Final Report. Toxic Reduction Plan. Conestoga-Rovers & Associates 651 Colby Drive Waterloo, Ontario N2V 1C2.

Transcription

1 Final Report Toxic Reduction Plan 10 µm Particulate Matter 2.5 µm Particulate Matter Prepared for: Firestone Textiles Co. Conestoga-Rovers & Associates 651 Colby Drive Waterloo, Ontario N2V 1C2 December 2013

2 Table of Contents Page Section 1.0 Introduction Basic Facility Information Statement of Intent Objectives Facility Description... 3 Section 2.0 Identification and Description Stages and Processes Process Flow Diagram... 4 Section 3.0 Tracking and Quantification Combustion Process Combustion Process (Created) Combustion Process (Released to Air) Input/Output Balance Cooling tower Process Cooling tower Process (Created) Cooling tower Process (Released to Air) Input/Output Balance Polymerization Process Polymerization Process (Created) Polymerization Process (Released to Air) Input/Output Balance Chip Extrusion Process Chip Extrusion Process (Created) Chip Extrusion Process (Released to Air) Input/Output Balance Yarn Extrusion Process Yarn Extrusion Process (Created) Yarn Extrusion Process (Released to Air) Input/Output Balance Section 4.0 Facility-Wide Accounting Information Use Creation Transformation Destruction Contained In Product Releases to Air Releases to Land Releases to Water Disposals (On-Site) Disposals (Off-Site) Off-Site Transfers (Treatment or Recycling) December 2013

3 Table of Contents Page Section 5.0 Direct and Indirect Cost Analysis Section 6.0 Toxic Substance Use and Creation Reduction Options Material or Feedstock Substitution Options Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility Product Redesign or Reformulation Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility Equipment or Process Modifications Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility Spill and Leak Prevention Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility On-Site Reuse and Recycling Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility Improved Inventory Management/Purchasing Techniques Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility Training or Improved Operating Practices Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility Section 7.0 Options to Be Implemented Section 8.0 Plan Certifications December 2013

4 List of Figures Page Figure 1 General Facility Process Flow Diagram... 5 Figure 2A PM10 created/released in the Combustion Process... 5 Figure 2B PM2.5 created/released in the Combustion Process... 6 Figure 3A PM10 created/released in the Cooling tower Process... 9 Figure 3B PM2.5 created/released in the Cooling tower Process... 9 Figure 4A PM10 created/released in the Polymerization Process Figure 4B PM2.5 created/released in the Polymerization Process Figure 5A PM10 created/released in the Chip Extrusion Process Figure 5B PM2.5 created/released in the Chip Extrusion Process Figure 6A PM10 created/released in the Yarn Extrusion Process Figure 6B PM2.5 created/released in the Yarn Extrusion Process List of Tables Page Table 1 Table 2 Table 3 Table 4 Total Amount of Particulate Matter released to air from Combustion Process in Total Amount of Particulate Matter released to air from Cooling tower Process in Total Amount of Particulate Matter released to air from Chip Extrusion Process in Total Amount of Particulate Matter released to air from Yarn Extrusion Process in Table 5 Indirect Costs Associated with PM December 2013

5 List of Appendices Appendix A Appendix B Planner Recommendations and Rationale Plan Summary December 2013

6 Section 1.0 Introduction 1.1 Basic Facility Information Basic facility information: Name & CAS # of Substance 10 µm Particulate Matter NA-M µm Particulate Matter NA-M10 Facility Identification and Site Address Company Name Facility Name Firestone Textiles Co. Firestone Textiles Co Dundas Street Facility Address Woodstock, Ontario N4S 7Y9 Spatial Coordination of Facility (UTM Easting, UTM Northing) (522432, ) Number of Employees 217 NPRI ID Ontario MOE ID Number 5955 Parent Company (PC) Information PC Name & Address Bridgestone Canada Inc Hurontario Street Mississauga, Ontario L5R 3G5 Percent Ownership for each PC 100% Business Number for PC Primary North American Industrial Classification System Code (NAICS) 2 Digit NAICS Code Manufacturing 4 Digit NAICS Code 3252 Resin, synthetic rubber, and artificial and synthetic fibres and filaments manufacturing 6 Digit NAICS Code Artificial and synthetic fibres and filaments manufacturing December

7 Facility Public Contact Company Contact Information Mr. Robert Galway General Manager Phone: (519) ext. 618 Fax: (519) Facility Technical Contact: Mr. David Mels Quality Manager Person who Prepared the Plan: Highest Ranking Employee Phone: (519) Erik Martinez, P. Eng. Consultant Conestoga-Rovers & Associates Limited 651 Colby Drive, Waterloo ON N2V 1C2 Phone: (519) ext Fax: (519) Mr. Robert Galway General Manager Phone: (519) ext. 618 Fax: (519) Planner Information: Planner Responsible for Making Recommendations Erik Martinez, P. Eng. Planner License No. TSRP0005 Conestoga-Rovers & Associates Limited 651 Colby Drive, Waterloo ON N2V 1C2 Phone: (519) ext Fax: (519) Erik Martinez, P. Eng. Planner Responsible for Certification Phone: (519) ext Fax: (519) December

