DESCOR INDUSTRIES TOXIC SUBSTANCE REDUCTION PLAN. Ethyl Acetate. Submitted to: Descor Industries 15 Riviera Drive Markham, ON, L3R 5M1

Transcription

1 DESCOR INDUSTRIES TOXIC SUBSTANCE REDUCTION PLAN Ethyl Acetate Submitted to: 15 Riviera Drive Markham, ON, L3R 5M1 Submitted by: Amec Foster Wheeler Environment & Infrastructure, a division of Amec Foster Wheeler Americas Limited Cambridge, ON Date November 2015 Project Number SWC154375

2 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure TABLE OF CONTENTS PAGE 1.0 INTRODUCTION Background Basic Facility Information TOXIC REDUCTION POLICY STATEMENT OF INTENT REDUCTION OBJECTIVES PROCESS DESCRIPTION Receiving Stage Preparation Stage Finishing Stage NGR Application Process Wiping Stain Application Process Sealer Application Process Paint Stripping Process (If Required) Top Coat Application Process Final Assembly Stage Shipping Stage ACCOUNTING ANNUAL COSTS REDUCTION OPTIONS Materials or Feedstock Substitution Product Design or Reformulation Equipment or Process Modification Spill and Leak Prevention On-Site Reuse or Recycling Improved Inventory Management or Purchasing Techniques Training or Improved Operating Practices Summary of Options ECONOMIC FEASIBILITY ANALYSIS IMPLEMENTATION CONCLUSIONS PLANNER RECOMMENDATIONS AND RATIONALE CERTIFICATIONS CLOSURE SWC November 2015 Page i

3 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure LIST OF TABLES Table 1.1: Summary of Options Table 2.1: Ethyl Acetate - Economic Analysis Table 2.2: List of Feasible Options LIST OF APPENDICES Appendix A: Appendix B: Appendix C: Appendix D: Appendix E: Process Flow Diagrams Toxic Substance Costing Toxic Substance Accounting Check List Plan Summary SWC November 2015 Page ii

4 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure 1.0 INTRODUCTION 1.1 Background Ontario s approach to reducing toxic substances aims towards safer alternatives and focuses on chemical use rather than traditional end of pipe management. In 2009, the Toxics Reduction Act (Act) and its associated regulation (O.Reg. 455/09) were promulgated as part of the Ministry of Environment and Climate Change (MOECC) toxics reduction strategy. The Act and regulation apply to manufacturing facilities with North American Industry Classification System (NAICS) codes starting with 31, 32 or 33 and facilities with NAICS codes starting with 212 that process minerals but only if chemicals are used to separate, concentrate, smelt or refine metallic or non-metallic mineral from an ore. In general, the Act requires regulated facilities to: track, quantify and report annually on the toxic substances they use, create, release, dispose, transfer and contain in products; develop plans to reduce the use and creation of these substances; and make annual reports and summaries of their plans available to their employees and the public. Regulated substances under the Act include all substances listed in Environment Canada s National Pollutant Release Inventory (NPRI) and O.Reg. 127/01 (acetone being the sole contaminant listed under this regulation). Forty-seven substances and substance groups were identified as priority substances and are listed in Table A of O.Reg. 455/09. Tracking of these Phase 1 substances began in 2010, with initial reduction plans due by 31 December Tracking for the remaining contaminants started 1 January 2012 with reduction plans due by 31 December Reduction plans must be revisited in 2018 and every five years thereafter. 1.2 (Descor) is a long-standing furniture manufacturer. Descor is responsible for the preparation, and finishing of raw furniture materials. The Descor facility is located at 15 Riviera Drive in Markham. The Descor facility is an industrial operation on a 4.3 hectare site located on a site zoned as MCS4 Industrial Zoning. The company operates Monday Thursday from 7am 4:30pm, and Friday from 7am 1:30pm. Currently the facility employs approximately 120 people. Although originally constructed in 1987, the Descor facility has been continually updated. The Descor facility is committed to sustainable development and has shown this through numerous improvements in product design, manufacturing and day to day business operations. Descor has implemented various voluntary environmental programs including Level, and ISO certification. processes raw wood material into office furniture. The raw wood is received by the facility. The raw wood is unloaded and stored on-site until needed; the wood is processed through the various stages until it is a finished piece of office furniture, where it is maintained in a warehousing and storage facility, and the product is shipped to customers. SWC November 2015 Page 3

