Toxic Reduction Act Gerdau Ameristeel Corporation Whitby Mill Phase 2 Toxics Reduction Plan Summaries

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1 Toxic Reduction Act Gerdau Ameristeel Corporation Whitby Mill Phase 2 Toxics Reduction Plan Summaries December 2013

2 Table of Contents 1. INTRODUCTION CERTIFICATION BY HIGHEST RANKING EMPLOYEE CERTIFICATION BY LICENSED PLANNER... 3 Table of Attachments TOXIC REDUCTION ACTION PLAN SUMMARY A PARTICULATE MATTER AND SIZE FRACTIONS TOXIC REDUCTION ACTION PLAN SUMMARY B - SULPHUR DIOXIDE TOXIC REDUCTION ACTION PLAN SUMMARY C NITROGEN OXIDES TOXIC REDUCTION ACTION PLAN SUMMARY D CARBON MONOXIDE

3 Gerdau Ameristeel Corporation, Whitby Mill December 2013 Phase 2 Toxic Substance Reduction Plan Summaries Page 1 1. Introduction The Province of Ontario developed a Toxics Reduction Strategy that included the introduction of the Toxics Reduction Act, 2009 to reduce toxic substances created or used in manufacturing processes. Gerdau Ameristeel Corporation Whitby Mill has prepared the mandated Toxic Reduction Plans for applicable substances under the Toxics Reduction Act. The Gerdau commitment to the future of new generations is reflected in its daily practices, in the investments it makes for the continuous upgrade of its equipment and in the programs it creates and supports to raise the environmental awareness of communities and employees. Consistent with the company s Integrated Policy for health and safety, environment and quality, Gerdau is committed to preventing environmental impacts and continually improving environmental performance. Gerdau steel mills have environmental management systems certified to the ISO 14001: 2004 international standard that follow a systematic approach to controlling and monitoring the environmental aspects of its operations. The toxics substance reduction plan summaries presented in this report have been prepared to meet the regulatory obligations specified in Section 8 of the Act and has been prepared in accordance with the requirements of s. 24 of Ontario Regulation (O. Reg.) 455/09, as amended from time to time. It meets the relevant reporting requirements and will be updated, as required by the Act and O. Reg. 455/09.

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6 Toxic Reduction Action Plan Summary A Particulate Matter and Size Fractions

7 Toxic Reduction Plan Summary Substance Substance Name and CAS # Particulate Matter, PM10, PM2.5 No CAS# applies to these substances Cadmium, Lead, Manganese, Zinc, Mercury, Arsenic, Substances for which other plans Dioxins and Furans, Sulphuric Acid, Hexachlorobenzene, have been prepared Carbon Monoxide, Sulphur Dioxide and Nitrogen Oxides Beneficial Uses at Facility Particulate Matter and Size Fractions has no beneficial use on site. Gerdau has previously implemented the following reduction activities for Particulate Matter and Size Fractions: EAF Baghouses; Rolling Mill finishing end dust collectors; dust control cyclone and scrubber on saw; Mist eliminator on spray chamber; Installed exhaust system for ladle preheater station EAF baghouse upgrades to improve reliability and Previously Implemented Reduction reduce Melt Shop fugitive emissions Activities dust control for slag handling; road paving and BMP for fugitive dust control including speed limits and road watering; inside unloading of scrap; inside unloading and silo storage for alloys, carbon, lime and, additives; Replaced dust transfer equipment to reduce spillage and provide additional handling of baghouse dust EAF dust loading practice Date December 11, 2013 Facility Information Company Name Facility Name Facility Physical Address Facility Mailing Address Spatial Coordinates of Facility Number of Employees 399 NPRI ID Digit NAICS Code 33 4 Digit NAICS Code Digit NAICS Code Parent Company Information Gerdau Ameristeel Corporation Gerdau Ameristeel Corporation Whitby Mill Same as physical address E N Parent Company Name Address Gerdau Ameristeel Corporation

