Toxic Substance Reduction Plans Summary For Propylene Glycol Methyl Ether Acetate (CAS# ) Hexavalent Chromium (CAS# N/A -19)

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1 Toxic Substance Reduction Plans Summary For Propylene Glycol Methyl Ether Acetate (CAS# ) Hexavalent Chromium (CAS# N/A -19) Caledon Tubing, a Division of Martinrea International Inc. 580 James Street South St. Marys, Ontario N4X 1B3 December 9, 2013 Pinchin File: Copyright 2013 by Pinchin Environmental Ltd MILLTOWER COURT, MISSISSAUGA, ONTARIO L5N 7W5 PHONE: (905) FAX: (905) ENVIRONMENTAL HEALTH & SAFETY MANAGEMENT SERVICES FROM OFFICES ACROSS CANADA

2 TABLE OF CONTENTS 1.0 BASIC FACILITY INFORMATION STATEMENT OF INTENT OBJECTIVES OF THE PLAN & ANY TARGETS DESCRIPTION OF WHY THE TOXIC SUBSTANCE IS USED OR CREATED Propylene glycol methyl ether acetate (PM Acetate) Hexavalent Chromium OPTIONS TO BE IMPLEMENTED (OR STATEMENT THAT NONE ARE TO BE IMPLEMENTED) ESTIMATED REDUCTIONS UNDER THE OPTIONS SELECTED (IF ANY) TIMELINES FOR ACHIEVING ESTIMATED REDUCTION (IF ANY) CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN COPY OF CERTIFICATIONS Pinchin Environmental Ltd. ii

3 1.0 BASIC FACILITY INFORMATION Substance Information Substance Name CAS # PM Acetate Hexavalent Chromium N/A - 19 Substances for which other plans have been prepared CAS # Zinc (and its compounds) N/A - 14 Facility Information Company Name Facility Address Site Coordinates (main entrance of site) Caledon Tubing, a Division of Martinrea International Inc. 580 James Street South, St. Marys, ON, N4X 1B3 17 T me mn NPRI ID MOE ID 9222 Number of Full-Time Employees in Digit NAICS Code Manufacturing 4- Digit NAICS Code 3312 Steel Product Manufacturing from Purchased Steel 6-Digit NAICS Code Cold-rolled steel shape manufacturing Facility Contact Information Public Contact Mr. Mike Hallam General Manager Phone #: Fax #: Mike.hallam@martinrea.com 580 James Street South St. Marys, ON N4X 1B3 2.0 STATEMENT OF INTENT Caledon Tubing, a Division of Martinrea International Inc. (Caledon Tubing) is committed to playing a leadership role in protecting the environment Pinchin Environmental Ltd. Page 1

4 Propylene glycol methyl ether acetate (PM Acetate) and the paint containing Hexavalent chromium are selected for use based on industry standards and client specifications. We intend to reduce the use and release of these materials through continuous improvement initiatives, while continuing to manufacture safe automotive vehicle parts. We will continue to use these in full compliance with all Federal and Provincial regulations. 3.0 OBJECTIVES OF THE PLAN & ANY TARGETS Caledon Tubing prides itself on technological innovation in order to produce high quality products in an environmentally responsible manner. Wherever feasible, we will aim to reduce the use and emissions of PM Acetate and Hexavalent Chromium at the facility. Further, this plan will determine the technical and economic feasibility of each option to determine which, if any, are viable for implementation at this time. As part of the continuous improvement practices at the facility, technical advances will be monitored for new opportunities to reduce the use of PM Acetate and Hexavalent Chromium at the facility. 4.0 DESCRIPTION OF WHY THE TOXIC SUBSTANCE IS USED OR CREATED 4.1 Propylene glycol methyl ether acetate (PM Acetate) PM Acetate is used to thin the paint and primer, as well as a solvent for cleaning the lines used to distribute the paint and primer for application onto parts. The lines are cleaned during shutdown periods, approximately 3 or 4 times per year. 4.2 Hexavalent Chromium Hexavalent chromium is a component of Barium chromate (1%) and Zinc chromate (2%) which make up part of the composition of the paint used to coat the tubing products. The chromates are required for its corrosion resistance property. 5.0 OPTIONS TO BE IMPLEMENTED (OR STATEMENT THAT NONE ARE TO BE IMPLEMENTED) Two reduction options have been identified for implementation to reduce the use of solvent (PM acetate) and paint (hexavalent chromium). The options are: 1. Stand-alone paint system 2. Inline viscosity check system 2013 Pinchin Environmental Ltd. Page 2

5 6.0 ESTIMATED REDUCTIONS UNDER THE OPTIONS SELECTED (IF ANY) Estimated Reductions for Stand-alone Paint System and In-line viscosity check system Both reduction options are expected to reduce the use and release of PM Acetate and use of Hexavalent Chromium. The estimated reduction of paint/solvent usage from implementing stand-alone paint system is 10%. The estimated reduction from implementing in-line viscosity check is also 10%. Used (kg) Created (kg) TOXIC SUBSTANCE: PM Acetate CiP* (kg) Released (kg) Disposed (kg) Off-site On- Off- Recycling Air Water Land Site Site (kg) Baseline 16, , New Estimated Amount 13, , Reduction % Reduction 20% % TOXIC SUBSTANCE: Hexavalent Chromium Baseline New Estimated Amount Reduction % Reduction 20% - 20% *CiP = Contained in Product 7.0 TIMELINES FOR ACHIEVING ESTIMATED REDUCTION (IF ANY) Reduction Options Description Description of Implementation Steps Implementation Schedule 1. Stand-alone Paint Line System Purchase equipment 3 rd qtr 2014 Install equipment 4 th qtr 2014 Run trial 4 th qtr 2014 Start-up Dec In-Line Viscosity Check Purchase equipment May 2014 Start-up July Pinchin Environmental Ltd. Page 3

6 8.0 CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN This Plan Summary accurately reflects the Toxic Substance Reduction Plans dated October 24, 2013, prepared for the substances listed in Section 1.0 of this Summary. 9.0 COPY OF CERTIFICATIONS See attachments Pinchin Environmental Ltd. Page 4

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8 Toxics Substance Reduction Plan PM Acetate, Hexavalent Chromium 580 James Street South, St. Marys, ON October 24, CERTIFICATION BY LICENSED PLANNER As of December 9, I, Connie Lum certify that I am familiar with the processes at Caledon Tubing that use the toxic substances referred to below, that I agree with the estimates referred to in subparagraphs 7 iii, iv and v of subsection 4 (1) of the Toxics Reduction Act, 2009 that are set out in the toxic substance reduction plans referred to below for the toxic substances and that the plans comply with the Act and the Ontario Regulation 455/09 (General) made under that Act. Plans prepared on December 9, 2013 for: PM Acetate Hexavalent Chromium Connie Lum, B.Sc., EP, #TSRP0089 Senior Project Manager Pinchin Environmental Ltd. clum@pinchin.com Pinchin Master Report Guide, Ver. 1, May 2007 J:\82000s\82422 Martinrea,MultipleFacilities,ENVNS,ENRPT\ Martinrea Caledon Tubing\TRA\Caledon Tubing TRA Plan - PM Acetate, Hex Chrome.docx 2013 Pinchin Environmental Ltd. 8