5 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure 1.3 Basic Facility Information Company Name: Contact Information: Highest Ranking Employee: Chanoch Friedel President Technical Contact: Certified Planner: Parent Company: Address: UTM Coordinates (NAD83): Larry Laycock QA/EHS Manager Beth Rhyno, P.Eng. License Number TSRP0273 Compliance Team Leader Amec Foster Wheeler Environment & Infrastructure Global Upholstery 560 Supertest Road, Downsview 95% Ownership 15 Riviera Drive Markham, Ontario L3R 5M1 Zone 17T m E, m N Business Number: Descor Global Upholstery The facility s NPRI ID: In 2014, Descor employed about 120 full time employees (equivalent) The NAICS codes applicable to the facility are: 33 Manufacturing 3372 Office Furniture (Including Fixtures) Manufacturing Wood Office Furniture Manufacturing In 2014, the site used ten (10 ) MOECC Toxic compounds at concentrations greater than the reporting threshold. SWC November 2015 Page 4

6 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure Two of these substances, methanol and toluene, were Phase I substances and therefore required plans in Plan Summary and associated reporting was completed to the MOECC as per regulatory requirements. In 2012 additional TRA plans were created for acetone, butyl acetate, ethanol, methyl ethyl ketone, methyl isobutyl ketone, mineral spirits, naphtha, xylene, PM10 and P2.5. TRA planning and reporting was done as per the regulatory requirements to the MOECC. In 2013, stoddard solvent met the reporting threshold for the first time and therefore a TRA Plan and Plan Summary was created and the TRA Plan Summary submitted prior to the December 31, 2014 deadline. For the 2014 NPRI/TRA annual reporting period, ethyl acetate use met reporting thresholds for the first time. Due to issues with durability of the Valspar finishes, Descor switched topcoat suppliers and products which resulted in the increased use of ethyl acetate. Since this change, Descor has switched from CCI/RPM back to the original supplier. This change is expected to result in less usage of ethyl acetate for the 2015 operating year. This TRA plan is now required for ethyl acetate and its TRA Plan Summary submission to the MOECC is due by December 31, The CAS number for the MOE Toxic Compounds identified in this report is: Ethyl Acetate 2.0 TOXIC REDUCTION POLICY STATEMENT OF INTENT Descor is committed to playing a leadership role in protecting the environment. Wherever feasible, we will eliminate or reduce the use, creation and discharge of toxic substances in full compliance with all federal and provincial regulations. Our employees are encouraged to participate in all types of toxic substance reduction activities. Toxic substance reduction will be an ongoing effort at Descor, and we will continue to build on past successes and develop new technologies. 3.0 REDUCTION OBJECTIVES All employees at Descor will be involved in the reduction of toxic substance use, creation and releases. Prescribed substances under the Toxic Reductions Act will be our first priorities for reduction. Our goal is to reduce the use of ethyl acetate, where technically and economically feasible. No reduction options were identified to be both technically and economically feasible. Therefore, no options are being implemented at this time. Potential options will continue to be monitored and revaluated as costs, market demands and production requirements change. SWC November 2015 Page 5

7 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure 4.0 PROCESS DESCRIPTION processes raw wood into office furniture. The company operates Monday Thursday from 7am 4:30pm, and Friday from 7am 1:30pm. Currently the facility employs approximately 120 people. The raw wood is received by the facility, unloaded and stored on-site until needed. Wood is processed through the various stages until it is a finished piece of office furniture, where it is maintained in a warehousing and storage facility until the product is shipped to customers. consists of two buildings. The main building includes all process and related equipment and offices. The second building includes the same processes as the main building as well as a warehouse storage area. There are three paint shops in total (with 2 currently in use), two in the first building and one in the second building. There are no significant differences in the operations of the paint shops. The raw wood received by the facility first enters the receiving stage, followed by the preparation stage. The preparation stage includes multiple processes including: veneer application, pressing, laminating, cutting, routing/drilling, sanding, and assembly. Not every piece of furniture requires each preparation process however multiple processes would be necessary. One dust collector (one in each building) is responsible for the collection and reduction of the particulate emissions created from the various preparation stage processes. After the preparation stage, the assembled product enters a two stage finishing process. The first of the finishing processes involves paint and stain application. The application of the base coat (NRG) and wiping stain to the products takes place in spray chambers to minimize the emissions of particulates and VOCs. The product(s) are air dried as it is treated to the NRG coat and then stained before being sent to the next stage. After the product has passed the quality inspection of the base coat and stain it is directed to the sealer and top coat application process. Both the sealer and top coat application are done within spray chambers to minimize the emissions of particulates and VOCs and then the product completes its curing in drying ovens. There is a quality inspection between the sealer application and cure and the top coat application. The product is individually inspected and any quality issues are addressed in-situ. Re-worked pieces are directed to the start of the finishing process to undergo the appropriate NRG coat and stain. After the finishing process, the final product is again inspected, packaged and stored until it is shipped to customers. For process flow diagram showing movement of ethyl acetate see Appendix A: Figure A Receiving Stage During the receiving stage, wood parts are received by truck. The raw wood materials received from suppliers include particleboard, solid wood, laminate and veneer. Stains, coatings, sealants and solvents are (some of which contain ethyl acetate) are also received via truck in the receiving SWC November 2015 Page 6

