United States   | •
            Environmental Protection
            Agency      1; •
               Enforcbment And
               Compliance Assurance
               (2221 A)' .-
EPA310-R-95-009
September 1995
            Profile Of The
            Motor Vehicle Assembly
            Industry
   EPA I
EPA Office Of Compliance Sector Notebook Project
NOTEBOOKS

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON, D.C. 20460
                                                                         THE ADMINISTRATOR
Message from the Administrator

Over the past 25 years, our nation has made tremendous progress in protecting public health and
our environment while promoting economic prosperity. Businesses as large as iron and steel
plants and businesses as small as the dry cleaner on the corner have worked with EPA to find
ways to operate cleaner, cheaper, and smarter. As a result, we no longer have rivers catching on
fire. Our skies are clearer. American environmental technology and expertise are in demand
throughout the world.

The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.

Within the past two years, the Environmental Protection Agency undertook its Sector Notebook
Project to compile, for a number of key industries, information about environmental problems and
solutions, case studies and tips about complying with regulations. We called on industry leaders,
state regulators, and EPA staff with many years of experience in these industries and with their
unique environmental issues. Together with notebooks for 17 other industries, the notebook you
hold in your hand is the result.

These notebooks will help business managers to better understand their regulatory requirements,
learn more about how others in their industry have undertaken regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.

I encourage you to use this notebook to evaluate and improve the way that together we achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that — in industry after industry, community after community —
environmental protection and economic prosperity go hand in hand.
                                               Carol M. Brownor
           Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)

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Motoi Vehicle Assembly Industry
Sector Notebook Project
                                                         EPA/310-R-95-009
             EPA Office of Compliance  Sector
                        Notebook  Project

  Profile of the:   Motor Vehicle  Assembly Industry
                              September 1995
                           Office of Compliance
               Office of Enforcement and Compliance Assurance
                   U.S. Environmental Protection Agency
                         401 M St., SW (MC 2221-A)
                           Washington, DC 20460
                           For sale by the U.S. Government Printing Office
                    Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
                               ISBN 0-16-048276-3
SIC Code 37
     September 1995

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 Sector Notebook Project
Motor Vehicle Assembly Industry
 This report is one in a series of volumes published by the U.S. Environmental
 Protection Agency  (EPA) to provide  information  of  general  interest  regarding
 environmental issues associated with specific industrial sectors.  The documents
 were developed under contract by Abt Associates (Cambridge, MA), and Booz-Allen
 & Hamilton,  Inc. (McLean, VA).  This publication may be purchased from the
 Superintendent of Documents,  U.S. Government Printing Office.  A  listing of
 available Sector Notebooks and document numbers is included at the end of this
 document.
 All telephone orders should be directed to:

      Superintendent of Documents
      U.S. Government Printing Office
      Washington, DC 20402
      (202) 512-1800
      FAX (202) 512-2250
      8:00 a.m. to 4:30 p.m., EST, M-F
Using the form provided at the end of this document, all mail orders should be
directed to:

      U.S. Government Printing Office
      P.O. Box 371954
      Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as
public and academic libraries, Federal, State, local, and foreign governments, and the
media.  For further  information, and for answers to questions pertaining to these
documents, please refer to the contact names and numbers provided within this
volume.
Electronic versions of all Sector Notebooks are available on the EPA Enviro$en$e
Bulletin  Board  and  via  Internet  on  the Enviro$en$e  World  Wide Web.
Downloading procedures are described in Appendix A of this document.
Cover  photograph, courtesy  of Saturn Motors,  Spring Hill,  Tennessee.   Special
thanks to Jennifer Graham for providing photographs.
September 1995
               SIC Code 37

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                                     Sector Notebook Contacts
The Sector Notebooks were developed by the EPA's Office of Compliance. Particular questions regarding the
Sector Notebook Project in general can be directed to:

         Seth Heminway, Coordinator, Sector Notebook Project
         US EPA, Office of Compliance
         401MSt, SW(2223-A)
         Washington, DC 20460
         (202) 564-7017 fax (202) 564-0050
         E-mail: heminway.seth@epamail.epa.gov

Questions and comments regarding the individual documents can be directed to the appropriate specialists listed
below.
Document Number
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310.
EPA/310.

EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
-R-95-001.
-R-95-002.
-R-95-003.
-R-95-004.
-R-95-005.
-R-95-006.
-R-95-007.
-R-95-008.
-R-95-009.
-R-95-010.
-R-95-011.
-R-95-012.
-R-95-013.
-R-95-014.
-R-95-015.
-R-95-016.
-R-95-017.
-R-95-018.

-R-97-001.
-R-97-002.
-R-97-003.
-R-97-004.
-R-97-005.
-R-97-006.
-R-97-007.
-R-97-008.
-R-97-009.
-R-97-010.
  Industry                            Contact

Dry Cleaning Industry
Electronics and Computer Industry
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry
Petroleum Refining Industry
Printing Industry
Pulp and Paper Industry
Rubber and Plastic Industry
Stone, Clay, Glass, and Concrete Industry
Transportation Equipment Cleaning Ind.

Air Transportation Industry
Ground Transportation Industry
Water Transportation Industry
Metal Casting Industry
Pharmaceutical Industry
Plastic Resin and Man-made Fiber Ind.
Fossil Fuel Electric Power Generation Ind.
Shipbuilding and Repair Industry
Textile Industry
Sector Notebook Data Refresh, 1997
                                                                       Phone (202)
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Jane Engert
Anthony Raia
Jane Engert
Robert Lischinsky
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Seth Heminway
Maria Malave
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Anthony Raia
Belinda Breidenbach
Seth Heminway
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-5021
564-6045
564-5021
564-2628
564-7067
564-7003
564-7072
564-7017
564-7027
564-7013
564-7057
564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-6045
564-7022
564-7017
This page updated during May 1998 reprinting

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Motor Vehicle Assembly Industry
                        Sector Notebook Project
                     MOTOR VEHICLE ASSEMBLY INDUSTRY
                                   (SIC 37)
                             TABLE OF CONTENTS
                                                                    Page
I.     INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT	I
      LA.    Summary of the Sector Notebook Project	1
      LB.    Additional Information	2
n.    INTRODUCTION TO THE MOTOR VEHICLES AND MOTOR VEHICLE
      EQUIPMENT INDUSTRY	4
      H.A.   Introduction, Background, and Scope of the Notebook	4
      H.B.    Characterization of Motor Vehicle and Motor Vehicle
             Equipment Industry	4
             n.B.l.    Industry Size and Geographic Distribution	5
             H.B.2.    Product Characterization	8
             E.B.3.    Economic Trends	9
m.    INDUSTRIAL PROCESS DESCRIPTION	14
      m.A.  Industrial Processes in  the Motor Vehicle and
             Motor Vehicle Equipment Industry	14
             in.A.l.   Motor Vehicle Equipment Manufacturing	14
                      DI.A.l.a. Foundry Operations	16
                      m.A.l.b. Metal Fabricating	21
                      m.A.l.c. Metal Finishing/Electroplating	23
             ni.A.2.   Motor Vehicle Assembly	24
             ffl.A.3.   Motor Vehicle Painting/Finishing	25
             HLA.4.   Emerging Industry Trends	31
                      m.AAa. Life Cycle Assessment	32
                      m.A.4.b. Recycling	32
                      IE.A.4.C. Other Initiatives	34
                      in.A.4.d. Manufacturer Initiatives	36
SIC Code 37
IV
September 1995

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Sector 'Notebook. Project
                                             Motor Vehicle Assembly Industry
IV.
V.
                      MOTOR VEHICLE ASSEMBLY INDUSTRY
                                   (SIC 37)
                         TABLE OF CONTENTS (CONT'D)
                                                                    Page
      m.B.
       Raw Material Inputs and Pollution Outputs	38
       III.B.l.   Foundry Operations	40
       HI.B.2.   Metal Fabricating	41
       ni.B.3.   Metal Finishing	42
       III.B.4.   Motor Vehicle Assembly	43
       III.B.5.   Motor Vehicle Painting/Finishing	43
HI. C.  Post Production Motor Vehicle Dismantling/Shredding	44
HI. D.  Management of Chemicals in Wastestream	44
CHEMICAL RELEASE AND TRANSFER PROFILE	47
IV.A.  EPA Toxic Release Inventory for the Motor Vehicles
       and Motor Vehicle Equipment Industry	50
IV.B.   Summary of Selected Chemicals Released	56
IV.C.  Other Data Sources	63
IV.D.  Comparison of Toxic Release Inventory Between
       Selected Industries	64
POLLUTION PREVENTION OPPORTUNITIES	68
V.A.   Motor Vehicle Equipment Manufacturing	69
V.B.   Motor Vehicle Assembly	72
V.C.   Motor Vehicle Painting/Finishing	73
V.D.   Motor Vehicle Dismantling/Shredding	75
V.E.   Pollution Prevention Case Studies	75
September 1995
                                                             SIC Code 37

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Motor Vehicle Assembly Industry
                                                          Sector Notebook Project
VI.
VII.
                     MOTOR VEHICLE ASSEMBLY INDUSTRY
                                   (SIC 37)
                         TABLE OF CONTENTS (CONT'D)
                                                                   Page
      SUMMARY OF FEDERAL STATUTES AND REGULATIONS	79

      VI.A.  General Description of Major Statutes	79
                                                         i
      VLB.  Industry Specific Regulations	1	90
             VLB.l.   Clean Water Act (CWA)	91
             VLB.2.   Clean Air Act (CAA)	92
             VI.B.3.   Comprehensive Environmental Response,
                      Compensation, and Recovery Act (CERCLA)	94
             VLB.4.   Resource Conservation and Recovery
                      Act(RCRA)	94

      VI.C.  Pending and Proposed Regulatory Requirements	96
             VT.C.l.   Motor Vehicle Parts Manufacturing	96
             VI.C.2.   Motor Vehicle Painting/Finishing	98
             VI.C.3.   Motor Vehicle Dismantling/Shredding	99

      COMPLIANCE AND ENFORCEMENT HISTORY	100

      VILA.  Motor Vehicles and Motor Vehicle Equipment
             Compliance History	104

      VII.B.  Comparison of Enforcement Activity Between
             Selected Industries	106

      VH.C.  Review of Major Legal Actions	Ill
             VE.C.1.  Review of Major Cases	Ill
             VH.C.2.  Supplemental Environmental  Projects	112

VIII.  COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES	114

      VIII.A. Sector-Related Environmental Programs and Activities	114

      Vin.B.  EPA Voluntary Programs	118
SIC Code 37
                                   VI
September 1995

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Sector 'Notebook Project
                 Motor Vehicle Assembly Industry
                      MOTOR VEHICLE ASSEMBLY INDUSTRY
                                   (SIC 37)
                         TABLE OF CONTENTS (CONT'D)
                                                                    Page

      VIII.C.  Trade Associations/Industry Sponsored Activity	122
              VIII.C.l. Environmental Programs	122
              VIILC.2. Summary of Trade Associations	124
IX.    CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/
      BIBLIOGRAPHY	
                                  .128
September 1995
VI1
                                 SIC Code 37

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Motor Vehicle Assembly Industry
Sector Notebook Project
                      MOTOR VEHICLE ASSEMBLY INDUSTRY
                                    (SIC 37)
                                EXHIBITS INDEX

                                                                         Page
Exhibit 1    Size Distribution of Motor Vehicle and Motor
            Vehicle Equipment Manufacturing Establishments	6

Exhibit 2    Geographic Distribution of the Motor Vehicles and Motor
            Vehicle Equipment Industry	7

Exhibit 3    Top 10 Motor Vehicle Manufacturers Ranked by
            World Production - 1994	8

Exhibit 4    Distribution of Automotive Assembly Plants - 1992	13

Exhibits    Automobile Composition  and Disposition - 1994	15

Exhibit 6    Automotive Material Usage 1984 to 1994 Model  Year	16

Exhibit 7    Identification of Major Automobile Parts by
            Material and Process	18,19

Exhibit 8    General Foundry Flow Diagram	20

Exhibit 9    Car Painting Process	26

Exhibit 10   Plating of Paint Solids from Specialized Water Paint Formula	27

Exhibit 11   Chemical Components of  Pigments Found in Paint	29

Exhibit 12   The Product Life Cycle System	33

Exhibit 13   Material Content Forecast for Passenger Cars	35

Exhibit 14   Use of Alternative Fuels Forecast	36

Exhibit 15   Materials Inputs/Pollution Outputs	39,40

Exhibit 16   Source Reduction and Recycling Activity for SIC 37	46

Exhibit 17   Top 10 TRI Releasing Auto and Auto Parts Facilities (SIC 37)	51

Exhibit 18   Top 10 TRI Releasing Transportation Equipment Facilities (SIC 37) ..51

Exhibit 19   TRI Reporting Auto and Auto Parts Facilities (SIC  37) by State	52
SIC Code 37
                                   Vlll
     September 1995

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 Sector Notebook Proj<
     ect
                                                     Motor Vehicle Assembly Industry
 Exhibit 20


 Exhibit 21


 Exhibit 22

 Exhibit 23


 Exhibit 24

 Exhibit 25

 Exhibit 26


 Exhibit 27


 Exhibit 28


 Exhibit 29


 Exhibit 30


 Exhibit 31

 Exhibit 32
           MOTOR VEHICLE ASSEMBLY INDUSTRY
                        (SIC 37)
                EXHIBITS INDEX (CONT'D)

 Releases for Auto  and Auto Parts (SIC 37) in TRI, by
 Number of Facilities	52,53,54

 Transfers for Auto and Auto Parts (SIC 37) in TRI, by
 Number of Facilities	,	54,55,55

 Pollutant Releases (Short Tons/Year)	64

 Summary of 1993  TRI Data: Releases and
 Transfers by Industry	66

 Toxic Release Inventory Data for Selected Industries	67

 Hazardous Wastes Relevant to the Automotive Industry	95,96

 Five Year Enforcement and Compliance Summary for
 Motor Vehicle Assembly Industry	105

 Five Year Enforcement and Compliance Summary for Selected
 Industries	107

 One Year Enforcement and Compliance Summary for Selected
 Industries	108

 Five Year Inspection and Enforcement Summary by
 Statute for Selected Industries	109

 One Year Inspection and Enforcement Summary by Statute for
 Selected Industries	110

Supplemental Environmental Projects	113

Motor Vehicle Assembly Facilities Participating
in the 33/50 Program	119
September 1995
                                   IX
                                                        SIC Code 37

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Motor Vehicle Assembly Industry
Sector Notebook Project
                     MOTOR VEHICLE ASSEMBLY INDUSTRY
                                  (SIC 37)
                             LIST OF ACRONYMS
AFS -       AIRS Facility Subsystem (CAA database)
AIRS -      Aerometric Information Retrieval System (CAA database)
BIFs -       Boilers and Industrial Furnaces  (RCRA)
BOD -       Biochemical Oxygen Demand
CAA -      Clean Air Act
CAAA -     Clean Air Act Amendments of 1990
CERCLA-   Comprehensive Environmental  Response, Compensation and
            Liability Act
CERCLIS -   CERCLA Information System
CFCs -      Chlorofluorocarbons
CO -        Carbon Monoxide
COD -       Chemical Oxygen Demand
CSI-        Common Sense Initiative
CWA -      Clean Water Act
D&B -      Dun and Bradstreet Marketing Index
ELP-        Environmental Leadership Program
EPA -       United States Environmental Protection Agency
EPCRA -    Emergency Planning and Community Right-to-Know Act
FIFRA -     Federal Insecticide, Fungicide, and Rodenticide Act
FINDS -     Facility Indexing System
HAPs -      Hazardous Air Pollutants  (CAA)
HSDB -      Hazardous Substances Data Bank
IDEA -      Integrated Data for Enforcement Analysis
LDR -       Land Disposal Restrictions (RCRA)
LEPCs -      Local Emergency Planning Committees
MACT -     Maximum Achievable Control Technology (CAA)
MCLGs -    Maximum Contaminant Level Goals
MCLs-      Maximum  Contaminant Levels
MEK -      Methyl Ethyl Ketone
MSDSs -    Material Safety Data Sheets
NAAQS -   National Ambient Air Quality Standards (CAA)
NAFTA -   North American Free Trade Agreement
NCDB -     National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP -      National Oil and Hazardous Substances Pollution Contingency Plan
NEIC -      National Enforcement Investigation Center
NESHAP -  National Emission Standards for Hazardous Air Pollutants
NO2 "       Nitrogen Dioxide
NOV -      Notice of Violation
NOx -      Nitrogen Oxide
NPDES -    National Pollution Discharge Elimination System (CWA)
SIC Code 37
     September 1995

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 Sectoc Notebook. Project
                                      Motor Vehicle Assembly Industry
 NPL-
 NRC-
 NSPS-
 OAR-
 OECA-
 OPA-
 OPPTS-
 OSHA-
 OSW-
 OSWER -
 OW-
 P2-
 PCS-
 POTW-
 RCRA-
 RCRIS-
 SARA -
 SDWA-
 SEPs-
 SERCs -
 SIC-
 SO2-
 TOC-
 TRI-
 TRIS-
 TCRIS-
 TSCA-
 TSS-
 UIC-
 UST-
 VOCs-
         MOTOR VEHICLE ASSEMBLY INDUSTRY
                       (SIC 37)
              LIST OF ACRONYMS (CONT'D)

 National Priorities List
 National Response Center
 New Source Performance Standards (CAA)
 Office of Air and Radiation
 Office of Enforcement of Compliance Assurance
 Oil Pollution Act
 Office of Prevention, Pesticides, and Toxic Substances
 Occupational Safety and Health Administration
 Office of Solid Waste
 Office of Solid Waste and Emergency Response
 Office of Water
 Pollution Prevention
 Permit Compliance System (CWA Database)
 Publicly Owned Treatments Works
 Resource Conservation and Recovery Act
 RCRA Information System
 Superfund  Amendments and Reauthorization Act
 Safe Drinking Water Act
 Supplementary Environmental Projects
 State Emergency Response Commissions
 Standard Industrial Classification
 Sulfur Dioxide
 Total Organic Carbon
 Toxic Release Inventory
 Toxic Release Inventory  System
 Toxic Chemical Release Inventory System
 Toxic Substances Control Act
 Total Suspended Solids
 Underground Injection Control (SDWA)
Underground Storage Tanks (RCRA)
Volatile Organic Compounds
September 1995
                     XI
SIC Code 37

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Sector Notebook Piojeci
                                       Motor Vehicle Assembly Industry
I.
       MOTOR VEHICLE ASSEMBLY INDUSTRY
                       (SIC 37)

INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
LA.
Summary of the Sector Notebook Project

Environmental policies based  upon  comprehensive  analysis of air,
water, and land pollution are an inevitable and logical supplement to
traditional  single-media  approaches to  environmental  protection.
Environmental regulatory  agencies are  beginning to  embrace
comprehensive,  multi-statute solutions  to  facility  permitting,
enforcement and compliance assurance, education/outreach, research,
and regulatory development issues.  The central concepts  driving the
new policy direction are that pollutant releases to each environmental
medium  (air,  water, and land)   affect  each other,  and  that
environmental strategies  must  actively  identify and address these
inter-relationships by designing policies for the "whole" facility.  One
way to achieve a whole facility  focus is to design environmental
policies for  similar industrial facilities. By doing so, environmental
concerns that  are common to the  manufacturing of similar products
can be addressed in a comprehensive manner. Recognition of the need
to develop  the industrial "sector-based"  approach within the  EPA
Office of Compliance led to the creation of this document.

The Sector Notebook Project was initiated by the  Office of Compliance
within the Office of Enforcement and Compliance Assurance (OECA)
to provide  its staff and  managers  with summary  information for
eighteen specific industrial sectors. As other EPA offices, States, the
regulated  community, environmental groups, and the public became
interested in  this project, the scope of the original project was
expanded.  The ability to design  comprehensive,  common sense
environmental  protection measures for  specific  industries  is
dependent on knowledge of  several inter-related topics.   For  the
purposes of this project, the key elements chosen for inclusion are:
general industry information (economic and geographic); a description
of  industrial  processes;  pollution  outputs; pollution prevention
opportunities;  Federal statutory and regulatory framework;  compliance
history; and a description of partnerships that have been formed
between regulatory agencies, the regulated community, and the public.

For any given industry, each  topic listed above could alone be the
subject of a  lengthy volume.  However,  in order to  produce  a
manageable document, this project  focuses on  providing summary
information for each  topic. This format provides the reader with a
September 1995
                                                       SIC Code 37

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Motor Vehicle Assembly Industry
                                                Sector Notebook Project
I.B.
synopsis of  each  issue,  and  references where  more  in-depth
information is available.  Text within each profile was researched from
a variety of sources, and was usually condensed from more detailed
sources pertaining to specific topics. This approach allows for a wide
coverage of activities  that  can be further  explored  based upon the
citations and references listed at the end of this profile.  As a check on
the information included, each notebook went  through an  external
review process.  The Office of Compliance appreciates the efforts of all
those that participated in this process and enabled us  to develop more
complete, accurate,  and  up-to-date summaries.  Many of those who
reviewed this notebook are listed as contacts in Section IX and may be
sources of additional information.  The individuals and groups on this
list do not necessarily concur with all statements within this notebook.

Additional Information
Providing Comments

            OECA's Office of Compliance plans to periodically review and update
            the notebooks and will make these updates available both in hard copy
            and electronically.   If you have  any  comments on the  existing
            notebook,  or  if you would like to provide  additional information,
            please send a hard copy and computer disk to the EPA Office of
            Compliance,  Sector Notebook  Project, 401  M St.,  SW  (2223-A),
            Washington,  DC  20460.   Comments can also  be  uploaded to the
            Enviro$en$e Bulletin Board or the Enviro$en$e World  Wide Web for
            general access to all users of the  system.   Follow  instructions in
            Appendix A for accessing these data systems. Once you have logged in,
            procedures for  uploading  text are available from the  on-line
            Enviro$en$e Help System.

Adapting Notebooks to Particular Needs

            The scope of  the  existing notebooks reflect an approximation of the
            relative national occurrence of facility types  that occur within each
            sector. In many instances, industries within specific geographic regions
            or States may  have unique characteristics that are not fully captured in
            these profiles. For this reason, the  Office of  Compliance encourages
            State  and  local  environmental  agencies  and  other groups  to
            supplement or re-package the information included in this notebook to
            include more  specific industrial and regulatory information that may
            be available.   Additionally,  interested  States may want to supplement
            the "Summary of Applicable Federal Statutes and Regulations" section
            with State  and local requirements. Compliance or technical assistance
            providers may also want to develop  the "Pollution Prevention" section
            in more detail.  Please  contact the appropriate specialist listed on the
SIC Code 37
                                                     September 1995

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 Sector Notebook Project
                                                       Motor Vehicle Assembly Industry
              opening page of this notebook if your office is interested in assisting us
              in the further development of the information or policies addressed
              within this  volume.

              If you are interested in assisting in the development of new notebooks
              for sectors  not covered in the  original eighteen, please  contact the
              Office of Compliance at 202-564-2395.
September 1995
SIC Code 37

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Motor Vehicle Assembly Industry
                                                Sector Notebook Project
n.
II.A.
INTRODUCTION TO THE MOTOR VEHICLES AND MOTOR VEHICLE
EQUIPMENT INDUSTRY

This section provides background information on the size, geographic
distribution, employment, production, sales, and economic condition
of the Motor Vehicle Equipment  industry.   The type  of  facilities
described within the document are also  described in terms of their
Standard Industrial  Classification (SIC) codes.  Additionally, this
section contains a list of the largest companies in terms of sales.


Introduction, Background, and Scope of the Notebook

This industry notebook  is designed to  provide an overview of the
motor vehicles and motor vehicle equipment industry as  listed under
the Standard Industrial Classification (SIC) code 37.  Establishments
listed under this code are engaged primarily in the manufacture and
assembly of equipment for the transportation of passengers and cargo
by land, air, and water.

Due to the broad scope of  the industries  listed under  SIC 37, this
notebook will  focus on  the  three-digit  SIC 371 which is limited to
motor vehicles and motor  vehicle equipment  (also known  as the
automotive industry). The primary focus within SIC 371  are numbers
3711 - motor vehicles and passenger car bodies, 3713 - truck and bus
bodies, and 3714 - motor vehicle parts and accessories.

Industry groups not covered  by this profile include:  SIC 372  - Aircraft
and Parts; 373 - Ship and Boat Building and Repairing; 374 - Railroad
Equipment; 375 - Motorcycles, Bicycles, and Parts; 376 - Guided Missiles
and Space Vehicles and Parts;  and 379 - Miscellaneous Transportation
Equipment.  The following automotive products are also not covered
in this profile:  diesel engines, tires, automobile stampings,  vehicular
lighting equipment,  carburetors, pistons,  ignition systems, and cabs  for
off-highway construction trucks.
 II.B.
 Characterization of Motor Vehicle and Motor Vehicle Equipment
 Industry

 The U.S. motor vehicle and motor vehicle equipment industry is a
 diverse and technically dynamic industry which plays a vital role in
 the U.S. economy. The massive size  of the automotive industry and
 the diverse nature of  parts required to produce  a car requires  the
 support of many  other major U.S.  industries such  as the plastics and
 rubber industry and the electronic components industry.
 SIC Code 37
                                                                  September 1995

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Sector Notebook Project
Motor Vehicle Assembly Industry
            Facilities involved with the manufacturing of automobiles are located
            across the U.S. and are  organized based on the types of products
            produced.  Businesses involved in the manufacturing of these products
            range from the large "Big Three"  automakers,  General  Motors
            Corporation (GM), Ford Motor Company., and Chrysler Corporation, to
            smaller, independent automotive parts suppliers such  as  Dana
            Corporation, Allied Signal, and Borg Warner.  Other facilities involved
            in the manufacture of automobiles include Toyota, Honda,  Nissan,
            Subaru, Isuzu, Auto Alliance, BMW, and Mitsubishi.
II.B.l.       Industry Size and  Geographic Distribution

            The motor  vehicle and motor vehicle equipment industry is a key
            component in  the U.S.  economy,  accounting  for a  substantial
            percentage  of direct  and indirect employment as well  as  overall
            industrial output.  The vast size and scope of the industry is  best
            understood  by examining the quantity and distribution of automotive
            facilities located  around  the U.S  and the  number of individuals
            employed by these facilities.

            The  U.S. Industrial Outlook 1994 states that an estimated 6.7  million
            persons were employed directly and in allied automotive industries in
            1991.  According to the Department of Commerce's U.S. Global Trade
            Outlook,  1995-2000,  in 1992 the total direct employment for SIC 3711,
            industries manufacturing just motor vehicles and passenger car bodies
            alone, was 314,000.  This figure is down from a peak high in  1985 of
            408,000.  The U.S. Bureau of Labor Statistics estimates that an additional
            six percent employment loss will occur by 2005 in the motor vehicles
            manufacturing industry. This loss in jobs will most likely result from
            a decrease in the number of individuals needed to manufacture  a car.

            Most individuals employed by the  motor vehicle  and motor  vehicle
            equipment industry work  at facilities employing between 20  and 49
            individuals  (See Exhibit 1). These facilities, as well as the  larger  and
            smaller operations,  are located throughout the United States. The  vast
            majority of production is concentrated in the Great Lakes Region.
            According to 1991 data in  the AAMA Motor Vehicle Facts and  Figures
            '94,  the  Great Lakes Region contains over 1,700 motor vehicle  and
            equipment manufacturers.  This figure represents 39 percent of the
            4,467 facilities  in the United States. California, Missouri, and Texas  also
            post  a large  number  of  automotive industries.   The number of
            establishments manufacturing  motor vehicles and motor  vehicle
            equipment increased for all size facilities from 1982 to 1987.  The value
            of shipments also increased during the same five year period.
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                                    Exhibit 1
         Size Distribution of Motor Vehicle and Motor Vehicle Equipment
                          Manufacturing Establishments

Number of
Employees
1-4
5-9
10-19
20-49
50-99
100-249
250-499
2:500
Totals
1982
Number of
Establishments
851
502
562
579
320
295
148
218
3,475
Value of Shipments
(millions of dollars)
127.5
246.5
567.5
1,306.9
1,897.5
4,062.0
4,739.9
96,580.0
128,057.4
1987
Number of
Establishments
918
549
647
650
382
362
202
226
3,936
Value of Shipments
(millions of dollars)
197.7
407.3
895.9
2,132.4
2,919.8
6,761.1
9,475.3
177,151.5
199,941.0
       Source: Census of Manufacturers: IVaz. lyg/. bureau of tne census, u.s. uepanmem oj
             States  in the  Great  Lakes  Region are home to  the majority  of
             automotive assembly plants.  As International companies have moved
             facilities to the U.S., additional States, including Tennessee, California,
             and  Kentucky have  become the  site of  automotive plants.   The
             geographic distribution of manufacturing plants will further increase
             with the completion of a BMW plant in Spartansburg, SC in 1995 and
             start of  production at the Mercedes Benz plant in January 1997 in
             Tuscaloosa, AL.   Exhibit  2 shows the  geographic distribution  of
             industries listed  under SIC 37 producing motor vehicles and motor
             vehicle equipment.
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Motor Vehicle Assembly Industry-
                  Geographic Distribution of the Motor Vehicles
                      and Motor Vehicle Equipment Industry
      Source: AAMA Motor Vehicle Facts & Figures 94, compiled from 1991 U.S. Department of Commerce,
                                Bureau of the Census data.

Motor Vehicle Equipment

            In 1992, the largest number of automotive parts producers, including
            approximately  450 relatively small  aftermarket part manufacturers,
            were located in California, while approximately 315 original equipment
            parts manufacturers were located in Michigan. Indiana and Ohio were
            the sites of 228 and 205 equipment parts manufacturers respectively. In
            order to minimize  transportation costs and  maximize responsiveness
            to automakers, producers of original equipment parts  are located in
            close  proximity  to auto  assembly  facilities; most are  located in
            Michigan,  Indiana, Illinois, and Ohio.    Conversely,  aftermarket
            suppliers have little incentive to locate near automotive  plants and are
            thus located across the country.   A concentration of  aftermarket
            suppliers are located in California, Texas, and Florida.