8 1.2 Statement of Intent Firestone Textiles Co. (Firestone) does not intend to reduce the creation of both 10 µm Particulate Matter (PM10) and 2.5 µm Particulate Matter (PM2.5). Firestone does not use any of the toxic substances and therefore, this plan does not address the reduction of use. 1.3 Objectives The objective of this plan is for Firestone to determine the technical and economic feasibility of each reduction option available to determine, which, if any, are available for implementation at this time. 1.4 Facility Description Firestone manufactures nylon-6 yarns, nylon-6 resin, and various tire cord and industrial fabrics. Caprolactam monomer is mixed with other raw materials and polymerized to produce the nylon-6. The nylon is then extruded into either nylon resins or nylon yarn, which are dried, spun and then packaged for shipping. The North American Industry Classification System (NAICS) Code that applies to this Facility is Artificial and synthetic fibres and filaments manufacturing. In 2012, the facility operated 24 hours per day, seven days per week. Section 2.0 Identification and Description 2.1 Stages and Processes Both PM10 and PM2.5 are created from the combustion of fuels onsite as well as from various processes onsite. The specific processes which create PM10 and PM2.5 are described below: The Receiving Stage consists of the receiving process, where the caprolactam monomer and other raw materials are received and stored. There is no PM10 or PM2.5 created in this process. In the receiving process in the Receiving Stage, the caprolactam monomer and other raw materials are received and stored. There is no PM created within this process. In the combustion process in the Combustion Stage, natural gas and diesel are combusted to produce steam which is then used within the various processes onsite. Both PM10 and PM2.5 are created and released from the combustion of natural gas, while PM10 is created and released from the combustion of diesel. This process and the quantification methods for PM10/PM2.5 are further described in Section 3.1. In the cooling tower process in the Cooling Tower Stage, water which has been used within the onsite processes is cooled in order to either re-use in the processes or release off-site. PM10 and December

9 PM2.5 are created and released in this process. This process and the quantification methods for PM10/PM2.5 are further described in Section 3.2. The Manufacturing Stage begins with the mixing process, where the caprolactam monomer is mixed with other chemicals and stored in a feed tank. There is no PM10 or PM2.5 created in this process. The mixed feed is then sent to the polymerization process, where the mixture undergoes the polymerization process to convert the caprolactam monomer into nylon-6. Unreacted monomer is then separated from the mixture, and a heat stabilizer product (Aminox) is then injected into the nylon mixture. Some of the nylon is then sent to the chip extrusion process, while the rest is sent to the yarn extrusion process. PM10 and PM2.5 is created and released during the injection of the heat stabilizer. This process and the quantification methods for PM10/PM2.5 are further described in Section 3.3. In the chip extrusion process, the nylon is sent through extruders to produce nylon pellets (chips). This process also includes a recycle extruder which processes additional recycled nylon material from recycled chips. PM10 and PM2.5 is created from the extrusion of the resin. This process and the quantification methods for PM10/PM2.5 are further described in Section 3.4. In the drying process, the extruded resin undergoes drying to remove any water present in the resin. There is no PM10 or PM2.5 created in this process. In the yarn extrusion process, the nylon is sent through extruders to produce long nylon threads (yarn), which are then lubricated and cooled. PM10 and PM2.5 is created from the extrusion of the resin. This process and the quantification methods for PM10/PM2.5 are further described in Section 3.5. In the yarn spinning and winding process, the yarn threads undergo a variety of spinning, drawing, winding and weaving operations in order to shape and modify the threads into tire cords and various other products as specified by the customers. There is no PM10 or PM2.5 created in this process. The Packaging and Shipping Stag consists of the packaging and shipping process, where the various nylon resins and products are packaged and then stored before being shipped to customers. There is no PM10 or PM2.5 created in this process. 2.2 Process Flow Diagram A process flow diagram of the various manufacturing stages and processes is provided as a visual aid in interpreting the movement of the toxic substances throughout the facility. December

10 Figure 1 - General Facility Process Flow Diagram Section 3.0 Tracking and Quantification 3.1 Combustion Process Natural gas is delivered to the combustion process in the Combustion Stage, where it is combusted in various boilers and heaters to provide heat for the building as well as steam for the various processes on-site. Diesel is also combusted onsite in various boilers. Both PM10 and PM2.5 are created from the combustion of natural gas, while PM10 is solely created from the combustion of diesel (C 1 ). The created PM10 and PM2.5 is then emitted out of the combustion process through a number of different stacks and vented to the atmosphere (A 1 ). Figure 2A - PM10 created/released in the Combustion Process December

11 Figure 32B - PM2.5 created/released in the Combustion Process Combustion Process (Created) A) Tracking and Quantification Method Quantification Method: Mass Balance The amount of PM10 and PM2.5 created in the combustion process was assumed to be the same as the PM10 and PM2.5 released to air in the combustion process (A 1 ) (see Section 3.2.2). B) Best Available Method Rationale See Section C) Quantification of Toxic Substance The quantification of the total amount created in the combustion process was assumed to be equal to the amount released to air from the combustion process. PM10 C 1 = PM10 created in combustion process: tonne PM2.5 C 1 = PM2.5 created in combustion process: tonne December

