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Aspect - Impact Environmental Assessment Form

Saturn Electronics & Engineering, Inc.


Coopersville Plant
Environmental Impact associated with aspect Surface water pollution (Spillage from truck into storm water sewer) Soil and ground water contamination Usage of fossil or nuclear fuels Scale of impact 5 Severity of impact 5 Prob/Freq Significance of Factor occurrence 1 25 Regulated or other requirements? No Significant Aspect (Y/N) N Means of achieving and/or method of monitoring progress toward achieving objectives/targets Responsibility Time frame for for achieving achieving objectives / objectives / targets targets

Number 1

Aspect Transmission fluid delivery

Activities associated with aspect Subcontracted delivery.

Control Method Letter sent to supplier specifying our requirements Slope of delivery area and asphalt coverage of ground at delivery point none

Objectives

Targets

25

No

Electricity usage

All

40

No

Increase efficiency and Reduce electricity reduce unnecessary costs (as a percent of electricity use sales) by 5% by Jan, 2004 (i.e. Motion detectors for bathroom lights, air compressor efficiency, HVAC controls, etc) Add labels to chemical room walls specifying location of each barrel type Review Site Identification form to see if we need to resubmit Review waste pickup schedule to ensure we don't exceed 100 kg per month. Characterize all wastes

Track the percent of sales dollars that are spent on electricity. Have a 5% reduction in this percentage by Jan 2004 Add this to monthly QOS Measurables. Use the 2002 numbers as a baseline

D. Ross R. Miller

start tracking in Jan 2003

Chemical Storage and Transport

Internal Waste Disposal (chemical Mixing of chemicals within room, VFS final test, hydraulics storage barrels, causing testing, Visteon audit) possible hazardous combinations

Chemical room access limited to Plant Engineer and 2nd shift maintenance, who ensure correct barrels are used

36

Yes, no mixing permitted by disposal company

D. Ross

by 1/31/03

BLDI

by 1/31/03

Storage of waste while waiting for Surface water pollution disposal company to pick up. (Spillage from container onto loading dock or into truck well) Storage of waste and "fresh" Leaks and spills into ground chemicals water Transporting waste from point of use to chemical room Spillage within building beyond chemical room containment Spillage within building beyond chemical room containment

Waste hauler takes container from chemical room (no storage period on loading dock) All chemicals stored over steel lined cement spill containment area in chemical room Due Care used by personnel

40

No

Running inventory.

D. Ross

by 12/31/02

12

No

BLDI

by 1/31/03

12

No

Transporting "fresh" chemicals from loading dock to chemical room or from chemical room to point of use within building (VFS final test, hydraulics testing, wave solder, Visteon audit) Waste transport by sub-contracted Improper disposal disposal company Spillage along roads In-house storage capacity for transmission and motor oil

Due Care used by personnel

12

No

5 5 4

5 5 4

Licensed disposal company used Licensed disposal company used Running inventory of capacity

1 1 1

25 25 16

Yes, for disposal Yes, for disposal Yes. 1320 gallons maximum allowed without reporting

N N N Stay below 1320 gallons capacity at all times Running inventory. D. Ross Begin Jan 2003

Possible surface and ground water contamination if capacity is exceeded

Handling and storage of universal Ground water wastes contamination (landfill leachate)

Universal wastes seperated and disposed of by licensed handler, as per SOP 5151.

24

Yes

Solder Emissions (Tin, Lead, Flux) into atmosphere

Wave solder, VFS/RFE solder pot, Air pollution wave solder washer, operations using solder irons

Periodic air quality testing

20

Yes, air permit may be required

Write SPCC plan if we are over 1320 gallons capacity Implement standard operating procedure (5151) for handling universal and hazardous wastes Determine if laws / regulations require us to have permits under MAERS.

BLDI

by 5/31/03

D. Johnson D. Ross

by 12/31/02

BLDI to test emissions (ppm). Outside consultant review of regulations.

BLDI

by 2/28/03

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Aspect - Impact Environmental Assessment Form


Saturn Electronics & Engineering, Inc.
Coopersville Plant
Environmental Impact associated with aspect Health risks to employees due to overexposure to lead vapors Scale of impact 5 Severity of impact 3 Prob/Freq Significance of Factor occurrence 1 15 Regulated or other requirements? Yes, OSHA Significant Aspect (Y/N) N Means of achieving and/or Responsibility Time frame for method of monitoring for achieving achieving progress toward achieving objectives / objectives / objectives/targets targets targets Testing by outside laboratory K. Stebbins by 1/31/03