            The U.S. automotive industry is the largest manufacturing industry in
            North America, accounting for approximately four percent of the  gross
            national product  (GNP).  The U.S. automotive industry contains the
            number one and two manufacturers  of automobiles in the world, GM
            and Ford (see Exhibit 3). According to 1993 data  from the American
            Automobile Manufacturers Association  (AAMA), the U.S. was the
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            third largest producer of cars in the world, behind Europe and Asia
            respectively, dominating 30.3 percent of the market.
                                   Exhibits
                      Top 10 Motor Vehicle Manufacturers
                       Ranked by World Production-1994
Manufacturer
General Motors
Ford
Toyota
Volkswagen
Nissan
PSA
Renault
Chrysler
Fiat
Honda
Country
United States
United States
Japan
Germany
Japan
France
France
United States
Italy
Japan
Passenger
Cars
4,989,938
3,685,415
3,649,640
3,119,997
2,222,985
2,252,121
1,929,858
727,928
1,557,556
1,629,666
Commercial
Vehicles
875,890
2,058,877
838,251
165,699
675,200
185,605
334,473
1,254,748
242,844
132,531
Total
6,865,828
5,744,294
4,487,891
3,285,696
2,898,185
2,437,726
2,264,331
1,982,676
1,800,400
1,762,19
                       Source: AAMA Motor vehicle tacts & Hvures
II.B.2.       Product Characterization

            The motor vehicles and motor vehicle equipment industry produces a
            wide range of diverse products from ambulances and automobiles to
            the cylinder heads, ball joints, and horns that go in these vehicles. The
            Bureau of the Census' SIC code categorizes the automotive industry
            based on the type of products manufactured.  The following  is a list of
            the four-digit SIC codes found under Industry Group Number 371:

                  SIC 3711 -  Motor Vehicle and Passenger Car Bodies
                  SIC 3713 -  Truck and Bus Bodies
                  SIC 3714 -  Motor Vehicle Parts and Accessories
                  SIC 3715 -  Truck Trailers - (not covered in this profile)
                  SIC 3716 -  Motor Homes - (not covered in this profile)

            The motor vehicle and motor vehicle equipment industry is  organized
            into four primary areas based on the types of product produced.  These
            areas are:  (1) passenger  cars and light trucks; (2) medium and heavy
            duty trucks;  (3) truck trailers; (4) and automotive parts and accessories.
            The automotive parts industry is further broken down into two sectors,
            original equipment suppliers and aftermarket suppliers.   Original
            equipment suppliers provide parts directly  to automakers  while
            aftermarket  suppliers provide parts exclusively to  the replacement
            parts market.   The original  equipment  market  accounts  for
            approximately 80 percent of all motor vehicle parts and accessories
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            consumed in the U.S., with the remaining 20 percent accounted for by
            the aftermarket.
II.B.3.       Economic Trends

Economic Health

Motor Vehicles
            According  to  the Department of Commerce's  U.S.  Global  Trade
            Outlook, 1995-2000, worldwide sales volume of cars, trucks, and buses
            have grown 1.2 percent annually  during the past ten years.  Slow
            growth in the industry can be attributed to the saturation of the market
            in developed nations.  In order to  adjust to the long-term changes in
            demand, the motor vehicle  industry is currently undergoing a global
            reorganization.  Within the next ten years, as companies consolidate
            and restructure, perhaps as few as ten mega-manufacturing alliances
            will dominate developed markets.

            The Big Three suffered global net losses in 1992 of $30 billion, due in
            large  part  to competition from  foreign  manufacturers.   These
            competitive pressures  have  stimulated the development of a number
            of cooperative manufacturing and  marketing ventures.  Examples of
            such ventures include GM's  "Geo," a compact sedan manufactured in a
            50-50 joint venture between GM and Toyota, and a sport-utility vehicle
            produced in a 50-50 joint venture between GM and Suzuki.  Another
            example is the Ford and  Auto  Alliance  Michigan plant, which
            manufactures the Ford Probe and the Mazda MX-6 in a 50-50 venture
            between Ford and Mazda.

            Production of passenger cars and light trucks increased 13 percent in
            1993.   Total sales also  increased  nine percent from 1992.   These
            increases are likely the result of improvements in vehicle design and
            added features, product quality, and manufacturing technology.  One
            factor dampening sales in the U.S.  market is the fact that the general
            population is keeping their cars longer.  Data collected by the AAMA
            shows that  the mean  average  age  of  the passenger cars in the U.S.
            automobile fleet in 1993 was  8.3 years -  the highest since 1948. Another
            factor expected to effect sales is that fewer individuals will be reaching
            driving age in the next  several years.  This negative impact could
            potentially be offset by the baby boom's entry into their peak earning
            years, a time when they can afford more expensive cars.

            Future  growth in the passenger car  and light truck sector of  the
            automotive industry is expected to be no  more than one to two percent
            in the coming years.  In response to an essentially saturated U.S.
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            market for new passenger cars and light trucks, competition among
            foreign and U.S. manufacturers is  growing.   As  a result  of  this
            competition, many companies have gone out of business, while others
            have become more competitive and increased their market share, often
            by investing in new or renovated facilities. In 1993, motor vehicle and
            equipment  manufacturers spent approximately  $12  billion on new
            plant facilities and equipment (AAMA, 1995), and  AAMA  estimates
            that motor vehicle and equipment manufactures spent an additional
            estimated $15.7 billion  in  1994.   Another benefit of the  increased
            competition  has been  a  reduction  of operating  expenses  as
            manufacturers have made strides  in improving  technology  and
            increasing productivity while reducing overhead.

            In 1992, 28 percent of  all vehicle  miles  traveled in the U.S. can be
            attributed to commercial truck use (AAMA Facts and Figures, 1994). In
            fact, the U.S. truck  market tends  to be  a magnification of the U.S.
            economy's business cycle (outside of normal replacement cycles). U.S.
            sales  of medium-and heavy-duty trucks  (14,050  gross vehicle weight
            rating (GVWR) and greater), grew 16 percent between 1993  and  1994,
            an  increase of approximately 50,000 units.   Sales for the industry
            through the first five months of 1995 were 167,000 units, a 22 percent
            increase over the same period in 1994.  New safety regulations outlined
            by the National Highway Traffic Safety Administration (NHTSA) will
            impact the truck and trailer industry.  Safety performance standards for
            new anti-lock brake systems are expected to be  complete by October
            1995.  Regulations for automatically adjustable brakes went into effect
            in October 1993 for hydraulic brakes and for air brakes in October 1994.
            Regulations proposed by NHTSA for under-ride guards are in the early
            stages of the regulatory  development process. Once in place,  these new
            regulations should reduce the number of fatalities that are attributed to
            rear-end collisions involving straight body trucks  and truck trailers.
Motor Vehicle Equipment
            According  to the  Department of  Commerce's  U.S. Global  Trade
            Outlook,  1995-2000, the U.S. automotive parts industry is emerging
            from a massive restructuring that has enabled it to greatly strengthen
            its competitive position in relation  to Japan, its  major rival.   Since
            1987,  productivity has increased about three percent annually and
            quality has improved greatly. The global automotive parts market will
            total about $460 billion in 1995 and an estimated $519 billion in 2000.

            In 1992, the U.S. International Trade Commission estimated that there
            were approximately 5,000 U.S. parts and accessories  manufacturers.
            These manufacturers are estimated to produce  22 percent, or $65
            billion, of world production of certain motor vehicle parts.  The U.S. is
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             the  third largest producer of automotive parts, behind Japan at 35
             percent and the  European Union  at  23 percent  of worldwide
             production.  A reduction in passenger car production and an increase
             in the  use of foreign-produced parts has resulted in a decline in
             shipments of U.S. parts, from $68 billion in 1988 to $65 billion in 1992.
             The drop in production  has  resulted  in  a  decline of sales and
             employment.  In 1988, 453,000 were employed in the motor vehicle
             equipment industry. Employment dropped to a low of 407,000 in 1991
             before increasing to 437,000 in 1992.

             The industry is currently undergoing a significant  restructuring.
             Factors influencing this restructuring include:  increased competition
             from Japan, new and innovative organizational  systems,  and  the
             passage of the North American Free Trade Agreement (NAFTA).  U.S.
             automakers and parts  producers are trying to produce higher-quality
             motor  vehicles and parts in a more cost effective  manner.   To
             accomplish this goal, lean and/or agile production techniques are being
             implemented.   These techniques, which  ultimately use less  of
             everything in the production process, also limit the number  of direct
             suppliers of components.

             Original equipment suppliers have been subject to changes in supplier
             relations with the  Big Three automakers over  the past few  years.
             Between 1988  and  1991,  taking advantage of  new manufacturing
             technologies, the Big Three gradually reduced the number of suppliers
             needed. Chrysler,  for example, ordered parts  from more than 3,000
             suppliers in the 1970s, but by 1993 reduced the number of suppliers to
             between 600 and 800 per model line.   As a result of this change  in
             supplier relationships,  original equipment manufacturers have altered
             their role in the industry by providing automakers with services such
             as financing for research and development, inventory, logistics, and
             tooling.

            Economic  uncertainties caused  consumers  to  defer  scheduled
            maintenance and servicing  of their cars between 1988 and 1992.  This
            resulted in a leveling off of  aftermarket parts sales during the same
            years.   Industry sources claim that better designed and  engineered
            original equipment  parts, such as longer lasting shock absorbers, also
            contributed to the flat market.  New  diagnostic technologies which
            identify possible faulty parts and reduce the need for preventative
            maintenance also played a role. The market is predicted to see a turn-
            around  based  on the Clean Air Act Amendments of 1990 and stricter
            emissions  standards, which is anticipated to result in more used car
            repairs and an increase in replacement parts.
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Future Economic Outlook
            Estimates of third-quarter earnings for 1994 show that earnings of U.S.
            automakers will likely triple from  the previous year.  This boom in
            business comes despite plant closures that are traditional during the
            third quarter due to employee vacations and production changeovers
            for new fall models.  AAMA estimates that the Big Three earned $2.3
            billion during the  period, compared  to  $773 million during third-
            quarter 1993. AAMA indicates that sales and earnings may be dropping
            in 1995.

            According to AAMA, growth has continued through the first quarter of
            1995, compared to the same period  in 1994, with a combined earnings
            for the Big Three of about $4.3 billion.  Financial strength over the last
            few quarters has been due, in part, to plants operating at high capacity,
            and to new models  being sold without discounts.  The weak dollar and
            strong Japanese yen also have played a role.  Predictions for continued
            growth of that magnitude through the remainder of 1995, however, are
            less certain.

            In the past  25 years, a growing number  of  foreign  automobile
            manufacturers have started doing business in the U.S., and they now
            play an important  role in the U.S. economy.  Since the  mid-1980s,
            seven  large  foreign automobile manufacturing plants  have  been
            constructed,  representing an investment of over $11 billion  (See
            Exhibit 4). According to AIAM, factories which produce  automobile
            brands such as Honda, Isuzu, Mazda, Mitsubishi, Nissan, Subaru, and
            Toyota, provide approximately 36,000 manufacturing jobs in the U.S.;
            with over 216,000 jobs in the automotive supply  industries.  These
            plants have proven  to be extremely  efficient, with output increasing 90
            percent since 1988.  In 1992 alone, 1,787,500  passenger cars  were
            produced in new U.S. factories  by international companies, a figure
            second only to GM's output.  One out of every four passenger cars
            produced in the U.S. today is the product of a foreign manufacturer.
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                                    Exhibit 4
                Distribution of Automotive Assembly Plants - 1992
State
Michigan
Ohio
Kentucky
Illinois
Tennessee
Indiana
California
Number of Big Three Plants
16
2
2
2
1
1
Number of Foreign-Owned
Plants
I
2
1
1
1
1
U.S. Foreign Joint Ventures
1
                bource: Ward s Automotive Reports, Automotive News Market Data Book.
            The recent passage of the NAFTA should prove beneficial to the auto
            industry as goods and services will be able to flow more freely between
            the U.S.  and Mexico and Canada.  Although Mexico has been a strong
            market for U.S. automotive and heavy-duty aftermarket components
            in the past, exports to Mexico have been limited by quotas and other
            trade restrictions. The passage of NAFTA  and the  elimination of past
            barriers to truck  imports should also prove beneficial to medium- and
            heavy-duty trucks manufacturers, and Mexico could prove to be one of
            the fastest growing truck markets of this decade.

            Another recent  development  that should facilitate further trade
            between the U.S. and Mexico was the creation of  the Pan American
            Automotive Components Exposition (PAACE).  PAACE, which had its
            first meeting in July  1994, is  sponsored by 12 North  American
            associations.  The purpose of the exposition is to bring an international
            show to the  Mexican marketplace as well  as establish PAACE as the
            dominant show  for automotive and  heavy duty  equipment in the
            future. Plans are  currently underway for PAACE 1995.
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ffl.
            INDUSTRIAL PROCESS DESCRIPTION

            This section describes the major industrial processes within the Motor
            Vehicles  and  Motor  Vehicle Equipment industry,  including the
            materials and  equipment used, and  the  processes  employed.   The
            section  is designed  for those  interested  in  gaining  a  general
            understanding of the industry, and for those interested in the inter-
            relationship between the industrial process and the topics described in
            subsequent sections  of this profile ~  pollutant  outputs, pollution
            prevention opportunities, and  Federal regulations.  This section does
            not attempt  to replicate published engineering  information that  is
            available for  this industry.  Refer to Section IX for a list of reference
            documents that are available.

            This section  specifically contains a description  of  commonly  used
            production processes,  associated  raw materials,  the byproducts
            produced or  released, and the  materials either recycled or transferred
            off-site.  This  discussion, coupled  with schematic  drawings of the
            identified processes, provide a concise description of where wastes may
            be produced in the process. This section also describes the potential fate
            (air, water, land) of these waste  products.
IIIA.
            Industrial Processes in the Motor Vehicle and Motor Vehicle
            Equipment Industry

            There is no single production process for Industry Group Number 371.
            Instead, numerous processes  are employed to  manufacture  motor
            vehicles and motor vehicle equipment. This section will focus  on the
            significant production processes including those used in the foundry,
            metal shop, assembly line, and paint shop.
            Motor Vehicle Equipment Manufacturing

            Motor vehicle parts and  accessories include both finished and semi-
            finished components. Approximately 8,000 to 10,000 different parts are
            ultimately assembled into approximately 100 major motor  vehicle
            components, including  suspension systems, transmissions,  and
            radiators.  These parts are eventually transported  to an automotive
            manufacturing plant for assembly.

            According  to a  1993 publication by  the  University of  Michigan
            Transportation Research Institute entitled "Material Selection  Process
            in the Automotive Industry,"  material selection plays a vital role in
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             the production process.  Materials are ultimately selected based on
             factors such as performance  (strength  vs. durability, surface finish,
             corrosion  resistance),  cost,  component manufacturing, consumer
             preference, and competitive responses.

             In the past, automobiles have been composed primarily of iron  and
             steel.  Steel has remained  a major automotive component because of
             its structural integrity and ability to maintain dimensional geometry
             throughout the manufacturing process (See Exhibit 5).

             In response to increasing demands for more fuel efficient cars, the past
             ten years have  seen changes in the composition of materials  used in
             automobiles (See Exhibit 6). Iron and steel use has steadily decreased,
             while plastics and aluminum  has steadily increased.  Aluminum  and
             plastics are valuable car components not only for their lighter weight,
             but also  because of their inherent corrosion resistance.  Although the
             use of plastics in the automotive  industry is increasing, expansion in
             this area  is finite because of limitations in current plastics materials.
                                     Exhibit 5
                  Automobile Composition and Disposition, 1994
                                                   Non.-Metals
                                                      .1%
                                                       Non-Ferrous
                                                        Metals
                                                         8.7%
                       Ferrous Metals
                         70.2%
                                                             \
                      H Non.-Metals
I Non-Ferrous Metals S3 Ferrous Metals
           Source:  Automotive Industries, I992^jrom AAMA Motor Vehicle facts and Figures '94.
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                                    Exhibit 6
                Automotive Material Usage 1984 to 1994 Model Year
                                  (in pounds)"
Material
Conventional Steel
High Strength Steel
Stainless Steel
Other Steels
Iron
Aluminum
Rubber
Plastics/Composites
Glass
Copper and Brass
Zinc Die Castings
Powder Metal Parts
Fluids and Lubricants
Other Materials
TOTAL
1994
1,388.5
263.0
45.0
42.5
408.0
182.0
134.0
245.5
89.0
42.0
16.0
27.0
189.5
99.0
3,171.0
1992
1,379.0
247.0
41.5
42.0
429.5
173.5
133.0
243.0
88.0
45.0
16.0
25.0
177.0
96.0
3,135.5
1990
1,246.5
233.0
31.5
53.0
398.0
158.5
128.0
222.0
82.5
46.0
19.0
23.0
167.0
88.0
2,896.0
1988
1,337.0
227.5
31.0
46.5
426.5
150.0
130.0
219.5
86.0
49.5
19.5
21.5
176.5
89.0
3,010.0
1986
1,446.0
221.0
30.0
47.0
446.5
141.5
131.5
216.0
86.5
43.0
17.0
20.0
182.5
89.5
3,118.0
1984
1,487.5
214.0
29.0
45.0
454.5
137.0
133.5
206.5
87.0
44.0
17.0
18.5
180.0
88.0
3,141.5
             Source:  "Material Usage, Vehicles Retired From Use and Vehicle Recycling" - from
                          AAMA Motor Vehicle Facts & Figures '94.
* Represents consumption per passenger car unit built in the U.S., rounded to the nearest tenth
pound.
                                    of a
             The manufacturing processes used to produce the thousands of discrete
             parts and accessories vary depending on the end product and materials
             used.   Different  process are employed for the production of metal
             components  versus the production  of plastic components.   Most
             processes,  however,  typically  include casting,  forging,  molding,
             extrusion, stamping, and welding.  Exhibit 7 lists major  automotive
             parts  and the primary materials and production processes used to
             manufacture  them.
ffl.A.l.a.    Foundry  Operations
            Foundries, whether they  are  integrated  with automotive assembly
            facilities or independent shops, cast metal products which play a key
            role  in  the production  of  motor vehicles  and  motor  vehicle
            equipment.   As  discussed previously,  even  though  aluminum  and
            other metals are  used increasingly in the production of automobiles
            and their parts, iron and steel are still the major metal components of
            an automobile.  Because of this, the following  discussion will focus on
            iron foundries and the typical production processes.

            The main steps in producing cast  iron motor  vehicle  products  are as
            follows (see Exhibit 8):
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             •     Pattern design and production
             •     Sand formulation
             •     Mold and core production
             •     Metal heating and alloying
             •     Metal molding
             •     Mold shakeout
             •     Product finishing and heat treating
             •     Inspection.

             The process begins with the mixing of moist silica sand with clay (3 to
             20 percent) and water (two to five percent) to produce the "green sand,"
             which forms the basis of the mold.  Other additives, including organics
             such as seacoal or oat hulls, may be  added to the green sand to help
             prevent casting defects.  The core is  then created using molded sand
             and  often  includes  binders,  such  as resins,  phenol,  and/or
             formaldehyde. The core is the internal section of a casting used to
             produce the open areas needed inside such items as an engine or a
             drive train.  After the  core has been molded,  it is baked to ensure its
             shape, and then  combined with  the  rest of the  casting mold in
             preparation for casting.  At the same time the core is being created, iron
             is being melted.  The iron charge, whether it be scrap or new iron, is
             combined with coal (as a fuel) and  other additives  such a calcium
             carbide and magnesium, and fed into  a furnace, which removes sulfur,
             (usually an electric arc, an electric induction, or a cupola furnace).

             Calcium carbide may be added for certain kinds of iron casting, and
             magnesium is added to  produce a more ductile iron.  Once the iron
             reaches the  appropriate temperature, it is poured into  the prepared
             mold.  The mold then proceeds through  the cooling tunnel and is
             placed on a  grid to undergo  a process called "shakeout. " During
             shakeout the grid vibrates, shaking loose the mold and core sand from
             the casting.  The  mold and core are then separated from the product
            which is ready for finishing.

             The finishing  process is  made up  of  many different  steps  depending
            upon the final product.  The surface may be smoothed using an oxygen
            torch  to remove any metal snags or chips, it may be blast-cleaned to
            remove any remaining sand, or it may be pickled using acids to achieve
            the correct surface.  If necessary, the item may  be welded to ensure the
            tightness of any seams or seals.  After finishing, the item undergoes a
            final  heat treatment  to  ensure  it  has the proper metallurgical
            properties. The item is then ready for inspection. Inspection may take
            place  in any  number  of ways be  it visually, by x- or gamma ray,
            ultrasonic, or magnetic particle.  Once an item passes inspection, it is
            ready to be shipped to the assembly area.
September 1995
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Motor Vehicle Assembly Industry
                            Sector Notebook Project
                                   Exhibit 7
       Identification of Major Automobile Parts by Material and Process
Automotive Part
Primary Materials
Primary Process
ENGINE
Block
Cylinder Head
Intake Manifold
Connecting Rods
Pistons
Camshaft
Valves
Exhaust Systems
Iron
Aluminum
Iron
Aluminum
Plastic
Aluminum
Powder Metal
Steel
Aluminum
Iron
Steel
Powder Metal
Steel
Magnesium
Stainless Steel
Aluminum
Iron
Casting
Casting
Machining
Casting
Molding
Machining
Molding
Forging
Machining
Forging
Machining
Molding
Forging
Machining
Stamping
Machining
Extruding
Stamping
TRANSAXLE
Transmission Case
Gear Sets
Torque Converter
CV Joint Assemblies
Aluminum
Magnesium
Steel
Magnesium
Steel
Steel
Rubber
Casting
Machining
Blanking
Machining
Stamping
Casting
Casting
Forging
Extruding
Stamping
BODY STRUCTURE
Body Panels
Bumper Assemblies
Steel
Plastic
Aluminum
Steel
Plastic
Aluminum
Stamping
Molding
Stamping
Molding
SIC Code 37
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September 1995

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Sector Notebook Project
                    Motor Vehicle Assembly Industry
                                      Exhibit 7 (cont'd)
           Identification of Major Automobile Parts by Material and Process
Automotive Part
Primary Materials
Primary Process
CHASSIS/SUSPENSION
Steering Gear /Column
Rear Axle Assembly
Front Suspension
Wheels
Brakes
Steel
Magnesium
Aluminum
Steel
Plastic
Steel
Aluminum
Steel
Aluminum
Steel
Friction Materials
Casting
Stamping
Forging
Machining
Stamping
Molding
Stamping
Forging
Stamping
Forging
Stamping
Forging
SEATS/TRIM
Seats
Instrument Panel
Headliner / Carpeting
Exterior Trim
Steel
Fabric
Foam
Steel
Fabric
Foam
Synthetic Fiber
Plastic
Aluminum
Zinc Die Casting
Molding
Stamping
Molding
Stamping
Molding
Molding
Casting
Stamping
HVAC SYSTEM
A/C Compressor
Radiator/Heater Core
Engine Fan
Aluminum.
Steel
Plastic
Copper
Aluminum
Plastic
Plastic
Steel
Casting
Molding
Stamping
Extruding
Molding
Stamping
Molding
                     Source: University of Michigan Transportation Research Institute,
                          "Material Selection in the Automotive Industry," 1993.
September 1995
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SIC Code 37

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 Motor Vehicle Assembly Industry
                             Sector Notebook Project
                                        Exhibit 8
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-------
 Sector Notebook Project
                 Motor Vehicle Assembly Industry
             of the primer to the metal.  The body is then rinsed with chromic acid,
             further enhancing the anti-corrosion properties of the zinc phosphate
             coating. The anti-corrosion operations  conclude with another' series of
             rinsing steps.

             Priming operations further prepare the body for finishing by applying
             various layers of  coatings designed to  protect the metal surface from
             corrosion and assure good  adhesion of subsequent coatings. Prior to
             the  application of these primer coats, however,  plastic parts to be
             painted and finished with the body are installed.

             As illustrated in Exhibit 10, a primer  coating is applied to the body
             using an electrodeposition method, creating a strong bond between the
             coating  and  the body  to  provide a more durable  coating.  In
             electrodeposition, a negatively-charged auto body is immersed in  a
             positively-charged  60,000  to  80,000  gallon bath of primer for
             approximately three minutes.  The  coating particles, insoluble in the
             liquid and positively-charged, migrate toward the body and  are, in
             effect, "plated" onto the body surface.
September 1995
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SIC Code 37

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Motor Vehicle Assembly Industry
                                Sector Notebook Project
                                            Exhibit 9
                                      Car Painting Process
                                                                                  Zinc
                                                                               Phosphate
                                                                                  Bath
             Cleaning
             Operation
                                Primer Electro
                                  Deposition
              Install
           Plastic Parts
                                                                   Chromic
                                                                   Acid Dip
                                                                                Primer -
                                                                             Surfacer Water
                                                                               Wash Booth
           Anti-Chip
            Booth
                                   Main Color
                                      Booth
              Wet Sand
                Deck
Clear Coat
  Booth
                                              Repairs and
                                              Two-Tone
                                               Finishing
                                                                              Final Repairs
                         Source: American Automobile Manufacturers Association.
SIC Code 37
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                                                                     September 1995

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Sector Notebook Project
                                              Motor Vehicle Assembly Industry
                               Exhibit 10
          Plating of Paint Solids from Specialized Water Paint Formula
                      PLATING OF PAINT SOLIDS
            FROM SPECIALIZED WATER PAINT FORMULA
 CONNECTED TO
   D.C.-
                           CATHODIC ELECTRODEPOSITION
              CONVEYOR
                                   ED PAINT GOES
                             TO VEHICLE / CATHODE
                                & PLATES METAI
 POWER SUPPLY
IMPARTS ELECTRIC
CHARGE TO PAINT
                  Source: American Automobile Manufacturers Association.
September 1995
                              27
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Motor Vehicle Assembly Industry
                         Sector Notebook Project
            Although the  primer bath is mostly  water-based with only small
            amounts of organic solvent (less than five to ten percent), fugitive
            emissions consisting of volatile organic compounds (VOCs) can occur.
            However, the amount of these emissions is quite small. In addition to
            solvents and pigments, the electrodeposition bath contains  lead,
            although the amount of lead used has been decreasing over the years.

            Prior to baking, excess  primer is removed through several  rinsing
            stages.  The rinsing operations use various systems to recover excess
            electrodeposited primer.  Once the body is thoroughly rinsed, it is baked
            for approximately 20 minutes at 350 to 380 degrees Fahrenheit.  VOC
            emissions  resulting  from  the  baking stage are  incinerated at
            approximately  90 percent  of automotive  and  automotive parts
            facilities.

            Next, the body  is further  water-proofed by sealing spot-welded joints of
            the body. Water-proofing is accomplished through the application of a
            paste or putty-like substance. This sealant usually consists of polyvinyl
            chloride and small amounts of solvents.  The body is again baked to
            ensure that the  sealant  adheres thoroughly to the spot-welded areas.

            After water-proofing, the automobile body proceeds to the anti-chip
            booth.  Here, a substance usually consisting of a urethane or an epoxy
            ester resin, in conjunction with solvents, is applied locally to  certain
            areas along the  base of the body, such as the rocker panel or the front of
            the car. This anti-chip  substance protects  the lower portions of  the
            automobile body from small objects, such as  rocks, which can fly up
            and damage automotive  finishes.

            The primer-surfacer  coating, unlike  the initial electrodeposition
            primer  coating, is applied by spray application in a water-wash spray
            booth.  The primer-surfacer consists primarily of pigments, polyester or
            epoxy ester resins, and solvents.   Due to the composition  of this
            coating, the primer-surfacer creates a durable finish which  can be
            sanded. The pigments  used in  this finish provide additional  color
            layers in case the primary color coating is damaged.  The water-wash
            spray booth is  generally 100 to 150 feet long and applies the primer-
            surfacer in a constant  air stream  through which the automobile body
            moves.  A continuous stream of air, usually from ceiling to floor, is
            used to transport airborne particulates  and  solvents from primer-
            surfacer overspray. The air  passes through  a water curtain which
            captures a portion of the airborne solvents for reuse or treatment at a
            waste water facility.   Efforts  have been made at certain facilities to
            recycle this air to reduce VOC emissions.
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September 1995

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 Sector Notebook Project
                 Motor Vehicle Assembly Industry
             After the primer-surfacer coating is baked, the body is then sanded, if
             necessary, to remove any dirt or coating flaws.  This is accomplished
             using a dry sanding technique. The primary environmental concern at
             this  stage  of the  finishing process is the generation of  p articulate
             matter.

             The next step of the finishing process is the application of the primary
             color coating.   This is accomplished  in  a manner  similar  to  the
             application of primer-surfacer. One difference between these two steps
             is the  amount of  pigments  and solvents  used in  the application
             process.  VOC emissions from primary color coating operations can be
             double that released from primer-surfacer operations.  In addition to
             the pigments and solvents, aluminum or mica flakes can be added to
             the  primary color  coating to create a finish with unique reflective
             qualities. Instead of baking, the primary color coat is allowed to "flash
             off,"  in other words, the solvent evaporates without the application of
             heat.

             Pigments, used to formulate both primers and paints, are  an integral
             part  of the paint formulation, which also contains other substances.
             The pigmented resin forms a coating on the body surface as  the solvent
             dries.  The  chemical composition of a pigment varies according to its
             color, as illustrated in Exhibit 11.

                                    Exhibit 11
                Chemical Components of Pigments Found in Paint
Pigment Color || Chemical Components
White
Red
Orange
Brown
Yellow
Green
Blue
Purple
Black
Metallic
Titanium dioxide, white lead, zinc oxide
Iron oxides, calcium sulfate, cadmium
selenide
Lead chromate-molybdate
Iron oxides
Iron oxides, lead chromate, calcium
sulfide
Chromium oxide, copper,
phosphotungstic acid, phosphomolybdic
acid
Ferric ferrocyanide, copper
Manganese phosphate
Black iron oxide
Aluminum, bronze, copper, lead, nickel,
stainless steel, silver, powdered zinc
                Source: McGraw Hill Encyclopedia of Science ana Technology. 1987.
September 1995
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Motor Vehicle Assembly Industry
                         Sector Notebook Project
            After the primary color coating is allowed to air-dry briefly, the final
            coating, a clear coat, is applied. The clear coat adds luster and durability
            to the automotive finish.  This coating generally consists of a modified
            acrylic or a urethane and is baked for approximately 30 minutes.

            Following the baking  of the clear coat, the body is  inspected  for
            imperfections in the finish.  Operators finesse minor flaws through
            light sanding and polishing and without any repainting.

            Once the clear coat is baked, a coating known as deadener is applied to
            certain  areas  of the  automobile underbody.   Deadener,  generally a
            solvent-based resin of tar-like consistency, is applied to areas such as
            the inside of wheel wells to reduce noise.  In  addition, anti-corrosion
            wax is applied to other areas, such as the inside of doors, to further seal
            the automobile body and prevent moisture damage.  This wax contains
            aluminum flake pigment and is applied using a spray wand.

            After painting and finishing, two types of trim are installed - hard and
            soft.  Hard trim, such as instrument panels, steering columns, weather
            stripping, and body glass, is installed first.  The car body is then passed
            through a water test where, by using phosphorous and a black light,
            leaks are identified.  Soft trim, including seats, door pads, roof panel
            insulation, carpeting, and upholstery, is then installed.  The only VOC
            emissions resulting from this stage of the process originate from  the
            use of adhesives to attach items, such as seat covers and carpeting.

            Next, the automobile body is  fitted  with the following:   gas tank,
            catalytic converter, muffler, tail pipe, and bumpers.  Concurrently,  the
            engine goes through a process known as "dressing," which consists of
            installing the transmission, coolant hoses, the alternator, and other
            components.  The engine and tires are then attached to  the  body,
            completing the assembly process.

            The finished vehicle is then  rigorously inspected to ensure that no
            damage has occurred as a result of the  final assembly stages. If there is
            major damage, the entire  body part  is replaced.   However,  if  the
            damage is minor, such as a scratch, paint is taken to the end of the line
            and applied using a hand-operated spray gun.  Because the automobile
            cannot be baked at temperatures as high as in earlier stages  of  the
            finishing process, the paint is catalyzed prior to application to allow for
            faster drying at lower temperatures. Approximately two percent of all
            automobiles manufactured  require this touch-up work.  Because  the
            paint used in this step is applied using a hand-operated  spray gun,
            fugitive air emissions are likely to be generated (depending on system
            design).
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Sector Notebook Project
                 Motor Vehicle Assembly Industry
            Generally, spray and immersion finishing methods are to a certain
            extent interchangeable, and the  application  method for various
            coatings varies from facility to facility.  The same variance applies to
            the number and order of rinsing steps for cleaning, phosphating, and
            electrodeposition primer operations.  Spray rinsing the body prior to
            immersion rinsing decreases  the amount of residues deposited in the
            bath and allows for greater solvent recovery.

            In addition to the above-mentioned uses of solvents as ingredients of
            coatings, solvents are often  used in  facility and equipment cleanup
            operations.  Efforts have been made at several facilities to reduce the
            amount of solvent used for  this purpose, thereby reducing fugitive
            VOC emissions, and to reuse  these solvents when preparing batches of
            coatings used in certain stages of the finishing process.