12 3.1.2 Combustion Process (Released to Air) A) Tracking and Quantification Method Quantification Method: Emission Factors The total PM10 released to air was based on emission factors as published in the United States Environmental Protection Agency (USEPA) AP-42 guidance document. B) Best Available Method Rationale Total Natural Gas/Diesel Usage The total usage rates of both natural gas and diesel have been determined based on purchasing records. Data based on purchasing records is considered to be of above-average data quality. Particulate Matter Emission Factors For natural gas combustion, the emission factor as described in the AP42 document, Chapter 1.4 (Natural Gas Combustion), Table was used. As all PM produced from natural gas combustion is assumed to be less than 2.5 µm in diameter, both PM10 and PM2.5 are released from natural gas combustion. The emission factor of particulate matter from natural gas has a data quality of "B" (natural gas), which is equivalent to above-average. Therefore, in comparing other methods and considering the total quantity of each source of emissions relative to total emissions, it is expected that the total amount of PM10/PM2.5 released has an above-average data quality. For diesel combustion, the emission factor in the AP42 document, Chapter 3.3 (Gasoline and Diesel Industrial Engines), Table was used. As the smallest possible diameter of particulate matter created is 10 µm, it is assumed that there are PM10 emissions from diesel combustion, but there are not any PM2.5 emissions. The emission factor of particulate matter from diesel has a data quality of "D" (natural gas), which is equivalent to marginal. Therefore, in comparing other methods and considering the total quantity of each source of emissions relative to total emissions, it is expected that the total amount of PM10 released has an uncertain data quality. For PM10, as there is a greater quantity of PM10 produced from natural gas relative to diesel, it has been assumed that the total PM10 emissions have a data quality of above-average. C) Quantification of Toxic Substance The total amount of PM10 and PM2.5 released to air is based on emission factors as described in the USEPA AP-42 guidance document for natural gas and diesel. December

13 Table 1 - Total Amount of Particulate Matter released to air from Combustion Process in 2012 PM10 Particulate Matter Total Releases Fuel-type Total Fuel Usage Emission Factor (tonne) Natural Gas 1,721,948 m kg/10 6 m Diesel 812 L lb/mmbtu Note: 1 Total fuel usage has been converted to an energy basis based on a heating value of diesel of 19,300 Btu/lb A 1 = PM10 released to air in the combustion process: A 1 = tonne tonne A 1 = tonne PM2.5 A 1 = PM2.5 released to air in the combustion process: A 1 = tonne Input/Output Balance To ensure that all PM10 and PM2.5 ass accounted for in this process, an input/output calculation was completed using the following equation: Use + Creation = Transformed + Destroyed + Contained in Product + On-Site or Off-Site Release (to Air, Land, Water) +Offsite Transfers (for treatment, recycling) + Disposals Note: This process only contains materials created and released to air PM10 C 1 = A tonne = tonne PM2.5 C 1 = A tonne = tonne Unaccounted Material = 0 kg December

14 After evaluating the input/output balance, no material sources were found to be missing and no calculation errors were identified. The quantity of PM10 and PM2.5 released to air was determined based on emission factors, and the overall calculated value is estimated to have above-average data quality. Therefore, given the data quality of the values used in the input/output balance, the results are considered to be approximately equal. 3.2 Cooling tower Process Water which has been used within the processes onsite is transferred to the cooling tower process in the Cooling tower Stage. In this process, the water is cooled in order to remove the waste heat that has accumulated and to allow the water to be reused in the production process (or discharged off-site). During the cooling tower process, particulate matter is created (C 1 ) due to water droplets becoming entrained in the air stream which leaves the cooling tower as a result of the process (this is referred to as liquid drift). This particulate is then emitted to the atmosphere (A 1 ). Figure 43A - PM10 created/released in the Cooling tower Process Figure 53B - PM2.5 created/released in the Cooling tower Process December

15 3.2.1 Cooling tower Process (Created) A) Tracking and Quantification Method Quantification Method: Mass Balance The amount of PM10 and PM2.5 created in the cooling tower process was assumed to be the same as the PM10 and PM2.5 released to air in the cooling tower process (A 2 ) (see Section 3.2.2). B) Best Available Method Rationale See Section C) Quantification of Toxic Substance The quantification of the total amount created in the cooling tower process was assumed to be equal to the amount released to air from the cooling tower process. PM10 C 2 = PM10 created in cooling tower process: tonne PM2.5 C 2 = PM2.5 created in cooling tower process: tonne Cooling tower Process (Released to Air) A) Tracking and Quantification Method Quantification Method: Engineering Calculations The total PM10 and PM2.5 released to air was based on engineering calculations based on the operating parameters of the cooling towers onsite. It has been assumed that all particulate matter released is less than 2.5 µm in diameter. B) Best Available Method Rationale The emissions of PM10/PM2.5 have been calculated based on the operating parameters for the cooling towers onsite, in particular the total liquid drift (0.33 gal/min), the estimated amount of total suspended solids (in ppm) contained in the cooling water (10 ppm), as well as the annual operating hours for each cooling tower. It has been estimated that the data quality for this calculation is average. December