Number

Aspect

Activities associated with aspect

Control Method Air (vacuum) exhaust at solder points

Objectives Perform testing on maintenance employee. Use results to determine future action Set up barrels to separate materials. Investigate recycling companies Issue quote request for vapor recovery system. Install system if feasable. Issue quote request for vapor recovery system. Install system if feasable. Write procedure to specify containment and clean-up of spills

Targets

Electronic components, Plastic, Metals dumped into trash compactor Transmission Fluid Vapor Emissions

ICT testers, Final testers, Rework Ground water and Salvage contamination (landfill leachate)

Metals separated and sold to salvage company

24

Yes, for listed elements and compounds only

Training of supervisors, material handlers, plant engineer

T. Zerfas

by 12/10/02

VFS final test, hydraulics testing

Air pollution

none

20

Yes, air permit may be required

Unit installed Nov. 2002

D. Ross

by 12/31/02

Transmission Fluid collects under testers

VFS final test, hydraulics testing

Ground water contamination (emissions condense on roof, then washed into ground) Spillage within building beyond chemical room containment

none

30

Yes, air permit may be required

Unit installed Nov. 2002

D. Ross

by 12/31/02

Trap pans under testers, vacuumed up as necessary. Vacuum then emptied into storage barrel in chemical room. Due Care used by personnel to dispose wastewater only into sanitary sewer system

16

No

D. Johnson D. Ross

by 11/21/02

Wastewater Disposal

Better Engineering parts washer, mop buckets, floor scrubber

Surface water contamination.

27

Yes, stormwater runoff

Investigate using an oil seperator to clean wastewater before disposal. Evaluate Coopersville's water ordinance

D. Ross

by 12/10/02

BLDI

By 12/31/02

Disposal of oily rags Maintenance, VFS final test, and gloves hydraulics testing Storm water runoff Truck well, parking lot

10

Ground water contamination (landfill leachate) Surface water contamination (from oil) Surface water contamination.

None for gloves. Subcontracted service for rags none

24

No

20

Yes, stormwater runoff Yes, stormwater runoff

Write Emergency Plan

D. Ross K. Stebbins No metals stored outside revise EMS monthly checklist J. Zerfas to include this requirement D. Johnson (11/22/02). BLDI to review BLDI Coopersville stormwater ordinance (by 12/31/02). BLDI to determine if SWPPP is needed (by 1/31/03). If needed, SWPPP to be complete by 7/1/03 revise EMS monthly checklist J. Zerfas to include this requirement D. Johnson

by 12/31/02

Outside storage of pallets and metal

none

20

Require protected storage of metals. (pallets will remain outside). Put Stormwater Pollution Prevention Plan in place

Outside storage of empty alcohol & flux containers and empty spools for recycle pickup

Surface water contamination.

none

20

Yes, stormwater runoff

Write procedure to specify that pallets of these containers must be shrink wrapped, including exposed tops Explain our requirements to contractors. Consumer's Power to test all unlabeled transformers

by 11/15/02

Contractors dispose of their scrap Surface water when performing work for Saturn contamination 11 Transformers containing PCBs All Ground water contamination at disposal

none

12

Yes, stormwater runoff Yes, for disposal

D. Ross

when work is performed by 7/31/03

Transformers will be tested for PCB content before disposal per Michigan Administrative Code # R 299.3313 -3317

16

2/25/03: Consumers tested Consumer's transformers. We are below Power pcb threshold. Certification sticker to be applied to pig Spring 2003.

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Aspect - Impact Environmental Assessment Form


Saturn Electronics & Engineering, Inc.
Coopersville Plant
Environmental Impact associated with aspect Scale of impact 4 Severity of impact 4 Prob/Freq Significance of Factor occurrence 1 16 Regulated or other requirements? Yes, for disposal Significant Aspect (Y/N) N Means of achieving and/or method of monitoring progress toward achieving objectives/targets Responsibility Time frame for for achieving achieving objectives / objectives / targets targets D. Johnson by 12/31/02 D. Ross

Number

Aspect Capacitors / Ballast containing PCBs

Activities associated with aspect

Control Method These will be disposed of as PCB hazardous waste Only licensed disposal company used (for recycling) No DEQ forbidden componds used by lawn service No DEQ forbidden componds used by lawn service none

Objectives Write disposal procedure.