            The expanded use of alternative coating methods, such as electrostatic
            powder spray, is being researched.  Powder coatings are being used
            instead of solvent-based coatings for some initial  coating steps, such as
            the anti-chip and the primer-surfacer process.
III.A.4.      Emerging Industry Trends

            Motor vehicles manufactured today are produced more  efficiently,
            brought to  market more  quickly, and  designed  to  be  more
            environmentally sensitive than the models of the 1980s. As a result,
            these vehicles are proving to have less  of a negative impact on the
            environment.  Automobile manufacturers are striving to meet new air
            emission standards, and  are  developing motor vehicles and motor
            vehicle equipment that  meet the demands of the growing market
            niche for "green" automobiles.  Much of the information for this
            section was adapted from the 1994 publication entitled "Automotive
            Demand, Markets, and  Material Selection  Processes" by David J.
            Andrea and Brett C. Smith of the University of Michigan.

            In  order  for  motor   vehicle  and  motor  vehicle  equipment
            manufacturers to remain competitive, it  is becoming more important
            to strike a balance between environmental  issues and industrial
            demands. Approaches such as life cycle  assessment (LCA), design for
            recycling (DFR™), and design for disassembly (DFD) encourage the
            development of products that are more environmentally acceptable.
            These  approaches are in various stages of implementation  in the
            automotive industry.  Evidence of their influence can be seen in some
            of the initiatives currently underway in the automotive industry, some
            of which are addressed later in this profile.
September 1995
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Motor Vehicle Assembly Industry
                        Sector Notebook Project
m.A.4.a.    Life Cycle Assessment
            LCA is an environmental approach that focuses on the environmental
            costs associated with each stage of the product life cycle (See Exhibit 12).
            LCA requires the evaluation of environmental effect at every stage of
            the cycle.  The evaluation focuses on such factors the waste streams
            generated during material acquisition and manufacturing, as well as
            energy consumption during processing and distribution.   Attempts to
            implement this structured approach have begun,  although full LCAs
            for automobiles have not yet been achieved due to product complexity.

            According to General Motors' 1994 Environmental Report, LCA is  an
            important part of the company's commitment to product stewardship.
            To implement  this commitment, GM environmental personnel work
            closely with vehicle  design  teams  to integrate environmental
            principles into the earliest possible stages  of the product program
            management process.  As part of this process, various statements of
            work,  which specify the health, safety, and  facility environmental
            criteria that must be met before a product can  be  released to the next
            development phase,  are used to provide  a  framework  for  an
            environmental and health evaluation of GM products. Ford and other
            automakers  are also working  to  develop  LCA technology.  LCA
            promises to be  a useful tool and  its  future applications in  the
            automotive  industry should improve overall industry environmental
            performance.
ni.A.4.b.    Recycling
            An important part of LCA is the "retirement" of a given product. Once
            a product reaches the retirement stage, it becomes eligible for recycling,
            another environmental trend.

            Autos have  been recycled for many years in the U.S., and  today
            approximately  94 percent (or  approximately 9  million)  of  all
            automobiles scrapped in the U.S. are collected and recycled. This effort
            results in approximately 11 million tons of recycled steel and 800,000
            tons of recycled nonferrous metals, and saves an estimated 85 million
            barrels of oil that would be used to manufacture new  parts.  The U.S.
            boasts one of the most effective  and prosperous  vehicle recycling
            industries  in the world. At least 75  percent of the  material collected
            from scrap vehicles  (steel,  aluminum, copper) is  recycled for raw
            material use.  According to the Automotive Recyclers Association
            (ARA), the automotive remanufacturing and  recycling industry  is
            responsible for approximately five billion dollars in annual sales.
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September 1995

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 Sector Notebook Project
                  Motor Vehicle Assembly Industry
                                     Exhibit 12
                           The Product Life Cycle System
                             The Earth
                           and Bioshpere
        Raw Material
         Acquisition
       Treatment or
         Disposal
        Retirement
                                Bulk
                              Processing
                              Material
                             Engineering
                                and
                             Processing
                             Use and        Component and
                             Service      Auto Manufacturing
                                          and Assemblying
  Source: Automotive Demand. Markets, and Material Selection Process. Society of Automotive F.nvinpurs - Ter niral
                Paper Series, International Congress & Exposition, Detroit, Michigan, 1994.

             Three  operations  are primarily responsible for vehicle recycling -
             automobile  scrapp age/disassembly,  automobile  shredders,  and
             materials  recycling.   There  are  an  estimated  12,000 automobile
             scrappage/disassernbly operations in the United States. Vehicles taken
             to these businesses are subject to two major dismantling  steps:  (1)
             drainage  and removal of hazardous and recyclable fluids (oil, auto
             coolants, CFCs), and  (2) removal of parts from the vehicle, which, if
             undamaged, are then cleaned, tested,  inventoried, and sold,  and if
             damaged, are recycled with similar materials.  The remaining hulk is
             then flattened and taken to a shredder.

             There are an estimated 200 shredding  operations in  North America.
             These operations use  large  machines to shred the hulk into fist-sized
             pieces which are then  separated by material types: ferrous, nonferrous,
             and automotive shredder residue (ASR) or "shredder fluff."

             Shredder output is first sorted by magnetic separation  to  "capture" the
             ferrous materials, which are then  transported  to a mill.  Nonferrous
             metals are then hand-sorted from a conveyor belt and sold for use in
September 1995
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Motor Vehicle Assembly Industry
                         Sector Notebook Project
            new products.  The remaining material (approximately 25 percent) is
            sent to landfills.   This  material is composed primarily of plastics,
            rubber, glass, dirt, fibers from carpet, seat foam, and undrained fluids.
            This waste currently constitutes about 1.5 percent of total  municipal
            landfill waste.  The amount of waste generated by shredding will be
            greatly reduced when vehicles are designed using concepts such as DFR
            and DFD.
HLA.4.C.     Other Initiatives

            Three  important  trends impacting vehicle development are:  the
            increased use of lighter weight materials such  as aluminum, plastic,
            and the various composites; the use of alternative fuels; and increased
            use of electric components.

            The Federal Corporate Average Fuel Economy (CAFE) Requirements,
            which mandate average motor-vehicle  fuel economy standards for
            passenger automobiles and light trucks, will push the increased usage
            of lighter-weight materials by  encouraging lower vehicle weight and
            increased fuel efficiency.  Industry experts predict that the use of lighter
            weight materials will increase  38 percent between 1992 and 2000.  A
            study  conducted by the University  of Michigan  Transportation
            Research Institute, Office for the Study of Automotive Transportation
            (OSAT),  entitled Delphi VII, states that industry experts expect to see a
            three percent drop in average  weight of a North American produced
            automobile by 1998 and an eight percent drop by 2003. Light-truck
            weight is expected to see similar reductions with a five percent decrease
            by 1998 and a seven percent decrease by 2003.

            In order to produce lighter-weight vehicles, new lightweight materials
            are needed.  The use of materials such as aluminum, magnesium, and
            plastic could potentially  increase 15 to 20 percent by 2003.   The  use of
            heavier material such as steel and cast iron, which account for the
            majority of car weight, is expected  to fall 9 to  15 percent  within the
            same time frame (See Exhibit 13). Currently, Ford is the largest user of
            aluminum per vehicle in North  America.   In  1991, the use  of
            aluminum in Ford vehicles was 15 percent above the industry average.
            Likewise, Ford researchers and engineers embarked  on the  "Synthesis
            1020" program, which is part of a $25 million effort to determine the
            feasibility of  a high-volume aluminum  intensive  vehicle   (AIV).
            Under that initiative, Ford built 40  AIV's which now are being fleet-
            tested. Chrysler is also exploring the use of aluminum in cars and may
            begin building an aluminum intensive car in 1996,  employing  600 to
            700 pounds  of aluminum per car.  The reduction in weight for a
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September 1995

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Sector 1-ioteboolt Project
                 Motor Vehicle Assembly Industry
             midsize vehicle would cut gasoline consumption by one gallon for
             each 100 miles driven.
                                   Exhibit 13
                   Material Content Forecast for Passenger Cars
Material
Content
Steel
Cast Iron
Aluminum
Plastics
Copper
(including electrical)
Zinc
Magnesium
Glass
Ceramics
Powdered Metals
Rubber
-Tires (inc. spare)
-All other rubber .
Estimated
Current Weight
27.5 mpg*
1709
430
174
243
45
37
7
88
2
25
94
39
Median Responses**
1988 | 1998
-1%
-5%
+10%
5%
0
0
5%
0
2%
4%
0
0
-5%
-10%
+15%
10%
0
-4%
8%
0
3%
4%
0
0
2003
-9%
-15%
+ 20%
15%
0
-4%
15%
0
5%
10%
0
0
                Source: Ward s Automotive Yearbook. 1992 and various OSAT estimates.
* Miles Per Gallon
** Percent change in material content
            In  order to satisfy the requirements of the CAA by lowering  the
            emission of hydrocarbons, carbon monoxide, and oxides of nitrogen,
            the  use  of alternative fuel  sources is being explored.   Various
            alternatives are being explored with different  levels of success (See
            Exhibit 14).   Oxygenated fuels, fuels that are blended with either
            alcohol or ethers, are slowly becoming more common in the United
            States. Oxygenated fuels are beneficial because they reduce emissions of
            carbon monoxide  without requiring vehicle adjustments.   This is
            particularly true in older  cars (pre-1981)  which do  not have systems
            which maintain a constant air-fuel mixture.  At least two States with
            severe  carbon  monoxide  problems,  Colorado and Arizona,  have
            implemented mandatory oxygenated fuel programs in order to meet
            ambient air quality standards. Currently, the State of California  plans
            to mandate the sale of electric cars beginning in 1998.  Research and
            development on electric car technology by the U.S. car companies
            predates the California mandate by several years. The main problem
            with manufacturing as well as driving electric cars is the battery; a long-
            lasting battery has not yet been developed.
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Motor Vehicle Assembly Industry
                         Sector Notebook Project
                                   Exhibit 14
                        Use of Alternative Fuels Forecast
Alternative Fuels
Alcohol or Alcohol/gasoline
(>10% alcohol; includes flex fuel or
variable fuel)
Diesel
Electric
Electric/ gasoline hybrid
Natural gas
Propane
Estimate
1992
0.5%
1.2%
0.0%
0.0%
0.0%
0.0%
Passenger Cars Median Response
1998 2003
1.0% 5.0%
1.0% 2.0%
0.2% 2.0%
0.0% 1.0%
0.5% 2.0%
0.1% 0.5%
      Source: UMTRI Research Review, Delphi VII - Forecast and Analysis of the North American Automotive
                     Industry, Information taken from various OS AT estimates.

            Electronic components such as anti-lock brakes, electric windows, sun-
            and moon-roofs have become more prominent in vehicles.  This being
            so, producers of specific motor-vehicle  parts  and accessories will be
            replaced  or  transformed  from  manufacturers  of  mechanically
            engineered products to producers of electronic goods. By the year 2000,
            the  proportionate  value of electronic  components used in  the
            automotive industry is  expected to increase by more than 200 percent
            from 1987 levels.  A study by Volkswagen estimates that by the year
            2000, approximately 25 percent of a vehicle's manufacturing cost will be
            attributed to electronics.
III.A.4.d.    Manufacturer Initiatives

            In response to new standards and other environmental concerns, the
            Big Three have committed substantial resources to researching and
            developing new technology.  One Big Three joint research initiative,
            under the umbrella of the U.S. Council for  Automotive Research
            (USCAR), is Low Emission Paint Consortium (LEPC), which aims to
            develop new technologies for low emitting paint processes.  In July
            1995, the LEPC dedicated a new facility at Wixom, Michigan, to test
            powder paint and other technologies.  In addition to other research
            initiatives relating to production, USCAR sponsors several that relate
            to releases  from  the car.   One  example  is the Low Emissions
            Technologies Research  and  Development  Partnership.    This
            partnership  was  formed to  explore  ways  to reduce  automotive
            emissions by improving the performance of catalytic  converters and
            other  exhaust related  components,  and by  refining  the internal
            combustion process.  The partnership is also researching the feasibility
            of  alternative  fuel sources  such  as  ethanol/methanol  gasoline
            mixtures, liquid natural gas (LNG), and liquid petroleum gas.
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             To respond to perceived future demands  for electric cars, The Big
             Three, together with the U.S. Department of Energy (DOE), formed the
             U.S. Advanced Battery Consortium.  The goal of this consortium is to
             develop new battery storage technology.

             Another Big Three initiative is aimed at developing new materials for
             vehicles. The U.S. Automotive Materials Partnership will explore the
             use of materials such as polymer composites, aluminum, plastics, iron,
             steel, ceramics, and advanced metals.  The use of these products in
             automotive manufacturing is expected to lead to lighter/cleaner, and
             safer vehicles.  Automakers are also exploring the feasibility of
             developing aluminum vehicles.   The Aluminum  Association reports
             that a mid-size sedan using 1,000 pounds  of aluminum would be 25
             percent lighter and 20 percent more fuel efficient than a car composed
             entirely  of steel. The aluminum  content of cars has increased over the
             years from an average of 78 pounds in 1970 to 191 pounds today.

             An additional Big Three initiative - the Vehicle Recycling Partnership
             (VRP) -  is exploring techniques to increase  automotive  recycling.
             Although 94 percent of all vehicles are taken to recycling facilities, only
             75 percent of a vehicle's actual weight is claimed for recycling purposes.
             One area of particular interest in automotive recycling is plastics.  A
             recent industry study claims that as much as  one billion pounds of
             automotive plastics end  up in landfills.  New technologies such as
             "polymer  renewal"  recycling are being developed  to  recycle
             thermoplastic polyester, nylon, and acetal into  first-quality  polymers.
             Ford was the first North American automaker to recycle plastic parts
             from  previously built vehicles.  Ford and  GM also are making new
             parts from recycled  plastic bumpers.  According  to AAMA, the
             automakers are helping to stimulate  the market for used materials by
             incorporating recycled materials into the car.  For example, Ford is
             making:  protective seat covers  from recycled  plastic; splash shields
             from battery casings; grille opening reinforcements and luggage racks
             from  recycled soda  pop bottles; grilles from computer housings and
             telephones,  head lamp housings  from plastic water cooler bottles, and
             on a test basis, brake pedal pads from tires.

             Heightened competition has led the Big Three to initiate several jointly
             funded  research  products, including  the Partnership for  a New
             Generation of  Vehicles  (PNGV).    PNGV  is  designed to generate
             technologies  that will lead to  more environmentally  friendly  cars.
             PNGV  is joining Federal agencies, under the  leadership of the
             Commerce  Department's Technology Administration, to initiate the
             New Technology Initiative,  The goal of this initiative, introduced by
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            President Clinton in 1993, is to develop a new generation of vehicles
            with three times greater fuel efficiency.
IH.B.
Raw Material Inputs and Pollution Outputs

The many different production processes employed to manufacture a
motor vehicle require a vast amount of material input and generate
large amounts of waste.  The outputs resulting from the various stages
of production range  from  air emissions from foundry operations to
spent solvents from surface painting and finishing.

Exhibit 15 highlights the production processes, the material inputs, and
the various wastes resulting from these operations.  Process waste
pollutants are treated or neutralized before discharge.
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              Exhibit 15
                          Material Inputs/Pollution Outputs
Process Material Input Air Emissions
Process Wastes
(Waste Water &
Liquids
Other Wastes
Metal Shaping
Metal Cutting and/or
Forming
Heat Treating
Cutting oils,
degreasing and
cleaning solvents,
acids, and metails
Acid /alkaline
solutions (e.g.,
hydrochloric and
sulfuric acid),
cyanide salts, and
oils
Solvent wastes
(e.g., 1,1,1-
trichloroethane,
acetone, xylene,
toluene, etc.)

Acid /alkaline
wastes (e.g.,
hydrochloric,
sulfuric and nitric
acids) and waste
oils
Acid / alkaline
wastes, cyanide
wastes, and waste
oils
Metal wastes
(e.g., copper,
chromium and
nickel) and
solvent wastes
(e.g., 1,1,1-
trichloroethane,
acetone, xylene,
toluene, etc.)
Metal wastes
(e.g., copper,
chromium, and
nickel)
Surface Preparation
Solvent Cleaning
Pickling
Acid /alkaline
cleaners and solvents
Acid /alkaline
solutions
Solvent wastes
(e.g., acetone,
xylene, toluene,
etc.)

Acid /alkaline
wastes
Acid /alkaline
wastes
Ignitable wastes,
solvent wastes,
(e.g., 1,1,1-
trichloroethane,
acetone, xylene,
toluene, etc.) and
still bottoms
Metal wastes
Surface Finishing
Electroplating
Acid /alkaline
solutions, metal
bearing and cyanide
bearing solutions

Acid / alkaline
wastes, cyanide
wastes, plating
wastes, and
wastewaters
Metal wastes,
reactive wastes,
and solvent
wastes
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                                   Exhibit 15
                   Material Inputs/Pollution Outputs (cont'd)
II II
Process 11 Material Input Air Emissions
11 II ,,. 	 _
Process Wastes
(Waste Water &
Liquids
Other Wastes
Surface Finishing (contd)
Surface Finishing
Facility Cleanup
Solvents
Solvents
Solvent wastes
(e.g., 1,1,1-
trichloroethane,
acetone, xylene,
toluene, etc.)
Solvent wastes
(e.g., 1,1,1-
trichloroethane,
acetone, xylene,
toluene, etc.)


Metal paint
wastes, solvent
wastes, ignitable
paint wastes, and
still bottoms
Solvent wastes
and still bottoms
            The discussion of pollution outputs from, automotive manufacturing
            follows the  same  format  as the  discussion of the manufacturing
            process: foundry  operations;  metal  fabricating; metal  finishing;
            assembly; painting/coating; and dismantling/shredding.

ni.B.l.      Foundry Operations

            Iron  foundries  create  a  number of  wastes  which  may  pose
            environmental concerns.  Gas and particulate emissions  are a concern
            throughout the casting process. Dust created during sand preparation,
            molding, and shakeout is of concern due to the carcinogenic potential
            of  the  crystalline  silica  in the  sand.   Gases containing lead  and
            cadmium and other particulate  matter and  sulfur dioxide  are  also
            created during foundry operation, especially during the melting of the
            iron.

            The wastewaters generated during foundry operations may also be  of
            an  environmental concern.  Wastewaters are  generated primarily
            during slag quenching operations (water is sprayed on the slag to both
            cool it as well as pelletize it) and by the wet scrubbers employed as air
            pollution control devices connected to furnaces and sand and shakeout
            operations.  Due to the presence of cadmium and lead  in iron, these
            metals may both be present in wastewaters.

            Foundry operations also create many  waste  materials that meet the
            definition  of a  RCRA hazardous waste.  Of primary concern is the
            calcium carbide desulfurization slag created during the melting of the
            iron. This slag readily reacts with water to create acetylene gas, a trait
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            which causes it to be classified  as a D003 reactive hazardous waste.
            Other materials such as wastewater sludges and baghouse dust may
            also fail the toxicity characteristic for lead and cadmium and would
            then be classified as D008 and D006 respectively. Foundries may also
            use solvents for cleaning, which when spent, may be characterized as
            characteristic (ignitable or toxic)  or listed hazardous waste depending
            upon the formulations used.
III.B.2.      Metal Fabricating

            Each of the metal shaping processes  can result in wastes containing
            constituents  of concern (depending  on the metal being used).   In
            general, there are two categories of waste generated in metal shaping
            operations: scrap  metal and metalworking fluids/oils.

            Scrap metal may consist of metal removed from the original piece (e.g.,
            steel or aluminum). Quite often, scrap is reintroduced into the process
            as a feedstock.

            In  general, metalworking  fluids can be petroleum-based, oil-water
            emulsions, or synthetic emulsions that are applied to either the tool or
            the metal being  tooled  to   facilitate  the  shaping operation.
            Metalworking fluid is used to:

            •     Keep tool and workpiece temperature down and aid lubrication,
            •     Provide a good finish
            •     Wash away chips and metal debris
            •     Inhibit corrosion or surface oxidation.

            Metalworking fluids typically become contaminated and spent with
            extended use and reuse.   When  disposed, these oils  may contain
            constituents of concern, including metals (cadmium, chromium, and
            lead), and therefore must be tested to see if they are  considered a RCRA
            hazardous waste.  Many fluids may contain chemical additives such as
            chlorine, sulfur and phosphorus compounds, phenols,  cresols, and
            alkalines. In the past, such oils have commonly been mixed with used
            cleaning fluids  and  solvents (including  chlorinated solvents).  Air
            emissions may result through volatilization during storage, fugitive
            losses during use,  and direct ventilation of fumes.

            Surface  preparation  operations  generate wastes contaminated with
            solvents and/or metals depending on the type of  cleaning operation.
            Concentrated solvent-bearing wastes and  releases may arise from
            degreasing operations. Degreasing operations may result in solvent-
            bearing  wastewaters, air emissions, and materials in  solid form.
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            Solvents may be rinsed into wash  waters and/or spilled into floor
            drains.  Although  contamination  of the wastewater  is possible,
            procedures are in place to prevent such pollution in the first place.  Air
            emissions may result through volatilization during storage,  fugitive
            losses  during use, and direct ventilation of fumes. Any  solid wastes
            (e.g., wastewater treatment sludges, still bottoms, cleaning tank
            residues, machining fluid residues, etc.)  generated by the operation
            may be contaminated with solvents, some of which may meet RCRA
            hazardous waste listings F001 and F005.

            Chemical treatment operations can result in wastes that contain metals
            of concern.  Alkaline, acid, mechanical, and abrasive cleaning methods
            can generate waste streams such as spent cleaning media, wastewaters,
            and rinse waters. Such wastes consist primarily of the metal complexes
            or particles, the cleaning compound, contaminants from the metal
            surface, and water.  In many cases, chemical treatment operations are
            used in conjunction  with organic solvent cleaning systems.  As such,
            many of these wastes may be cross-contaminated with solvents.

            The  nature  of the  waste will depend upon the specific cleaning
            application  and manufacturing operation.   Wastes from  surface
            preparation operations may  contribute to  commingled waste streams
            such as wastewaters  discharged to centralized treatment.  Further, such
            operations  can result in direct releases such as fugitive emissions and
            easily segregated wastes such as cleaning tank residues.
ni.B.3.      Metal Finishing

            Surface finishing and related washing operations account for a large
            volume of wastes associated with automotive metal finishing.  Metal
            plating and related waste account for the largest volumes of metal (e.g.,
            cadmium, chromium, copper, lead, mercury, and nickel) and cyanide-
            bearing wastes.

            Electroplating operations  can result in solid and liquid wastestreams
            that contain constituents of concern.   Liquid wastes  result from
            workpiece rinses and process cleanup waters.  Most surface finishing
            (and many  surface  preparation) operations  result in  liquid
            wastestreams. Centralized wastewater treatment systems are common,
            and can  result in solid-phase wastewater treatment sludges.   In
            addition to these wastes, spent process solutions and quench bathes are
            discarded periodically when the concentrations of contaminants inhibit
            proper function of the solution or bath.  When discarded, process
            bathes usually  consist of solid- and liquid-phase wastes that may
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             contain high concentrations of the constituents of concern, especially
             cyanide (both free and complex).

             Related  operations,  including all non-painting  processes,  can
             contribute wastes including scrap metals, cleaning wastewaters,  and
             other solid materials.  The nature of these wastes will depend on the
             specific process, the nature of the workpiece, and the composition of
             materials used  in the process.
HI.B.4.      Motor Vehicle Assembly

            Due to advances in technology, well designed operating procedures,
            and the implementation of strategies to limit waste from assembly,
            little hazardous waste is generated during the actual assembly of an
            automobile  (with the  exception  of painting/finishing  which is
            discussed in the following section).

            The majority of wastes  generated during assembly are solid wastes
            resulting from parts packaging.  Parts packaging can be grouped into
            two categories - returnable and expendable.   Returnable packaging
            (containers) is shipped back to the  original suppliers once empty.  It
            includes such items as:  metal racks, metal skids, returnable bins, totes,
            and rigid plastic racks and dunnage.  Expendable packaging is used once
            and recycled, for the most part.  Examples include styrofoam. peanuts,
            wood skids, plastic, corrugated boxes, metal barding, and shrink-wrap.
            Advances  in packaging design,  changes in purchasing,  and  the
            elimination of unneeded materials have greatly reduced  the amount of
            expendable waste generated.

            Additional wastes  generated  from assembly operations  may  be
            attributed  to general plant operations, cleaning and maintenance, as
            well as the disposal of faulty equipment and parts.


III. B.5.      Motor Vehicle Painting/Finishing

            Many of the wastes generated during automotive  production are  the
            result of painting and finishing operations.  These operations result in
            air emissions as well as the generation of solid and liquid wastes.

            Air emissions, primarily VOCs, result from the painting and  finishing
            application processes  (paint storage, mixing, applications,  and drying)
            as well as  cleaning operations.  These emissions are composed mainly
            of organic  solvents which are used as carriers  for the paint.  Solvents
            are also used during cleanup processes to  clean spray equipment
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            between color changes, and to clean portions of the spray booth. The
            solvent  utilized during cleaning is generally  referred  as "purge
            solvent" and is often composed of a mixture of dimethyl-benzene,
            2-Pranone, 4-methyl-2-pentanone, butyl ester acetic acid, light aromatic
            solvent naphtha, ethyl benzene, hydrotreated heavy naphtha,
            2-butanone, toluene, and 1-butanol.

            Various solid and liquid wastes may be generated throughout painting
            operations and are usually the result of the following operations:

            •     Paint application - paint overspray caught by emissions control
                  devices (e.g., paint booth collection systems, ventilation filters,
                  etc.);

            •     Paint drying - ventilated emissions as paint carriers evaporate;

            •     Cleanup operations - cleaning of equipment and paint booth
                  area; and

            •     Disposal - discarding of leftover and unused paint as well as
                  containers used to hold paints, paint materials, and overspray.

            Solid and liquid wastes may also contain metals from paint pigments
            and organic  solvents.


III. C       Post Production Motor Vehicle Dismantling/Shredding

            Dismantling operations involve  both automotive fluids  and solids.
            The fluids,  such  as  engine oil, antifreeze,  and air  conditioning
            refrigerant, are recovered to the extent possible, reprocessed for reuse or
            sent to  energy recovery facilities. Many solid parts, such as the radiator
            and catalytic converter, contain  valuable  metal materials which  are
            removed  for recycling or reuse.  In addition, the dismantler will
            remove and recycle the battery, fuel tank, and tires to reduce shredder
            processing  concerns.    The  shredder  processes  the   remaining
            automotive hulk, along with other metallic goods (such as household
            appliances),  into ferrous materials, non-ferrous  materials, and shredder
            residue.  The residue is a heterogeneous mix that may include plastics,
            glass, textiles, metal fines, and dirt.  This  material is predominantly
            landfilled.

ffl. D.      Management of Chemicals in Wastestream

            The Pollution Prevention Act of 1990 (EPA) requires facilities to report
            information about the management of  TRI chemicals  in waste and
             efforts  made to  eliminate  or  reduce those quantities. These data have
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            been collected  annually in Section 8 of the TRI reporting Form  R
            beginning with the 1991 reporting year.  The data summarized below
            cover  the years  1992-1995  and  is  meant to  provide a  basic
            understanding of the quantities of waste handled by the industry, the
            methods typically used to manage this waste, and recent trends in these
            methods.  TRI waste management data can be used to assess trends in
            source  reduction within individual industries and facilities,  and for
            specific TRI chemicals. This information could then be used as a tool
            in  identifying  opportunities  for pollution prevention compliance
            assistance activities.

            While  the quantities  reported for  1992  and  1993 are  estimates  of
            quantities already managed, the quantities reported for 1994 and 1995
            are projections only.  The EPA requires these projections to  encourage
            facilities to consider future waste generation and source reduction of
            those quantities as well  as  movement up  the  waste  management
            hierarchy. Future-year estimates are not commitments  that facilities
            reporting under TRI are required to meet.

            Exhibit 16 shows that  the motor vehicle, bodies, parts and accessories
            industry  managed about  333 million pounds of production-related
            waste (total quantity of TRI chemicals  in the waste from  routine
            production operations) in 1993 (column B). Column C reveals that of
            this production-related waste, 66% was either transferred  off-site  or
            released to the environment.  Column C is calculated by dividing the
            total TRI transfers and releases by the total quantity of production-
            related  waste. In other words, about 33%  of the industry's TRI wastes
            were managed on-site  through recycling, energy recovery, or treatment
            as shown in columns D, E and F, respectively.  The majority of waste
            that is released or transferred off-site can be divided into portions that
            are recycled off-site, recovered for energy off-site,  or treated  off-site  as
            shown in columns G, H, and I, respectively.  The remaining  portion of
            the production-related wastes (25.7%), shown in column J, is either
            released to the  environment through direct discharges  to  air,  land,
            water, and underground injection, or it is disposed off-site.

            From the yearly data presented below it is apparent that the  portion of
            TRI wastes reported as recycled on-site has decreased and the portions
            treated  or managed through  energy recovery on-site have  increased
            between 1992 and 1995 (projected).
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                                     Exhibit 16
                 Source Reduction and Recycling Activity for SIC 37
A
Year
1992
1993
1994
1995
B
Production
Related
Waste
Volume
(106lbs.)
333
333
317
337
C
% Reported
As Released
and
Transferred
65%
66%
—
—
D | E
F
On-Site
%
Recycled
19.99%
18.42%
14.47%
15.60%
% Energy
Recovery
0.26%
0.23%
0.35%
0.28%
%
Treated
12.38%
14.75%
16.54%
15.81%
G 1 H
I
Off-Site
%
Recycled
36.54%
34.11%
34.96%
36.89%
% Energy
Recovery
3.99%
3.82%
3.97%
3.92%
%
Treated
2.27%
2.97%
3.36%
3.21%
J
Remaining
Releases
and
Disposal
25.84%
25.71%
26.36%
24.48%
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IV.
CHEMICAL RELEASE AND TRANSFER PROFILE

This section is designed to provide background information on the
pollutant releases that are reported by this industry. The best source of
comparative  pollutant  release  information  is  the Toxic  Release
Inventory System (TRI). Pursuant to the Emergency Planning  and
Community Right-to-Know  Act,  TRI includes self-reported  facility
release and  transfer data for over 600 toxic chemicals. Facilities within
SIC Codes 20-39 (manufacturing industries) that have more than 10
employees,  and that are above weight-based reporting thresholds are
required to report TRI  on-site releases  and off-site transfers.   The
information presented within the sector notebooks is  derived from the
most recently available (1993) TRI reporting year (which then included
316 chemicals), and focuses primarily on  the on-site releases reported
by each sector. Because TRI requires consistent reporting regardless of
sector, it is an excellent tool for drawing comparisons across industries.

Although this sector notebook does not present historical information
regarding TRI chemical releases over time, please note that in general,
toxic chemical releases have been declining. In fact, according to the
1993 Toxic Release Inventory Data Book, reported releases dropped by
42.7%  between 1988  and  1993.    Although  on-site  releases have
decreased, the total amount of reported toxic waste has not declined
because  the  amount  of toxic chemicals transferred off-site  has
increased. Transfers have increased from  3.7 billion pounds in 1991 to
4.7 billion pounds in 1993.  Better  management practices have led to
increases in off-site transfers of toxic chemicals  for recycling.  More
detailed  information  can be  obtained  from EPA's annual Toxics
Release  Inventory Public Data Release book  (which is available
through  the EPCRA Hotline at 1-800-535-0202),  or directly from the
Toxic Release Inventory System database (for user support call 202-260-
1531).