16 C) Quantification of Toxic Substance The total amount of PM10 and PM2.5 released to air is based on the operating parameters of the cooling towers onsite. Table 2 - Total Amount of Particulate Matter released to air from Cooling tower Process in 2012 Total Liquid Total Suspended Annual Operating Total Releases Cooling Tower No. Drift (gal/min) Solids (ppm) Hours (hr) (tonne) S , S , PM10 A 2 = PM10 released to air in the cooling tower process: A 2 = tonne tonne A 2 = tonne PM2.5 A 2 = PM2.5 released to air in the cooling tower process: A 2 = tonne tonne A 2 = tonne Input/Output Balance To ensure that all PM10 and PM2.5 ass accounted for in this process, an input/output calculation was completed using the following equation: Use + Creation = Transformed + Destroyed + Contained in Product + On-Site or Off-Site Release (to Air, Land, Water) +Offsite Transfers (for treatment, recycling) + Disposals Note: This process only contains materials created and released to air PM10 C 2 = A tonne = tonne PM2.5 C 2 = A tonne = tonne December

17 Unaccounted Material = 0 kg After evaluating the input/output balance, no material sources were found to be missing and no calculation errors were identified. The quantity of PM10 and PM2.5 released to air was determined based on the operating parameters the on-site cooling tower, and was assumed to have average data quality. Therefore, given the data quality of the values used in the input/output balance, the results are considered to be approximately equal. 3.3 Polymerization Process The caprolactam and other raw materials, after being received in the Receiving Stage and then being mixed in the mixing process in the Manufacturing Stage, are then transferred to the polymerization process. In this process, the mixture is heated in order to induce the polymerization reaction, where the caprolactam monomer reacts to produce nylon-6. The nylon mixture is then sent through a blend tube which mixes the nylon to create a more uniform mixture, then through a vacuum vessel to remove unreacted caprolactam, which is recycled back into the feed. Then, a heat stabilizer compound (Aminox) is injected into the mixture to allow for the nylon to retain its strength prior to heat-treatment. PM10 and PM2.5 is created from the injection of Aminox (C 3 ) these emissions are then released to the atmosphere (A 3 ). The nylon is then sent to either the chip extrusion process or the yarn extrusion process. Figure 64A - PM10 created/released in the Polymerization Process December

18 Figure 74B - PM2.5 created/released in the Polymerization Process Polymerization Process (Created) A) Tracking and Quantification Method Quantification Method: Mass Balance The amount of PM10 and PM2.5 created in the polymerization process was assumed to be the same as the PM10 and PM2.5 released to air in the polymerization process (A 3 ) (see Section 3.3.2). B) Best Available Method Rationale See Section C) Quantification of Toxic Substance The quantification of the total amount created in the polymerization process was assumed to be equal to the amount released to air from the polymerization process. PM10 C 3 = PM10 created in polymerization process: tonne PM2.5 C 3 = PM2.5 created in polymerization process: tonne December

19 3.3.2 Polymerization Process (Released to Air) A) Tracking and Quantification Method Quantification Method: Engineering Calculations The total PM10 and PM2.5 released to air was based on engineering calculations based on the emission rate of Aminox released during the injection process. It has been assumed that all Aminox released is less than 2.5 µm in diameter. B) Best Available Method Rationale The emissions of PM10/PM2.5 have been calculated based on the estimated emission rate of Aminox particulate released during the injection operation, which was estimated by Firestone based on the operating parameters of the operation. This emission rate (in grams/second) was then converted to yearly emissions based on assuming Aminox injection occurred 24 hours/day, 7 days/week. C) Quantification of Toxic Substance The total amount of PM10 and PM2.5 released to air is based on the emission rate of Aminox released. PM10 A 3 = PM10 released to air in the polymerization process: A 3 = tonne A 3 = g s tonne 3,600 s 24 hrs 10 6 g hr day 365 days year PM2.5 A 3 = PM2.5 released to air in the polymerization process: A 3 = tonne Input/Output Balance To ensure that all PM10 and PM2.5 ass accounted for in this process, an input/output calculation was completed using the following equation: Use + Creation = Transformed + Destroyed + Contained in Product + On-Site or Off-Site Release (to Air, Land, Water) +Offsite Transfers (for treatment, recycling) + Disposals Note: This process only contains materials created and released to air December

20 PM10 C 3 = A tonne = tonne PM2.5 C 3 = A tonne = tonne Unaccounted Material = 0 kg After evaluating the input/output balance, no material sources were found to be missing and no calculation errors were identified. The quantity of PM10 and PM2.5 released to air was determined based on the operating parameters of the Aminox injection operation and the overall calculated value is estimated to have average data quality. Therefore, given the data quality of the values used in the input/output balance, the results are considered to be approximately equal. 3.4 Chip Extrusion Process Some of the nylon produced is sent to the chip extrusion process. In this process, the nylon produced is sent through an extruder which shapes the nylon into individual pellets. This process also contains a recycle extruder which produces additional nylon pellets from recycled materials. These nylon chips are then sent to the drying process, where they undergo drying to remove entrained water before being packaged and shipped to customers. PM10 and PM2.5 is created in this process through the extrusion processes (both for the main chip line as well as in the recycle extruder) (C 4 ) this particulate is then emitted to the atmosphere from a dedicated stack (A 4 ). Figure 85A - PM10 created/released in the Chip Extrusion Process December

