Pollution Prevention Planning Program P2 Plan Template Sewer By-law 92/2010 Part 1 - Facility Information

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1 Pollution Prevention Planning Program P2 Plan Template Sewer By-law 92/2010 Part 1 - Facility Information Business name Parent organization Facility address ABC COMPANY ABC GROUP 2230 MAIN STREET Mailing address Same as facility address Postal code NAICS code R2V 0P (Coating, Engraving, Heat Treating and Allied Activi (as reported by the City) Part 2 - Contact Information for Authorized Representative Name Position/title KEN JONES PLANT MANAGER Phone number Fax number address kjones@abccompany.com Alternate Representative Name Position/title JOE SMITH PRESIDENT Phone number Fax number address jsmith@abccompany.com

2 Part 3 - Pollutant List Complete this section using: The analytical data provided by the City of Winnipeg Any self monitoring results you may have Inventorying products used onsite to determine if products contain pollutants (complete disclosure of products can be found within the MSDS). In the chart below, please check off the pollutants that have been detected or are used in any stage of the operations of the premises. This includes: wastewater discharges land drainage discharges product used or product on premises Pollutant Present or used on premises Present in discharges Exceeds by-law limit Aldrin / dieldrin Aluminum (total) Ammonia (total) Anitmony (total) Arsenic (total) Benzene Di-n-butyl phthalate Biochemical oxygen demand Cadmium (total) Chlordane (cis plus trans isomers) Chromium (hexavalent) Chromium (total) Cobalt (total) Chlorine (total residual) Copper (total) Cyanide (weak acid dissociable) Cyanide (total) 1,1,2,2 tetrachloroethane 1,2 - dichlorobenzene

3 Pollutant Present or used on premises Present in discharges Exceeds by-law limit 1,4 - dichlorobenzene 3,3 dichlorobenzene Dichlorophenyltrichloroethane (DDT) Cis - 1,2 - dichloroethylene Trans -1,3 - dichloropropylene Ethyl benzene Bis (2-ethylhexyl) phthalate Fluoride Hexachlorobenzene Hexachlorocyclohexane (Lindane) Lead (total) Manganese Mercury (total) Methylene chloride Mirex Molybdenum (total) Nickel (total) Nitrogen (total) Nonylphenols Nonylphenol ethoxylates Oil and grease - animal or vegetable Oil and grease - mineral or synthetic Pentachlorophenol (PCP) Phenolics (total by 4AAP method) ph Phosphorus (total)

4 Pollutant Present or used on premises Present in discharges Exceeds by-law limit Polychlorinated biphenyls (PCBs) - total Polycyclic aromatic hydrocarbons (PAHs) - total Purgeable hydrocarbons (total) Selenium (total) Semivolatile hydrocarbons (total) Silver (total) Sulphate (total) Sulphide Suspended solids (total) Temperature Tetrachloroethylene Tin (total) Titanium (total) Toluene Trichloroethylene Zinc (total) Xylenes (total) Comments: Wastewater was collected from final discharge pit. Part 4 - Process Overview Insert or attach process flow diagram of all processes at this facility. Uniquely label each step and include wastewater discharge points for future reference in the plan. A flow diagram must be attached after you click submit at the end of this document.

5 Part 5 - Pollutant Evaluation Complete the following sections for each pollutant that exceeds the by-law limits as identified in the pollutant list (Part 3). Pollutant Description & Options Pollutant # 1 Hexavalent Chromium Concentration (mg/l) (see sampling results as reported by the City of Winnipeg) 13.0 Where is the pollutant discharged? sewer land drainage other Describe how and when the pollutant is generated. Please identify sources and/or process steps including estimated volumes of discharge. Excess substance from process Chromic Acid Anodize L/day generated during rinsing step after anodizing Hard Chrome Plating L/day generated during rinsing step after hard plating Decorative Chrome Plating L/day generated during rinsing step after decorative plating Option # 1 Evaporator The evaporator would boil all the rinse water leaving a chrome rich solution to be disposed of by a hazardous waste company. With this method the chrome rinse waters are not connected to any sewer drains. Expected implementation time for this option: 6 months to 1 year Option # 2 Sodium Metabisulfate The addition of sodium metabisulfate to the chrome waste waters will convert the hexavalent chromium to trivalent chromium. The trivalent chromium can then be treated by metal precipitation. This option is suitable because it is more cost effective than Option #1.

6 Expected implementation time for this option: 1 to 3 years Add another option for this pollutant Pollutant # 2 Zinc Concentration (mg/l) (see sampling results as reported by the City of Winnipeg) 10.0 Where is the pollutant discharged? sewer land drainage other Describe how and when the pollutant is generated. Please identify sources and/or process steps including estimated volumes of discharge. Excess substance from process. Generated from Zinc Cyanide that is used during zinc plating. The zinc is released after the freshly plated part is rinsed off from zinc plating. Discharge volume 8000L/day Option # 1 Metal Precipitation After ph neutralization, coagulant and flocculant are added to the wastewater with agitation. This will cause the zinc particles to precipitate out of the solution. The precipitate will settle (using a clarifier) and form a sludge which can be dewatered (using a filter press). The sludge will be disposed of by a hauled waste company and the filtrate will be cycled back to the clarifier. Expected implementation time for this option: 1 to 3 years Add another option for this pollutant Pollutant # 3 Cyanide Concentration (mg/l) (see sampling results as reported by the City of Winnipeg) 5.0 Where is the pollutant discharged? sewer

