ASMO NORTH CAROLINA, INC.

1. ASMO NORTH CAROLINA, INC. External Audits Conducted by DNV (DET NORSKE VERITAS) and Corrective Actions Implemented. Internal Audits Conducted by ANC’s Internal Audit Teams & Corrective Actions Implemented Management Review.

2. External Audits Conducted by DNV (DET NORSKE VERITAS)& Corrective Actions Implemented • 11-13 Aug.’98 - 1st Surveillance Audit, PA1/01, Clause: 4.4.2 • 22-23 July ‘99 - 3rd Surveillance Audit, PA3/01, Clause: 4.4.7 • 8-10 Feb.’00 - 4th Surveillance Audit, PA4/04, 05, & 08, Clause: 4.5.1, 4.4.1, & 4.4.6.

3. 11-13 Aug.’98 - 1st Surveillance Audit, PA1/01, Clause: 4.4.2 • Finding:@ ASMO North Carolina, Inc. - Statesville facility. • The organizations process for identification and completion of training does not, in all cases, provide desired results. • Examples: • 1) PPE Training is required annually. Records indicate that personnel with certain hire dates have not attended the PPE Training. 2)Regardless of how many times a person is scheduled for the training, appears no mechanism to hold manager accountable, • 3)It was determined 2 of 9 people selected from records had actually received the training.

4. 11-13 Aug.’98 - 1st Surveillance Audit, PA1/01, Clause: 4.4.2 • CORRECTIVE ACTION RESPONSE: • Updated training records. • Started issuing corrective actions for repeat offenders. • Hold managers accountable for repeat offenders. • Ensuring records are transferred when associates change departments. • Changed new associate orientation.

5. 22-23 July ‘99 - 3rd Surveillance Audit, PA3/01, Clause: 4.4.7 • Finding:@ ASMO North Carolina, Inc. - Statesville facility. • Spill kits in Paint and Tool / Die have not been monitored in accordance with the specified process. • The spill kit in the paint department had missing goggles and hard hat.

6. 22-23 July ‘99 - 3rd Surveillance Audit, PA3/01, Clause: 4.4.7 CORRECTIVE ACTION RESPONSE: All spill kits checked, contents replaced, and spill kits sealed. Inspection instruction changed to include no need for inspecting entire contents unless seal is broken. Inspection responsibility changed from department associate to emergency response technician associate. EMSI-2005-177 Emergency Spill Equipment Instruction was Updated. PREVENTATIVE ACTION RESPONSE: Added kits outside receiving docks, beside above ground oil tank, and at storm water drains.

7. 8-10 Feb.’00 - 4th Surveillance Audit, PA4/04, 05, & 08 , Clause:4.5.1, 4.4.1,& 4.4.6 Findings: @ ASMO North Carolina, Inc. - Statesville facility. Monitor equipment is not, in all cases, calibrated and maintained. Examples: 1. Manomenter in paint department was not in calibration recall system, 2. Thermometer in Press not in calibration recall system. 3. Air analyzer recalibration cycle not established. 4. One standard for calibrating the air analyzer had passed its shelf life date (the second bottle is very close). Responsibilities and authorities have not been maintained. Example: Calibrating air analyzer. EMSI-110: Rev.2, requires Hot Work Permits if combustible material is within 35’ of the Hot Work.

8. 8-10 Feb.’00 - 4th Surveillance Audit, PA4/04, 05, & 08 , Clause: 4.5.1, 4.4.1, & 4.4.6 CORRECTIVE ACTION RESPONSE: Manometer’s have been entered into calibration system and are calibrated. Thermometer in Press department has been entered into calibration system. Air analyzer calibration cycle is being evaluated. New standard for calibrating air analyzer has been purchased and entered into calibration system. Additional air analyzer and thermometer were added for Maintenance / Tool & Die Departments. Forms and Instructions are being updated. Air analyzer training has been conducted. Authorities and Responsibilities for calibrating air analyzer has been discussed and is currently being determined. Hot Work Permits are being evaluated. Hot Work Permit Training has been conducted. Non Hot Work Permit areas are being reviewed. Form and Instructions are being updated.

9. Internal Audits Conducted by ANC’s Internal Audit Teams & Corrective Actions Implemented Internal Audit # 98-15-005, 8-27-98, Clause 4.6 Internal Audit # 99-02: 001-005, 2-23-99,Clause 4.4.7, 4.4.6. Internal Audit # 99-11: 001-004, 7-12-99,Clause 4.4.2 Internal Audit # 99-13: 001-005,12-13-99, Clause 4.2,4.4.7,4.4.6,4.5.1,& 4.5.2.

