAP — Sterling Heights Assembly Plant.
DEQ — Department of Environmental Quality — The state gov-              solvent — A substance (usually liquid) that is capable of dissolv-
ernment agency responsible for developing and administering             ing another substance.
environmental regulations in Michigan.                                  storm water runoff —The portion of rainfall, melted snow or irriga-
Industrial Pretreatment Program — A local permitting program            tion water that flows across ground surfaces and eventually re-
that may require industry to treat their wastewater before sending      turns to surface waters. Runoff can pick up pollutants from the air
it to the municipal sewage treatment plant.                             or the land and carry them to surface
lead — A heavy metal that is hazardous to health if breathed or         waters.
swallowed. Its use in gasoline, paints, and plumbing compounds          sulfur dioxide (SO2) — A pungent, colorless, gaseous pollutant
has been sharply restricted or eliminated by federal laws and           formed primarily by the combustion of fossil fuels.
regulations.                                                            Superfund Amendments and Reauthorization Act — The Super-
LEPC — Local Emergency Planning Committee — Local com-                  fund Amendments and Reauthorization Act reauthorized
mittee that develops a community-specific response plan in case         cleanup activities of abandoned or uncontrolled hazardous waste
of a chemical emergency. There are 86 LEPC’s throughout Michi-          sites around the country.
gan.                                                                    TRI — Toxic Chemical Release Inventory — A federal program
mercury — A naturally occurring heavy metal with several forms,         described in SARA Title III that requires certain facilities to report
including shiny, silver-white, odorless liquid and colorless, odor-     releases and transfers of toxic chemicals to the U.S. EPA and DEQ.
less gas. Mercury can accumulate in the environment and is highly       underground storage tank (UST) — A tank or combination of tanks
toxic if breathed or swallowed.                                         which is used to contain a “regulated substance(s)” and has a
National Response Center — The primary communications cen-              volume of ten percent or more, including connected underground
ter operated by the U.S. Coast Guard to receive reports of major        piping, beneath the ground.
chemical and oil spills and releases of other hazardous substances      U.S. EPA — United States Environmental Protection Agency —
into the environment.                                                   The U.S. government agency responsible for developing and ad-
nitrogen oxides (NOx) — Nitrogen oxides refer to NO2 and NO,            ministering environmental regulations.
which are emissions from fuel combustion.                               violation - In this document, the use of the word violation means the
NPDES — National Pollutant Discharge Elimination System —               DEQ believes environmental requirements have been violated and
A permit program with the goal of moving toward minimal dis-            has cited the company for such. The citation is not proof that a
charge of pollutants to surface waters (lakes and rivers) and           violation has actually occurred but rather an allegation of non-
groundwater.                                                            compliance.
ozone (O3) — One layer of beneficial ozone occurs at seven to 18        volatile organic compound (VOC) — Any organic compound which
miles above the surface and shields the earth from ultraviolet          evaporates readily to the atmosphere. VOCs contribute significantly
light. Scientists have documented several holes in this protective      to photochemical smog production and certain health problems.
layer. Ozone also concentrates at the surface as a result of reac-      wastewater — Water carrying wastes from homes, businesses
tions between byproducts of fossil fuel combustion and sun-             and industries that is a mixture of water and dissolved or sus-
light, having harmful health effects. Ozone is formed in the air by     pended solids.
a mixture of volatile organic compounds (VOCs) and nitrogen

                                                                                      Michigan Department of Environmental Quality

				
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