21 Figure 95B: PM2.5 created/released in the Chip Extrusion Process Chip Extrusion Process (Created) A) Tracking and Quantification Method Quantification Method: Mass Balance The amount of PM10 and PM2.5 created in the chip extrusion process was assumed to be the same as the PM10 and PM2.5 released to air in the chip extrusion process (A 4 ) (see Section 3.4.2). B) Best Available Method Rationale See Section C) Quantification of Toxic Substance The quantification of the total amount created in the chip extrusion process was assumed to be equal to the amount released to air from the chip extrusion process. PM10 C 4 = PM10 created in chip extrusion process: tonne PM2.5 C 4 = PM2.5 created in chip extrusion process: tonne December

22 3.4.2 Chip Extrusion Process (Released to Air) A) Tracking and Quantification Method Quantification Method: Source Testing The emissions of PM10/PM2.5 from the chip extrusion process have been calculated based using emission factors as based on source testing results on both the main chip extruders and the recycle extruder. B) Best Available Method Rationale The PM10 and PM2.5 emissions from the chip extrusion process have been determined based on an emission factor for emissions of PM10/PM2.5 based on the hourly production rate of chips. This factor was developed based on historically approved source testing results performed at the Facility. The main chip line extruders are vented through a scrubber with an assumed 70% efficiency in the removal of particulates. Therefore, to calculate total emissions of PM10/PM2.5, the following equation is used: g PM = P rate s PM 100 kg (100% CE) hr chips Where: PM = emissions of PM10/PM2.5 P rate = yearly production rate of chips (in 100 kg/hr) (g/s PM)/(100 kg/hr chips) = emission factor for PM emissions (as based on historically approved source testing results) CE = control efficiency of scrubber (30% for main chip line extruder, 0% (i.e., no scrubber) for recycle extruder) As these emissions are based on historically-approved source testing results and the actual production rate of nylon chips, it has been assumed to be of average data quality. C) Quantification of Toxic Substance The total amount of PM10 and PM2.5 released to air is based on production rate of nylon chips, and a historically-approved emission factor from source testing. December

23 PM10 Table 3 - Total Amount of Particulate Matter released to air from Chip Extrusion Process in 2012 Chip Production Rate (kg/year) Annual Operating Hours (hr) Scrubber Efficiency Source ID Total Releases (tonne) Chipline 2,620,925 8,760 70% Extrusion Recycle Extruder 516,800 8,760 N/A A 4 = PM10 released to air in the chip extrusion process: A 4 = tonne tonne A 4 = tonne PM2.5 A 4 = PM2.5 released to air in the chip extrusion process: A 4 = tonne Input/Output Balance To ensure that all PM10 and PM2.5 ass accounted for in this process, an input/output calculation was completed using the following equation: Use + Creation = Transformed + Destroyed + Contained in Product + On-Site or Off-Site Release (to Air, Land, Water) +Offsite Transfers (for treatment, recycling) + Disposals Note: This process only contains materials created and released to air PM10 C 4 = A tonne = tonne PM2.5 C 4 = A tonne = tonne Unaccounted Material = 0 kg After evaluating the input/output balance, no material sources were found to be missing and no calculation errors were identified. The quantity of PM10 and PM2.5 released to air was determined December

24 based on source-test derived emission factors, and the overall calculated value is estimated to have average data quality. Therefore, given the data quality of the values used in the input/output balance, the results are considered to be approximately equal. 3.5 Yarn Extrusion Process Some of the nylon produced is sent to the yarn extrusion process. In this process, the nylon produced is sent through extruder which shapes the nylon into long threads (referred to as yarn). Once the yarn threads have been produced, they are sent to the yarn spinning and winding process where they undergo a variety of spinning, winding and weaving operations to shape the yarn threads into the various products before sent to the Packaging and Shipping Stage. PM10 and PM2.5 is created in this process through the extrusion processes (C 5 ) this particulate is then emitted to the atmosphere from a dedicated stack (A 5 ). Figure 106A: PM10 created/released in the Yarn Extrusion Process Figure 116B: PM2.5 created/released in the Yarn Extrusion Process December

25 3.5.1 Yarn Extrusion Process (Created) A) Tracking and Quantification Method Quantification Method: Mass Balance The amount of PM10 and PM2.5 created in the yarn extrusion process was assumed to be the same as the PM10 and PM2.5 released to air in the yarn extrusion process (A 5 ) (see Section 3.5.2). B) Best Available Method Rationale See Section C) Quantification of Toxic Substance The quantification of the total amount created in the yarn extrusion process was assumed to be equal to the amount released to air from the yarn extrusion process. PM10 C 5 = PM10 created in yarn extrusion process: tonne PM2.5 C 5 = PM2.5 created in yarn extrusion process: tonne Yarn Extrusion Process (Released to Air) A) Tracking and Quantification Method Quantification Method: Source Testing The emissions of PM10/PM2.5 from the yarn extrusion process have been calculated based using emission factors as based on source testing results on yarn extrusion operation. B) Best Available Method Rationale The PM10 and PM2.5 emissions from the yarn extrusion process have been determined based on an emission factor for emissions of PM10/PM2.5 based on the hourly production rate of yarn. This factor was developed based on historically approved source testing results performed at the Facility. The main yarn line extruders are vented through a scrubber with an assumed 97% efficiency in the removal of particulates. Therefore, to calculate total emissions of PM10/PM2.5, the following equation is used: PM = P rate g s PM 1,696 lb (100% CE) hr yarn December