Wherever possible,  the sector  notebooks present  TRI data as  the
primary  indicator of chemical release within each industrial category.
TRI data provide the  type, amount,  and media receptor  of each
chemical released or transferred.  When other sources of pollutant
release data have been  obtained, these data have been included to
augment the TRI information.
TRI Data Limitations
            The reader should keep in mind the following limitations regarding
            TRI data.  Within some sectors, the majority of facilities are not subject
            to TRI reporting because  they are not considered  manufacturing
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            industries,  or because  they are below  TRI reporting  thresholds.
            Examples are the mining, dry cleaning, printing, and transportation
            equipment  cleaning sectors.  For these sectors, release information
            from other sources has been included.

            The reader should also be  aware that TRI "pounds  released" data
            presented within  the notebooks is not equivalent to a "risk" ranking
            for each industry. Weighting each pound of release equally does not
            factor  in the relative toxicity of each chemical that is released.  The
            Agency is  in the process  of developing  an  approach to  assign
            toxicological weightings  to  each  chemical released so that  one can
            differentiate between pollutants with significant differences in toxicity.
            As a  preliminary indicator of the environmental impact  of the
            industry's  most commonly released chemicals,  the notebook  briefly
            summarizes the toxicological properties of the top five chemicals (by
            weight) reported by each industry.

Definitions Associated With Section IV Data Tables

General Definitions

            SIC Code  - the Standard Industrial Classification (SIC) is a statistical
            classification standard used for all establishment-based Federal
            economic statistics.  The SIC codes  facilitate  comparisons  between
            facility and industry data.

            TRI Facilities — are manufacturing facilities that have 10 or more full-
            time employees  and are above established  chemical  throughput
            thresholds.   Manufacturing  facilities are  defined  as facilities  in
            Standard Industrial Classification primary  codes  20-39. Facilities must
            submit estimates  for all chemicals that are on  the EPA's defined list
            and are above throughput thresholds.

Data Table Column Heading Definitions

            The following definitions are based upon   standard  definitions
            developed by EPA's Toxic Release Inventory Program.  The categories
            below represent the possible pollutant destinations that  can  be
            reported.


            RELEASES — are an  on-site discharge  of a  toxic chemical to the
            environment. This includes emissions to  the air, discharges to bodies
            of water, releases at the facility to land, as well as contained disposal
            into underground injection wells.
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             Releases to Air (Point and Fugitive Air Emissions) — Include all air
             emissions from industry activity.   Point emissions occur through
             confined air streams as  found  in stacks, ducts, or  pipes.  Fugitive
             emissions include losses  from equipment leaks, or evaporative losses
             from impoundments, spills, or leaks.

             Releases to Water (Surface Water Discharges) - encompass any releases
             going directly to streams, rivers, lakes, oceans, or other bodies of water.
             Any estimates for stormwater runoff  and non-point losses must also be
             included.

             Releases to Land -- includes disposal of waste to  on-site landfills, waste
             that is land treated or incorporated  into soil, surface impoundments,
             spills, leaks,  or waste piles.  These  activities must occur within the
             facility's boundaries for inclusion in this  category.

             Underground  Injection — is a contained release of  a  fluid into a
             subsurface well for the purpose of waste disposal.

             TRANSFERS — is a transfer of toxic chemicals in wastes to a facility that
             is geographically or physically  separate from  the facility reporting
             under TRI.   The quantities  reported represent a  movement of the
             chemical away from the reporting facility. Except for off-site transfers
             for disposal, these quantities  do not  necessarily represent  entry of the
             chemical into the environment.

             Transfers to POTWs — are wastewaters transferred through pipes or
             sewers to a publicly owned treatments works (POTW). Treatment and
             chemical removal depend  on the chemical's nature and  treatment
             methods used.  Chemicals not treated or destroyed by the POTW are
             generally released to surface waters or landfilled within the sludge.

             Transfers  to  Recycling  -- are  sent  off-site  for the purposes  of
             regenerating or recovering  still  valuable materials.    Once  these
             chemicals have been recycled, they may  be returned to the originating
             facility or sold commercially.

             Transfers  to Energy Recovery — are  wastes combusted off-site in
             industrial furnaces for energy recovery.  Treatment of a chemical by
             incineration is not considered to be energy recovery.

             Transfers  to Treatment  — are  wastes moved  off-site for either
             neutralization,  incineration, biological destruction, or physical
             separation.  In some cases, the chemicals are not destroyed but prepared
             for further waste management.
September 1995
49
SIC Code 37

-------
Motor Vehicle Assembly Industry
                         Sector Notebook Project
            Transfers to Disposal — are wastes taken to another facility for disposal
            generally as a release to land or as an injection underground.
IV.A.       EPA Toxic Release Inventory for the Motor Vehicles and Motor
            Vehicle Equipment Industry

            Exhibits 17-21 illustrate the TRI releases  and transfers for the motor
            vehicles and motor vehicle equipment industry (SIC 37).   Exhibit 18
            shows the top TRI  releasing transportation equipment facilities.  As
            shown in Exhibit 19, the majority of TRI reporting facilities are located
            in Michigan,  Ohio, Indiana,  Illinois, and Tennessee.  As mentioned
            earlier,  these States, with the exception of Tennessee, have historically
            been the focal point of automobile manufacturing.

            For the industry as a  whole, solvents such as toluene, xylene, methyl
            ethyl ketone, and acetone, comprise the largest number of TRI releases.
            The large of quantity of solvent release, both fugitive and point source
            can be attributed to the solvent-intensive finishing processes employed
            by the  industry.  In addition to being used to clean  equipment and
            metal parts, solvents  are a component found in many of  the coating
            and  finishes  applied  to automobile  during  the  assembly  and
            painting/finishing operations.

            The TRI  database contains a detailed compilation of self-reported,
            facility-specific chemical releases.  The top reporting facilities for this
            sector are listed below. Facilities that have reported only the SIC codes
            covered under this notebook appear  in Exhibit 17. Exhibit 18 contains
            additional facilities that have reported the  SIC code covered within this
            report,  and one or more SIC codes that are not within the scope of this
            notebook.  Therefore,  Exhibit 18  includes  facilities that  conduct
            multiple operations — some that are under the scope of this notebook,
            and some that are not.  Currently, the facility-level  data do not allow
            pollutant releases to be broken apart by industrial process.
SIC Code 37
50
September 1995

-------
Sector Notebook Project
                   Motor Vehicle Assembly Industry
                                       Exhibit 17
             Top 10 TRI Releasing Auto and Auto Parts Facilities (SIC 37)
Rank
1
2
3
4
5
6
7
8
9
10
Total TRI
Releases in
Pounds
2,689,968
2,519,315
1,820,840
1,733,637
1,693,900
1,669,603
1,633,125
1,602,429
1,523,625
1,490,075
Facility Name
Ford Motor Co., Kansas City Assembly Plant
Nissan Motor Mfg. Corp., USA Corp.
Ford Motor Co., St. Louis Assembly Plant
Ford Motor Co., Michigan Truck Plant
CMC NATP Moraine Assembly Plant
Ford Electronics & Refrigeration Corp.
Cadillac Luxury Car Div., Detroit Hantranck
Assembly
Ford Motor Co., Louisville Assembly Plant
North American Truck Platform, Pontiac E
Assembly
Purolator Prods, Inc.
City
Claycomo
Smyrna
Hazelwood
Wayne
Moraine
Connersville
Detroit
Louisville
Pontiac
Fayetteville
State
MO
TN
MO
MI
OH
IN
MI
KY
MI
NC
                      Source:  U.S. EPA, Toxics Release Inventory Database, 1993.

                                       Exhibit 18
         Top 10 TRI Releasing Transportation Equipment Facilities (SIC 37)
SIC Codes
3711, 3751
3711, 3713
3711
3711
3711
3714, 3231
3713
3714
3711
3711
Total TRI
Releases in.
Pounds
3,438,305
2,689,968
2,519,315
1,820,840
1,733,637
1,727,400
1,693,900
1,669,603
1,633,125
1,602,429
Facility Name
Honda of America Mfg., Inc.
Ford Motor Co., Kansas City
Assembly Plant
Nissan Motor Mfg. Corp.,
USA Corp.
Ford Motor Co., St. Louis
Assembly Plant
Ford Motor Co., Michigan
Truck Plant
Harman Automotive, Inc.,
CMC NATP Moraine
Assembly Plant
Ford Electronics &
Refrigeration Corp.
Cadillac Luxury Car Div.,
Detroit Hantranck Assembly
Ford Motor Co., Louisville
Assembly Plant
City
Marysville
Claycono
Smyrna
Hazelwood
Wayne
Bolivar
Moraine
Commersville
Detroit
Louisville
State
OH
ND
TN
MO
MI
TN
OH
IN
MI
KY
                     Source: U.S. EPA, Toxics Release Inventory Database, 1993.

Note:  Being included on these lists does not mean that the release is associated with non-
       compliance with environmental laws.
September 1995
51
SIC Code 37

-------
Motor Vehicle Assembly Industry
Sector Notebook Project
                                    Exhibit 19
           TRI Reporting Auto and Auto Farts Facilities (SIC 37) by State
State
AL
AR
AZ
CA
CO
CT
DE
FL
GA
IA
IL
IN
KS
KY
LA
MA
MD
ME
MI
MN
MO
MS
Number of
Facilities
11
10
3
21
1
4
2
6
14
12
31
63
9
24
1
2
4
1
101
7
22
6

Source: U.S. EPA, Toxics Release
State
NC
ND
NE
NH
NJ
NV
NY
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VA
WA
WI

Number of
Facilities
28
1
5
1
5
1
15
76
5
3
20
1
1
12
1
33
12
5
12
6
11

nventory Database, 1993.
                                     Exhibit 20
 Releases for Auto and Auto Parts Facilities (SIC 37) in TRI, by Number of Facilities
                         (Releases reported in pounds/year)
Chemical Name
Toluene
SulfuricAcid
Xylene
(Mixed Isomers) 	
Copper 	
Methyl Ethyl Ketone
Acetone
Glycol Ethers 	
Chromium

Ethylene Glycol 	
Nickel
Zinc Compounds
Manganese 	

# Facilities
Reporting
Chemical
154
152
150
142
125
107
105
99
96
95
95
95
85
85
Fugitive Air
1165126
12783
1416695
3423
1111122
1149162
689599
16632
316128
33573
7746
31398
4680
4826
Point Air
5507143
46013
21584687
9331
3619253
3422729
6957693
9124
2297245
163221
2718
5906
4710
13413
Water
Discharges
13416
13000
23
1261
13400
0
7682
777
0
1052
495
3564
614
0
under-
ground
Inject-
ion
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
3978
0
0
4056
0
0
250
10
0
415
2233
19528
0
0
Total
Releases
6689663
71796
23001405
18071
4743775
4571891

26543
2613373
198261
13192
60396
10004
18239
Releases
per
Facility
43439
472
153343
127
37950

72907
268

2087
139
636
118
215
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
 SIC Code 37
                                      52
      September 1995

-------
Sector Notebook Project
                  Motor Vehicle Assembly Industry
                                  Exhibit 20 (cont'd)
 Releases for Auto and Auto Parts Facilities (SIC 37) in TRI, by Number of Facilities
                          (Releases reported in pounds/year)
Chemical Name
Hydrochloric Acid
N-Butyl Alcohol
Methyl Isobutyl Ketone
Barium Compounds
1,1,1 -Trichloroethane
Dichlorodifluoromethane
Ethylbenzene
Lead
Benzene
Methylenebis
(Phenylisocyanate)
Nickel Compounds
Nitric Acid
Manganese Compounds
1 ,2,4-Trimethylbenzene
Chromium Compounds
Lead Compounds
Styrene
Ammonia
Copper Compounds
Trichloroethylene
Dichloromethane
Asbestos (Friable)
Diethanolamine
Phenol
Di(2-Ethylhexyl) Phthalate
Formaldehyde
Tetrachloroethylene
Freon 113
Aluminum (Fume Or Dust)
Cyclohexane
Cobalt
Methyl Tert-Butyl Ether
Cumene
Chlorine
Zinc (Fume Or Dust)
Antimony Compounds
Butyl Benzyl Phthalate
Cyanide Compounds
Hydrogen Fluoride
Propylene
Sec-Butyl Alcohol
Toluene-2,4-Diisocyanate
Toluene-2,6-Diisocyanate
Bis(2-Ethylhexyl) Adipate
Naphthalene
Phosphorus
(Yellow Or White)
Trichlorofluoromethane
# Facilities
Reporting
Chemical
83
78
73
71
67
56
56
53
49
48
48
48
45
43
37
34
33
32
29
29
24
17
16
16
14
14
13
12
10
10
9
9
7
6
6
4
4
4
4
4
4
4
. 4
3
3
3
3
Fugitive Air
6480
247976
657257
16614
1688511
206893
195835
712
15678
7384
760
3857
1541
84346
877
1034
669058
6788
1255
935372
402279
71
505
25785
250
12515
69959
160695
6130
1110
512
6627
5841
13816
979
0
0
5
6
350
15305
1652
490
0
702
15
500
Point Air
911854
4852404
5664383
16858
1451218
5012
2332692
4107
10293
2816
2515
4147
2106
1206168
3295
1455
787529
139153
2487
1834267
410601
2144
4405
268220
41665
177775
293383
73286
800971
1321
269
4860
67234
278
182
0
10792
279
345
110
42250
5105
1502
90052
2926
0
250
Water
Discharges
0
0
0
602
0
0
0
559
0
0
510
0
1320
5
1046
752
0
30
284
0
0
0
0
0
0
0
0
0
0
0
250
0
0
0
43
0
0
3
0
0
764
0
0
0
0
0
0
Under-
ground
Inject-
ion
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
0
0
0
1252720
0
0
0
0
0
0
190
0
1800
0
0
0
0
0
0
0
0
0
0
50906
0
15115
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Total
Releases
918334
5100380
6321640
1286794
3139729
211905
2528527
5378
25971
10200
3975
8004
6767
1290519
5218
3241
1456587
145971
4026
2769639
812880
2215
4910
344911
41915
205405
363342
233981
807101
2431
1031
11487
73075
14094
1204
0
10792
287
351
460
58319
6757
1992
90052
3628
15
750
Average
Releases
per
Facility
11064
65389
86598
18124
46862
3784
45152
101
530
213
83
167
150
30012
141
95
44139
4562
139
95505
33870
130
307
21557
2994
14672
27949
19498
80710
243
115
1276
10439
2349
201
0
2698
72
88
115
14580
1689
498
30017
1209
5
250
                      Source:  U.S. EPA, Toxics Release Inventory Database, 1993.
September 1995
53
SIC Code 37

-------
Motor Vehicle Assembly Industry
Sector Notebook Project
                                Exhibit 20 (cont'd)
 Releases for Auto and Auto Parts Facilities (SIC 37) in TRI, by Number of Facilities
                        (Releases reported in pounds/year)
Chemical Name
2-Ethoxyethanol
4,4'-
Isopropylidenediphenol
Chlorobenzene
Cobalt Compounds
Toluenediisocyanate
(Mixed Isomers)
1 ,4-Dioxane
Aluminum Oxide
(Fibrous Form)
Antimony 	
Butyl Acrylate
Carbon Tetrachloride
Cumene Hydroperoxide
Dibutyl Phthalate
Dicthyl Phthalate
Ethylene Oxide
Isopropyl Alcohol
(Manufacturing) 	
M-Xylene 	
O-Xylene
Quinone 	

# Facilities
Reporting
Chemical
3
3
2
2
2
2
1
1
1
1
1
1






....
Fugitive Air
3920
0
12911
250
255
4000
0
0
880
275509
250
2
750
0
750
0
0
0
11,736,697
Point Air
24300
5
3230
250
5
250
0
0
9400
826526
5484
0
60000
0
0
8998
0
0
66,116,598
Water
Discharges
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
61,452
Under-
ground
Inject io
n
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
0
0
0
0
0
0
0
0
0
0
0
0
250
0
0
0
0
0
1,351,451
Total
Releases
28220
5
16141
500
260
4250
0
0
10280
1102035
5734
2
61000
0
750
8998
0
0
79,266,198
Releases
per
Facility
9407
2
8071
250
130
2125
0
0
10280
1102035
5734
2
61000
0
750
8998
0
0
....
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
                                    Exhibit 21
 Transfers for Auto and Auto Parts Facilities (SIC 37) in TRI, by Number of Facilities
                        (Transfers reported in pounds/year)
Chemical Name
Toluene
Sulfuric Acid
Xylene (Mixed Isomers)
Copper 	
Methyl Ethyl Ketone

Glycol Ethers 	
Chromium
Mcthanol
Ethylene Glycol 	
Nickel

# Facilities
Reporting
Chemical
154
152
150
142
125
107
105
99
96
95
95
95
POTW
Discharges
954
22
1801
2729
1899
17402
2652452
3915
6312
169438
4313
35127
Disposal
21709
710
192692
260467
15933
10415
45884
446383
31276
17890
133121
750093
Recycling
2540713
4800000
14495581
23058138
4839058
4237359
943328
7966830
334497
210618
3730134
2502350
Treatment
83965
1067714
183599
26472
92419
76693
228100
46368
41293
391126
6971
272103
Energy
Recovery
1739857
0
4256914
267
1153386
1534387
498232
36
285819
306410
5
24930
Total
Transfers
4387448
5868446
19130587
23348073
6102695
5876256
4367996
8463532
699197
1095482
3874544
3584603
Transfers
per
Facility_
28490
38608

164423
48822
54918
41600
85490
7283
11531
40785
37733
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
 SIC Code 37
                                      54
      September 1995

-------
 Sector Notebook Project
                   Motor Vehicle Assembly Industry
                                   Exhibit 21 (cont'd)
  Transfers for Auto and Auto Parts Facilities (SIC 37) in TRI, by Number of Facilities
                          (Transfers reported in pounds/year)
Chemical Name
Manganese
Phosphoric Acid
Hydrochloric Acid
N-Butyl Alcohol
Methyl Isobutyl Ketone
Barium Compounds
1,1,1 -Trichloroethane
Dichlorodifluoro-
methane
Ethylbenzene
Lead
Benzene
Methylenebis
(Phenylisocyanate)
Nickel Compounds
Nitric Acid
Manganese Compounds
1,2,4-
Trimethylbenzene
Chromium Compounds
Lead Compounds
Styrene
Ammonia
Copper Compounds
Trichloroethylene
Dichloromethane
Asbestos (Friable)
Diethanolamine
Phenol
Di(2-Ethylhexyl)
Phthalate
Formaldehyde
Tetrachloroethylene
Freon 113
Aluminum (Fume Or
Dust)
Cyclohexane
Cobalt
Methyl Tert-Butyl Ether
Cumene
Chlorine
Zinc (Fume Or Dust)
Antimony Compounds
Butyl Benzyl Phthalate
Cyanide Compounds
Hydrogen Fluoride
Propylene
if facilities
Reporting
Chemical
85
85
83
78
73
71
67
56
56
53
49
48
48
48
45
43
37
34
33
32
29
29
24
17
16
16
14
14
13
12
10
10
9
9
7
6
6
4
4
4
4
4
POTW
Discharges
4167
37205
13855
1885
28787
10860
867
0
796
857
500
5
18060
5
17892
26
4349
7068
0
19330
2913
565
9
0
103572
3366
0
937
1
0
0
0
5
0
0
21313
48
1
0
62
0
0
Disposal
232071
8433C
20710
43422
5675
3202950
7610
225
3491
62803
22
36295
162808
710
154918
40
409788
90442
364260
0
183868
5400
0
1871982
555
187182
8120
15353
2772
0
44377

3865
0
0
0
99338
3412
2894
0
0
0
Recycling
4698891
275
0
1017184
8971374
55850
1113333
45932
2153976
2586617
4215
105801
402186
0
2660652
323150
637987
824896
1574
0
18303568
372186
128604
0
105993
0
0
3602
166884
155501
731959
850
231524
0
2871
250
531602
2400
0
3400
0
0
Treatment
1689
75444
30375
318581
67282
288758
24921
132
5362
59112
578
15356
82076
26895
35886
6012
33227
52401
15750
210
37197
71991
80182
250
139
4132
2500
301
32861
14524
0
250
0
67
2

51858
513
1477
38
149
0
Energy
Recovery
2
0
0
372643
1124723
2646
65309
0
687526
284
5423
29161
8
0
250
182922
1651
675
41199
258
630
77401
261284
0
36200
7911
10925
3076
15000
25111
0
1550
0
5849
24829

250
0
0
0
0
0
Total
Transfers
4936820
197254
64940
1753715
10197841
3561064
1212040
46289
2851151
2709673
10738
186618
665138
27610
2869598
512150
1087002
975482
422783
19798
18528176
587543
470079
1872232
246459
202591
21545
23269
217518
195136
776336
2650
235394
5916
27702
21563
683096
6326
4371
3500
149
0
Average
Transfers
per
58080
2321
782
22484
139696
50156
18090
827
50913
51126
219
3888
13857
575
63769
11910
29378
28691
12812
619
638903
20260
19587
110131
15404
12662
1539
1662
16732
16261
77634
265
26155
657
3957
3594
113849
1582
1093
875
37
0
                      bource: U.i>. tFA, 1 oxics Release Inventory Database, 1993.
September 1995
55
SIC Code 37

-------
Motor Vehicle Assembly Industry
Sector Notebook Project
                               Exhibit 21 (cont'd)
 Transfers for Auto and Auto Parts Facilities (SIC 37) in TRI, by Number of Facilities
                       (Transfers reported in pounds/year)
Chemical Name
Sec-Butyl Alcohol
Toluenc-2,4-
Diisocyanate 	
Tolucnc-2,6-
Bis(2-Ethylhexyl)
Adipatc 	
Naphthalene
Phosphorus
(Yellow Or White)
Trichlorofluoromethane
2-Ethoxvethanol
4,4'-Isopropylidenedi-
phcnol
Chlorobenzene
Cobalt Compounds
Toluenediisocyanate
(Mixed Isomers) 	
I.4-Dioxane
Aluminum Oxide
(Fibrous Form)
Antimony 	
Butyl Acrylate 	
Carbon Tetrachloride
Cumcne Hydroperoxide
Dibutyl Phthalate
Dicthvl Phthalate
Ethylenc Oxide 	
Isopropyl Alcohol
M-Xylene 	
O-Xvlene
Quinone 	

# Facilities
Reporting
Chemical
4
4
4
3
3
3
3
3
3
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
....
POTW
Discharges
0
0
0
0
0
0
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3,195,675
Disposal
5627
3900
980
1540
0
250
2702
0
20401
0
250
0
0
19002
5
0
0
0
0
0
1600
250
0
0
0
9,294,768
Recycling
0
32300
8100
0
0
80800
0
0
0
0
5570
0
8140
0
56600
11
0
0
0
0

0
0
0
0
116,195,214
Treatment
745
0
0
0
0
0
1587
0
0
0
5
0
0
0
5
3
0
0
0
2375
300
0
0
0
0
3,960,321
Energy
Recovery
7
0
0
0
653
0
0
7200
0
75
0
0
1225
0
0
602
0
516
173
0
0
0
2236
9575
0
12,807,201
Total
Transfers
6379
36200
9080
1540
653
81050
4289
7200
20401

5830
0
9365
19002
56610
616
0
516
173
2375
1900
250
2236
9575
0
145,513,429
Transfers
per
Facility
1595
9050
2270
513
218
27017
1430
2400
6800
38
2915
0
4683
19002
56610
616
0
516
173
2375
1900
250
2236
9575
0
-"••
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
 IV.B.  Summary of Selected Chemicals Released

             The  following is  a synopsis of  current scientific toxicity and fate
             information for the top chemicals  (by weight) that facilities within this
             sector self-reported as released to the environment based upon 1993
             TRI data.  Because this section is based upon self-reported release data,
             it does not attempt to provide  information on management practices
             employed  by the sector to reduce the release  of  these chemicals.
             Information regarding pollutant release reductions over time  may be
             available from EPA's TRI and  33/50 programs, or directly from the
             industrial  trade associations  that are  listed  in  Section IX  of this
             document.  Since these descriptions are cursory, please consult the
 SIC Code 37
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Acetone
             sources referenced below for a more detailed description of both the
             chemicals described  in this section, and the chemicals that appear on
             the full list of TRI chemicals appearing in Section IV.A.

             The brief descriptions provided below were taken from the 1993 Toxics
             Release Inventory Public Data Release (EPA, 1994), and the Hazardous
             Substances  Data Bank (HSDB),  accessed via  TOXNET.   The  brief
             descriptions  provided below were taken from the 1993 Toxics Release
             Inventory Public  Data Release (EPA, 1994), the  Hazardous  Substances
             Data Bank (HSDB), and the Integrated Risk Information System (IRIS),
             both accessed via TOXNET1.  The information contained below is based
             upon exposure assumptions that have been conducted using standard
             scientific procedures.  The effects listed below must be taken in context
             of these exposure assumptions  that are more fully explained within the
             full chemical profiles in HSDB.

             The top  TRI  release for  the motor vehicles and  motor vehicle
             equipment industry (SIC 37) as a whole are as follows: toluene, xylene,
             methyl ethyl ketone, acetone, glycol ethers,  1,1,1,-trichloroethane,
             styrene,  trichloroethylene,   dichloromethane,   and   methanol.
             Summaries for several of these chemicals are provided below.
             Toxicity.  Acetone is irritating to the eyes, nose, and throat. Symptoms
             of exposure to large  quantities  of  acetone may include headache,
             unsteadiness,  confusion,  lassitude,  drowsiness,  vomiting,  and
             respiratory depression.

             Reactions of acetone (see environmental fate) in the lower atmosphere
             contribute to the formation  of  ground-level ozone.   Ozone (a major
             component of urban smog) can affect the respiratory system, especially
             in sensitive individuals such as asthmatics or allergy sufferers.
•*• TOXNET is a computer system run by the National Library of Medicine that includes a number of
toxicological databases managed by EPA, National Cancer Institute, and the National Institute for
Occupational Safety and Health. For more information on TOXNET, contact the TOXNET help line at
1-800-231-3766. Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research
Information System), DART (Developmental and Reproductive Toxicity Database), DBIR (Directory of
Biotechnology Information Resources), EMICBACK (Environmental Mutagen Information Center
Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous Substances Data Bank), IRIS
(Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical Substances), and
TRI (Toxic Chemical Release Inventory). HSDB contains chemical-specific information on
manufacturing and use, chemical and physical properties, safety and handling, toxicity and biomedical
effects, pharmacology, environmental fate and exposure potential, exposure standards and regulations,
monitoring and analysis methods, and additional references.
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            Carcinogenicity. There is currently no evidence to suggest that this
            chemical is carcinogenic.

            Environmental Fate. If released into water, acetone will be degraded by
            microorganisms or will evaporate into the atmosphere.  Degradation
            by microorganisms will be the primary removal mechanism.

            Acetone is highly volatile, and once it reaches  the troposphere (lower
            atmosphere),  it  will react with other gases, contributing  to  the
            formation  of  ground-level ozone and other air pollutants.  EPA is
            reevaluating acetone's reactivity in the lower atmosphere to determine
            whether this contribution  is significant.

            Physical  Properties. Acetone is a volatile and  flammable organic
            chemical.

            Note:  Acetone was removed from the  list of TRI chemicals on June 16,
            1995 (60 FR 31643) and will not be reported for 1994 or subsequent years.
Glvcol Ethers
            Due to data limitations, data on diethylene glycol (glycol ether) are used
            to represent all glycol ethers.

            Toxicity.   Diethylene glycol  is only a  hazard to human health  if
            concentrated  vapors  are generated  through  heating or vigorous
            agitation or if appreciable  skin contact or ingestion occurs over an
            extended period of time.  Under normal occupational and ambient
            exposures, diethylene glycol is low in oral toxicity, is not irritating to
            the eyes or skin, is not readily absorbed through the skin, and has a low
            vapor pressure so that toxic concentrations of the vapor can not occur
            in the air at room temperatures.

            At high levels of exposure,  diethylene glycol causes central nervous
            depression  and liver  and kidney damage.   Symptoms of moderate
            diethylene  glycol  poisoning  include  nausea, vomiting, headache,
            diarrhea, abdominal pain, and damage  to  the  pulmonary  and
            cardiovascular systems.  Sulfanilamide in diethylene glycol was once
            used therapeutically against bacterial infection; it was withdrawn from
            the market after causing over 100 deaths from acute kidney failure.

            Carcinogenicity.  There is currently no evidence  to  suggest that this
            chemical is  carcinogenic.

            Environmental Fate.  Diethylene glycol is a water-soluble, volatile
            organic chemical.  It  may enter the environment in liquid form via
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             petrochemical plant effluents or as an unburned gas from combustion
             sources.   Diethylene glycol typically does not occur  in  sufficient
             concentrations to pose a hazard to human health.

 Methanol

             Toxicity.  Methanol is readily absorbed from the gastrointestinal tract
             and the respiratory tract, and is toxic to humans in moderate to high
             doses.  In the body, methanol is  converted into  formaldehyde  and
             formic acid. Methanol is excreted as formic acid.  Observed toxic effects
             at high dose levels generally include central nervous  system damage
             and blindness.  Long-term exposure  to high levels of methanol via
             inhalation cause liver and blood damage in animals.

             Ecologically, methanol is expected to have low toxicity to aquatic
             organisms.  Concentrations lethal to half  the  organisms  of a  test
             population are  expected to exceed 1 mg methanol per liter water.
             Methanol is not likely to persist in water or to bioaccumulate in aquatic
             organisms.

             Carcinogenicity. There is currently no evidence to suggest that  this
             chemical is carcinogenic.

             Environmental Fate. Liquid methanol is likely to evaporate when left
             exposed.   Methanol reacts  in air to produce formaldehyde which
             contributes to the formation of air pollutants.  In the atmosphere it can
             react with other atmospheric chemicals or  be washed out by rain.
             Methanol is readily degraded by microorganisms in soils and surface
             waters.

             Physical Properties.  Methanol is highly flammable.

Methylene Chloride (Dichloromethane)

             Toxicity.  Short-term exposure to dichloromethane (DCM)  is associated
             with  central nervous system effects, including headache, giddiness,
             stupor,  irritability,  and numbness  and tingling  in the limbs.  More
             severe neurological effects  are reported from longer-term exposure,
             apparently due to increased carbon monoxide in the blood  from the
            break down of DCM. Contact with DCM causes  irritation of  the eyes,
             skin, and respiratory tract.

            Occupational exposure to DCM has  also been linked to increased
            incidence of spontaneous abortions in women.  Acute damage to the
            eyes and upper respiratory tract, unconsciousness, and death were
            reported in workers exposed to high concentrations of DCM. Phosgene
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            (a degradation product of DCM) poisoning has been reported to occur
            in several cases where DCM was used in the presence of an open fire.

            Populations at special risk from exposure to DCM include obese people
            (due to  accumulation of DCM in fat), and people  with impaired
            cardiovascular systems.

            Carcinogenicity. DCM is a probable human carcinogen via both oral
            and inhalation exposure, based  on inadequate  human data  and
            sufficient evidence in animals.

            Environmental Fate.  When spilled on land, DCM is rapidly lost from
            the soil surface through volatilization.  The remainder leaches  through
            the subsoil into the groundwater.

            Biodegradation is possible in natural waters but will probably be very-
            slow  compared  with evaporation.    Little  is  known about
            bioconcentration in aquatic organisms or adsorption to sediments  but
            these are not likely to be significant  processes.  Hydrolysis is not an
            important process under normal environmental conditions.