7 land drainage other Describe how and when the pollutant is generated. Please identify sources and/or process steps including estimated volumes of discharge. Excess Substance from process. Generated from Zinc Cyanide that is used during zinc plating. The zinc is released after the freshly plated part is rinsed off from zinc plating. Discharge volume 8000L/day Option # 1 Zinc Chloride An alternative to zinc cyanide is the use of zinc chloride which will eliminate cyanide from our process. In order to do this, we will require minor construction and process changes, bench testing, product testing, product reformulation as well as applying for ISO and industry accreditation. This option would help us eliminate all costs associated with cyanide treatment. Expected implementation time for this option: 1 to 3 years Option # 2 Second Chlorination Tank Another chlorination tank would retreat the cyanide after the fist process of chlorination, removing 99% of the cyanide. This would require minor construction. Expected implementation time for this option: less than 6 months Add another option for this pollutant Pollutant # 4 Nitrogen Concentration (mg/l) (see sampling results as reported by the City of Winnipeg) 150 Where is the pollutant discharged?

8 sewer land drainage other Describe how and when the pollutant is generated. Please identify sources and/or process steps including estimated volumes of discharge. Excess substance from process. Generated from Nitric Acid that is used during acid cleaning prior to plating. Discharge Volume 500 L/day Option # 1 Overstrength Discharge Licence Until we can find a cost effective solution to reducing nitric acid from the acid cleaning process, we are applying for an Overstrength Discharge Licence from the City of Winnipeg. Expected implementation time for this option: less than 6 months Add another option for this pollutant Add another pollutant Part 6 - Current Treatment System Is any of your wastewater treated prior to discharge to the sewer? yes no Describe the current devices or processes used in your treatment system. Explain how and why it works to reduce each pollutant. We currently treat for ph as well as use chlorination to reduce cyanide. ph neutralization changes the ph of the wastewater to be within the range of 7.0 to 10.0 using sulphuric acid and sodium hydroxide. Cyanide is treated by using sodium hypochlorite reducing cyanide levels to 5.0 mg/l Part 7 - Anticipated Process Changes

9 Do you anticipate any additional operational or process changes not included in your pollution prevention options? yes no Describe the planned changes that will be made to your processes or facility and how they might affect the waste water discharges. We will be adding a hydrochloric acid tank to clean parts due to the increase in production volume. This is not expected to change any characteristics of our wastewater because our current neutralization tank should treat any ph imbalances the tank may introduce. Part 8 - Pollution Prevention Plan Summary Identify which pollution prevention options from Part 5 you are going to implement for each pollutant. Pollutant Hexavalent Chromium Zinc Cyanide Nitrogen Option chosen Addition of Sodium Metabisulfate Metal Precipitation Replace with Zinc Chloride Apply for Overstrength Discharge Licence Add row How long do you estimate it will take to implement all of the pollution prevention options you have selected? less than 6 months 6 months - 1 year 1-3 years 3-5 years more than 5 years (specify) Why will it take that long to implement? major construction minor construction product redevelopment cost other

10 Describe the timeline and reasoning for your implementation schedule. The addition of Sodium Metabisulfate to the treatment process will be implemented with the construction for the Metal Precipitation treatment system. We can use the same coagulant and flocculant to precipitate both the chromium and zinc out of solution. This construction project requires introducing treatment tanks, equipment, a filter press as well as finding a company to haul the waste. Replacing Zinc Cyanide with Zinc Chloride requires process changes, product reformulation, product testing as well as ISO and industry accreditation. Since we are removing cyanide from our process, we will also be removing our sodium hypochlorite tank (no longer needed). Applying for Overstrength Discharge Licence will begin immediately. Part 9 - Pollution Prevention Plan Implementation Schedule Expected start date Sep 10, 2014 Expected completion date Jan 1, 2017 Progress milestone Completion date Provide details of significant tasks that will be completed. 1 Oct 1, 2014 Submission of OSD Licence application with required documentation. 2 April 1, 2015 Begin zinc chloride reformulation and testing 3 Sep 1, 2015 Begin construction of treatment system 4 Apr 1, 2016 Zinc Chloride product testing complete, start reapplying for accreditation. 5 Sep 1, 2016 Zinc Chloride implementation complete. Zinc Cyanide process shut down. 6 Nov 1, 2016 Construction complete for new treatment system. 7 Dec 1, 2016 Ongoing monitoring of new treatment system Add row

11 Part 10 - Authorized Representative Statement I declare that I am an authorized representative of the business. I declare that the information given in this Pollution Prevention Plan is accurate. I understand that the City of Winnipeg can apply the penalties outlined in the Sewer By-law if I provide false or misleading information. I accept Name Title Ken Jones Plant manager Date/time Sep 10, 2014 When you click submit an will be generated. Please ensure flow diagram Part 4 is attached before you send. Submit