26 Where: PM = emissions of PM10/PM2.5 P rate = yearly production rate of yarn (in 100 kg/hr) (g/s PM)/(1,696 lb/hr yarns) = emission factor for PM emissions (as based on historically approved source testing results) CE = control efficiency of scrubber As these emissions are based on historically-approved source testing results and the actual production rate of nylon yarn, it has been assumed to be of average data quality. C) Quantification of Toxic Substance The total amount of PM10 and PM2.5 released to air is based on production rate of nylon yarns, and a historically-approved emission factor from source testing. PM10 Table 4 - Total Amount of Particulate Matter released to air from Yarn Extrusion Process in 2012 Source ID Yarn Production Rate (kg/year) Annual Operating Hours (hr) Scrubber Efficiency Total Releases (tonne) Yarn Extrusion 4,495,206 8,760 97% A 5 = PM10 released to air in the yarn extrusion process: A 5 = tonne PM2.5 A 5 = PM2.5 released to air in the yarn extrusion process: A 5 = tonne Input/Output Balance To ensure that all PM10 and PM2.5 ass accounted for in this process, an input/output calculation was completed using the following equation: Use + Creation = Transformed + Destroyed + Contained in Product + On-Site or Off-Site Release (to Air, Land, Water) +Offsite Transfers (for treatment, recycling) + Disposals Note: This process only contains materials created and released to air December

27 PM10 C 5 = A tonne = tonne PM2.5 C 5 = A tonne = tonne Unaccounted Material = 0 kg After evaluating the input/output balance, no material sources were found to be missing and no calculation errors were identified. The quantity of PM10 and PM2.5 released to air was determined based on source-test derived emission factors, and the overall calculated value is estimated to have average data quality. Therefore, given the data quality of the values used in the input/output balance, the results are considered to be approximately equal. Section 4.0 Facility-Wide Accounting Information 4.1 Use There was zero use of PM10 on-site in Creation The total facility wide created is equal to the amount of PM10 which is created from the various processes on-site in PM10 Facility Wide Created = C 1 + C 2 + C 3 + C 4 + C 5 Facility Wide Created = tonne tonne tonne tonne tonne Facility Wide Created = tonne PM2.5 Facility Wide Created = C 1 + C 2 + C 3 + C 4 + C 5 Facility Wide Created = tonne tonne tonne tonne tonne Facility Wide Created = tonne December

28 4.3 Transformation There were zero transformations of PM10 on-site in Destruction There was zero destruction of any of PM10 on-site in Contained In Product There was zero contained in product of any of PM10 on-site in Releases to Air The total facility wide amount of PM10 released to air on-site during 2012 is equal to the total amount released from the welding and combustion processes. PM10 Facility Wide Released to Air = C 1 + C 2 + C 3 + C 4 + C 5 Facility Wide Released to Air = tonne tonne tonne tonne tonne Facility Wide Released to Air = tonne PM2.5 Facility Wide Released to Air = C 1 + C 2 + C 3 + C 4 + C 5 Facility Wide Released to Air = tonne tonne tonne tonne tonne Facility Wide Released to Air = tonne 4.7 Releases to Land There were zero releases to land of PM10 on-site in Releases to Water There were zero releases to water of PM10 on-site in Disposals (On-Site) There were zero on-site disposals of PM10 in Disposals (Off-Site) There were zero off-site disposals of PM10 in 2012 December

29 4.11 Off-Site Transfers (Treatment or Recycling) There were zero off-site transfers of PM10 in 2012 Section 5.0 Direct and Indirect Cost Analysis It has been determined that there are no direct costs associated with PM10, as it is not directly purchased (created from combustion of natural gas, the cooling tower and various process operations) and is not directly modified or treated within the process. Table 5 - Indirect Costs Associated with PM10 Item Total Total Caprolactam monomer purchases $40,543,428 Total Aminox purchases $117,216 TOTAL $40,660,644 In total the costs associated with the creation and release of PM10 and PM2.5 in 2012 were estimated to be equal to $40,660,644. Note that the costs above were based on the monthly average costs for the materials in 2013 it was expected that these costs would be reasonably similar to Section 6.0 Toxic Substance Use and Creation Reduction Options 6.1 Material or Feedstock Substitution Options Identification of Options PM10 and PM2.5 are created as a by-product from the operation of the various processes onsite, and are not present in the raw materials used in the process. Therefore, no possible reduction options for material or feedstock substitution were identified for PM10 or PM Estimated Reductions Not Applicable Technical Feasibility Not Applicable. December