8 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure process. The chemicals are received in drums and pails and are transferred to dedicated chemical storage areas by forklifts or manual transportation. Ethyl acetate would be present in specific finishing products or substances used during Finishing stage, however there would be no emissions or use associated with the Receiving Stage. 4.2 Preparation Stage The preparation stage involves various processes. The products may move through the steps in various orders depending on the specific product that is being produced. The processes included in the preparation stage are: veneer application, pressing, HPL laminating, cutting/shaping, sanding, and assembly. Minimal amounts of contact cement are used in the HPL laminating process. The contact cement is used to apply high pressure laminate. The contact cement is sprayed on with a hand-held spray gun in a fume hood, the toluene flows through an air filtration system before being exhausted into the air. There is no significant residual waste of contact cement. The mold release is used on machinery to keep hot glue from sticking to the machine parts. The mold release is used on-site in an aerosol can. When empty, the aerosol cans are punctured and residual propellant is drained into a drum, which is then sent for recycling. There is no significant residual waste of mold release. Ethyl acetate is not present in any of the products or substances used during the preparation stage. 4.3 Finishing Stage The finishing stage takes place after the product has been prepared. The finishing stage involves four or five processes, depending on the specific product. The processes include NGR application, wiping stain application, sealer application, paint stripping (if required), and top coat application. NRG colour base, stains, sealers and topcoats are applied to the parts using a spray gun process, whereby the parts are placed on conveyors which move the parts through the finishing process. For process flow diagram see Appendix A: Figure A NGR Application Process Ethyl acetate is present in some of the NGR paints used on-site. NGR paints are transferred from the chemical receiving process, and are applied to the wood components in a spray chamber. Emissions from the NGR spray chamber are vented (moved) to the spray chambers filtration system and pass through untreated as an on-site release to air. SWC November 2015 Page 7

9 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure Since the spray guns are manually controlled, and the configuration of the sprayer there is negligible amounts of overspray. Any collection and disposal of the overspray has been accounted for in the total volumes of NGR used and its associated air emissions. NGR paints are mixed and applied in a batch basis as products/components require specific custom ordered colours. Excess NGR paints are collected at the end of each day and stored until they are transferred off-site for recycling. Empty NGR cans containing residual NGR, are left to dry out. The residual ethyl acetate left in the cans are evaporated into the air. The empty cans are then sent off-site for recycling with the other metals. Ethyl acetate is present is the solvent used for cleaning the spray guns. The cleaning of the spray guns takes place within the spray chamber. The used solvent is collected at the end of each day and stored until transferred off-site for recycling, which is accounted for in the total amount of waste for recycle Wiping Stain Application Process Ethyl acetate is present in some of the wiping stains used on-site. The stains are transferred from the chemical receiving process, and are applied to the wood components in a spray chamber. Ethyl acetate emissions from the wiping stain spray chamber are vented (moved) to the spray chambers filtration system and pass through untreated as an on-site release to air. Since the spray guns are manually controlled, and the configuration of the spraying applications there is negligible amounts of overspray. Any collection and disposal of the overspray has been accounted for in the total volumes of stain used and its associated air emissions. Stains are mixed and applied in a batch basis as products/components require specific custom ordered colours. Excess stains are collected at the end of each day and stored until they are transferred off-site for recycling. Ethyl acetate left in the cans is evaporated into the air. The empty cans are then sent off-site for recycling with the other metals. Ethyl acetate is present in the solvent that is used for cleaning the spray guns. The cleaning of the spray guns takes place within the spray chamber. Therefore, emissions from the cleaning of the guns are vented to the filtration system and accounted for in total emissions to air. The used solvent is collected at the end of each day and stored until transferred off-site for recycling, which is accounted for in the total amount of waste for recycle. After the stain is applied with the spray guns, the furniture is manually wiped down with rags. The rags are left to air dry. Once dry, the rags are disposed of as non-hazardous waste, as 100% of the ethyl acetate from the stain is assumed to have evaporated to the air Sealer Application Process Next, the product is sprayed with a sealer and passes through a curing oven. Emissions to air are expected from both the chamber during spray application and as flash-off in the drying oven. Ethyl acetate is present in some of the sealers that are transferred from the chemical receiving process, and are applied to the wood components in a spray chamber. Ethyl acetate emissions SWC November 2015 Page 8