Targets

Lighting fixtures, Durability testers Ground water contamination at disposal Wave solder, Solder pots Upkeep of building grounds (sub-contracted) Ground water contamination Ground water contamination Surface water contamination. Landfill usage

12 13

Solder Dross disposal Lawn Chemical usage

4 2 2 2

4 2 2 3

2 1 1 5

32 4 4 30

Yes, for disposal No No No

N N N Y Obtain certification from lawn service stating no forbidden chemicals used Implement cardboard recycling. K. Stebbins J. Zerfas by 10/31/02

14

Paper and cardboard usage

All

Reduce trash compactor volume by 20% by Jan, 2004

15

Conformal coating of circuit boards

Electronics (John Deere module only)

Air pollution

Performed outside, no point discharges

45

Yes, SARA title III, for current compound used (Humiseal)

Get customer approval to use a coating that is more environmentally friendly

Monitor and graph how often the trash container is changed (by month) starting in Jan 2003 Check customer requirements. If customer does not specify Humiseal, use a different compound. Review of new compounds is in progress

K. Mercer D. Ross S. Carlson K. Baker A. Hamelink

Recycling company to be chosen by 1/31/03 by 2/14/03

16

Trash compactor (excessive litter when changing container) Painting done outside, no spray booth

All

Surface water contamination.

none

20

No

Write instruction stating that area must be cleaned before new container is placed.

S. Carlson D. Johnson

by 11/15/02

17

Model Shop, Maintenance

Air pollution

Performed outside, no point discharges Performed outside, no point discharges Performed outside, no point discharges Due care used by personnel

12

No

18

Miscellaneous use of hazardous chemicals

Research & Development Model Shop

Surface water contamination. Ground water contamination Air pollution

2 2 2

2 2 2

3 3 3

12 12 12

No No Yes, air permit may be required

N N Y Put policy in place that no sales samples or other chemicals are to be used until an environmental review is done. Also reduce the number of hazardous chemicals used Reduce the number of Written policy and employee K. Stebbins hazardous chemicals training used by 10% by Jan, 2004 Keep running inventory of D. Ross different chemicals used Policy to be in place by 10/31/02 Inventory to be complete by 12/31/02. Begin running inventory in Jan 2003 by 11/5/02

Surface water contamination. Ground water contamination

2 2

2 2

Due care used by personnel Due care used by personnel

3 3

12 12

Y Y

19

Pesticide use

Kill mice

Surface water contamination

Trap opening protected by building overhang

18

No

Current traps to be Traps to be removed removed. All future by 11/5/02 traps used to be evaluated for environmental impacts before use (type of poison and placement) Improve inventory control of on-hand quantity of solder

D. Ross

20

Lead (Pb) useage

Soldering operations. Electric hilo. Electric transport cart.

21

Use of chemicals Circuit board conformal coating. that are reportable R&D activities. Maintenance under SARA Title III activities

Inventory (including batteries) exceeds permitted amount. Amount above permitted level triggers TRI form R reporting requirements Air pollution

Environmental consultant (BLDI) to perform initial assessment and training of Saturn personnel in TRI form R requirements (SARA Title III) Due care used by personnel

12

Yes, reportable if 100 lbs. on site is exceeded

Tighten the window for solder J. Zerfas deliveries, through JBA and C. Sweers working with supplier.

by 12/31/02

12

Yes

see # 18

see # 18

Surface and ground water contamination

Due care used by personnel

12

Yes

Perform review of all MSDS sheets to determine which chemicals are above the reporting threshold. Report these chemicals as needed. Prepare contingency plans.

BLDI

by 7/31/03

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Aspect - Impact Environmental Assessment Form


Saturn Electronics & Engineering, Inc.
Coopersville Plant
Environmental Impact associated with aspect Scale of impact Severity of impact Prob/Freq Significance of Factor occurrence Regulated or other requirements? Significant Aspect (Y/N) Means of achieving and/or method of monitoring progress toward achieving objectives/targets Responsibility Time frame for for achieving achieving objectives / objectives / targets targets

Number

Aspect

Activities associated with aspect

Control Method

Objectives

Targets

Positive Aspects are hi-lighted in GREEN

Significant Aspects are hilighted in YELLOW

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Objectives completed on (date)

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Objectives completed on (date)

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Objectives completed on (date)

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Objectives completed on (date)

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Scale of Impact
How much of an impact will the aspect make on the environment? How heavily will the impact (based on the given aspect) affect the environment? Impact Type Hazardous effect on environment High effect Medium Low None Scale 5 4 3 2 1

Severity of Impact
Based on the Scale of impact, how severe is the impact? Take into account how long the impact will have a negative effect. Severity of Impact Hazardous High Medium Low None Scale 5 4 3 2 1

Prob/Freq of Occurrence
How frequently will the specified impact occur? Take into account: a. Any control method(s) placed on the aspect and/or impact b. The activities associated with the aspect and/or impact c. How the activities are performed d. Our history performing the activities. Prob/Freq of Occur. Always High Medium Remote None Scale 5 4 3 2 1

"Significance Factor" = (Scale of Impact) X (Severity of Impact) X (Prob/Freq of Occurrence)