            DCM released into the atmosphere degrades via contact  with other
            gases with a half-life of several  months.   A  small  fraction of  the
            chemical diffuses to the stratosphere where it rapidly degrades through
            exposure to ultraviolet radiation and contact with chlorine ions. Being
            a moderately soluble chemical, DCM is expected to partially return to
            earth in rain.
Methvl Ethvl Ketone
            Toxicity. Breathing moderate amounts of methyl ethyl ketone (MEK)
            for short periods of time can cause adverse effects on  the nervous
            system ranging from headaches, dizziness, nausea, and numbness in
            the fingers and toes to unconsciousness.  Its vapors are irritating to the
            skin, eyes,  nose, and throat and can damage  the eyes.  Repeated
            exposure to moderate to high amounts may cause liver and  kidney
            effects.

            Carcinogenicitv. No agreement exists over the carcinogenicity of MEK.
            One source believes MEK is a possible carcinogen in humans based on
            limited animal evidence.   Other  sources believe  that there  is
            insufficient evidence  to  make  any  statements  about possible
            carcinogenicity.

            Environmental Fate.  Most of the MEK released to the  environment
            will end up in the atmosphere.   MEK can contribute to the formation
 SIC Code 37
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Toluene
            of air pollutants in the lower atmosphere.  It can be  degraded by
            microorganisms living in water and soil.

            Physical Properties. Methyl ethyl ketone is a flammable liquid.
            Toxicity. Inhalation or ingestion of toluene can cause headaches,
            confusion, weakness, and memory loss.  Toluene may also affect the
            way the kidneys and liver function.

            Reactions of  toluene (see  environmental  fate) in the atmosphere
            contribute to the formation of ozone in the lower atmosphere.  Ozone
            can affect the respiratory system, especially in sensitive individuals
            such as asthma or allergy sufferers.

            Some studies have shown that unborn  animals were harmed when
            high levels  of toluene were inhaled by their mothers, although the
            same effects were not seen when the mothers were fed large quantities
            of toluene.  Note that these  results may reflect similar difficulties in
            humans.

            Carcinogenicity. There is currently no evidence to suggest that this
            chemical is carcinogenic.

            Environmental Fate.  The majority of releases of toluene to land and
            water   will  evaporate.    Toluene  may  also  be  degraded  by
            microorganisms.  Once volatized, toluene in the lower atmosphere
            will  react with  other atmospheric components contributing to  the
            formation of ground-level ozone and other air  pollutants.

            Physical Properties. Toluene is a volatile organic chemical.

1,1,1-Trichloroethane

            Toxicity. Repeated contact of 1,1,1-trichloroethane (TCE) with skin may
            cause serious skin cracking and infection.   Vapors cause a slight
            smarting  of the eyes  or respiratory  system if present  in  high
            concentrations.

            Exposure  to high concentrations  of TCE causes reversible mild liver
            and  kidney dysfunction, central nervous  system  depression,  gait
            disturbances, stupor,  coma, respiratory depression, and even death.
            Exposure  to lower  concentrations of TCE leads to light-headedness,
            throat  irritation,  headache,  disequilibrium, impaired  coordination,
            drowsiness, convulsions and mild changes in perception.
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            Carcinogenicity. There is currently no evidence to suggest that this
            chemical is carcinogenic.

            Environmental  Fate.  Releases of TCE to surface water or land will
            almost entirely  volatilize.  Releases to air may be transported long
            distances and may partially return to earth in  rain.  In the lower
            atmosphere, TCE degrades very slowly by photooxidation and slowly
            diffuses to the upper atmosphere where photodegradation is rapid.

            Any TCE that does not evaporate from soils leaches to groundwater.
            Degradation in  soils and  water is slow.  TCE does not hydrolyze in
            water, nor does it significantly bioconcentrate in aquatic organisms.
Trichloroethvlene
            Toxicity.  Trichloroethylene was once used as an anesthetic, though its
            use caused several fatalities due to liver failure.  Short term inhalation
            exposure  to high levels of trichloroethylene may cause rapid coma
            followed by eventual death from liver, kidney, or heart failure.  Short-
            term exposure to lower concentrations of trichloroethylene causes eye,
            skin,  and respiratory tract  irritation.  Ingestion causes a burning
            sensation  in  the mouth, nausea,  vomiting and abdominal pain.
            Delayed effects from short-term trichloroethylene poisoning include
            liver and kidney lesions, reversible nerve degeneration, and psychic
            disturbances.  Long-term exposure can produce headache,  dizziness,
            weight loss, nerve damage, heart damage, nausea, fatigue,  insomnia,
            visual impairment, mood perturbation, sexual  problems, dermatitis,
            and rarely jaundice.  Degradation  products  of trichloroethylene
            (particularly phosgene) may cause rapid death due to respiratory
            collapse.

            Carcinogenicitv.  Trichloroethylene is a probable  human carcinogen via
            both oral and inhalation exposure, based on limited  human evidence
            and sufficient animal evidence.

            Environmental Fate. Trichloroethylene breaks down slowly in water
            in the presence of sunlight and bioconcentrates  moderately  in  aquatic
            organisms. The  main removal  of trichloroethylene from water is via
            rapid evaporation.

            Trichloroethylene does not photodegrade in the  atmosphere, though it
            breaks down quickly under smog conditions, forming other pollutants
            such as phosgene,  dichloroacetyl chloride, and  formyl chloride. In
            addition, trichloroethylene vapors may be decomposed to toxic levels
 SIC Code 37
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             of phosgene in the presence of an intense heat source such as an open
             arc welder.

             When spilled on the land, trichloroethylene rapidly volatilizes from
             surface soils.  The remaining  chemical leaches  through  the soil to
             groundwater.
Xvlene (Mixed Isomers)
            Toxicity. Xylenes are rapidly absorbed into the body after inhalation,
            ingestion, or skin contact.  Short-term exposure of humans  to high
            levels of xylenes can cause irritation of the skin, eyes, nose, and throat,
            difficulty in breathing, impaired lung function, impaired memory, and
            possible changes in the liver and kidneys.  Both short- and long-term
            exposure to high  concentrations can cause effects such as headaches,
            dizziness, confusion, and  lack of muscle  coordination.  Reactions of
            xylenes (see environmental fate) in the atmosphere contribute to  the
            formation of ozone in  the lower  atmosphere.  Ozone can affect  the
            respiratory system, especially in sensitive  individuals such as asthma
            or allergy sufferers.

            Carcinogenicity.  There is currently no evidence to suggest that this
            chemical is carcinogenic.

            Environmental  Fate. The majority of releases to land and water will
            quickly evaporate, although some degradation by microorganisms will
            occur.
            Xylenes  are  moderately  mobile  in  soils  and  may
            groundwater, where they may persist for several years.
                                                        leach into
            Xylenes are volatile organic chemicals.  As such, xylenes in the lower
            atmosphere  will  react  with other  atmospheric  components,
            contributing to the formation of ground-level ozone and other air
            pollutants.
IV.C.
Other Data Sources

The Aerometric Information Retrieval System (AIRS) contains a wide
range of information related to stationary sources of air pollution,
including the emissions of a number of air pollutants which may be of
concern within a particular industry.  With the exception of volatile
organic compounds  (VOCs),  there  is  little overlap  with the TRI
chemicals reported above.   Exhibit 22 summarizes annual releases of
carbon monoxide (CO), nitrogen dioxide (NO2), particulate matter of 10
September 1995
                       63
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Motor Vehicle Assembly Industry
Sector Notebook Project
            microns or less (PM10), total particulates (FT), sulfur dioxide (802), and
            volatile organic compounds (VOCs).

                                 Exhibit 22
                    Pollutant Releases (Short Tons/Years)
Industry
U S Total
Metal Mining
Nonmetal Mining
Lumber and Wood
Products
Wood Furniture and
Fixtures
Pulp and Paper
Printing 	
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc. Plastic
Products
Stone, Clay, Glass, and
Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Electronics
Motor Vehicles,
Bodies, Parts, and
Accessories

CO
97 208 000
5,391
4,525
123,756
2,069
624,291
8,463
166,147
146,947
419,311
2,090
58,043
1,518,642
448,758
3,851
367
35,303
101
N02
23,402,000
28,583
28,804
42,658
•2,981
394,448
4,915
108,575
236,826
380,641
11,914
338,482
138,985
55,658
16,424
1,129
23,725
179
PMio
45,489,000
39,359
59,305
14,135
2,165
35,579
399
4,107
26,493
18,787
2,407
74,623
42,368
20,074
1,185
207
2,406
3
PT
7,836,000
140,052
167,948
63,761
3,178
113,571
1,031
39,082
44,860
36,877
5,355
171,853
83,017
22,490
3,136
293
12,853
28
SO2
21,888,000
84,222
24,129
9,149
1,606
341,002
1,728
182,189
132,459
648,153
29,364
339,216
238,268
373,007
4,019
453
25,462
152
voc
23,312,000
1,283
1,736
41,423
59,426
96,875
101,537
52,091
201,888
309,058
140,741
30,262
82,292
27,375
102,186
4,854
101,275
7,310
Source U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.
IV.D.        Comparison of Toxic Release Inventory Between Selected Industries

             The following information is presented as a comparison  of pollutant
             release and transfer data across industrial categories. It is provided to
             give a general sense  as to the relative scale  of releases and transfers
             within each sector profiled  under this project.  Please note that the
             following table does  not  contain releases  and transfers for industrial
             categories that are not included in this project, and thus cannot be used
             to draw  conclusions regarding the total release and transfer amounts
             that are  reported  to TRI.  Similar information is available within the
             annual TRI Public Data Release book.

             Exhibit 23 is a graphical representation of a summary of the 1993 TRI
             data for the motor vehicles assembly industry and the other sectors
             profiled  in separate notebooks. The bar graph presents the total TRI
 SIC Code 37
                                     64
      September 1995

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Sector Notebook Project
                 Motor Vehicle Assembly Industry
            releases and total transfers on the left axis and the triangle points show
            the average releases per facility on the right axis. Industry sectors are
            presented in the  order of increasing total TRI releases.  The graph is
            based on the data shown  in Exhibit 24 and is meant to facilitate
            comparisons between the relative amounts  of releases, transfers, and
            releases per facility both within and between these sectors.  The reader
            should note, however, that differences  in the proportion  of facilities
            captured by TRI exist between industry sectors.  This can be a factor of
            poor SIC matching and relative differences in the number of facilities
            reporting to TRI  from the various sectors.  In the case of the motor
            vehicles assembly industry, the 1993 TRI data presented here covers 609
            facilities.   These facilities listed SIC 37  (Motor Vehicles Assembly
            Industry) as a primary SIC code.
September 1995
65
SIC Code 37

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 Motor Vehicle Assembly Industry
                             Sector Notebook Project
                         (suoijjnii)
                                                                                  •s

                                                                                              .B
SIC Code 37
66
September 1995

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                    Motor Vehicle Assembly Industry











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V.
POLLUTION PREVENTION OPPORTUNITIES

The best way to reduce pollution is to prevent it in the first place.
Some companies have  creatively implemented pollution prevention
techniques that improve efficiency and increase profits while at the
same time minimizing  environmental impacts.  This can be done in
many ways such as reducing material inputs, re-engineering processes
to reuse by-products, improving management practices, and employing
substitution of toxic  chemicals.   Some smaller facilities  are  able to
actually get below regulatory thresholds just by reducing pollutant
releases through aggressive pollution prevention policies.

In order to encourage  these  approaches, this section provides both
general  and  company-specific  descriptions  of some pollution
prevention advances  that  have been implemented within the Motor
Vehicles and Motor Vehicle Equipment industry. While the list is not
exhaustive, it  does provide core  information that can be used as the
starting point  for facilities  interested in beginning their own pollution
prevention projects.  When possible, this section provides  information
from real activities that  can, or are being implemented by  this sector —
including a discussion of associated costs, time frames, and expected
rates  of return.  This  section provides summary information from
activities that  may be, or are being implemented by this sector.  When
possible, information is provided that gives the context in which the
techniques  can be effectively used.   Please  note that the  activities
described in this section do not necessarily apply to all facilities that fall
within this sector.   Facility-specific conditions must be  carefully
considered when pollution prevention options are evaluated, and the
full impacts of the change must examine how each option affects, air,
land, and water pollutant releases.

Much of the  automotive  industry is involved in exploring  pollution
prevention opportunities.   The discussion which follows highlights
some of the  current pollution prevention activities undertaken  by
manufacturers involved in all stages of the  automotive manufacturing
process.   This  is  just  a sampling  of  the  numerous pollution
prevention/waste minimization efforts currently underway.
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 V.A.        Motor Vehicle Equipment Manufacturing

 Non-Production Material  Screening

             As part of its  Non-Production Material approval system, Chrysler
             Corporation implemented pollution prevention practices to eliminate,
             substitute, or reduce, to the extent possible, regulated substances from
             both products supplied to Chrysler as well as those resulting from their
             manufacturing  process.    First implemented  in April  1993, the
             environmental  strategy focuses on avoiding the  use of regulated
             substances and materials of concern whenever possible as part of an
             effort to eliminate "end-of-pipe" controls.   One example of how this
             screening approach has been utilized was the refusal to approve a
             transmission fluid for Chrysler's new TE Van which contained 10 to 30
             percent butyl benzyl phthalate.  This  was accomplished by working
             with suppliers and design teams to identify a substitute material. As
             part of the initiative, suppliers are being requested to certify their parts
             regarding the presence of Chrysler's identified materials of concern.

             Other similar Chrysler successes include:

             •      Elimination of hexavalent chromium from all materials and
                   processes;

             •      Reformulating paints and solvents to exclude  the majority of
                   listed toxic solvents;
                  Reformulating new coatings to reduce odor; and

                  Elimination of lead from all paints except electrocoat primer.
Used  Oil Recycling
            In an effort to reduce the waste oil produced at Chrysler  stamping,
            machining, and engine plants,  the automobile manufacturer  has
            developed comprehensive recycling programs with outside  suppliers.
            More than 800 million gallons of used oil is recycled annually. Other
            company efforts designed to reduce waste oil include:

            •     Recovering and remanufacturing waste oil on-site for return to
                  the process;

            •     Reducing the amount used by replacing petroleum-based metal
                  working fluids with longer lasting semi-synthetic materials; and

            •     Developing purchasing programs to promote the use of recycled
                  oils.
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Trichloroethylene  Reduction

            Trichloroethylene (TCE)  is traditionally employed by the automotive
            industry as a degreaser  to clean oil from very thin aluminum parts.
            Although vapor collection systems are  used during the degreasing
            process to collect and recycle TCE, some TCE inevitably remains on the
            high-surface-area parts. The remaining TCE then evaporates. In order
            to reduce  emissions  of TCE, Ford Motor Company  developed  a
            detergent and aqueous solution which was comparable  to TCE. The
            new water  wash did not etch or damage  aluminum parts and met
            brazing process requirements.  With assistance from a supplier, Ford
            also designed an enclosed water spray system for the new degreasing
            operations.  According to AAMA, after a 1992 pilot evaluation proved
            successful,  Ford began  to convert  production processes using heat
            exchangers  (e.g., radiators) to one relying on aqueous cleaning instead
            of TCE degreasing.  As a result, TCE releases at one plant dropped by
            250,000 pounds annually. Ford expects comparable further reductions
            worldwide as the remaining plants implement this process change.

Elimination of Chromium From Radiator  Paint

            In past years, radiators were spray painted with a coating containing
            chromium for protection purposes.  This process resulted in overspray
            paint waste (sludge) that contained hazardous constituents.  Wastes
            were collected and shipped to an approved hazardous waste disposal
            facility. In order to minimize the  risk associated with the material
            constituents and resultant waste associated with coating containing
            chromium,  Chrysler's Dayton Thermal Products Plant explored  the use
            of new products which would meet performance specifications for the
            required surface coating. The result is a water-based material which is
            chromium  as  well  as lead-free.  The use of this  new water-based
            material will eliminate approximately 18,000 gallons of paint waste per
            year that was previously landfilled, as well as reduce substantially VOC
            emissions.

 Lead-Free Black Ceramic Paint

            Ceramic black glaze paint (ink), used for aesthetic purposes  as well  as
             an ultraviolet (UV)  light shield for the adhesive (adhesive is sensitive
            to  UV light),  is applied to glass  where the interior trim  abuts the
            window.  Application of the ink,  which contains  lead, to the glass
             involves a silk-screening process.  In an  attempt  to minimize both
             solid and liquid waste,  McGraw Glass (supplier for Chrysler assembly
             plants), launched a program to develop, test, and approve a lead-free
             black ceramic glass paint. A suitable substitute, which  was approved
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            and in use by  1994, would eliminate approximately 700 drums of
            hazardous waste per year.
Recovering Lead  From  Wastewater
            One of the waste streams associated with battery-making operations is
            wastewater which contains lead.  Although in the past it was possible
            to remove lead from the wastewater, it had not been possible to recycle
            the lead.  In 1990, Delco Remy, a GM supplier, developed a method
            which allows the lead to be recycled.  The process involves a  series of
            steps and  the use of a proprietary chemical  (identified through a
            cooperative effort between the plant personnel and a chemical vendor)
            which allows lead to settle to the bottom  when tank contents are
            neutralized.  After the lead has settled, wastewater  is decanted and
            filtered through  a  sand filter  to remove remaining  lead.  The
            remaining water and lead are agitated with air to put lead back into
            suspension before the mixture is pumped into a filter press where
            water is removed leaving behind the lead. The dried, lead-containing
            mixture is  then sent to a secondary smelter. As a result of this lead
            removing process, approximately 125,000 pounds of lead are reclaimed
            and recycled each year.

PCB Elimination  Program

            Polychlorinated biphenyls (PCBs), which are utilized as a coolant and
            flame  retardant  fluid  in  closed  system high voltage electrical
            equipment, are one of the most persistent  toxics used  in  the
            automotive industry.  In order to eliminate the use of  PCBs in  its
            facilities, Chrysler initiated a program  that would eliminate the use of
            PCB containing equipment at its facilities by 1998.  The program also
            plans to minimize the risk of Superfund liability through  alternate
            disposal practices.  Similar programs are in place at GM and Ford.

Solvent-Free Spray  Adhesive  For  Interior Trim

            General Motors Inland Fisher Guide plant in Livonia, MI produces soft
            trim for the interior of  automobiles.  In order to produce  car door
            panels that offer a variety of colors, textures, and materials, an assembly
            process which glues together small pieces is used.   In the past, the
            adhesive used to  bind these parts together contained four percent
            methylene chloride; 30 percent methyl ethyl ketone; 30 percent hexane,
            and  14 percent toluene.   The combination  of VOCs  resulted  in
            approximately 20 tons of emissions  a year. In order to eliminate the
            emissions associated with this adhesive, a water-based adhesive was
            identified.   The  new  adhesive,  which  was  implemented  in  the
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            beginning of 1993, converted the waste stream from hazardous to non-
            hazardous.
Reducing  Chlorofluorocarbon  Use
            Chlorofluorocarbons (CFCs)  and  1,1,1-trichlorethane are chemical
            substances that deplete the ozone layer.  Depletion of the ozone layer
            causes skin cancer, cataracts and has other human and environmental
            effects.  Under the Montreal Protocol on Substances that Deplete the
            Ozone Layer and the Clean Air Act, production of these chemicals will
            be halted by January 1996.  The automobile industry used CFC-12 as a
            refrigerant in air conditioning systems, CFC-11  as foam blowing agent
            for flexible seating foams,  and CFC-113 and 1,1,1-trichloroethane
            (methyl chloroform) as  a solvent  in electronics manufacturing and
            metal cleaning.   The automobile industry undertook voluntary and
            cooperative projects with EPA's Stratopheric  Protection Division to
            reduce and eliminate each of these uses.  As a result of these efforts,
            recycling  was implemented  and most uses were halted well before
            regulations took effect (Stratopheric Protection Division 1995).  For
            example, in order to reduce the use of CFCs, GM's Lansing Automotive
            Division (LAD)  Facilities Division decided to remove CFCs wherever
            possible from its operating procedures.  The first step  was to identify
            CFC containing  materials that were approved for purchase and which
            departments  were authorized to use them.  Departments were then
            sent a letter asking whether a non-CFC material could be substituted.
            Results from the inquiries led to identification  of acceptable and cost-
            effective alternatives.  Since mid-1992, no CFC-containing products
            have been purchased  by LAD plants.  In addition, LAD  found  a
            substitute for a degreaser it had been  using that has only about 12
            percent  of ozone-depletion potential  of the Freons  it replaced.
            According to the Stratopheric Protection Division, another example of
            technology and  engineering excellence is that Ford joined with other
            companies under the  auspices of  the International Cooperative for
            Ozone Layer Protection  (ICOLP) to develop inert gas wave and  "no
            clean" soldering which replaces CFC-cleaning of printed wiring boards,
            (PWBs).  Electronics are the key to meeting vehicle emissions  safety
            and security.   The new process  was designed for  environmental
            reasons, but Ford found it also improved the quality of the PWBs.
V.B.        Motor Vehicle Assembly

Plants Switch  To Clean-Burning Gas

            In an effort to reduce air emissions from manufacturing facilities, Ford
            has converted  from coal-fired boilers to natural gas.  An estimated
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            $500,000 to $600,000 is saved each year in operating costs for each plant
            that converts from coal to natural gas.  The environmental benefits of
            the conversion include:  a reduction in carbon monoxide emissions by
            one half; a reduction in sulfur  dioxide emissions by approximately
            3,000 tons per year system wide; and a reduction in nitrogen oxide
            emissions of approximately 1,100 tons  per year.  The switch has also
            reduced p articulate emissions by over 500 tons a year for Ford system-
            wide, and by as much as 95 percent at some facilities. In addition, 8,000
            tons of ash a year, from coal burning, and 4,100 tons of ash collected by
            emission collectors will no longer have to be disposed of in a landfill.
Solid  Waste Recycling
V.C.
            As part of an effort to reduce the amount of waste generated from
            assembly operations, Chrysler is using durable returnable containers.
            By using these containers, the company has successfully eliminated 55
            percent of its expendable packaging wastes and diverted significant
            volumes of paper, cardboard, plastic and wood from landfills.  Chrysler
            has designed new product programs which plan to eliminate 95 percent
            of packaging waste.  In addition, each  year  the company  salvages
            700,000 tons of scrap metal  and recycles thousands of tons of wooden
            pallets and cardboard from  its plants.  Chrysler has also instituted one
            of the largest paper recycling programs in the U.S., recycling more than
            800 tons of paper per year.

            Ford also has a program  to reduce solid waste.  At Ford Casting and
            Forging, steel drums are recycled in the foundry's  melting process.
            Ford's  North American  assembly plants are recycling 380  million
            pounds of waste each year.  European and North American suppliers
            have  been asked to ship  components in reusable  and returnable
            containers. Ford's Romeo Engine Plant receives over 90 percent of its
            parts in returnable containers.  Also, Ford uses recycled plastic shrink
            wrap from its own manufacturing operations to make plastic seat
            covers to protect seats during car shipment to dealers.
Motor Vehicle Painting/Finishing
Facility Emission Controls
            During the past 10 years,  automobile companies have  reduced the
            amount  of emissions  resulting  from vehicle  painting operations
            through more efficient paint application  techniques, use  of lower
            solvent content paints, and incineration of process emissions.  In an
            attempt  to lower emissions  without jeopardizing  quality, a paint
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            development pilot plant has been established at  the  Ford Wixom,
            Michigan Assembly Plant.

Rescheduling Paint Booth Cleaning Reduces Solvent  Use And VOC Emissions

            One of the major factors in customer satisfaction is the quality of a car's
            paint job.   To insure that each vehicle of a given color  has  a uniform
            and consistent coating, paint spraying equipment must be cleaned
            properly each time a color is changed.  It is also important that the
            paint booth be cleaned properly to prevent stray drops or flakes of old
            paint from dropping onto  subsequent paint jobs.  The solvent used in
            these cleaning operations is generally referred  to as "purge solvent."
            One of the disadvantages of using purge solvent is  that  it readily
            evaporates  causing VOC emissions.  In March 1993 the  GM Fairfax
            Assembly Plant initiated a new booth-cleaning schedule which reduced
            the number of required cleanings.  In addition to  changing cleaning
            frequency, the company also monitored the amount of purge solvent
            used in production and cleaning operations. Information from these
            monitoring activities helped to identify  the most efficient cleaning
            techniques.  Implementation of these practices is expected  to greatly
            lower emissions from purge solvent.

Surface Coating Toxics  Reduction  Program

            Painting operations account for the majority of total releases attributed
            to  automobile assembly.   This  is  because painting  and finishing
            operations result in VOC  emissions  from solvents used as  carriers to
            apply solids to the vehicle. In order to reduce the amount of toxics
            generated during the painting/finishing process as well  as eliminate
            future regulatory burden, the following projects  are either underway or
            being planned at Chrysler:

             •      Evaluation of the feasibility of using coatings which eliminate or
                   reduce VOCs/toxics; the goal is a 75 percent reduction in toxics by
                   1996.  Various process changes and material reformulation will
                   be required.

             •      Elimination of lead from surface coatings - lead has already been
                   eliminated from all Chrysler color coats (basecoats).  Further
                   reductions in lead are being pursued for the electrodeposition
                   primer (E-coat), with a goal of total removal by 1995.  A lead-free
                   E-coat is currently being tested.

             •      Elimination  of hexavalent chromium phosphate pre-treatment  -
                   hexavalent chromium has already been eliminated from
                   phosphate pre-treatment.  Trivalent chromium remains in the
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                   final rinse that seals the phosphate at all but one of Chrysler's
                   assembly plants; elimination of trivalent chromium is slated for
                   1995.
 V.D.        Motor Vehicle Dismantling/Shredding

 Management Standards For Used  Antifreeze

             An  article  in the September/October  1994 edition of Automotive
             Recycling  stated that  The Coalition  on  Antifreeze  and  the
             Environment, in conjunction with Automotive Recyclers  Association
             (ARA), has  developed voluntary management standards for antifreeze.
             Management standards were developed, in part,  to  encourage the
             Federal and State governments to consider less restrictive regulations
             on recycling and disposal  of antifreeze.  Recent data show that
             antifreeze  can  become  hazardous  when  handled  and  stored
             improperly.   The voluntary management  standards address the
             following:

             •     Handling - procedures for good housekeeping and proper
                  handling of antifreeze

             •     Storage - guidelines for proper storage, such as the use of
                  dedicated and well-labeled collection equipment

             •     Education - methods for educating employees on the importance
                  of keeping collected, used antifreeze free from exposure to
                  chemicals such as petroleum products, cleaning solvents, and
                  other solvent-containing materials. Employees should also be
                  taught not to use chlorinated solvents to clean antifreeze
                  collection equipment.
V.E.        Pollution Prevention Case Studies

Pollution Prevention at General Motors Corporation

            General  Motor's  internal pollution prevention initiative  -  Waste
            Elimination and Cost Awareness  Reward Everyone (WE CARE) - was
            piloted in 1990 at selected GM facilities.   The initiative was then
            expanded to GM's operations throughout the U.S. and Canada in 1991
            and was introduced to Mexican facilities in 1992.  The foundation for
            this program is provided in the mission statement:
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               To minimize  the impact of our operations, we will reduce
               emissions  to  air,  water, and  land  by putting priority  on
               waste prevention  at the  source, elimination  or reduction
               of wasteful  practices, and the utilization  of recycling
               opportunities whenever available.   The responsibility for
               achievement of this goal is primarily  dependent  on  both
               management's support and actions of every  employee to
               modify existing methods,  procedures, and processes and to
               incorporate waste prevention  into  all new endeavors.

            WE CARE provides guidance to individual facilities for setting up a
            multi-discipline  committee  to  direct  pollution prevention efforts.
            These  committee  include  representatives   from the  following
            departments:   maintenance, quality  control,  materials management,
            production, engineering, purchasing,  environmental  affairs,  as well as
            from the local union.  In bringing together representatives from all
            aspects of  the company, GM is making pollution prevention part of
            everyone's job.  In 1992, GM encouraged employees to suggest ways to
            reduce  the use of raw materials (especially toxics),  reduce waste
            generation, and simple ways to benefit the environment.

            GM has undertaken two broad-based initiatives to implement  this
            philosophy;  chemicals management  and packaging reduction  and
            recycling. Each is discussed below.

      Chemicals  Management

            The automotive industry is a large consumer of chemicals including
            cleaners, machining fluids,  hydraulic fluids, quenching fluids, water
            treatment  chemicals,  and solvents.  These chemicals  are  known as
            indirect chemicals because they are not directly incorporated into the
            final product.  Direct chemicals, which are incorporated into the final
            product, include automotive paints, vehicle lubricants, and fluids.  GM
            aims to reduce chemical waste and  save money by:  (1) leveraging
            resources  and expertise from other  sources; and  (2)  reshaping the
            relation between the supplier and the customer.  By developing and
            implementing an effective chemical management  system, GM has
            reduced the amount of chemicals used at the source and reduced waste
            treatment and disposal costs.

            Under the new chemical management program, GM no longer simply
            purchases  chemicals from suppliers. Instead, they purchase  a chemical
            service. The goal was to  have one supplier for all of the indirect
            chemicals  used at a facility.  Since no one supplier can supply every
            chemical,  the primary supplier  is responsible  for  getting chemicals
            from secondary suppliers.  Under the program, the primary supplier
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            ultimately becomes a part of the production team by providing GM
            with  chemical management,  analysis,  inventory  control,  and
            information management  services.   The  benefits of  this initiative
            include:

            •     Cost savings through the reduced number of suppliers, types and
                  volumes of chemicals,  and chemical  inventories

            *     Better environmental control (waste treatment and disposal)

            •     Improved information management

            •     Improved chemical technology application

            •     Reduced purchase order processing

            •     Reduced freight.

            The first assembly plant to implement this program went from having
            35 different suppliers providing  348  chemicals, to  12 suppliers
            supplying 200  chemicals.  This equates to a  66 percent reduction in the
            number of suppliers  and a  43  percent  reduction  in the number of
            chemicals. Total savings were well over $750,000 per year.

      Packaging Reduction  and Recycling

            One of the major waste streams associated with automotive assembly is
            solid waste.  Solid waste is primarily the result of parts packaging from
            suppliers.   The goal  of  GM's  packaging reduction  and recycling
            initiative was to reduce the amount of packaging coming into the plant
            and to ensure that packaging was easily recycled or returned.

            Because GM has many different divisions and business  units,  one
            packaging strategy was  not  feasible.  Therefore,  each division was
            responsible  for setting  its own goals  and strategies.   Packaging
            guidelines and requirements were developed and communicated to
            suppliers. The guidelines, which were used throughout GM include:


            •     Eliminate packaging altogether, where possible

            •     Minimize the amount of material used in packaging

            •     Use packages that are returnable or  refillable/reusable, where
                  practical

            •     Use packaging that is recyclable and uses recycled material.
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            Requirements pertaining to expendable packaging (packaging which is
            used  once and not recycled) were established  for suppliers.  These
            requirements pertained to package construction  (easy to disassemble),
            the use of recycled material (use recyclable packaging), the use of lead
            and cadmium (do not use), and other provisions which reduce the
            amount of waste generated and facilitate recycling.

            The GM Midsize Car Division has been able to  reduce  the amount of
            packaging waste going to  landfill per vehicle manufactured by 75
            percent in just two years as part of its "zero packaging-to-landfill" goal.
            As of September 1993, one GM assembly plant has been able to reduce
            the amount of waste to less than one pound of packaging per vehicle.

            Ford's Manufacturing Environmental Leadership Strategy includes the
            objective and practice of increasing the use of returnable  containers  and
            recycling expendable  packaging.  Ford's  North American assembly
            plants now use returnable packaging for over 87 percent of all parts
            shipped to the  plants.  These  plants  alone recycle more than  380
            million pounds  of waste each year.  Many parts are shipped in
            returnable containers and packaging plastic is made into protective  seat
            covers for use during car shipment.
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VI.
SUMMARY OF FEDERAL STATUTES AND REGULATIONS
            This section discusses the Federal statutes and regulations that may
            apply to this sector.  The purpose of this section is to highlight, and
            briefly describe the applicable Federal requirements, and to provide
            citations for more detailed information.  The three  following sections
            are included.