10. Internal Audit # 98-15-005, 8-27-98, Clause 4.6 • Finding: @ ASMO N.C., Inc. - Statesville facility. • After investigation of an outside vendor not following safety rules, it was determined that a supplier survey had not been completed.

11. Internal Audit # 98-15-005, 8-27-98, Clause 4.6 • Corrective Action: • Letters were drafted and resent to all ASMO Suppliers stating the expected rules & regulations that their associates are to follow while on ANC’s property. The letters were signed and returned along with the supplier survey information.

12. Internal Audit # 99-02: 001-005, 2-23-99,Clause 4.4.7, 4.4.6. • Findings: @ Offsite Warehouse. • Emergency Prep. & Response: Eyewash station blocked, and fire extinguisher not inspected. • Forklifts to be checked before use, check sheet not up to date. • Spill kit had wood stacked on top of it, not available for quick response. • Recycling of Aluminum cans: Special marked containers to be made available. This was observed to be not true. • Bulk materials were not labeled with labels indicating hazards of chemicals and P.P.E. to wear while using chemicals.

13. Internal Audit # 99-02: 001-005, 2-23-99,Clause 4.4.7, 4.4.6. • Corrective Action: • Marked area around eyewash stations with yellow tape, Extinguisher was rechecked. • Teamleaders met with associates and reviewed instruction and reminded them of their responsibilities. • Spill kit, top of kit, was cleared of wood. Associates instructed to keep spill kit clear of obstructions and keep ready for use. • New aluminum containers marked and provided for associates. Associates were instructed on use of containers. • Bulk materials were labeled, instruction corrected on who was responsible for labeling of containers.

14. Internal Audit # 99-11: 001-004, 7-12-99, Element 4.4.2 • Finding: • There were (4) four findings that were written against ANC’s Management / Associates for not completing training as required by the ISO Section 4.4.2, EMSI-2005-165.

15. Internal Audit # 99-11: 001-004, 7-12-99, Element 4.4.2 • Corrective Action: • Required Safety / Environmental Training for each Management Member and / or associate was completed by 7/20/1999. • Audit Findings were closed out on 1/28/2000.

16. Internal Audit # 99-13:001-005,12-13-99, Clause 4.2,4.4.7,4.4.6,4.5.1,& 4.5.2. • Findings: @ ASMO Appalachian Corp. • Environmental Policy to be documented, etc., & communicated to associates. For new associates, in this case, this was not being performed. • New temporary associate, evacuation route had not been shown to them. • No instruction for floor sweeper, cleaner was found to be posted and / or written to indicate proper disposal of wastewater. • No written instruction for recycling of used grease. • Incident / injury reports were not all signed by responsible general manager, manager, or assistant Manager.

17. Internal Audit # 99-13:001-005,12-13-99, Clause 4.2,4.4.7,4.4.6,4.5.1,& 4.5.2. • Environmental policy is now part of orientation for all new associates. • All temporary associates will attend orientation on the 1st working day. Evacuation route and environmental policy will be part of the orientation. Attendees will confirm attendance by signing attendance form. • Instruction for floor sweeper / cleaner was submitted and posted by 1/28/2000. • Instruction for disposal of used grease was submitted and posted by 1/20/2000. • General Manager was not always available. N/A (Not Applicable) should have been written on all incident / injury reports till that position was filled.

18. Management Review1999 - 4th Quarter: ANC-Environmental Report Agenda: 1. Hierarchy 2. Roles and Current Activities 3. Air Quality Review 4. Waste Management Review 5. Water Quality Review 6. ISO 14001 Review 7. Summary

19. ASMO N.C., Inc. Government Agencies Regulating ANC, Inc. Federal Gov’t (EPA & OSHA& DOT) State Gov’t (DENR) Local Gov’t (City of Statesville) ASMO N.C., INC.