30 6.1.4 Economic Feasibility Not Applicable. 6.2 Product Redesign or Reformulation Identification of Options PM10 and PM2.5 are created as a by-product from the operation of the various processes onsite, and are not present in the final products. Therefore, no possible reduction options for material or feedstock substitution were identified for PM10 or PM Estimated Reductions Not Applicable Technical Feasibility Not Applicable Economic Feasibility Not Applicable. 6.3 Equipment or Process Modifications Identification of Options Option 1: Increase the efficiency of the chiplines extruder and the recycle extruder scrubber. This will allow additional product (in particular unreacted caprolactam monomer) to be captured and recycled back into the polymerization process. This would also specifically reduce total PM10 and PM2.5 emissions to the atmosphere. Option 2: Develop and install a hard media filtration system on the exhaust to capture dust generated during the product loading within the polymerization process. This would then decrease the quantity of Aminox which is lost during the operation, and therefore reduce total PM10 and PM2.5 emissions to the atmosphere Estimated Reductions Option 1: Currently, the efficiency on the chiplines extruder is 70%, while there is no scrubber on the recycled extruder. The actual reductions are dependent on the current efficiencies of the scrubbers as well as the efficiencies of the new scrubbers, with this difference being currently reviewed by Firestone. However, it is estimated that as much as a 50% reduction could be achieved in total particulate released December

31 from the scrubbers. This would then result in the following reductions (note: see Section for a description of the calculation procedure): Created (old scrubber) = Released to Air (old scrubber) = tonne Released to Air (old scrubber) = tonne Created (new scrubbers) = Released to Air (new scrubbers) = tonne*50% = tonne Total Reduction = tonne tonne = tonne (18.0% reduction in total PM10 and a 18.1% reduction in PM2.5 created/released to air) Option 2: Currently, the Aminox loading operation is uncontrolled. If the loading operation were to be fitted with a filtration system with a minimum efficiency of 80%, this would result in the following reductions (note: see Section for a description of the calculation procedure): Created (old) = Released to Air (old) = tonne Created (new filter) = Released to Air (new filter) = tonne * (100% - 80%) = tonne Total Reduction = tonne tonne = tonne (42.1% reduction in PM10 and a 42.3% reduction in PM2.5 created/released to air) Technical Feasibility Option 1: To replace the scrubbers would involve minimal work done on the extruder process itself, with the only significant work being done on the exhaust system. The new scrubbers would not significantly affect the operation, and in fact would allow additional recovery of the caprolactam monomer, which would thereby increase overall product efficiency. Therefore, this option has been determined to be technically feasible. Option 2: The installation of the filtration system would involve minimal work done on the Aminox loading operation in order to ensure that no excess particulate is emitted. This new filtration system would not significantly affect the operation of the Facility, as it would only affect the releases from the process and not the operation itself. Therefore, it has been determined to be technically feasible Economic Feasibility Option 1: The total costs to implement this option would be equal to the total costs of the new equipment, the installation costs for the equipment and other incidentals. This total cost has been estimated to be equal to $200,000. December

32 The savings associated with the implementation of this option are equal to the reduction in total material purchased due to the re-use of savings out of the exhausts from the scrubber. A reduction of 50% (as discussed above) would therefore result in a maximum potential reduction in material usage of about 50% of total material in, which is equivalent to tonnes of the monomer (i.e., the total estimated reductions), or 357 pounds. As the material costs are approximately $1/lb, this would therefore be a yearly reduction of $357. This results in a payback period of 560 years. Option 2: The total costs to implement this option would be equal to the total costs of the new equipment, the installation costs for the equipment and testing for the determination of annual emissions. This total cost has been estimated to be equal to $50,000. There are no savings associated with the installation of a filtration unit for the aminox exhaust. Therefore, there is no payback associated with the filtration unit but would serve to significantly reduce any potential emissions. 6.4 Spill and Leak Prevention Identification of Options All PM10 created within the various processes is directly released to the atmosphere, and does not have the potential to be spilled or leaked. Therefore, no potential reduction options were identified in this category Estimated Reductions Not applicable Technical Feasibility Not applicable Economic Feasibility Not applicable. 6.5 On-Site Reuse and Recycling Identification of Options All PM10 created within the various processes is directly released to the atmosphere there are no potential ways for the material to be collected and reused or recycled. Therefore, no potential reduction options were identified in this category. December

33 6.5.2 Estimated Reductions Not applicable Technical Feasibility Not applicable Economic Feasibility Not applicable. 6.6 Improved Inventory Management/Purchasing Techniques Identification of Options All PM10/PM2.5 is created at the Facility through the combustion of fuels or generated from other process sources and is then immediately released to the atmosphere. Improvement in inventory management procedures would not change the emissions of PM. Therefore, no potential reduction options were identified in this category for PM Estimated Reductions Not Applicable Technical Feasibility Not Applicable Economic Feasibility Not Applicable. 6.7 Training or Improved Operating Practices Identification of Options All employees at Firestone are trained to operate the equipment used in the manufacture of their products. Improved training or operating practices would not reduce the creation of PM10 or PM2.5. Therefore, there were no possible reduction options for training or improved operating practices identified. December

