FINAL Toxics Substance Reduction Plan Summary for Cobalt (CAS# NA - 05) 10 Reagens Industrial Parkway, Bradford West Gwillimbury, Ontario

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1 Toxics Substance Reduction Plan Summary for Cobalt (CAS# NA - 05) 10 Reagens Industrial Parkway, Bradford West Gwillimbury, Ontario Prepared for: Galata Chemicals (Canada) Inc. 10 Reagens Industrial Parkway Bradford West Gwillimbury, Ontario, L3Z 2A4 Attn: Tim Hamilton EHS Manager December 18, 2017 Pinchin File: Pinchin Ltd.

2 INTRODUCTION Galata Chemicals operates a PVC compound and additive manufacturing facility, known as Galata Chemicals (Canada) Inc., located in Bradford West Gwillimbury, Ontario. The Bradford West Gwillimbury facility manufactures products which are sold under the Galata Chemicals brand name, and offers their customers a high-quality line of additives for PVC applications. Product offerings include a broad mix of process aids, impact modifiers and stabilizers. Additives produced at the Bradford West Gwillimbury facility have a solid track record of successful performance, dating back to Today, Galata Chemicals additives are marketed globally and used in downstream operations of commercial customers around the world. An ongoing commitment to safe operations, optimization of processes and product excellence, drives sustainable development at the Bradford West Gwillimbury organization. Galata Chemicals reported to the 2016 National Pollutant Release Inventory and to Ontario s Toxics Reduction Act under O.Reg 455/09 for the substance Cobalt, and is therefore required to prepare a Toxics Reduction Plan Pinchin Ltd. Page i

3 TABLE OF CONTENTS 1.0 BASIC FACILITY INFORMATION STATEMENT OF INTENT SUBSTANCES REQUIRING PLANS OBJECTIVES OF THE PLAN & ANY TARGETS OPTIONS TO BE IMPLEMENTED (OR STATEMENT THAT NONE ARE TO BE IMPLEMENTED) CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN TERMS AND LIMITATIONS Pinchin Ltd. Page ii

4 1.0 BASIC FACILITY INFORMATION Substance Information Name Cobalt CAS # NA - 05 Facility Information Company Name Facility Address Site Coordinates (main entrance of site) 10 Reagens Industrial Parkway, Bradford West Gwillimbury, Ontario E, N; Zone 17 NPRI ID 2011 MOECC ID 6645 Number of Full-Time Employees in Digit NAICS Code 4-Digit NAICS Code 6-Digit NAICS Code Manufacturing 3252 Resin, Synthetic Rubber, Artificial and Synthetic Fibres and Filaments Resin and Synthetic Rubber Manufacturing Facility Contact Information Public Contact Tim Hamilton EHS Manager Phone # ext. 231 tim.hamilton@galatachemicals.com Address- Same as facility 2.0 STATEMENT OF INTENT Galata is committed to playing a leadership role in protecting the environment. The use of Cobalt compounds is integral to the products that are manufactured, and it is not technically or economically feasible to reduce them. We will continue to use these substances in accordance with applicable environmental regulations and will evaluate alternatives as they become commercially available. With reference to the Ontario Toxics Reduction Act, the reduction objectives are outlined in Section 4.0 of this Plan, for the reportable substance Cobalt, used at Galata Pinchin Ltd. Page 1 of 4

5 3.0 SUBSTANCES REQUIRING PLANS The substance requiring a plan is Cobalt based on 2016 Toxics Reduction Act accounting information. Cobalt is contained in a pigment used at the facility. 4.0 OBJECTIVES OF THE PLAN & ANY TARGETS Galata prides itself on technological innovation in order to produce high quality products in an environmentally responsible manner. We will strive to optimize the use of Cobalt at the facility. No new options have been identified during this planning process, however, as part of the continuous improvement practices at this facility, technical advances will be monitored for new opportunities to reduce the use of Cobalt in the future. 5.0 OPTIONS TO BE IMPLEMENTED (OR STATEMENT THAT NONE ARE TO BE IMPLEMENTED) At this time, no new reduction options have been identified for Cobalt. However, as part of ongoing practices Galata dedicates significant time and resources to producing a lean manufacturing process that maximizes its use of raw materials. To be competitive in this global economy the plant monitors new technologies and new raw materials and strives for continuous improvement. Galata will continue to review and evaluate new advances as they become available on the market and, as appropriate, will incorporate changes in to future Toxic Substance Reduction Plans. 6.0 CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN This Plan Summary accurately reflects the Toxic Substance Reduction Plans dated December 18, 2017, prepared for the substances listed in Section 1.0 of this Summary. 7.0 TERMS AND LIMITATIONS This work was performed subject to the Terms and Limitations presented or referenced in the proposal for this project. Information provided by Pinchin is intended for Client use only. Pinchin will not provide results or information to any party unless disclosure by Pinchin is required by law. Any use by a third party of reports or documents authored by Pinchin or any reliance by a third party on or decisions made by a third party based on the findings described in said documents, is the sole responsibility of such third parties. Pinchin accepts no responsibility for damages suffered by any third party as a result of decisions made or actions conducted. No other warranties are implied or expressed Pinchin Ltd. Page 2 of 4

6 Toxics Substance Reduction Plan for Cobalt (CAS# NA - 05) 1O Reagens Industrial Parkway, Bradford West Gwillimbury, Ontario December 18, 2017 Pinchin File: CERTIFICATION BY HIGHEST RANKING EMPLOYEE As of December 18, 2017, I, Sven Bachmann, certify that I have read the toxic substance reduction plan for the toxic substance referred to below and am familiar with its contents, and to my knowledge the plan is factually accurate and complies with the Toxics Reduction Act, 2009 and Ontario Regulation 455/09 (General) made under that Act. COBALT CAS# Employee: Plant Manager ext. 251 sven.bachmann@galatachemicals.com MEMBER OF 2017 Pinchin Ltd. Page 6 of 7 THE PINCHIN GROUP

7 CERTIFICATION BY LICENSED PLANNER As of December 18, 2017, I, Ajay Madan, TSRP#0010 certify that I am familiar with the processes at that use or create 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 that Act and Ontario Regulation 455/09 (General) made under that Act. Cobalt CAS# Planner: Ajay Madan, TSRP#0010 Senior Project Engineer amadan@pinchin.com J:\120000s\ GALATACHEMICA,10ReagensIndu,ENVNS,CONS\ GALATACHEMICA,10ReagensIndu,ERC,TRA\Deliverables\ TRA Plan 10 Reagens Industrial Parkway, Bradford Galata Dec. 18, 2017.docx Template: Master Report for Toxics Substance Reduction Plan, ERC, June 27, Pinchin Ltd. Page 4 of 4