8 Percent Ownership 100% Business Number RC0001 Facility Contact Public Contact Phil Revington, Environmental Manager Address Phone Fax Statement of Intent The Gerdau commitment to the future of new generations is reflected in its daily practices, in the investments it makes for the continuous upgrade of its equipment and in the programs it creates and supports to raise the environmental awareness of communities and employees. Consistent with the company s Integrated Policy for health and safety, environment and quality, Gerdau is committed to preventing environmental impacts and continually improving environmental performance. Gerdau steel mills have environmental management systems certified to the ISO 14001: 2004 international standard that follow a systematic approach to controlling and monitoring the environmental aspects of its operations. Particulate Matter and Size Fractions are created during the steel making process. In the last two years, Gerdau has invested over $12,000,000 in capital equipment (including Melt Shop fume control system and Baghouse upgrades) which will result in reduced emissions of particulate matter. Gerdau does not intend to further reduce the creation of Particulate Matter and Size Fractions because it is not technically feasible considering business growth plans with installed production capacity. Gerdau is committed to continual improvement in managing Particulate Matter and Size Fractions releases through equipment or process modifications, inventory management and purchasing techniques and operating practices. Plan Objectives The plan was developed with the following objectives: we will continue to operate in compliance with all applicable environmental regulations; and we will continue to manage releases of Particulate Matter and Size Fractions through current and future pollution prevention and best management practices. Description of Substance Particulate Matter and Size Fractions is incidentally created during the steel making process. Particulate Matter and Size Fractions are not intentionally introduced into the facility and serve no useful purpose in the steelmaking process or final product. Toxic Substance Reduction Option(s) To Be Implemented For the purposes of the Toxics Reduction Act, the Whitby Mill will not be implementing any options to reduce the creation of Particulate Matter and Size Fractions in its operations because no feasible options were identified. Plan Summary Statement This plan summary accurately reflects the content of the toxic substance reduction plan for Particulate Matter and Size Fractions, prepared by Gerdau Whitby, dated December 11, 2013.

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10 Toxic Reduction Action Plan Summary B - Sulphur Dioxide

11 Toxic Reduction Plan Summary Substance Sulphur Dioxide Substance Name and CAS # CAS# Cadmium, Lead, Manganese, Zinc, Mercury, Arsenic, Substances for which other plans Dioxins and Furans, Sulphuric Acid, Hexachlorobenzene, have been prepared Carbon Monoxide, Particulate Matter, PM10, PM2.5 and Nitrogen Oxides Beneficial Uses at Facility Sulphur Dioxide has no beneficial use on site. Gerdau has previously implemented the following reduction activities for Sulphur Dioxide: Previously Implemented Reduction Eliminated #2 fuel oil in reheat furnaces (2007) as Activities backup fuel Established scrap specifications for sulphur content Date December 11, 2013 Facility Information Company Name Facility Name Facility Physical Address Facility Mailing Address Spatial Coordinates of Facility Number of Employees 399 NPRI ID Digit NAICS Code 33 4 Digit NAICS Code Digit NAICS Code Parent Company Information Gerdau Ameristeel Corporation Gerdau Ameristeel Corporation Whitby Mill Same as physical address E N Parent Company Name Gerdau Ameristeel Corporation Address Percent Ownership 100% Business Number RC0001 Facility Contact Public Contact Phil Revington, Environmental Manager Address Phil.revington@gerdau.com Phone Fax