34 6.7.2 Estimated Reductions Not Applicable Technical Feasibility Not Applicable Economic Feasibility Not Applicable. Section 7.0 Options to Be Implemented Firestone is in the process of testing the scrubber and exhaust systems to determine the potential reductions possible in order to determine if the addition/replacement of the current equipment with new scrubbers and/or a filtration system is warranted. Therefore, Firestone will not be implementing any reduction options at this time. December

35

36 Appendix A Planner Recommendations and Rationale December 2013

37 651 Colby Drive, Waterloo, Ontario, N2V 1C2 Telephone: (519) Fax: (519) December 31, 2013 Reference No Mr. David Mels Firestone Textiles Co Dundas Street Woodstock, Ontario N4S 7V9 Dear Mr. Mels: Re: 10 µm Particulate Matter/2.5 µm Particulate Matter Planner Recommendations 1.0 Introduction The Toxics Reduction Act and Ontario Regulation (O. Reg.) 455/09 require that each toxic substance reduction plan be reviewed and certified by a Certified Toxic Substance Reduction Planner (Planner). Section 18 of O. Reg. 455/09 also requires the Planner to provide recommendations, with supporting rationale, for the purposes of improving all aspects of the plan including the potential for reducing the use and creation of the toxic substance at the facility and the business rationale for implementing the plan. The Planner is required to provide recommendations for any of the following relevant issues, or a written explanation of why a recommendation is not necessary: 1. Whether improvements could be made in the expertise relied on in preparing the plan 2. Whether improvements could be made in: i. The data and methods used for accounting purposes ii. The process flow diagrams iii. Reasons why the input and output balances are not approximately equal iv. A description of how, when, where and why the substance is used or created 3. Whether there are technically and economically feasible options for reducing the use and creation of the substance at the facility that have not been identified in the plan that would result in reductions that are equal to or greater than those already identified in the plan 4. Whether improvements could be made in: i. The estimates of anticipated reduction of use or creation, releases to environment and contained in product of the substance ii. In determination of the technical feasibility of options iii. In determination of the economic feasibility of options Worldwide Engineering, Environmental, Construction, and IT Services

38 December 31, 2013 Reference No Whether improvements could be made to the estimates of the direct and indirect costs 6. Whether the steps and timetable set out in the implementation plan are likely to be achieved 2.0 Expertise Relied on in Preparing the Plan This Toxic Substance Reduction Plan (Plan) was developed by a planning team that included David Mels, the Quality Manager at Firestone Textiles Co. (Firestone) and Erik Martinez, a Licensed Certified Toxics Reduction Planner. Mr. Mels has intimate knowledge of all aspects of the production processes at Firestone and was the lead for developing the plan and providing input. Mr. Martinez was responsible for preparing the plan through consultation with the necessary personnel at Firestone. All relevant data was collected from the appropriate departments. The level of expertise relied on during the preparation of the Plan was sufficient that the involvement of any additional parties with relevant technical experience would not have improved the plan or increased the potential to reduce the creation and releases of 10 µm Particulate Matter/2.5 µm Particulate Matter (PM). 3.0 Accounting Data and Methods Used The total quantity of PM created is assumed to be equal to the amount which is released to air from the various processes. As all PM is created and released from the Facility, this is appropriate. The total quantity of PM released to air from the facility from combustion has been calculated based on US EPA AP 42 emission factors for Stationary Combustion for natural gas and diesel combustion (PM10 only). The total quantity of PM released to air from the cooling towers is based on the cooling tower flow rate and the quantity for the liquid drift and suspended solids in the cooling water. The emissions of PM from the aminox injection (polymerization) have been estimated based on the emission rate of aminox (as PM) released to the air during the injection process based on the operating parameters of the operation. It is recommended that the methodology used to calculate the emission rate be clearly elaborated upon to ensure accuracy. Worldwide Engineering, Environmental, Construction, and IT Services

39 December 31, 2013 Reference No The emissions of PM from the chiplines and yarn extrusion processes have been estimated using emission factors for PM generation (referenced to chip and yarn nylon production) as developed from historical source testing results. All emission estimates are based on the best available method without conducting site specific source tests. Therefore, a recommendation is not necessary. Process Flow Diagrams Firestone keeps very detailed process flow charts at the Facility for all stages of production. The process flow diagrams provided for the purposes of this Plan are considered to be comprehensive and accurate; therefore there are no recommendations for this section. Input/Output Balance The input and output balances were calculated using a mass balances. The inputs are approximately equal to the outputs; therefore there are no recommendations for this section. Description of How, When, Where, and Why the Substance is Used or Created The Plan satisfies this condition of the Regulation and I have no recommendations to improve the Plan regarding this requirement. 4.0 Toxic Substance Reduction Options Firestone has identified two options to reduce PM emissions the first is to increase the efficiency of the scrubber within the chipline extruders from the current 70% (with no scrubber on the recycle extruder) to 80% for both. This has been estimated to result in a reduction of tonne (or 18.7%) in total PM creation and releases. The second option would be to install a filtration system on the aminox injection to control PM created from this process (the process is currently uncontrolled). The reductions have been calculated based on a filter efficiency of 80%, which would result in a reduction of tonne (or 42.1%) in total PM creation and releases. Therefore, no recommendation is necessary. Worldwide Engineering, Environmental, Construction, and IT Services