20. ASMO N.C., INC.Roles & Current Activities Safety, Health, & Environment • Main Goals for 1999: • Monitor Accidents per 100 associates • Zero Plant Fires • Maintain Emission Standards • Maintain Effluent Standards • Reduce Solid Waste by 6% • Increase Recycling by 7% • Maintain G.E. Budget • QS9000- No major findings • ISO14001 - No major findings • EPA (Air/ Haz.Waste/ Water) - No Major Findings • OSHA - No Major Findings • Paint - Eliminate liquid painting • Noise - Reduce Plant Level • Dust - Reduce Powder & Molding Levels • RMI /CTD - Establish Cost Reduction Team Areas of Responsibilities • ISO14001 - Environmental Management System (EMS) • Air Quality Programs (CAA) • Waste Water Quality (CWA) • Storm Water Quality Programs (NPDES) • Hazardous Waste Disposal (RCRA) • Community Right to Know Regulations (EPCRA) • Pesticide Regulations (FIFRA) • Chemical Import and Registrations (TSCA) • Hazardous Material Shipping (DOT) • Support Emergency Response (HAZWOPER) • Safety of all Associates (OSHA) • Key Points And Activities: • Achieved ISO14001 Certification for AMT • MACT Survey for Metal Industries - Submitted to EPA on April 9, 1999 • Tier II Report on Isopropyl Alcohol - Submitted for AMT & Submitted on time to EPA for ANC in March 1999 • Daily Air Toxic Report Spreadsheet Updated & Implemented in April 1999 • Applied on 2/11/2000 to EPA / City of Statesville’s - Common Sense Initiative ( Multi-Media Reduction of Pollution) • S.P.C.C.(Spill Prevention Control & Countermeasure) -Approved by P.E.& ANC-Managers • DNV Issued on 2/10/2000 some findings & observations to ASMO North Carolina, Inc. during EMS Audit.

21. Air Quality Status Key Points and Activities: • Daily VOC Emissions Spreadsheet Updated • MACT Survey Submitted 4/9/99 • 1998 Air Toxic Annual Report Completed 4/19/99 • Submitted Letter concerning AMT Air Permit Status • Submitted ANC Air Permit Modifications to NC Dept.Of Nat’l Resources - Air Quality Section on 11/15/99. • 4th Quarter 1999 Report: Submitted on 12/30/1999 • Future: Update Title V Application • Attend E.P.A.‘s : MACT Standards Stakeholder Meeting in March 2000

22. Hazardous Waste Status • Overview of Activities: • 1994- Eliminated 1-1-1 Trichloroethane (Saved: + $ 20,000 per year) • 1996 - Retested paint booth sludge for barium, test proved waste is non-hazardous (Saved: $35,000 per year) • 1999:(Non-Haz.): Changed from Water Wash to Paper Filter Booth; Paint Booth Sludge:12,700 lbs/ month to 0 Paint Solids Changed from 8 to 15 drums per month or 3200 lbs to 6000 lbs per month.

23. ISO 14000EMS Management Review 2nd Quarter-Qty. Increased AAC 25,004 to 60,853 lbs. (AAC: Due to re-packing armatures) AMT : 54,000 TO 59,000 lbs ANC: 72 TO 78 TONS Target

24. ISO 14000EMS Management Review Polyrep Grinds Same type Plastic once qty is large enough to process, thus causing high peaks & dips in chart Polyrep Recycling Company Issued No Recycling Reports for 3rd Qtr.’98 Target

25. ISO 14000EMS Management Review Container Corp. Of Carolina Picked Up: 19.7 TONS On 2/10/99: Cause Unexplained Target

26. Water Quality Status Key Points & Activities • Maintain volume w/ one shift even with addition of P/W S/A degreasers & Spot Weld degreasers & Additional Armature Degreasers • Has not exceeded effluent limits since 1991. • Added use of filter aid in 1993, reduced overtime. • Received City of Statesville PACE Award for Environmental Excellence in Oct. 1994. • August 18, 1999: City implemented a Level II Water Emergency. • EMSI:033 Approved & Posted Countermeasure for: Lab error resulting in penalty for lead emission. • Applied to Common Sense Initiative on Feb. 11, 2000

27. 1999 - 4th Quarter ANC-Environmental & Safety Report ISO14001 Implementation Status • DGEMC • (DENSO Group Environmental Management Committee) • Organization of North American Environmental Staff. Meet Quarterly. • (DENSO and affiliates) • Devised to facilitate communications, • share knowledge, and increase expertise. • Concept developed by DMMI, initiated by DIAM • First Meeting - April 1996 • Chaired by DMMI staff, 1996-1997 • Initial Focus on ISO 14001 • Developed Environmental Policy in 1997 • Developed ISO 14000 System Consistent Program • DMMI designated as an “ISO 14000 Pilot Company” ANC Activities: • Pre-Assessment in November 1997 • Certified in January 1998 • Added AAC to Certification in August 1998 • Added AMT to Certification in January 1999 • Feb. 2000 ISO14001 Audit Results: • Several NCN’s & Observations

28. 1999 EMS INTERNAL AUDITS

29. Management Review1999: 4th Quarter - Environmental / Safety Summary