12 Statement of Intent The Gerdau commitment to the future of new generations is reflected in its daily practices, in the investments it makes for the continuous upgrade of its equipment and in the programs it creates and supports to raise the environmental awareness of communities and employees. Consistent with the company s Integrated Policy for health and safety, environment and quality, Gerdau is committed to preventing environmental impacts and continually improving environmental performance. Gerdau steel mills have environmental management systems certified to the ISO 14001: 2004 international standard that follow a systematic approach to controlling and monitoring the environmental aspects of its operations. Sulphur Dioxide is created in the electric arc furnace during the steel melting process and fuel combustion processes. Gerdau does not intend to further reduce the creation of Sulphur Dioxide because it is not technically feasible considering business growth plans with installed production capacity. Gerdau is committed to continual improvement in managing Sulphur Dioxide releases. Plan Objectives The plan was developed with the following objectives: we will continue to operate in compliance with all applicable environmental regulations; and we will continue to manage releases of Sulphur Dioxide through current and future pollution prevention and best management practices. Description of Substance Sulphur Dioxide is incidentally created in the steel making process. Sulphur Dioxide is not intentionally introduced into the facility and serves no useful purpose in the steelmaking process or final product. Toxic Substance Reduction Option(s) To Be Implemented For the purposes of the Toxics Reduction Act, the Whitby Mill will not be implementing any options to reduce the use of Sulphur Dioxide in its operations because no feasible options were identified. Plan Summary Statement This plan summary accurately reflects the content of the toxic substance reduction plan for Sulphur Dioxide, prepared by Gerdau Whitby, dated December 11, 2013.

13 Toxic Reduction Action Plan Summary C Nitrogen Oxides

14 Toxic Reduction Plan Summary Substance Nitrogen Oxides Substance Name and CAS # CAS# Cadmium, Lead, Manganese, Zinc, Mercury, Arsenic, Substances for which other plans Dioxins and Furans, Sulphuric Acid, Hexachlorobenzene, have been prepared Carbon Monoxide, Particulate Matter, PM10, PM2.5 and Sulphur Dioxide Beneficial Uses at Facility Nitrogen Oxides has no beneficial use on site. Gerdau has previously implemented the following reduction activities for Nitrogen Oxides: Replacing cryogenic oxygen plant with VSA eliminated boilers Low-NOx burners (~72% of Bar Mill reheat furnace Previously Implemented Reduction burners soak and screen zones) Activities Recuperators on both reheat furnaces Energy reduction for Structural Mill - combustion control system upgrade and installation of a peel bar for furnace Partial hot charging of billets into reheat furnace Date December 11, 2013 Facility Information Company Name Facility Name Facility Physical Address Facility Mailing Address Spatial Coordinates of Facility Number of Employees 399 NPRI ID Digit NAICS Code 33 4 Digit NAICS Code Digit NAICS Code Parent Company Information Gerdau Ameristeel Corporation Gerdau Ameristeel Corporation Whitby Mill Same as physical address E N Parent Company Name Gerdau Ameristeel Corporation Address Percent Ownership 100% Business Number RC0001 Facility Contact Public Contact Address Phil Revington, Environmental Manager Phil.revington@gerdau.com

15 Phone Fax Statement of Intent The Gerdau commitment to the future of new generations is reflected in its daily practices, in the investments it makes for the continuous upgrade of its equipment and in the programs it creates and supports to raise the environmental awareness of communities and employees. Consistent with the company s Integrated Policy for health and safety, environment and quality, Gerdau is committed to preventing environmental impacts and continually improving environmental performance. Gerdau steel mills have environmental management systems certified to the ISO 14001: 2004 international standard that follow a systematic approach to controlling and monitoring the environmental aspects of its operations. Nitrogen Oxides is created in the electric arc furnace during the steel melting process. Gerdau intends to include two energy reduction projects in its capital planning process. Implementation time frame for these projects is pending corporate approval of the funding. It is unclear that any reduction of emissions can be obtained given the business growth plans with installed production capacity. Gerdau is committed to continual improvement in managing Nitrogen Oxides releases. Plan Objectives The plan was developed with the following objectives: we will continue to operate in compliance with all applicable environmental regulations; and we will continue to manage releases of Nitrogen Oxides through current and future pollution prevention and best management practices. Description of Substance Nitrogen Oxides is incidentally created in the steel making process. Nitrogen Oxides is not intentionally introduced into the facility and serves no useful purpose in the steelmaking process or final product. Toxic Substance Reduction Option(s) To Be Implemented For the purposes of the Toxics Reduction Act, the Whitby Mill has identified two projects to reduce the Bar Mill Furnace reheating energy which will reduce the creation of Nitrogen Oxides. These projects have been included in the facility capital planning process but are not approved for implementation pending Corporate approval. Therefore Gerdau Whitby is unable to commit to a time frame for implementing these options in its operations until such time as project approval is granted and funding provided. It is unclear that any reduction of emissions can be obtained given the business growth plans with installed production capacity Plan Summary Statement This plan summary accurately reflects the content of the toxic substance reduction plan for Nitrogen Oxides, prepared by Gerdau Whitby, dated December 11, 2013.