            •      Section IV.A contains a general overview of major statutes
            •      Section IV.B contains a list of regulations specific to this industry
            •      Section IV.C contains a list of pending and proposed regulations

            The descriptions within Section IV are  intended solely for general
            information. Depending upon the nature  or scope of the activities at a
            particular facility, these summaries may or may not necessarily describe
            all applicable environmental requirements.  Moreover, they do not
            constitute formal interpretations or clarifications of the statutes and
            regulations.  For further information, readers should consult the Code
            of Federal Regulations and other state or local regulatory agencies. EPA
            Hotline contacts are also  provided for each major statute.
VI.A. General Description of Major Statutes

Resource Conservation And Recovery Act

            The Resource Conservation And Recovery Act (RCRA) of 1976 which
            amended the Solid Waste Disposal Act, addresses solid (Subtitle D) and
            hazardous (Subtitle C) waste  management activities.  The Hazardous
            and Solid Waste Amendments (HSWA) of 1984 strengthened RCRA's
            waste  management provisions and added  Subtitle I, which governs
            underground storage tanks (USTs).

            Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
            260-299) establish a "cradle-to-grave" system  governing hazardous
            waste  from the point of generation to disposal.   RCRA hazardous
            wastes include  the  specific materials listed in  the regulations
            (commercial chemical products, designated with the code "P" or "U";
            hazardous wastes from specific industries/sources, designated with the
            code "K"; or hazardous wastes from non-specific sources, designated
            with the code "F")  or materials which  exhibit a hazardous waste
            characteristic (ignitibility, corrosivity,  reactivity,  or  toxicity  and
            designated with the code "D").
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            Regulated entities that generate hazardous waste are subject to waste
            accumulation, manifesting, and recordkeeping standards.   Facilities
            that treat, store, or dispose of hazardous waste must obtain  a permit,
            either from EPA or from a State agency which EPA has authorized to
            implement the permitting program. Subtitle C permits contain general
            facility standards  such as  contingency plans, emergency procedures,
            recordkeeping  and  reporting requirements, financial assurance
            mechanisms,  and unit-specific standards.   RCRA also  contains
            provisions (40  CFR Part 264  Subpart S  and §264.10) for conducting
            corrective actions  which govern the cleanup of releases of hazardous
            waste or constituents from solid waste management units  at RCRA-
            regulated facilities.

            Although RCRA  is a Federal  statute, many States  implement the
            RCRA program.   Currently, EPA has  delegated its  authority to
            implement various provisions  of RCRA to 46 of the 50 States.

            Most RCRA requirements  are not industry specific  but apply to any
            company that transports, treats, stores, or disposes of hazardous waste.
            Here are some  important RCRA regulatory requirements:

            •     Identification of Solid and Hazardous Wastes (40 CFR Part 261)
                  lays out the procedure every generator should follow to
                  determine whether the material created is considered a
                  hazardous waste, solid waste, or is exempted from regulation.

            •     Standards for Generators of Hazardous Waste (40 CFR Part 262)
                  establishes the responsibilities of hazardous waste generators
                  including obtaining an ID number, preparing a manifest,
                  ensuring proper packaging and labeling, meeting standards for
                  waste accumulation units, and recordkeeping and reporting
                  requirements. Generators can accumulate hazardous waste  for
                  up to 90  days (or 180 days depending on the amount of waste
                  generated) without obtaining a permit.

            •     Land Disposal Restrictions (LDRs) are regulations prohibiting
                  the disposal of hazardous waste on land without prior
                  treatment. Under the LDRs (40 CFR 268), materials must meet
                  land disposal restriction (LDR) treatment standards prior to
                  placement in a RCRA land disposal unit (landfill, land
                  treatment unit, waste pile, or surface impoundment).  Wastes
                  subject to the LDRs include solvents, electroplating wastes,
                  heavy metals, and acids. Generators of waste subject to the LDRs
                  must provide notification of such to the designated TSD facility
                  to ensure proper treatment prior to disposal.
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             •      Used Oil Management Standards (40 CFR Part 279) impose
                   management requirements affecting the storage, transportation,
                   burning, processing, and re-refining of the used oil.  For parties
                   that merely generate used oil, regulations establish storage
                   standards. For a party considered a used oil marketer (one who
                   generates and sells off-specification used oil directly to a used oil
                   burner), additional tracking and paperwork requirements must
                   be satisfied.

             •      Tanks and Containers used to store hazardous waste with a high
                   volatile organic concentration must meet emission standards
                   under RCRA.  Regulations (40 CFR Part 264-265, Subpart CC)
                   require generators to test the waste to determine the
                   concentration of the waste, to satisfy tank and container
                   emissions standards, and to inspect and monitor regulated units.
                   These regulations apply to all facilities who store such waste,
                   including generators operating under the 90-day accumulation
                   rule.

             •      Underground Storage Tanks (USTs) containing petroleum and
                   hazardous substance are regulated under Subtitle I of RCRA.
                   Subtitle I regulations (40 CFR Part 280) contain tank  design and
                   release detection requirements, as well as financial responsibility
                   and corrective action standards for USTs. The UST program also
                   establishes increasingly stringent standards, including upgrade
                   requirements for existing tanks, that must be met by 1998.

             •      Boilers and Industrial Furnaces (BIFs) that use or burn fuel
                   containing hazardous waste must comply with strict design and
                   operating standards.  BIF regulations (40 CFR Part 266, Subpart
                   H) address unit design, provide performance standards, require
                   emissions monitoring, and restrict the  type of waste  that may be
                  burned.

            EPA's RCRA/Superfund/UST  Hotline,  at  (800) 424-9346, responds  to
            questions  and  distributes guidance regarding all  RCRA  regulations.
            The RCRA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., EST,
            excluding  Federal  holidays.

Comprehensive Environmental Response, Compensation, And  Liability Act

            The  Comprehensive Environmental Response,  Compensation,  and
            Liability Act (CERCLA), a 1980 law commonly known as Superfund,
            authorizes EPA  to  respond  to  releases, or  threatened  releases, of
            hazardous substances that may endanger public health, welfare, or the
            environment.  CERCLA also enables EPA to force parties responsible
            for environmental contamination to clean  it up or to reimburse the
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            Superfund  for response  costs incurred by EPA.   The  Superfund
            Amendments and Reauthorization  Act (SARA)  of  1986 revised
            various sections  of CERCLA, extended the taxing  authority for the
            Superfund, and created a free-standing law, SARA Title III, also known
            as  the Emergency Planning and  Community Right-to-Know Act
            (EPCRA).

            The CERCLA hazardous substance release reporting regulations (40
            CFR Part 302) direct the person in charge of a facility to report to the
            National  Response Center (NRC)  any environmental release of a
            hazardous substance which exceeds a reportable quantity.  Reportable
            quantities are defined and listed in 40 CFR § 302.4.  A release report
            may trigger a response by EPA, or by one  or more Federal or State
            emergency response authorities.

            EPA implements hazardous  substance   responses according  to
            procedures  outlined in the National Oil and Hazardous  Substances
            Pollution Contingency Plan (NCP) (40  CFR Part 300).  The NCP
            includes  provisions for  permanent  cleanups,  known as remedial
            actions, and other cleanups referred to as "removals."  EPA generally
            takes remedial actions only at sites  on  the National  Priorities List
            (NPL), which currently includes approximately  1300 sites.  Both EPA
            and states can act at other sites; however,  EPA provides responsible
            parties the opportunity to conduct removal and remedial actions and
            encourages  community  involvement  throughout the  Superfund
            response process.

            EPA's  RCRA/Superfund/UST Hotline,  at  (800) 424-9346, answers
            questions  and  references guidance  pertaining  to  the  Superfund
            program.  The CERCLA  Hotline operates weekdays from 8:30 a.m.  to
            7:30 p.m., EST, excluding  Federal holidays.

Emergency Planning And Community Right-To-Know Act

            The Superfund Amendments and Reauthorization Act (SARA) of 1986
            created the Emergency Planning and Community Right-to-Know Act
            (EPCRA,  also known as SARA Title III), a statute designed  to improve
            community access to  information about chemical hazards and  to
            facilitate  the development of chemical emergency  response plans by
            State and local governments. EPCRA required the establishment of
            State  emergency response  commissions  (SERCs), responsible  for
            coordinating certain emergency response  activities and  for appointing
            local emergency planning committees (LEPCs).
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             EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish
             four types of reporting obligations for facilities which store or manage
             specified chemicals:

             •     EPCRA §302 requires facilities to notify the SERC and LEPC of
                   the presence of any "extremely hazardous substance" (the list of
                   such substances is in 40 CFR Part 355, Appendices A and B) if it
                   has such substance in excess of the substance's threshold
                   planning quantity, and directs the  facility to appoint an
                   emergency response coordinator.

             •     EPCRA §304 requires the facility to notify the SERC and the LEPC
                   in the event of a release exceeding the reportable quantity of a
                   CERCLA hazardous substance or an EPCRA extremely
                   hazardous substance.

             •     EPCRA §§311 and 312 require a facility at which a hazardous
                   chemical, as defined by the Occupational Safety and Health Act,
                   is present in an amount exceeding a specified threshold  to
                   submit to the  SERC, LEPC, and local fire department material
                   safety data sheets (MSDSs) or lists  of MSDSs and hazardous
                   chemical inventory forms (also known as Tier I and II forms).
                   This information helps the local government respond in the
                   event of a spill or release of the chemical.

             •     EPCRA §313 requires manufacturing facilities included in SIC
                   codes 20 through 39, which have ten or more employees, and
                   which manufacture, process, or use specified chemicals in
                   amounts greater than threshold quantities, to submit an annual
                   toxic chemical release report. This report, commonly known as
                   the Form R, covers releases and transfers of toxic chemicals to
                   various facilities and environmental media, and  allows EPA to
                   compile the national Toxic Release Inventory (TRI) database.


            All information submitted pursuant to EPCRA regulations is publicly
            accessible, unless protected by a trade secret claim.

            EPA's  EPCRA  Hotline,  at  (800) 535-0202,  answers questions  and
            distributes  guidance   regarding  the   emergency   planning  and
            community right-to-know regulations.    The  EPCRA  Hotline  operates
            weekdays from 8:30 a.m. to 7:30 p.m., EST, excluding Federal holidays.
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Clean Water Act
            The primary objective of the Federal Water Pollution Control Act,
            commonly referred to as the Clean Water Act (CWA), is to restore and
            maintain the chemical, physical, and biological integrity of the nation's
            surface waters.  Pollutants regulated under the CWA include "priority"
            pollutants,  including  various   toxic  pollutants;  "conventional"
            pollutants, such as biochemical oxygen demand (BOD), total suspended
            solids  (TSS), fecal coliform, oil and  grease,  and pH; and  "non-
            conventional" pollutants, including any  pollutant  not identified as
            either conventional or priority.

            The CWA regulates both direct and indirect discharges. The National
            Pollutant Discharge Elimination System (NPDES) program (CWA §402)
            controls direct discharges into navigable waters.  Direct discharges or
            "point source" discharges are from sources such  as pipes and sewers.
            NPDES permits, issued by either EPA or an authorized State (EPA has
            presently authorized forty States to administer the NPDES program),
            contain industry-specific, technology-based and/or water quality-based
            limits,  and establish pollutant monitoring and reporting requirements.
            A facility that intends to discharge into the nation's waters must obtain
            a permit prior  to initiating its discharge.  A permit applicant must
            provide quantitative  analytical data identifying the types of pollutants
            present in the facility's effluent.  The permit will then  set forth the
            conditions  and effluent limitations under  which a facility may make a
            discharge.

            A NPDES permit may also include discharge limits based on Federal or
            State water quality criteria or standards, that were designed to protect
            designated uses of surface waters, such as supporting aquatic  life or
            recreation.   These  standards,  unlike the technological  standards,
            generally do not take into  account technological feasibility or costs.
            Water quality criteria and standards vary from State to State, and site to
            site, depending on the use classification of the receiving body of water.
            Most States follow  EPA guidelines which propose aquatic life and
            human health criteria for many of the 126 priority pollutants.

             Storm Water Discharges

             In 1987 the CWA was amended to require EPA to establish a program
             to address storm water discharges. In response, EPA promulgated the
             NPDES storm water permit application regulations.   Storm water
             discharge associated with industrial activity means the discharge from
             any conveyance which is used for collecting and conveying storm
             water and which is directly related to manufacturing, processing or raw
             materials storage areas at an industrial plant (40 CFR 122.26(b)(14)).
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             These regulations require that facilities with the following storm water
             discharges apply for a NPDES permit: (1) a discharge associated with
             industrial activity; (2) a discharge from a large or medium municipal
             storm sewer system; or  (3)  a discharge  which EPA  or the State
             determines to contribute to a violation of a water quality standard or is
             a significant contributor of pollutants to waters of the United States.
             The term "storm water  discharge associated with industrial activity"
             means a storm water discharge from  one of 11 categories of industrial
             activity defined at 40 CFR 122.26.  Six of the categories are defined by
             SIC codes while the  other five are  identified  through narrative
             descriptions of the regulated industrial activity.  If the primary SIC code
             of the facility is one of those identified in the regulations, the facility is
             subject  to the storm water permit application  requirements.  If any
             activity at a facility is covered by one of the five narrative categories,
             storm water discharges from those areas where the activities occur are
             subject to storm water discharge permit application requirements.

             Those facilities/activities  that  are subject to storm water discharge
             permit application requirements are  identified below.  To determine
             whether a particular facility falls within one of these categories, the
             regulation should be consulted.

             Category i:   Facilities subject to storm water effluent  guidelines, new
             source performance standards, or toxic pollutant effluent standards.

             Category ii:  Facilities classified, as SIC 24-lumber and wood products
             (except wood kitchen cabinets); SIC 26-paper and allied products (except
             paperboard containers and  products); SIC 28-chemicals  and allied
             products (except drugs and paints); SIC 29-petroleum refining; and SIC
             311-leather tanning and finishing.

             Category iii:  Facilities classified as SIC 10-metal mining; SIC 12-coal
             mining;  SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral
             mining.

             Category iv: Hazardous waste treatment, storage, or disposal facilities.

             Category v:   Landfills, land  application sites, and open dumps that
             receive or have received industrial wastes.

             Category vi:  Facilities classified as SIC 5015-used motor  vehicle parts;
             and SIC 5093-automotive scrap and waste material recycling facilities.

             Category vii:  Steam electric power generating facilities.
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            Category viii: Facilities classified as SIC 40-railroad transportation; SIC
            41-local passenger transportation; SIC 42-trucking and warehousing
            (except public warehousing and storage); SIC 43-U.S. Postal Service; SIC
            44-water transportation; SIC 45-transportation by  air;  and SIC 5171-
            petroleum bulk storage stations and terminals.

            Category ix: Sewage treatment works.

            Category x: Construction activities except operations that result in the
            disturbance of less than five acres of total land area.

            Category xi: Facilities classified  as SIC 20-food and kindred products;
            SIC 21-tobacco products; SIC 22-textile mill products;  SIC  23-apparel
            related products; SIC 2434-wood kitchen  cabinets manufacturing; SIC
            25-furniture and fixtures; SIC 265-paperboard containers and boxes; SIC
            267-converted paper and paperboard  products; SIC  27-printing,
            publishing, and  allied industries; SIC  283-drugs; SIC 285-paints,
            varnishes,  lacquer, enamels, and allied products;  SIC 30-rubber and
            plastics; SIC 31-leather and leather products (except  leather and tanning
            and finishing); SIC 323-glass products; SIC 34-fabricated metal products
            (except fabricated structural  metal); SIC 35-industrial and commercial
            machinery  and computer equipment; SIC 36-electronic  and other
            electrical  equipment  and  components;   SIC  37-transportation
            equipment  (except  ship  and boat building and repairing); SIC 38-
            measuring,  analyzing,  and  controlling  instruments;  SIC  39-
            miscellaneous manufacturing industries; and  SIC 4221-4225-public
            warehousing and storage.

            Pretreatment Program

            Another type of discharge that is regulated by the CWA is  one that goes
            to  a  publicly-owned  treatment  works  (POTWs).  The  national
            pretreatment program (CWA §307(b)) controls the indirect discharge of
            pollutants  to POTWs by "industrial users."  Facilities regulated under
            §307(b) must meet  certain pretreatment  standards.  The goal of the
            pretreatment program is to protect municipal  wastewater treatment
            plants from damage that may occur when hazardous, toxic, or other
            wastes are discharged into a  sewer system and to protect the quality of
            sludge generated by these plants. Discharges to a POTW  are regulated
            primarily by the POTW itself, rather than the State or EPA.

            EPA has developed technology-based standards for industrial users of
            POTWs. Different standards apply to  existing and  new sources within
            each category.  "Categorical" pretreatment standards applicable to  an
            industry on a nationwide basis  are developed  by EPA.  In addition,
            another kind of pretreatment standard, "local limits," are developed  by
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             the  POTW in order to assist the POTW  in  achieving the effluent
             limitations in its NPDES permit.

             Regardless of whether a State is  authorized to implement either the
             NPDES or the pretreatment program, if it develops its own program, it
             may enforce  requirements more stringent than Federal standards.

             EPA's Office of Water, at  (202) 260-5700,  will direct callers with
             questions  about the CWA to the  appropriate EPA  office.   EPA  also
             maintains  a   bibliographic database  of  Office  of Water publications
             which  can  be accessed through  the Ground Water and Drinking Water
             resource center, at (202) 260-7786.
Safe Drinking Water Act
            The Safe Drinking Water Act (SDWA) mandates that EPA establish
            regulations to protect human health from contaminants in drinking
            water.  The law authorizes EPA to develop national drinking water
            standards and  to create a  joint Federal-State system to  ensure
            compliance with these standards.   The SDWA also  directs EPA to
            protect underground sources of drinking water through the control of
            underground injection of liquid wastes.

            EPA has developed primary and secondary drinking water standards
            under its SDWA authority.  EPA and  authorized States enforce the
            primary  drinking water standards, which are, contaminant-specific
            concentration limits  that apply to  certain public  drinking water
            supplies.  Primary drinking water standards  consist of maximum
            contaminant level goals (MCLGs), which are non-enforceable health-
            based goals, and maximum contaminant levels  (MCLs), which are
            enforceable limits set  as close to MCLGs as possible, considering cost
            and feasibility of attainment.

            The SDWA Underground Injection Control (UIC) program (40 CFR
            Parts  144-148) is  a permit program which protects underground sources
            of drinking water by regulating five classes of injection wells.  UIC
            permits  include  design,  operating,  inspection,  and  monitoring
            requirements.  Wells used to inject hazardous wastes must also comply
            with RCRA corrective action standards in order to be granted a RCRA
            permit, and must meet applicable RCRA land disposal restrictions
            standards. The UIC permit program is primarily State-enforced, since
            EPA has  authorized all but a few States to administer the program.

            The SDWA also provides for a Federally-implemented  Sole Source
            Aquifer program, which prohibits Federal funds from being expended
            on  projects that may contaminate the sole or principal source  of
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            drinking water for a given area, and for a State-implemented Wellhead
            Protection program, designed to protect  drinking water wells and
            drinking water recharge areas.

            EPA's  Safe  Drinking  Water  Hotline,  at  (800)  426-4791,  answers
            questions and  distributes guidance pertaining to  SDWA standards.   The
            Hotline operates from 9:00 a.m. through  5:30  p.m.,  EST, excluding
            Federal holidays.
Toxic Substances Control Act
            The Toxic Substances Control Act (TSCA) granted EPA authority to
            create a regulatory framework to collect data on chemicals in order to
            evaluate,  assess, mitigate, and control  risks  which may be posed by
            their manufacture, processing, and use.  TSCA provides a variety of
            control methods to prevent chemicals from posing unreasonable risk.

            TSCA standards may apply at any point during a chemical's life cycle.
            Under TSCA §5, EPA  has  established an inventory  of  chemical
            substances. If a chemical is not already on the inventory, and has not
            been excluded by TSCA, a  premanufacture notice  (PMN) must be
            submitted to EPA prior to manufacture  or import.  The PMN must
            identify the chemical and provide available information on health and
            environmental effects. If available data are not sufficient to evaluate
            the  chemical's  effects,  EPA can  impose  restrictions  pending the
            development of information on its health and environmental  effects.
            EPA can  also restrict significant new uses of chemicals based upon
            factors such as the projected volume and use of the chemical.

            Under TSCA §6,  EPA can ban the manufacture or distribution in
            commerce, limit the  use, require labeling,  or place other restrictions on
            chemicals that pose unreasonable  risks.  Among the chemicals EPA
            regulates  under §6 authority are asbestos, chlorofluorocarbons (CFCs),
            and polychlorinated  biphenyls (PCBs).

            EPA's TSCA Assistance Information Service, at (202)  554-1404, answers
            questions   and  distributes guidance  pertaining  to  Toxic  Substances
            Control Act  standards.  The  Service operates from 8:30  a.m. through
            4:30 p.m., EST, excluding Federal holidays.
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  Clean Air Act
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              The Clean Air Act (CAA) and its amendments, including the Clean Air
              Act Amendments (CAAA) of 1990, are designed to "protect and
              enhance the nation's air resources so as to promote the public health
              and welfare and the productive capacity of the population."  The CAA
              consists of six sections, known as Titles, which direct EPA to establish
              national standards for ambient air quality and for EPA and the States to
              implement, maintain, and enforce these standards  through a variety of
              mechanisms.  Under the CAAA, many facilities  will be  required to
              obtain  operating  permits  for the  first time.   State  and  local
              governments oversee, manage, and enforce many of the requirements
              of the CAAA. CAA. regulations appear at 40 CFR Parts 50-99.

             Pursuant to Title I of the CAA, EPA  has established national ambient
             air quality standards (NAAQSs) to limit levels of  "criteria  pollutants,"
             including carbon monoxide, lead, nitrogen dioxide, particulate  matter,
             ozone, and sulfur dioxide.  Geographic areas that meet NAAQSs for a
             given pollutant  are  classified as attainment areas; those that  do not
             meet NAAQSs are classified as non-attainment  areas.  Under §110 of
             the CAA, each State must develop a State Implementation Plan (SIP) to
             identify sources  of air pollution and to determine what reductions are
             required to meet Federal air quality standards.

             Title I also authorizes EPA to  establish  New Source  Performance
             Standards (NSPSs), which are nationally uniform  emission standards
             for new  stationary  sources  falling within  particular  industrial
             categories.  NSPSs are based  on the pollution  control technology
             available to that category of industrial source but allow the affected
             industries the flexibility to devise a cost-effective  means of  reducing
             emissions.

             Under  Title  I,  EPA establishes  and enforces National  Emission
             Standards  for Hazardous  Air Pollutants (NESHAPs),  nationally
             uniform standards oriented towards controlling particular  hazardous
             air pollutants (HAPs).  Title III  of the CAAA further directed EPA to
             develop a  list  of sources that emit any of 189 HAPs, and to develop
             regulations for these categories of sources. To date EPA has listed 174
             categories and developed a schedule for the establishment of  emission
             standards.  The emission standards will be developed  for both new and
             existing  sources based on "maximum achievable control technology"
             (MACT). The MACT is defined as the control technology achieving the
             maximum  degree of reduction  in the emission  of the HAPs, taking
             into account cost and other factors.
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            Title E of the CAA pertains to mobile sources, such as cars, trucks,
            buses,  and planes.   Reformulated  gasoline,  automobile pollution
            control devices, and vapor recovery nozzles on gas pumps are a few of
            the mechanisms EPA uses to regulate mobile air emission sources.

            Title IV establishes a  sulfur dioxide emissions program designed to
            reduce the formation of acid rain.  Reduction of sulfur dioxide releases
            will be  obtained by  granting  to certain sources limited emissions
            allowances, which, beginning in 1995, will be set below previous levels
            of sulfur dioxide releases.

            Title V of the CAAA of 1990 created an operating permit program for
            all "major sources" (and certain other sources) regulated under the
            CAA.   One purpose of the operating permit is to include in a single
            document all air emissions  requirements that apply to a given facility.
            States  are developing the permit programs in accordance with  guidance
            and regulations from EPA.  Once a State program is approved by EPA,
            permits will be issued and monitored by that State.

            Title VI is intended to protect stratospheric  ozone by phasing out the
            manufacture of ozone-depleting chemicals and restrict their use  and
            distribution.  Production of Class I substances, including 15 kinds of
            chlorofluorocarbons (CFCs), will be phased out entirely by the year
            2000,  while certain hydrochlorofluorocarbons (HCFCs) will be phased
            out by 2030.

             ERA'S Control Technology  Center,  at  (919)  541-0800, provides general
             assistance and  information on CAA  standards.   The Stratospheric
             Ozone Information  Hotline,   at  (800)  296-1996,  provides general
             information about  regulations  promulgated under Title VI  of  the CAA,
             and EPA's  EPCRA Hotline, at  (800) 535-0202,  answers  questions about
             accidental release  prevention  under CAA  §112(r).   In addition, the
             Technology  Transfer  Network  Bulletin  Board  System  (modem  access
             (919)  541-5742))  includes recent CAA rules,  EPA  guidance documents,
             and updates of EPA activities.


 VLB.       Industry Specific Regulations

             Though production  processes associated with the  industries listed
             under SIC 37 have few specific regulatory requirements, the diverse
             and complex nature of the industry makes it one of the most heavily
             regulated industries in the manufacturing sector.

             The large number of facilities engaged in activities covered by SIC 37, as
             well  as  the  diversity of processes and products involved, make it
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             difficult to provide a precise regulatory framework; the statutes and
             regulations governing a producer of a specific part which uses a specific
             manufacturing process will differ significantly from those affecting an
             integrated manufacturing plant performing foundry, metal finishing,
             and painting operations.  Thus, the discussion which follows identifies
             those regulations that are of concern to the industry at large.

 VI.B.l.      Clean Water Act (CWA)

             The Clean Water Act regulates the amount of chemicals/toxics released
             by industries via direct and indirect wastewater/effluent discharges.
             Regulations developed  to  implement  this Act establish effluent
             guidelines and standards for different industries.  These  standards
             usually set concentration-based limits  on  the discharge of a given
             chemical by any one facility.  If a facility is discharging directly into a
             body  of  water,  it  must obtain a National  Pollution  Discharge
             Elimination System (NPDES)  permit.  However, if a  facility  is
             discharging  to a  publicly owned  treatment works (POTW), it must
             adhere to the specified pretreatment standards.  (Information provided
             by Chrysler indicates that all of the company's manufacturing facilities
             discharge process wastewater to POTWs.  Much of their water is treated
             at an on-site industrial wastewater treatment plant prior to discharge to
             the POTW.)

             The following regulations are potentially  applicable to various stages in
             the auto  and  auto  parts manufacturing  and  assembly  processes.
             Because so many regulations are potentially  applicable to segments of
             the industry, we have  divided the regulations into  the following
             categories: foundry/metal forming  operations; metal  finishing
             operations; and painting operations.

Foundry/Metal Forming Operations

             The following effluent guidelines and standards are applicable  to the
             activities performed  during the foundry/metal forming operations.

                  Iron and Steel Manufacturing (40 CFR Part 420)
                  Metal Molding and Casting (40 CFR Part 464)
                  Aluminum Forming (40 CFR Part 467)
                  Copper Forming (40 CFR Part 468)
                  Nonferrous Forming (40 CFR Part 471)
                  Lead-Tin-Bismuth Forming Category (40 CFR Part 471
                  Subpart A)
                  Zinc Forming Subcategory (40 CFR Part 471, Subpart H).
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Metal Finishing Operations

            The following effluent guidelines and standards are applicable to metal
            finishing activities:

            •     Electroplating (40 CFR Part 413)
            •     Metal Finishing (40 CFR Part 433)
            •     Coil Coating (40 CFR Part 465).

            The standards applicable to  metal finishing regulate  discharges
            resulting from numerous activities  performed by manufacturers of
            autos and auto parts.  The metal finishing and electroplating guidelines
            address discharges from the following six activities:  (1) electroplating;
            (2) electroless plating; (3) anodizing; (4) coating; (5) chemical etching
            and milling; and  (6) printed circuit  board manufacturing.   If one of
            these operations is performed, the metal finishing guidelines provide
            effluent  standards for 40 additional  operations, including machining;
            grinding; polishing; welding; soldering; and solvent degreasing.

VLB.2.      Clean Air Act (CAA)

            Several existing regulations promulgated under the CAA are applicable
            to  various  stages in  the automobile production process.  These are
            discussed below.

            The Standards of Performance for Automobile and Light Duty Truck
            Surface Coating Operations (40 CFR Part 60, subpart MM) are applicable
            to  assembly plant operations where prime coats,  guide coats,  and
            topcoats  are applied.  These standards prohibit assembly plants  that
            begin construction, modification, or reconstruction after October 5, 1979
            from discharging VOC emissions in excess of:

             •     0.16 kg of VOC  per liter of applied coating solids from each prime
                  coat,

             •     1.40 kg of VOC  per liter of applied coating solids from each guide
                  coat operation, and/or

             •     1.47 kg of VOC  per liter of applied coating solids from each top
                  coat.

            The Standards of Performance for Metal Coil Surface Coating (40  CFR
            Part  60, subpart TT)  may be  relevant  to  some  facilities in the
             automotive industry.  This standard regulates the discharge of VOCs.

             The Standards of Performance for Fossil-Fired Steam  Generators for
             Which Construction Commenced after August  17,1971 (40 CFR Part 60,
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             subpart D) are applicable to motor vehicle plants which have fossil-
             fuel-fired steam generating units of more that 73 megawatts (MW) heat
             input rate and fossil-fuel and wood-residue-fired steam generating
             units capable of firing fossil fuel at a rate of more that 73 MW (though
             these standards do riot apply to electric utility steam generating units).

             The  regulations set emissions standards for sulfur dioxide, particulate
             matter,  and nitrogen oxides,  and contain compliance, performance,
             emissions  testing, and recordkeeping requirements.

             The  Standards of Performance  for Small Industrial-Commercial-
             Institutional Steam Generating Units (40 CFR Part 60 subpart DC) apply
             to motor  vehicle and  motor vehicle equipment plants which have
             steam generating units for which  construction, modification, or
             reconstruction is commenced  after June  9,  1989  and  that  have a
             maximum design capacity of 29 MW input capacity or less, but greater
             than or equal to 2.9 MW.

             These regulations set  emissions  standards  for  sulfur dioxide  and
             particulate matter  and require certain  compliance, performance,
             emissions testing, and recordkeeping requirements.

             National Emission  Standards  for Hazardous  Air Pollutants for
             Industrial Process Cooling Towers (40 CFR Part 63, subpart Q) apply to
             motor vehicle  and motor vehicle  equipment plants  that have
             industrial  process cooling towers (IPCTs) that  are operated  with
             chromium-based water treatment chemicals  and  are  either major
             sources or  are integral parts of facilities that are major sources. Major
             sources are those  sources that emit or have the potential to  emit 10
             tons per year or more of any hazardous air pollutant or 25 tons per year
             or more of any combination of hazardous air pollutants.

