E nvironmental P erformance R eview - A udit

1. Environmental Performance Review - Audit

2. Agenda • Introductions and Plant Safety Orientation • Organization Chart • Purpose • Goals and Objectives • Criteria • Applicability • Mechanics/Procedures • Findings/Finding Structure • Report Development • Performance Ratings • Closing Meeting • Team Approach

3. Organizational Chart

4. Purpose • The purpose of an Environmental Audit Program is to provide managementand facility personnel an objective and independent assessment of the compliance status of the site and to allow for informed business planning.

5. Goals and Objectives • Assess the Site’s Environmental Compliance and Conformance Status • Initiate a Program to Return to Compliance and Conformance (If Necessary) • Minimize Corporate Risk • Allow Delphi Legal Staff to Render Legal Advice to the Facility and to the Corporation • Further Develop Site Awareness of Regulations and Corporate Environmental Requirements • Communicate and Encourage Best Practices

6. Audit Criteria • General Environmental Program • Air Quality • Water Quality • Waste Management • Product Storage Tanks • Hazardous Substances

7. Applicability • Compliance to Federal, State, and Local Requirements • Conformance to Delphi Environmental Performance Criteria (EPCs) • Period of Review: • maximum of 5 years of data (or as appropriate to Delphi’s ownership)

8. Mechanics Opening Meeting - Clarify Audit Plan Execute Facility Tour Collect Audit Evidence Document Audit Findings Discuss Audit Findings With Facility Personnel Preliminary Closing Audit Meeting Prepare Draft Audit Report Conduct Closing Meeting Approximately 3 Days

9. Procedures • Audit Process is “Delphi Confidential” • “Need-to-Know” • Conducted by Sampling Site Environmental Data Through: • Employee Interviews • Review of Site Records • Review of Current Site Operating Conditions (Site Tour)

10. Findings • Organized By Media (Air, Water, Waste, etc.) • Out-of Code (OoC) • Regulatory-Based Findings • Potential Problems (PP) • Possible Regulatory or Future Regulatory-Based Finding • Delphi EPCs • Corporate Requirements • Corrected Problems Are Noted • Become a Delphi Environmental “Metric”

11. Findings Structure • Structure • Observation • Requirement • Recommendation • Corrective Action Plan • Major, Moderate, Minor

12. Report Development • Daily Debriefings Conducted • Concurrence by Site Personnel of Validity of Findings (to Date) • Open Lines of Enquiry • Preliminary Closing Meeting Conducted • Agreement by Site Environmental Personnel and Audit Team of Draft Audit Report • Bilingual Report Developed • Portuguese and English

13. Meets Requirements Substantially Meets Requirements Generally Meets Requirements Requires Improvement to Consistently Meet Requirements Requires Significant Improvement to Consistently Meet Requirements Performance Ratings Excellent Poor Note: This is another Delphi Environmental Metric.

14. Closing Meeting • Who Should Attend? • Site Top Management • Recipients of the Final Report • Signatory for Corrective Action Plan Implementation • Personnel Responsible for Environmental Compliance • Other Affected Salary Personnel • What is Discussed? • Review of Site Audit Findings and Performance Rating • Post-Site Audit Processes • Final Report Generation • Corrective Action Plan Development and Approval

15. Team Approach • FSG - Environmental Audit Team (incl. Contract Auditors) • Facility Personnel • FSG Support Personnel • Delphi Legal Staff