16 Toxic Reduction Action Plan Summary D Carbon Monoxide

17 Toxic Reduction Plan Summary Substance Substance Name and CAS # Carbon monoxide CAS# Cadmium, Lead, Manganese, Zinc, Mercury, Arsenic, Substances for which other plans have been prepared Dioxins and Furans, Sulphuric Acid, Hexachlorobenzene, Nitrogen Oxides, Particulate Matter, PM10, PM2.5 and Sulphur Dioxide Carbon monoxide is utilized to generate chemical energy and foamy slag in the Electric Arc Furnace. Foamy slag Beneficial Uses at Facility improves thermal and electrical energy efficiency, reduces furnace electrode and refractory consumption, and increases steel making productivity. Gerdau has previously implemented the following reduction Previously Implemented Reduction activities for Carbon monoxide: Activities Established and maintain Electric Arc Furnace operating programs and practices Date December 11, 2013 Facility Information Company Name Facility Name Facility Physical Address Facility Mailing Address Spatial Coordinates of Facility Number of Employees 399 NPRI ID Digit NAICS Code 33 4 Digit NAICS Code Digit NAICS Code Parent Company Information Parent Company Name Gerdau Ameristeel Corporation Gerdau Ameristeel Corporation Whitby Mill Same as physical address E N Gerdau Ameristeel Corporation Address Percent Ownership 100% Business Number RC0001 Facility Contact Public Contact Phil Revington, Environmental Manager Address Phil.revington@gerdau.com Phone Fax

18 Toxic Reduction Plan Summary, Continued ii Statement of Intent The Gerdau commitment to the future of new generations is reflected in its daily practices, in the investments it makes for the continuous upgrade of its equipment and in the programs it creates and supports to raise the environmental awareness of communities and employees. Consistent with the company s Integrated Policy for health and safety, environment and quality, Gerdau is committed to preventing environmental impacts and continually improving environmental performance. Gerdau steel mills have environmental management systems certified to the ISO 14001: 2004 international standard that follow a systematic approach to controlling and monitoring the environmental aspects of its operations. No feasible options were identified to reduce the use or creation of Carbon Monoxide which has fundamental beneficial uses in the steel making process; therefore for the purposes of the Toxic Reduction Act, Gerdau does not intend to reduce the creation of Carbon Monoxide at our Whitby Mill considering business growth plans with installed production capacity. However, Gerdau remains committed to continually managing its environmental releases of Carbon Monoxide through process optimization techniques and furnace operating practices. Plan Objectives The plan was developed with the following objectives: we will continue to operate in compliance with all applicable environmental regulations; and we will continue to manage releases of Carbon monoxide through current and future pollution prevention and best management practices. Description of Substance Carbon Monoxide is created during the steel making process in the Electric Arc Furnace by the combustion of carbon inputs to generate chemical energy and create foamy slag. Foamy slag improves thermal and electrical energy efficiency, reduces the consumption of electrodes and refractory and increases productivity. Additional carbon monoxide is generated in combustion sources such as the reheat furnaces. Toxic Substance Reduction Option(s) To Be Implemented For the purposes of the Toxics Reduction Act, the Whitby Mill will not be implementing any options to reduce the use of Carbon monoxide in its operations because no feasible options were identified. Plan Summary Statement This plan summary accurately reflects the content of the toxic substance reduction plan for Carbon monoxide, prepared by Gerdau Whitby, dated December 11, 2013.