             The standards  prohibit  the use of chromium-based  water treatment
             chemicals in:

                  Existing IPCTs on or after March 8,1996, and/or

             •     New IPCTs (IPCTs for which construction or reconstruction
                  commenced after August 12, 1993) on or after September 8, 1994.
Chromium Electroplating
            Human health studies suggest that various adverse effects result from
            acute, intermediate, and chronic exposure to chromium. As a result,
            in January 1995, EPA established  National Emission  Standards for
            Chromium  Emissions  From Hard  and  Decorative  Chromium
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            Electroplating And Chromium Anodizing Tanks (40 CFR Part 9 and 63,
            Subpart N)  The regulation is  an MACT-based performance standard
            that  sets limits on chromium and chromium compounds  emissions
            based  upon concentrations  in the  waste  stream  (e.g.,  mg  of
            chromium/m^ of air).

            EPA holds that these performance standards allow a degree of flexibility
            since facilities  may choose their own technology as long  as  the
            emissions limits (established by the MAGT)  are  achieved.  The
            standards differ according to the sources (e.g., old sources of chromium
            emissions will have different standards than new ones),  further
            reducing the standards' rigidity.

VI.B.3.      Comprehensive Environmental Response. Compensation,  and—
            Liability Act rCERCLA)

            CERCLA has had a much greater impact on the Big Three with facilities
            built before RCRA's enactment than it  has had  on the so-called
            transplant companies which have newer plants.

VLB .4.      Resource Conservation and Recovery Act (RCRA)

            RCRA was  passed in 1976,  as an  amendment to  the  Solid Waste
            Disposal Act,  to  ensure  that solid wastes  are  managed in  an
            environmentally sound manner.  A material is classified under RCRA
            as a hazardous waste if the material meets  the definition of solid waste
            (40 CFR 261.2),  and that  solid waste material exhibits one of the
            characteristics of a hazardous waste (40 CFR 261.20-24) or is specifically
            listed as a hazardous waste (40 CFR 261.31-33). A material defined as a
            hazardous waste is then subject to Subtitle C generator (40 CFR 262),
            transporter  (40 CFR 263), treatment, storage, and disposal  facility (40
            CFR 254 and 265) and land disposal requirements (40 CFR 268).  The
            motor vehicle and motor vehicle equipment manufacturing industry
            must be concerned with the regulations  addressing all  these. Most
            automobile  and light truck assembly and component  manufacturing
            facilities are not considered hazardous waste treatment,  storage or
            disposal facilities requiring RCRA permits, although they may generate
            hazardous waste subject to RCRA management requirements.

            The greatest quantities  of RCRA listed waste  and characteristically
            hazardous waste are identified in Exhibit 25.  For more information on
            RCRA hazardous waste, refer to 40 CFR Part 261.
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                                           Exhibit 25
                Hazardous Wastes Relevant to the Automotive Industry
  EPA Hazardous
    Waste No.
                             Hazardous Waste
 D001
 Wastes which are hazardous due to the characterization of ignitibility
 D002
 Wastes which are hazardous due to the characteristic of corrosivity
 D006 (cadmium)
 D007 (chromium)
 D008 (lead)
 D009 (mercury)
 D010 (selenium)
 D011 (silver)
 D035 (methyl
 ethyl ketone)
 D039
 (tetrachloro-
 ethylene)
 D040 (trichloro-
 ethylene)	•
 Wastes which are hazardous due to the characteristic of toxicity for each of
 the constituents.
 F001
Halogenated solvents used in degreasing: tetrachloroethylene, methylene
chloride, 1,1,1-trichloroethane, carbon tetrachloride, and chlorinated
fluorocarbons; all spent solvent mixtures/blends used in degreasing containing,
before use, a total of 10% or more (by volume) of one or more of the above
halogenated solvents or those solvents listed in F002, F004, and F005; and still
bottoms from the recovery of these spent solvents and spent solvent mixtures.
F002
Spent halogenated solvents; tetrachloroethylene, methylene chloride,
trichlorethylene, 1,1,1-trichloroethane chlorobenzene, l,l,2~trichloro-l,2,2-
trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2-
trichloroethane; all spent solvent mixtures/blends containing, before use, one
or more of the above halogenated solvents or those listed in F001, F004, F005;
and still bottoms from the recovery of these spent solvents and spent solvent
mixtures.
F003
Spent non-halogenated solvents: xylene, acetone, ethyl acetate, ethyl benzene,
ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and
methanol; all spent solvent mixtures/blends containing, before use, only the
above spent non-halogenated solvents; and all spent solvent mixtures/blends
containing, before use, one or more of the above non-halogenated solvents, and,
a total of 10% or more (by volume) of one of those solvents listed in F001, F002,
F004, F005; and still bottoms from the recovery of these spent solvents and
spent solvent mixtures.
F004
Spent non-halogenated solvents: cresols and cresylic acid, and nitrobenzene;
all spent solvent mixtures/blends containing, before use, a total of 10% or more
(by volume) of one or more of the above non-haiogenated solvents or those
solvents listed in F001, F002, and F005; and still bottoms from the recovery of
these spent solvents and spent solvent mixtures.
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                               Exhibit 25 (cont'd)
             Hazardous Wastes Relevant to the Automotive Industry
EPA Hazardous
Waste No.
F005
F006
F007
F008
F009
F010
F011
F012
F019
Source: Sustainable
~~ Hazardous Waste
Spent non-halogenated solvents: toluene, methyl ethyl ketone, carbon
disulfide, isobutanol/pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane;
aU spent solvent mixtures/blends containing, before use, a total of 10% or more
(by volume) of one or more of the above non-halogenated solvents or those
solvents listed in F001, F002, or F004; and still bottoms from the recovery of
these spent solvents and spent solvents mixtures.
Wastewater treatment sludges from electroplating operations except from the
following processes: (1) sulfuric acid anodizing of aluminum; (2) tin plating on
carbon steel; (3) zinc plating (segregated basis) on carbon steel; (4) aluminum or
zinc-aluminum plating on carbon steel; (5) cleaning/stripping associated with
tin, zinc, and aluminum plating on carbon steel; and (6) chemical etching and
milling of aluminum. ^^^_ 	 . 	 __
Spent cyanide plating bath solutions from electroplating operations.
Plating bath residues from the bottom of plating baths from electroplating
operations where cyanides are used in the process."
Spent stripping and cleaning bath solutions from electroplating operations
where cyanides are used in the process.
Quenching bath residues from oil baths from metal heat treating operations
where cyanides are used in the process. • •
Spent cyanide solutions from salt bath pot cleaning from metal heat treating
operations. 	 ' • ' 	 	 	 . 	
Quenching waste water treatment sludges from metal heat treating operations
where cyanides are used in the process.
Wastewater treatment sludges from the chemical conversion coating of
aluminum except from zirconium phosphating in aluminum can washing when
suchphosphating is an exclusive conversion coating process.


Industry- Promoting Strategic Environmental Protection in the Industrial Sector, Phase 1 Report,
y' EPA, OERR, June 1994. . '
 VI.C.       Pending and Proposed Regulatory Requirements

             Numerous regulatory requirements which might affect the
             automotive industry are under consideration.  Summaries of some of
             these potential future regulations are discussed below.
 VI.C.1.
Motor Vehicle Parts Manufacturing
 Clean Water Act (CWA)
             Although Congress did not reauthorize the Clean Water Act in 1994,
             future legislative requirements and/or reform may impact the motor
             vehicle manufacturer.  Several of the regulations currently under
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             consideration or development will have a significant impact on the
             automotive  industry.   The effluent  guidelines  and standards for
             Electroplaters (40 CFR Part 413) and Metal Finishers (40 CFR Part 433)
             are currently under review. EPA is also currently developing effluent
             guidelines  and standards  for the  metal products and  machinery
             industry (Phase II, 40 CFR Part 438), which are Scheduled to be finalized
             by December 1999.  It is likely that EPA will integrate new regulatory
             options for metal finishing industry processes into this guideline.

             The Effluent Guidelines  and  Standards for the Metal Products and
             Machinery  Category,  Phase  II,  will propose effluent  limitation
             guidelines for facilities that  generate wastewater  while  processing
             metal parts, metal  products and machinery, including: manufacture,
             assembly, rebuilding, repair, and maintenance. The Phase II regulation
             will cover eight major industrial groups, including: motor vehicles,
             buses  and   trucks, household equipment,  business equipment,
             instruments, precious  and nonprecious metals,  shipbuilding, and
             railroads. The court-ordered deadline is December 31,1997.

Clean Air Act (CAA)

             In addition to the CAA requirements discussed above, EPA is currently
             working on several regulations that  will  directly affect the metal
             finishing portion of the motor vehicle manufacturing industry. Many
             proposed standards  will  limit  the  air emissions from  various
             industries by proposing  Maximum Achievable Control Technology
             (MACT) based performance standards that will set limits on emissions
             based.upon  concentrations of pollutants in the waste stream.  Various
             potential standards are described below.

Organic  Solvent  Degreasing/Cleaning

            EPA has also proposed a NESHAP (58 FR 62566, November 19,1993) for
            the source category of halogenated solvent degreasing/cleaning that
            will directly affect the metal finishing industry. This will apply to new
            and  existing organic  halogenated solvent emissions  to  a  MACT-
            equivalent  level,   and will apply to  new  and  existing organic
            halogenated solvent cleaners (degreasers) using any of the HAPs listed
            in the CAA Amendments.   EPA is  specifically  targeting vapor
            degreasers  that  use  the following  HAPs:   methylene  chloride,
            perchloroethylene,  trichloroethylene,  1,1,1-trichloroethane,  carbon
            tetrachloride, and chloroform.

            This NESHAP proposes to implement a MACT-based equipment and
            work practice compliance  standard. This would require that a facility
            use a designated type  of pollution prevention technology along with
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            proper operating procedures.  EPA has also provided an alternative
            compliance standard. Existing operations, which utilize performance-
            based standards, can continue  if they reach the same limit as the
            equipment and work practice compliance standard.
Steel Picklinv. HCl
VLC2.
            Hydrochloric acid (HCl) and chlorine are among the pollutants listed as
            hazardous  air pollutants  in  Section 112  of the  Clean Air Act
            Amendments of 1990.  Steel pickling processes that use HCl solution
            and HCl regeneration processes have been identified by the  EPA as
            potentially significant sources of HCl and chlorine air emissions and, as
            such,  a source category for which national emission standards may be
            warranted.  EPA is required to promulgate national emission standards
            for 50 percent of the source categories listed in Section  112(e) by
            November  15, 1997.  EPA plans  to promulgate this  standard by
            September 30,1996.
Motor Vehicle Painting/Finishing
Clean Air Act (CAA)
            The 1990 CAAA identified a number of ozone non-attainment areas
            throughout the U.S. and gave those States most affected by high VOC
            emissions until November 1993 to develop implementation plans to
            combat the problem. The legislation further required that States reduce
            VOCs by 15 percent by 1996 and that States with extreme problems
            reduce emission an additional three percent each  year following.
            Although State VOC limits have been established, national limits have
            not. A national rule on VOC limits is likely to come next year.

            VOCs are  one  of  the primary emissions from the  automotive
            painting/finishing  process and come from  common  paint solvents.
            Though  no standards are currently proposed, industry  officials are
            making their thoughts known.   According to Ron Hilovsky, manager
            of regulatory affairs for PPG Fleet Finishes, as stated in an August 1994
            article in Heavy Duty Trucking entitled "You Can Breath Easier, "
            national limits will effectively eliminate lacquer products and systems.

            According to Heavy Duty Trucking,  limits for paints and finishes are
            likely to be based on the pounds of VOCs released per gallon. Most
            topcoats have VOC levels of 5.5 Ibs/gallon or more.  New limits on
            VOCs are likely to be as follows:

            •      Pretreat/wash primer - 6.5 Ibs./gallon
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                    Primer/primer surfacer - 4.6 Ibs./gallon

                    Primer sealer - 4.6 Ibs./gallon

                    Topcoats (including single-stage solids and metallics and
                    basecoat/clearcoat) - 5.0 Ibs./gallon

                    Tri and quad coat basecoat/clearcoat - 5.2 Ibs./gallon

                    Specialty coatings - 7.0 Ibs./gallon.
 VI.C.3.      Motor Vehicle Dismantling/Shredding

             According  to  AAMA, future  U.S.  regulatory activity  affecting the
             vehicle recycling process, if it occurs at all, is likely to aim at improving
             the  efficiency  of  the  existing and  already  successful  market
             infrastructure.  For example, it may promote:


             •     Common definitions and terms

             •     Market incentives for the use of recycled materials, and

             •     Common standards for operating dismantling and shredding
                   facilities
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VII.         COMPLIANCE AND ENFORCEMENT HISTORY

Background

            To date, EPA  has focused  much  of  its attention on measuring
            compliance with specific environmental statutes.   This approach
            allows the Agency to track compliance with the Clean  Air Act, the
            Resource Conservation and Recovery Act, the Clean Water Act, and
            other environmental  statutes.   Within  the  last several years, the
            Agency has begun to  supplement single-media compliance indicators
            with facility-specific, multimedia indicators of compliance. In doing so,
            EPA is in a better position to  track compliance with all statutes at the
            facility level, and within specific industrial sectors.

            A major step  in building the  capacity to  compile multimedia data for
            industrial sectors  was the  creation of EPA's  Integrated  Data  for
            Enforcement Analysis (IDEA) system. IDEA has the capacity to "read
            into" the Agency's single-media databases, extract compliance records,
            and match the records to individual facilities.  The IDEA system can
            match  Air,  Water,  Waste,  Toxics/Pesticides/EPCRA,  TRI,  and
            Enforcement Docket records for a given facility,  and generate a list of
            historical permit, inspection, and enforcement activity.  IDEA also has
            the capability to analyze data  by geographic area and corporate holder.
            As the capacity to generate multimedia compliance data improves, EPA
            will  make  available more  in-depth compliance  and  enforcement
            information.   Additionally,  sector-specific  measures  of success for
            compliance assistance efforts are under development.

 Compliance and Enforcement Profile Description

            Using inspection, violation,  and  enforcement  data from the  IDEA
            system, this  section  provides information regarding the  historical
            compliance and enforcement  activity of this sector.  In order to mirror
            the facility universe reported in the Toxic Chemical Profile, the data
            reported within this section consists of records only from the TRI
            reporting universe.  With this  decision, the  selection criteria are
            consistent across sectors with  certain exceptions.  For the sectors that do
            not normally report to the TRI program, data have been provided from
            EPA's Facility Indexing System (FINDS) which tracks facilities in all
            media databases. Please note, in this section, EPA does not attempt to
             define the actual number of facilities that fall within each  sector.
             Instead, the section portrays  the records of a subset of facilities within
             the sector that are well defined within EPA databases.

             As a check  on the  relative size of the full sector  universe,  most
             notebooks contain an estimated number of facilities within the sector
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             according  to the  Bureau of Census (See Section II).  With sectors
             dominated by small businesses, such as metal finishers and printers,
             the reporting universe within the  EPA  databases may be small in
             comparison to Census data.  However, the group selected for inclusion
             in this data analysis section should be consistent with this sector's
             general make-up.

             Following  this  introduction  is  a  list defining each  data  column
             presented within this section.  These values represent a retrospective
             summary of inspections and enforcement actions,  and solely reflect
             EPA, State, and local compliance assurance activities that have been
             entered into EPA databases.  To identify any changes in trends, the EPA
             ran two data queries, one for the past five calendar years  (August 10,
             1990 to August 9,1995) and the other for the most recent twelve-month
             period (August 10,1994 to August 9,1995).  The five-year analysis gives
             an average level of activity for that period for comparison to the more
             recent activity.

             Because most inspections focus on single-media requirements, the data
             queries presented in this section are taken from single media databases.
             These databases do not  provide data on whether inspections  are
             State/local or EPA-led.  However, the table breaking down the universe
             of violations does  give the reader a  crude measurement of the EPA's
             and States' efforts within each media program.  The presented data
             illustrate the variations across regions  for  certain sectors.2  This
             variation may be attributable  to State/local data entry variations,
             specific geographic concentrations,  proximity to population centers,
             sensitive  ecosystems, highly toxic chemicals  used in production, or
             historical noncompliance.   Hence,  the exhibited  data  do  not rank
             regional performance or necessarily reflect  which regions may have the
             most compliance problems.

Compliance and Enforcement Data Definitions

General Definitions

             Facility Indexing  System (FINDS)  — this system assigns a common
             facility number  to EPA  single-media permit records.   The  FINDS
             identification number allows EPA to compile and  review all permit,
2  EPA Regions include the following States: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI)- III
(DC, DE, MD, PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V DL, IN, MI, MN, OH, WI); VI
(AR, LA, NM, OK, TX); VII (IA, KS, MO, NE); VHI (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI,
NV, Pacific Trust Territories); X (AK, ID, OR, WA).
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            compliance, enforcement, and pollutant  release data for any given
            regulated facility.

            Integrated Data for Enforcement Analysis (IDEA) - is a data integration
            system  that can retrieve information from the major EPA program
            office databases. IDEA uses the FINDS identification number to "glue
            together" separate data records from EPA's databases.  This is done to
            create a "master  list" of data records for any given facility.  Some of the
            data systems accessible through IDEA are: AIRS (Air Facility Indexing
            and Retrieval System, Office of Air and  Radiation), PCS (Permit
            Compliance System, Office of Water), RCRIS  (Resource Conservation
            and Recovery Information System,  Office of Solid Waste), NCDB
            (National Compliance  Data Base, Office of Prevention, Pesticides, and
            Toxic Substances),  CERCLIS  (Comprehensive  Environmental and
            Liability Information  System,  Superfund),  and TRIS (Toxic Release
            Inventory  System).   IDEA also contains information from outside
            sources such as  Dun and Bradstreet and the Occupational Safety and
            Health  Administration (OSHA).  Most  data queries displayed  in
            notebook Sections IV and VII were conducted using IDEA.

Data Table Column Heading Definitions

            Facilities in Search - are based on the universe of TRI reporters within
            the listed  SIC  code range.  For industries not covered under TRI
            reporting requirements, the  notebook uses the  FINDS universe for
            executing data queries. The SIC code range selected for each search is
            defined by each notebook's selected SIC  code coverage described in
            Section n.

            Facilities  Inspected — indicates the level of EPA and State agency
            facility  inspections for the  facilities in this data search.  These values
            show what percentage of the facility universe is inspected in a 12 or 60
            month  period.   This column  does not  count  non-inspectional
            compliance activities such as the review of  facility-reported discharge
            reports.

            Number of  Inspections ~ measures the total number of inspections
            conducted  in titiis sector. An inspection event is counted each time it is
            entered into a single media database.

            Average Time  Between Inspections — provides an average length of
            time, expressed in months, that a compliance inspection occurs at a
            facility within the defined universe.
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             Facilities  with One or More  Enforcement Actions — expresses the
             number of facilities that were party to at least one enforcement action
             within the defined time period.  This category is broken down further
             into Federal and State actions.   Data are obtained for administrative,
             civil/judicial, and criminal enforcement  actions.   Administrative
             actions include Notices of Violation  (NOVs). A facility with multiple
             enforcement actions is  only counted  once in this column (facility with
             3 enforcement actions  counts as 1).   All percentages that appear are
             referenced to the number of facilities  inspected.

             Total  Enforcement  Actions  —  describes the  total  number  of
             enforcement actions identified for  an industrial sector  across  all
             environmental statutes. A facility with multiple enforcement  actions
             is counted multiple times (a facility with 3 enforcement actions counts
             as 3).

             State Lead Actions — shows what percentage of the total enforcement
             actions are taken by State and local environmental agencies. Varying
             levels of use by States  of EPA  data systems may limit the volume of
             actions accorded State  enforcement activity. Some States extensively
             report enforcement activities into EPA data systems, while other States
             may use their own data systems.

             Federal Lead Actions — shows what percentage of the total enforcement
             actions are taken by the U.S.  EPA. This value includes referrals from
             State agencies.  Many of these actions result from coordinated or joint
             State/Federal efforts.

             Enforcement to Inspection Rate — expresses how often enforcement
             actions result from inspections.  This value is a ratio of enforcement
             actions to inspections, and is presented for comparative purposes only.
             This  measure is a  rough  indicator of  the relationship between
             inspections  and  enforcement.   This measure simply  indicates
             historically  how  many enforcement actions can be  attributed  to
             inspection  activity.  Related inspections and enforcement actions under
             the Clean Water Act (PCS), the  Clean Air Act (AFS) and the Resource
             Conservation and  Recovery Act (RCRA)  are included in this ratio.
             Inspections and actions from the TSCA/FIFRA/EPCRA database are
             not factored into this ratio because most  of the actions taken under
             these programs are not the result of facility inspections.  This ratio does
             not  account for enforcement  actions  arising  from non-inspection
             compliance monitoring activities (e.g., self-reported water discharges)
             that can result in enforcement action within the CAA,  CWA and
             RCRA.
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            Facilities  with One or More Violations Identified — indicates the
            number and percentage of inspected facilities having  a  violation
            identified in one of the following data categories:   In Violation or
            Significant  Violation  Status (CAA);  Reportable  Noncompliance,
            Current Year Noncompliance,  Significant  Noncompliance (CWA);
            Noncompliance and Significant Noncompliance (FIFRA,  TSCA,  and
            EPCRA);  Unresolved  Violation and Unresolved High  Priority
            Violation  (RCRA).  The values presented for  this column reflect the
            extent of noncompliance within the measured  time frame, but do not
            distinguish between the severity of the noncompliance.  Percentages
            within this column can exceed 100% because facilities can be in
            violation status without being inspected.  Violation status may be a
            precursor to an enforcement action, but does not necessarily indicate
            that an enforcement action will occur.

            Media Breakdown of  Enforcement Actions and Inspections — four
            columns identify  the proportion of total inspections  and enforcement
            actions within EPA Air, Water, Waste,  and TSCA/FIFRA/EPCRA
            databases.   Each  column is a  percentage  of  either  the  "Total
            Inspections," or the "Total Actions" column.


VILA.      Motor Vehicles and Motor Vehicle Equipment Compliance History

            Exhibit 26 provides a Regional breakdown of the five year enforcement
            and compliance activities for the automobile industry. Of 2,734 total
            inspections performed  during the five-year period, 1,255 (46 percent)
            were  conducted  in Region V.   This  large percentage is due to the
            concentration of automobile manufacturers in the Great Lakes Region.
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                                       Motor Vehicle Assemblv Industrv
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VII.B.       Comparison of Enforcement Activity Between Selected Industries

            Exhibits 27-30 contain summaries of the one and five year enforcement
            and compliance activities  for the motor vehicles and motor vehicle
            equipment industry, as well as for other  industries.  As shown in
            exhibits 27 and 28, the automotive industry has a moderately  high
            enforcement  to  inspection rate when compared to other industries.
            Exhibits 29 and 30 provide a breakdown of inspection and enforcement
            activities  by  statute.   Of all  the  automotive facilities inspected,
            approximately 54 percent were performed under RCRA and 33 percent
            under CAA.  The large percentages of CAA and RCRA inspections for
            this industry  are due to the high levels of VOC emissions released
            during solvent-intensive manufacturing processes.  The  low number
            of CWA inspections is  fairly surprising due the large quantities of
            water used during metal finishing and painting/finishing processes.
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                                       107
                                                                              SIC Code 37

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Motor Vehicle Assembly Industry
                                                          Sector Notebook Project
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                             108
September 1995

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                                                                   Sector Notebook Project
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-------
  Sector Notebook Project
  VII.C.       Review of Major Legal Actions

              As indicated in EPA's Enforcement Accomplishments Report, FY 1991,
              FY 1992, and FY 1993 publications, eight significant enforcement cases
              were resolved between 1991 and 1993 for the motor vehicle industry.
              Two  of these cases involved CAA violations, two were comprised of
              CERCLA violations, while the other  four  involved  one RCRA,  one
              TSCA,  one CWA, and one action involving  violations of multiple
              statutes.  The companies against which  the cases were brought are
              primarily motor vehicle and motor vehicle parts manufacturers.


 VII.C. 1.      Review of Major Casps

             This section provides  summary information about major cases that
             have  affected this sector.   Four of the  eight cases  resulted in  the
             assessment of  a civil penalty.  Penalties  ranged from  $50,000 to
             $1,539,326, and the average civil penalty paid was $691,965.  In three
             cases, the defendant was required to spend additional money to
             improve production processes or technologies, and to increase further
             compliance.  For example,  in  U.S. v. General Motors Corporation
             (1991), a consent decree was entered requiring GM to install a coating
             system  that reduces VOCs from  its paint shop operations from
             approximately 3,400 tons per year to 750-800 tons per year. GM also
             paid a civil penalty of $1,539, 326.

             A Supplemental Environmental Project (SEP) was required in one of
             the  cases.   The  settlement in In the  Matter of  the  KnaphpiHn
             Manufacturing  Co., includes  SEPs to partially offset the $428,533
             penalty.  The initial SEP requires performance of an environmental
             compliance audit, which will identify and propose additional SEPs as
             binding  commitments.

             M U-S. v.  Raymark Industries,  Inc.  (1991), the Department of Justice
             filed a civil complaint requesting that the court  order the company to
             study  and perform corrective action at its  facility  in Stratford, CT.
             Raymark had manufactured automobile  brakes and friction products at
             this  34-acre facility and had disposed of its  hazardous  wastes
             (principally lead-asbestos wastes and dust) onsite.  In some areas, this
             lead-asbestos fill is  17 feet deep. The complaint requests that the court
             order Raymark to comply with an administrative order issued by EPA
             in 1987, pursuant to §3031 of RCRA, which instructs the company to
             study its site in order to ascertain the nature  and extent of the hazard
             created by the presence  and release of hazardous waste.  Raymark has
            failed to  comply with the terms of the order.  Based on the results  of
September 1995
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                                                                    SIC Code 37

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Motor Vehicle Assembly Industry
Sector Notebook Project
            this study, the complaint also requests that Raymark be ordered to carry
            out a corrective action plan as approved by EPA.

            In U.S. v. Chrysler Corporation et. al. (1993), the court entered a
            CERCLA  consent decree under which the settling defendants will
            clean up the PCB contamination at the Cater Industrials Superfund site
            in Detroit, Michigan and pay about $3 million in past costs.  The total
            cost of the cleanup is estimated to be $24 million  Settling defendants
            include Chrysler, Ford, GM, Michigan's two public utilities,  and the
            City of Detroit. Unusual features of the  decree include provisions for
            EPA to perform some of the work, and a special covenant not to sue in
            accordance with §122(f)(2) of CERCLA.

VII.C.2.     Supplemental Environmental Projects

            Below is list of Supplementary Environmental Projects (SEPs).  SEPs
            are compliance agreements that reduce a facility's stipulated penalty in
            return for an  environmental project that exceeds the value  of  the
            reduction. Often, these projects fund  pollution prevention activities
            that can significantly reduce the future pollutant loadings of a facility.

            In December, 1993, the Regions were asked  by EPA's Office of
            Enforcement and Compliance Assurance to provide  information on
            the number and  type of SEPs entered into by the Regions. Exhibit 31
            contains a sample of the Regional responses addressing the automotive
            industry.    The  information  contained  in  the   chart  is   not
            comprehensive and  provides only  a  sample of the types  of SEPs
            developed for the automotive industry.
 SIC Code 37
                                    112
      September 1995

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 Sector Notebook Project












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September 1995
113
SIC Code 37

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Motor Vehicle Assembly Industry
Sector Notebook Project
VIII.        COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES

            This section highlights the activities undertaken by this industry sector
            and public agencies to voluntarily improve the sector's environmental
            performance. These activities include those independently initiated by
            industrial trade associations. In this section, the notebook also contains
            a listing and description of national and regional trade associations.


VIII.A.      Sector-Related Environmental Programs and Activities

            The automotive industry is involved in  numerous  sector-related
            environmental activities. Some of these efforts are highlighted below.

Common Sense  Initiative

            The Common Sense Initiative (CSI), a partnership between EPA and
            private industry, aims  to create environmental protection strategies
            that are cleaner for the environment and cheaper  for industry and
            taxpayers.  As part of CSI, representatives from Federal, State, and local
            governments;   industry;   community-based  and   national
            environmental organizations; environmental justice groups; and labor
            organizations,  come  together  to examine  the  full  range   of
            environmental  requirements affecting the following six selected
            industries:  automobile manufacturing; computers and electronics,
            iron and steel, metal finishing, petroleum refining, and printing.

            CSI participants are looking for solutions that:

            •     Focus on the industry as a whole rather than one pollutant

            •     Seek consensus-based solutions

            •     Focus on pollution prevention rather than end-of-pipe controls

            •     Are  industry-specific.


            The Common  Sense Initiative Council  (CSIC), chaired  by EPA
            Administrator  Browner,  consists of  a  parent council  and  six
            subcommittees (one per industry sector).  Each  of the subcommittees
            have met and  have identified issues and project  areas for emphasis,
            and  workgroups  have  been  established  to  analyze  and  make
            recommendation on these issues.
 SIC Code 37
                                   114
      September 1995

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Sector Notebook Project
                 Motor Vehicle Assembly Industry
EPA/Auto  Protocol
            Procedures for assessing compliance during automobile painting and
            finishing operations  were first outlined in a  December 1988 EPA
            publication entitled, Protocol for Determining  the  Daily Volatile
            Organic Compound  Emission Rate of Automobile and Light-Duty
            Truck Topcoat Operations. (EPA-450/3-88-018).  This document, which
            is referred to as  the EPA/Auto  Protocol, contains information on
            recordkeeping, testing,  and compliance calculation procedures.  The
            Protocol has been used  to demonstrate compliance  with emission
            limits for topcoat and  spray primer/surface coating activities.

            EPA and AAMA  have  discussed  and hope to  update  the protocol.
            AAMA hopes to have  an automotive spraybooth capture efficiency
            procedure as well as  some  acceptable spraybooth/oven split test
            modifications for in-plant simulation incorporated into  the protocol as
            a technical update.
Research
The  American  Industry/Government Emissions Research Cooperative Research
and  Development Agreement  (AIGER CRADA)

            AIGER CRADA was officially launched in October 1992.  The founding
            members - U.S. EPA, the California Air Resources Board, and USCAR's
            Environmental Research  Consortium - came together to identify,
            encourage, evaluate, and develop the instrumentation and  techniques
            needed  to accurately and efficiently measure emissions from motor
            vehicles as required by the Clean Air  Act and the California Health and
            Safety Code.   This effort  will help ensure that technologies are
            commercialized and available to emissions testing facilities.

Partnership For A New Generation Of Vehicles

            Partnership For A New Generation Of Vehicles (PNGV), one of several
            research consortia under USCAR,  is a partnership between domestic
            automotive manufacturers  and  the Federal government.    The
            partnership is  aimed  at  strengthening  U.S.  competitiveness  by
            expanding the industry's technology base. Research will be performed
            in the following three areas:
                  Advanced manufacturing techniques to make it easier to get
                  new product ideas to the marketplace quickly;
September 1995
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Motor Vehicle Assembly Industry
                                                Sector Notebook Project
            •     Technologies leading to near-term improvements in automobile
                  efficiency, safety, and emissions; and

            •     Research leading to production prototypes of a vehicle capable of
                  up to three times current fuel efficiency.

President's Council on Sustainable Development - Eco-Efficiency  Task Force

            The purpose of the Eco-Efficiency Task Force  is to develop and
            recommend to the President's Council on Sustainable  Development a
            strategy for  making  eco-efficiency and sustainable development
            standard business practices in American industry.  The Task Force will
            highlight how changes  in  economic, regulatory, statutory,  and other
            policies  will encourage industry to  become more  aware  of the
            interdependence among environmental, economic, and  social well-
            being, and recommend policies effective in promoting sustainable
            business practices.  The Task Force  is sub-divided into five Eco-
            Efficiency  Task Force Teams:  Autos Team; Chemicals Sector Team;
            Eco-Industrial Park  Team; Policy Team; and Printers/Small Business
            Team. The three goals of the Auto Team are to recommend ways to:

            •     Improve the "eco-efficiency" of automobile manufacturing by
                  making pollution prevention, waste reduction, and product
                  stewardship standard business practices

            •     Improve the system  of environmental policy and regulation
                  affecting automobile manufacturing

            •     Improve the sustainability of road-based transportation.
            As part of its efforts, the Auto Team is collecting information on the
            "life  cycle"  analysis  of automobile  painting operations at a GM
            assembly plant.  The team is also collecting data from the paint and
            pigment industry, the steel,  plastics, and  aluminum manufacturing
            industries, as well as  the  auto repainting industry.  The project will
                   the  environmental, energy, and economic implications of
assess
            various auto body material/coating choices such as solvent, water, or
            powder. The Task Force is expected to deliver its findings in late 1995.
 SIC Code 37
                                    116
                                                     September 1995

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 Sector Notebook Project
                  Motor Vehicle Assembly Industry
 Outreach and Education Activity

 Pollution Prevention  and Waste Minimization in  the Metal Finishing Industry
 Workshop

             The University of Nebraska-Lincoln sponsored a Pollution Prevention
             and Waste Minimization  in the Metal Finishing Industry workshop in
             1993.  The workshop was  designed for  managers and operators of
             electroplating  and galvanizing operations; engineers; environmental
             consultants; waste management consultants; Federal, State, and local
             government officials; and individuals responsible for training in the
             area of metal finishing waste management. Topics covered:

             •      Saving money and reducing risk through pollution prevention
                   and waste minimization;

             •      Incorporating pollution prevention into planning electroplating
                   and galvanizing operations;

             •      Conducting waste minimization audits;

             •      Developing and analyzing options for pollution
                   prevention/waste  minimization; and

             •      Implementing a pollution prevention/waste minimization
                   program.

            For  more information  concerning  this  workshop,  contact David
            Montage of the University of Nebraska at W348 Nebraska Hall,
            Lincoln, NE 68588-0531.

Hazardous  Waste Management for  Small Business  Workshop

            The University of Northern Iowa, with support from U.S. EPA, Des
            Moines  Area  Community  College,  Northeast Iowa  Community
            College,  Scott  Community  College, and  Indiana Hills Community
            College,  sponsored  a  Hazardous  Waste  Management for  Small
            Business  workshop.  This workshop  was geared for small businesses
            and  was intended to provide practical  answers to environmental
            regulatory questions.  Small  businesses  covered by  the workshop
            include:   manufacturers, vehicle maintenance  and  repair  shops,
            printers,  machine shops, and other businesses that generate potentially
            hazardous waste.   Topics covered  included:   hazardous waste
            determination,  waste generator categories, management of specific
            common waste  streams, including used oil and solvents, and pollution
            prevention.  For more information regarding workshop, contact Duane
            McDonald (319) 273-6899.
September 1995
117
                                                                   SIC Code 37

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Motor Vehicle Assembly Industry
                                               Sector Notebook Project
Envirotimentally Conscious  Painting  Workshop

            Kansas  State  University,  NIST/Mid-America  Manufacturing
            Technology Center,  Kansas Department of Health  & Environment,
            EPA Region VII, Allied Signal, Inc., Kansas City Plant, and the U.S.
            Department of  Energy  sponsored  the  Environmentally  Conscious
            Painting workshop.  This workshop covered topics such as upcoming
            regulations and the current  regulatory climate, methods to cost-
            effectively reduce painting wastes  and emissions, and alternative
            painting processes.  For  more information regarding this workshop,
            contact the Kansas State  University Division of Continuing Education
            (913) 532-5566.

Pollution Prevention Workshop for the Electroplating Industry

            Kansas State  University Engineering Extension, EPA  Region VII,
            Kansas Department of Health and Environment, and  the University of
            Kansas sponsored   the Pollution  Prevention  Workshop for  the
            Electroplating Industry. The workshop described simple techniques for
            waste  reduction in  the electroplating industry, including:  plating,
            rinsing processes and wastewater, wastewater management options,
            metals  recovery options,  waste treatment  and management, and
            product substitutions and plating alternatives.  For more information
            regarding this workshop, contact the Kansas State University Division
            of Continuing Education at (800) 432-8222.
VIII.B.
EPA Voluntary Programs
33/50 Program
            The  "33/50 Program" is  EPA's voluntary program to reduce  toxic
            chemical releases and transfers of 17 chemicals from  manufacturing
            facilities. Participating companies pledge to reduce their toxic chemical
            releases and transfers by 33 percent as of 1992 and by 50 percent as of
            1995 from  the 1988 baseline  year.  Certificates of Appreciation have
            been given to  participants  who met their 1992 goals.   The list of
            chemicals  includes  17 high-use chemicals  reported  in the Toxics
            Release Inventory.

            Sixty-six companies listed under SIC 37 (transportation) are currently
            participating in the 33/50 program. They account for approximately 20
            percent of  the 405 companies under SIC 37, which is  slightly higher
            than the average for all industries of 14 percent participation. It should
            be noted, however, that the two digit SIC 37 covers a large number of
SIC Code 37
                       118
September 1995

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 Sector Notebook Project
                  Motor Vehicle Assembly Industry
             small firms performing numerous manufacturing processes. (Contact:
             Mike Burns (202) 260-6394 or the 33/50 Program (202) 260-6907)

             Exhibit 32 lists those companies participating in the 33/50, program that
             reported under SIC  code 37 to  TRI.  Many of the participating
             companies listed multiple SIC codes (in no  particular order), and are
             therefore likely to conduct operations in addition to the motor vehicle
             assembly industry.  The table shows the number of facilities within
             each company that are participating in the  33/50 program; each
             company's total 1993 releases and transfers of 33/50 chemicals; and the
             percent reduction in these chemicals since 1988.
                                   Exhibit 32
        Motor Vehicle Assembly Facilities Participating in the 33/50 Program
Parent Facility name
American Honda Motor Co.,
Inc,
Chrysler Corporation
Ford Motor Company
General Motors Corporation
Harsco Corporation
Navistar International Corp.
New United Motor
Manufacturing
Northrop Grumman Corp.
Superior Coaches
Parent
City
Torrance
Highland
Park
Dearborn
Detroit
Camp Hill
Chicago
Fremont
Los Angeles
Lima
ST
CA
MI
MI
MI
PA
IL
CA
CA
OH
SIC
Codes
3711
3711
3465, 3711
3711
3711,3713
3711
3711
3711
3711
# of
Participating
Facilities
2
8
19
23
1
1
1
1
1
1993
Releases
and
Transfers
(Ibs.)
3,254,180
3,623,717
15,368,032
16,751,198
415,574
180,834
420,125
2,357,844
87,900
%
Reduction
1988 to
1993
*
80
15
*
**
*
**
35
44
* = not quantifiable against 1988
data.
** = use reduction goal only.
*** = no numerical goal.
Environmental Leadership Program
            The Environmental Leadership Program (ELP) is a national initiative
            piloted by EPA and State agencies in which facilities have volunteered
            to demonstrate innovative approaches to environmental management
            and compliance.  EPA  has selected  12 pilot projects  at  industrial
            facilities  and  Federal  installations  which will demonstrate  the
            principles  of  the  ELP  program.    These  principles  include:
            environmental  management  systems,  multimedia   compliance
            assurance, third-party verification of compliance,  public  measures of
            accountability, community involvement,  and mentoring programs.  In
September 1995
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Motor Vehicle Assembly Industry
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            return for participating, pilot participants receive public recognition
            and are given a period of time to correct any violations  discovered
            during these  experimental projects.  (Contact: Tai-ming Chang, ELF
            Director (202)  564-5081 or Robert Fentress (202) 564-7023)
Project XL
            Project XL was initiated in March 1995 as a part of President Clinton's
            Reinventing  Environmental  Regulation initiative.  The projects seek
            to  achieve  cost  effective  environmental  benefits  by  allowing
            participants to replace or modify existing regulatory requirements on
            the condition that they produce greater environmental benefits.  EPA
            and program  participants will negotiate and sign a Final Project
            Agreement, detailing specific objectives that the regulated entity shall
            satisfy. In exchange, EPA will allow the participant a certain degree of
            regulatory flexibility and may seek changes in underlying regulations
            or statutes.  Participants are encouraged to seek stakeholder support
            from local governments, businesses, and environmental groups.  EPA
            hopes  to implement fifty pilot projects in four categories  including
            facilities, sectors, communities, and government agencies  regulated by
            EPA.  Applications will be accepted on a rolling basis and projects will
            move to implementation within six  months of their selection.  For
            additional information regarding XL Projects, including application
            procedures and criteria, see the May 23,1995 Federal Register Notice, or
            contact Jon Kessler at EPA's Office of Policy Analysis (202) 260-4034.
 Green Lights Program
             EPA's Green Lights program was initiated in 1991 and has the goal of
             preventing pollution by encouraging U.S. institutions to use energy-
             efficient lighting technologies. The program has over 1,500 participants
             which  include  major corporations;  small  and  medium  sized
             businesses;  Federal, State and local governments; non-profit groups;
             schools;  universities; and  health care  facilities.  Each  participant is
             required to  survey their facilities and upgrade lighting  wherever it is
             profitable.  EPA provides  technical assistance to the participants
             through  a decision support software package, workshops and manuals,
             and a financing registry.   EPA's Office of Air  and Radiation is
             responsible  for operating the Green Lights Program.  (Contact: Susan
             Bullard at (202) 233-9065 or the Green Light/Energy Star Hotline at (202)
             775-6650)
 SIC Code 37
                                     120
September 1995

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 Sector Notebook Project
                  Motor Vehicle Assembly Industry
 WasteWi$e Program

             The WasteWi$e Program was started in 1994 by EPA's Office of Solid
             Waste and Emergency Response.  The program is aimed at reducing
             municipal solid wastes by promoting waste minimization, recycling
             collection, and the manufacturing and purchase of recycled products.
             As of 1994, the  program had about  300 companies as members,
             including a number of major corporations.  Members agree to identify
             and implement actions to reduce their solid wastes and must provide
             EPA  with their waste reduction goals along with yearly progress
             reports.   EPA  in turn provides technical  assistance to member
             companies and allows the use of the WasteWi$e logo for promotional
             purposes.  (Contact:  Lynda Wynn (202) 260-0700 or the WasteWi$e
             Hotline at (800) 372-9473)

 Climate Wise Recognition Program

             The Climate Change Action Plan was initiated in response to the U.S.
             commitment  to reduce greenhouse gas  emissions in accordance with
             the Climate Change Convention of the 1990 Earth Summit.  As part of
             the Climate  Change Action Plan, the Climate Wise  Recognition
             Program  is a  partnership  initiative run  jointly by  EPA and the
             Department of Energy. The program is designed to reduce greenhouse
             gas emissions by encouraging  reductions across all  sectors  of the
            economy, encouraging participation in the  full  range of Climate
            Change Action Plan initiatives, and fostering innovation.  Participants
            in the program  are required to identify and commit to actions that
            reduce greenhouse  gas emissions.  The  program, in turn, gives
            organizations early  recognition for their reduction  commitments;
            provides technical assistance through consulting services, workshops,
            and guides;  and provides  access to  the  program's centralized
            information system.  At EPA, the program is operated by the Air and
            Energy Policy  Division within the Office of Policy  Planning and
            Evaluation. (Contact:  Pamela Herman (202)  260-4407)
NICE3
            The  U.S.  Department  of  Energy  and  EPA's  Office  of  Pollution
            Prevention are jointly  administering  a grant program called The
            National Industrial Competitiveness through Energy, Environment,
            and Economics (NICE3).  By providing grants of up to 50 percent of the
            total project cost, the program encourages industry to reduce industrial
            waste  at  its  source and become more energy-efficient and cost-
            competitive through waste minimization efforts.  Grants are used by
            industry to design, test,  demonstrate, and assess the feasibility of new
            processes and/or equipment with the potential to  reduce pollution and
September 1995
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Motor Vehicle Assembly Industry
                                                             Sector Notebook Project
            increase energy efficiency.  The  program is open to all industries;
            however, priority is given to proposals from participants in the pulp
            and paper, chemicals, primary metals, and petroleum and coal products
            sectors. (Contact: DOE's Golden Field Office (303) 275-4729)


VIII.C.      Trade Associations/Industry Sponsored Activity

            As one of the most highly regulated  industries in the  U.S.,  the
            automotive industry is constantly forced  to identify and  develop new
            ways  to produce motor vehicles and   motor vehicle parts  more
            efficiently and with less waste.  In an effort to pool  resources, three
            manufacturers  have  formed a  partnership to promote pollution
            prevention initiatives.  Information is also provided on the  various
            trade associations which support the industry.
Vm.C.l.    Environmpntal Programs

Automobile  Pollution Prevention Project  (Auto Project)

            Auto  Project  is  a voluntary  partnership between the  Big Three
            automobile manufactures and the  State of Michigan (on behalf of eight
            Great Lakes States and the U.S. EPA) to promote pollution prevention.
            Initiated on September 24, 1991, Auto Project is  the first public/private
            initiative focused specifically on  the environmental impacts resulting
            from automobile  manufacturing.  Auto Project  is administered by the
            American Automobile Manufacturers Association (AAMA) and  the
            Michigan Department of Natural  Resources (MDNR).  The  purpose of
            the project is to:

             •     Identify Great Lakes Persistent Toxic (GLPT) substances and
                   reduce their generation and release

             •     Advance pollution prevention within the auto industry and  its
                   supplier base

             •     Reduce releases of GLPT substances beyond regulatory
                   requirements

             •     Address regulatory barriers that inhibit pollution prevention.


             A progress report released in February 1994  states that significant
             accomplishments have been achieved in the last two years and  that
             releases of the listed GLPT substances by auto companies have been cut
             by 20.2 percent in the  first year of the  Auto  Project.   Other
             accomplishments of Auto Project include:
             •      Developed criteria for identification of GLPT substances
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                  Motor Vehicle Assembly Industry
             •     Identified 65 GLPT substances based on the criteria

             •     Provided highlights of historical pollution prevention efforts

             •     Established priorities and identified opportunities to reduce the
                   generation and release of the listed substances

             •     Provided pollution prevention case study information for
                   technology transfer to auto suppliers and other companies

             •     Established a pilot program to identify and reduce regulatory
                   barriers to pollution prevention actions!


             In October 1993 a comprehensive evaluation of the first  two years  of
             the Auto Project  was  conducted by members of the  Great Lakes
             environmental community.    Results   of  the  evaluation were
             documented in a 1993 report entitled So  Much Promise, So Little
             Progress - An  Evaluation of the State of Michigan/Auto Industry Great
             Lakes Pollution Prevention  Initiative  written by the  Ann Arbor,
             Michigan Ecology Center.   The  report concludes  that although  still
             promising, Auto Project has been mostly unsuccessful.   The Great
             Lakes environmental groups claimed the following:

             •      Auto companies have not conducted  the promised surveys of
                   pollution generated by individual plants and  manufacturing
                   processes

             •      Auto companies have initiated few new pollution prevention
                   projects

             •      Auto company suppliers,  who account for more toxic releases
                   than the auto companies themselves, have not been brought
                   into the project

             •      Stakeholders (environmental groups and labor) have not had
                   adequate opportunities to participate

             •      Auto companies have yet  to establish clear goals or timetables
                   for eliminating toxic substances from  their processes.
September 1995
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         Sector Notebook Project
VHI.C.2.     Summary of Trade Associations

Trade Associations

Automotive  Manufacturers
             American Automobile Manufacturers Association
             (AAMA)
             1401 H Street, NW, Suite 900
             Washington, DC 20005
             Phone: (202)326-5500
             Fax: (202)326-5567       	
Members: 3
Staff: 100
Budget: $14,000,000
Contact: Andrew H. Card, Jr.
             Founded in 1913, AAMA, formerly the Motor Vehicle Manufacturers
             Association,  represents manufacturers of passenger and commercial
             cars, trucks, and buses to improve vehicle safety, reduce air pollution,
             and  assist in  long-term energy  conservation  objectives.   This
             association compiles statistics, disseminates information,  and conducts
             research programs and legislative monitoring on Federal and  State
             levels.  AAMA also maintains patents and communications libraries,
             and publishes the following annual documents:  Motor Vehicle  Facts
             and  Figures, Motor Vehicle Identification Manual, and  World Motor
             Vehicle  Data  Book.
             Association of International Automobile
             Manufacturers (AIAM)
             1001 19th Street, North, Suite 1200
             Arlington, VA 22209
             Phone: (703)525-7788
             Fax: (703)525-3289             	
Members: 35
Budget: $4,200,000
Contact: Phillip Hutchinson
             Founded in  1964,  AIAM represents  companies  that  manufacture
             automobiles or automotive equipment and that import into, or export
             from, the United States.  This association acts as a clearinghouse for
             information,  especially with  regard to proposed  State and Federal
             regulations in the  automobile industry  as  they bear  on imported
             automobiles,  and reports proposed regulations by State or Federal
             governments  pertaining to equipment standards, licensing, and  other
             matters  affecting members.  AIAM publishes materials on State and
             Federal laws,  regulations, and standards.
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              American Foundrymen's Society (AFS)
              505 State Street
              Des Plaines, IL 60016
              Phone: (708)824-0181
              Fax:  (708)824-7848	
                   Members: 13,500
                   Staff: 52
                   Contact: Ezra L. Kotzin
             Founded  in  1896, AFS  represents  foundrymen,  patternmakers,
             technologists, and  educators and  sponsors foundry training courses
             through the  Cast Metals  Institute on all subjects pertaining to the
             castings industry. The Society conducts  educational and instructional
             activities on the foundry industry and sponsors ten regional foundry
             conferences and 400 local foundry technical meetings.  AFS maintains
             the Technical Information Center, a literature  search and  document
             retrieval service, arid the Metalcasting Abstract Service, which provides
             abstracts of the latest metal casting literature. In addition to providing
             environmental services  and testing, AFS publishes Modern  Casting
             (monthly), which  covers current technology practices  and  other
             influences affecting  the production and marketing of metal castings.
             Automotive Presidents Council (APC)
             1325 Pennsylvania Avenue, NW, 6th Floor
             Washington, D.C. 20004
             Phone: (202)393-6362
             Fax: (202)737-3742
                  Members: 50
                  Contact: Christopher Bates
             Founded in 1966, APC represents presidents and chief executive officers
             of leading  manufacturing  companies producing  automotive parts,
             equipment, accessories, tools,  paint, and refinishing  supplies.   This
             council provides a forum in which chief executives can discuss areas of
             mutual interest or  top management problems,  share  ideas,  and
             exchange  solutions.
Automotive Parts  and Equipment
             Automotive Parts and Accessories Association
             (APAA)
             4600 East West Highway, Suite 300
             Bethesda, MD 20814
             Phone: (301)654-6664
             Fax: (301)654-3299	_^
                  Members: 2000
                  Staff: 26
                  Budget: $3,000,000
                  Contact: Lawrence Hecker
             Founded  in  1967,  this association represents automotive  parts and
             accessories retailers, distributors,  manufacturers, and manufacturers'
             representatives.  APAA conducts research, compiles statistics, conducts
             seminars, provides  a specialized education program, and operates a
September 1995
125
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         Sector Notebook Project
            speakers' bureau and placement service.  This association publishes
            APAA Frontlines  (bimonthly), APAA  Government  Report  (periodic),
            APAA Tech  Service Report (monthly), APAA  Who's  Who (annual),
            APAA  Membership   Directory  (periodic), Computer News  for  the
            Automotive  Aftermarket  (monthly),  and Foreign  Buyers  Directory
            (annual).
            Motor and Equipment Manufacturers Association
            (MEMA)
            #10 Laboratory Drive
            P.O. Box 13966
            Research Triangle Park, NC 27709-3966
            Phone:  (919)549-4800
            Fax:  (919) 549-4824	
Members: 750
Staff: 62
Budget: $3,500,000
Contact: Robert Miller
            Founded in 1904, MEMA represents manufacturers of automotive and
            heavy-duty original  equipment  and replacement  components,
            maintenance equipment, chemicals, accessories, refinishing supplies,
            tools, and service  equipment.   This organization  provides  the
            following  manufacturer-oriented services:   marketing consultation;
            Federal  and State legal, safety,  and  legislative representation and
            consultation;  personnel services;  and  manpower  development
            workshops.  La addition, MEMA  conducts  seminars on domestic and
            overseas marketing, Federal trade regulations, freight forwarding, and
            credit and collection.   This  association  publishes the following
            documents:   Automotive Distributor  Trends  and Financial  Analysis
            (periodic),  Credit  and Sales Reference  Directory  (semiannual),
            International  Buyer's  Guide of  U.S.  Automotive  and  Heavy Duty
            Products  (Biennial), Marketing  Insight (quarterly), and Autobody
            Supply and Equipment  Market.
Finishing and  Dismantling
             Paint, Body, and Equipment Association (PBEA)
             c/o Martin Fromm and Associates
             9140 Ward Parkway, Suite 200
             Kansas City, MO 64114
             Phone: (816)444-3500
             Fax:  (816)444-0330          	
Members: 100
Staff:  6
Contact: Barbara Aubin
             Founded  in 1975, PBEA represents  warehouse  distributors  and
             manufacturers specializing in  the automotive paint,  body,  and
             equipment field.   This organization conducts management seminars
             and  publishes an  annual Membership  Directory and a bimonthly
             Newsletter.
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             Automotive Recyclers Association (ARA)
             3975 Fair Ridge Drive
             320 Terrace Level North
             Fairfax, VA 22033
             Phone:  (703)385-1001
             Fax: (703)385-1494
                  Members: 5,500
                  Staff:  12
                  Budget:  $1,100,000
                  Contact:  William Steinkuller
             Founded in 1943, ADRA represents firms that sell used auto, truck,
             motorcycle, bus, farm, and construction equipment parts,  as  well as
             firms  that  supply  equipment and  services to  the industry.  This
             organization seeks to  improve industry business practices  and
             operating techniques through information exchange via meetings and
             publications, including  ADRA  Newsletter (monthly),  Automotive
             Recycling (bimonthly), and Industry  Survey (biennial).
September 1995
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Motor Vehicle Assembly Industry
                                                Sector Notebook Project
DC.
CONTACTS/ACKNOWLEDGMENTS/RESOURCE
MATERIALS/BIBLIOGRAPHY
General Profile
AAMA Motor Vehicle Facts & Figures '93, Government Affairs Division, The
American Automobile Manufacturers Association, 1993.

Encyclopedia of Associations, 27th ed., Deborah M. Burek, ed., Gale Research Inc.,
Detroit, Michigan, 1992.

Enforcement Accomplishments Report, FY 1991, U.S. EPA, Office of Enforcement
(EPA/300-R92-008), April 1992.

Enforcement Accomplishments Report, FY 1992, U.S. EPA, Office of Enforcement
(EPA/230-R93-001), April 1993.

Enforcement Accomplishments Report, FY 1993, U.S. EPA, Office of Enforcement
(EPA/300-R94-003), April 1994.

Industry & Trade Summary, Official Statistics of the U.S. Dept. of Commerce,  USITC
Publication 2751 "Certain Motor Vehicle Parts & Accessories" March 1994.

Metakasting Makes America Strong, American Foundrymen's Society, Inc., 1994.

Recycling Old Vehicles:  Its Everybody's  Business,  American  Automobile
Manufacturers Association.

The Real Climate of the Auto Industry, David E. Cole and Michael S.  Flynn, The
Detroiter, December 1992.

Standard Industrial Classification Manual, Office of Management and  Budget, 1987.

UMTRI Research Review:   Delphi VII -  Forecast and Analysis of the North
American Automotive Industry, University of Michigan Transportation Research
Institute, Volume 24, Number 5, March-April 1994.

U.S. Industrial Outlook 1994, Department of Commerce.

U.S. Global Trade Outlook,  1995-2000, Towards the 21st Century. Department  of
Commerce. March 1995.

1987 Census  of Manufacturers,  Industry Series: Motor Vehicles and Equipment,
Bureau of the Census, (MC87-I-37A).

2992 Census  of Manufacturers,  Industry Series: Motor Vehicles and  Equipment
Bureau of the Census. Bureau of the Census, (MC82-I-37A).
SIC Code 37
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September 1995

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                   Motor Vehicle Assembly Industry
 Process Description
 Changing Casting Demands Shape Ford's New Foundry, David P. Kanicki, Modern
 Casting, September 1994.

 Gene Prashan, American Automobile Manufacturers Association, October 1994.

 Hot Dip Galvanized Coatings, American Society for Metals Committee on Hot Dip
 Galvanized Coatings, Metals Handbook, 9th Edition, Volume 5.

 Machining, American Society for Metals, Metals Handbook:  9th Edition, Volume
 16,1989.

 Making the Car, American Automobile Manufacturers Association, January 1992.

 McGraw-Hill Encyclopedia of Science &  Technology, 6th ed., vols. 5, 6, 11, 13, 14, 16,
 18,19, McGraw-Hill Book Company, New York, New York, 1987.

 Properties and  Selection:  Stainless Steels, Tool Materials and Special  Purpose
 Materials, American Society for Metals, Metals Handbook, 9th Edition, Volume 3
 1980.

 Selection of Cleaning Process Metals, American Society for Metals  Committee on
 Selection of Cleaning Process, Handbook, 9th Edition.             •     ,

 Surface Cleaning, Finishing, and Coating, American Society  for Metals, Metals
 Handbook:  9th Edition, Volume 5, 1982.


 Regulatory Profile	

 Environmental Regulation and  Control  in US Foundries, J.T. Radia, BCIRA
 International Conference, 1993.

 EPA OPPTS Title III Section 313 Release Reporting Guidance:  Estimating Chemical
 Releases from  Electroplating Operations, 1988.

 Guidance Manual for Electroplating and Metal Finishing Pretreatment Standards,.
EPA/Effluent Guidelines Division and  Permits Division, 1984.

 The U.S. Auto Industry 2000:   Plastic Application Issues from an  Industry
Perspective, Society of Plastic Engineers, 1992.

You Can Breath Easier, Andrew Ryder, Heavy  Duty Trucking, August 1994.
beptember 1995
129
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Motor Vehicle Assembly Industry
                                      Sector Notebook Project
Pollution Prevention
Automotive Pollution Prevention Progress Report, American  Automobile
Manufacturers Association and The State of Michigan, February 1994.

General Motors Environmental Report,  1994.

Minnesota Technical Assistance Program Checklists for Identifying Waste
Reduction Opportunities.

Pollution  Prevention at General Motors, Sandra S. Brewer, P.N. Mishra Ph.D., O.
Warren Underwood, and Todd Williams, General Motors Corporation, Detroit,
Michigan, 1995.

Pollution  Prevention  In  Metal Manufacturing:   Saving Money Through Pollution
Prevention, EPA, OSW, October 1989.

Pollution  Prevention Options In Metal Fabricated Products  Industries:  A
Bibliographic Report, EPA, QPPT, January 1992.

So Much  Promise,  So Little Progress - An Evaluation of the State of Michigan/Auto
Indiistry  Great Lakes Pollution Prevention Initiative, Chanes Griffith and Rober
Ginsburg Ph.D., On behalf of the Michigan Environmental Council, October 1993.

Sustainable Industry:  Promoting Strategic Environmental  Protection in  the
Industrial Sector,  Phase I  Report, EPA, OPPE, June 1994.

Toxic Chemical Release Inventory:   Clarification and Guidance for the Metal
Fabrication Industry, EPA, OTS, 1990.
Contacts	

Contacts*

Carol Kemker

John Lank
Organization

Region IV

Region IV
 Telephone

(404) 347-3555

(404) 347-7603
    Many of the contacts listed above have provided valuable background information and comments
    during the development of this, document. EPA appreciates this support and acknowledges that
    the individuals listed do not necessarily endorse all statements made within this notebook.
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                                            September 1995

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Sector Notebook Project
                               Motor Vehicle Assembly Industry
Contacts*

Paul Novak

Kurt Hildebrandt

David Cole
Ellen Shapiro
Larry Slimack
Gene Praschan
Ezra L. Kotzin
Chris Richter

David Carelson
Connie Pell

Sandy Brueher
Lee Hachigian

Mike Swartz

Amy Lilly
Organization

Region V

Region VII

University of Michigan
Transportation Research
Institute (UMTRI)
Office for the Study of Automotive
Transportation (OSAT)

Automotive Parts and Accessories
Association (APAA)

Motor and Equipment Manufacturers
Association (MEMA)

American Automobile Manufacturers
Association (AAMA)
AAMA
AAMA
AAMA

American  Foundrymen's
Society, Inc, (AFS)
AFS
AFS

Chrysler Corp.
Chrysler Corp.

General Motors Corp.
General Motors Corp.

Ford Motor Corp.

AIAM, Director of Plant.
Operations
 Telephone

(216) 522-7260

(913) 551-7413
                                                               (313) 764-2171


                                                              (301) 654-6664


                                                              (919) 549-4824
(313) 872-4311
(202) 326-5549
(313) 871-5340
(919) 361-0210
(800) 537-4237
(708) 824-0181
(202) 842-4864

(810) 576-4876
(810) 476-5502

(313) 556-7625
(313) 556-7658

(313) 594-2492

(703) 525-7788
    Many of the contacts listed above have provided valuable background information and comments
    during the development of this document. EPA appreciates this support and acknowledges that
    the individuals listed do not necessarily endorse all statements made within this notebook.
September 1995
             131
         SIC Code 37
                                   Appendix A

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          United Stotes Government
          INFORMATION
PUBLICATIONS * PERIODICALS * ELECTRONIC PRODUCTS
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055-000-00512-5
055-000-00513-3
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055-000-00516-8
055-000-00517-6
055-000-00519-2
055-000-00520-6
055-000-00521-4
055-000-00522-2
055-000-00523-1
055-000-00524-9
055-000-00525-7
055-000-00526-5
055-000-00527-3
055-000-00528-1
055-000-00529-0
055-000-00514-1
Published in 1995 Title
Profile of the Dry Cleaning Industry, 104 pages
Profile of the Electronics and Computer Industry, 160 pages
Profile of the Fabricated Metal Products Industry, 164 pages
Profile of the Inorganic Chemical Industry, 136 pages
Profile of the Iron and Steel Industry, 128 pages
Profile of the Lumber and Wood Products Industry, 136 pages
Profile of the Metal Mining Industry, 148 pages
Profile of the Motor Vehicle Assembly Industry, 156 pages
Profile of the Nonferrous Metals Industry, 140 pages
Profile of the Non-Fuel, Non-Metal Mining Industry, 108 pages
Profile of the Organic Chemical Industry, 152 pages
Profile of the Petroleum Refining Industry, 160 pages
Profile of the Printing Industry, 1 24 pages
Profile of the Pulp and Paper Industry, 1 56 pages
Profile of the Rubber and Plastic Industry, 152 pages
Profile of the Stone, Clay, Glass and Concrete Industry, 124 pages
Profile of the Transportation Equipment Cleaning Industry, 84 pages
Profile of the Wood Furniture and Fixtures Industry, 1 32 pages
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9.00
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055-000-00570-2
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055-000-00575-3
055-000-00576-1
055-000-00577-0
055-000-00578-8
055-000-00579-6
Published in 1997 Title
Profile of the Air Transportation Industry, 90 pages
Profile of the Ground Transportation Industry, 130 pages
Profile of the Water Transportation Industry, 90 pages
Profile of the Metal Casting Industry, 1 50 pages
Profile of the Pharmaceutical Manufacturing Industry, 147 pages
Profile of the Plastic Resin & Man-made Fiber Industry, 180 pages
Profile of the Fossil Fuel Electric Power Generation Industry, 1 60 pages
Profile of the Shipbuilding and Repair Industry, 120 pages
Profile of the Textile Industry, 1 30 pages
Sector Notebook Data Refresh -1997, 210 pages
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