10 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure from the sealer spray chamber are vented (moved) to the spray chambers filtration system and pass through untreated as an on-site release to air. Any ethyl acetate still present in the sealer on the part is transferred to the curing over, and is subsequently released to the atmosphere form the curing ovens. Since the spray guns are manually controlled, and the configuration of the spraying applications there is negligible amounts of overspray. Any collection and disposal of the overspray has been accounted for in the total volumes of sealant used and its associated air emissions. Sealers are mixed and applied in a batch basis as products/components require specific custom ordered colours/finishes. Excess sealant is collected at the end of each day and stored until they are transferred off-site for recycling. Empty sealer drums containing residual sealer, are left to dry out. The residual ethyl acetate left in the cans is evaporated into the air. The empty drums are then returned to the supplier. Ethyl acetate is present in the solvent that is used for cleaning the spray guns. The cleaning of the spray guns takes place within the spray chamber. Therefore, emissions from the cleaning of the guns are vented to the filtration system and accounted for in total emissions to air. The used solvent is collected at the end of each day and stored until transferred off-site for recycling, which is accounted for in the total amount of waste for recycle Paint Stripping Process (If Required) Ethyl acetate is not present in the paint stripped used on-site. Paint stripper is used in small quantities by the facility, in case of finish mistakes or equipment malfunctions. The paint stripper is transferred from the chemical receiving process, and applied to the wood components in order to remove the finish. Emissions from the application of the paint stripper are vented as on-site releases to air. The paint stripper is applied manually which minimizes waste. If required in the case of a paint/stain mistake or equipment malfunction, paint stripper is applied manually to remove the finish from wood products. There is no waste of paint stripper from this process Top Coat Application Process Ethyl acetate is present in some of the top coats that are transferred from the chemical receiving process, and are applied to the wood components in a spray chamber. Ethyl acetate emissions from the top coat spray chamber are vented (moved) to the spray chambers filtration system and pass through untreated as an on-site release to air. Any ethyl acetate still present in the top coat on the part is transferred to the curing over, and is subsequently released to the atmosphere from the curing ovens. Since the spray guns are manually controlled, and the configuration of the spraying application there is negligible amounts of overspray. Any collection and disposal of the overspray has been accounted for in the total volumes of top coat used and its associated air emissions. SWC November 2015 Page 9

11 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure Top coats are mixed and applied in a batch basis as products/components require specific custom ordered colours/finishes. Excess top coat is collected at the end of each day and stored until they are transferred off-site for recycling. Empty topcoat drums containing residual topcoat, are left to dry out. The residual ethyl acetate left in the cans are evaporated into the air. The empty drums are then returned to the supplier. Ethyl acetate is present in the solvent that is used for cleaning the spray guns. The cleaning of the spray guns takes place within the spray chamber. Therefore, emissions from the cleaning of the guns are vented to the filtration system and accounted for in total emissions to air. The used solvent is collected at the end of each day and stored until transferred off-site for recycling, which is accounted for in the total amount of waste for recycle. 4.4 Final Assembly Stage The final assembly stage involves four processes including: the inspection process, final touchup process, final assembly process, and the packaging process. Ethyl acetate is present in some of the aerosol paints used in the touch-up process. Finished products are touched-up with stain markers and aerosol cans before being packaged where there are any quality issues identified. The aerosol cans are used to spray the paint directly on the finished wood products. Any emissions of ethyl acetate from the aerosol spray cans are released into the general ventilation space of the area and due to the insignificant quantities, are released untreated as on-site release to air. After use, the cans are punctured to release the propellant and excess paint is drained into a drum and is stored on-site until collected for off-site recycling. Empty cans are recycled with other metals. For process flow diagram see Appendix A: Figure A Shipping Stage Finished products are packaged and sent to the on-site warehouse where they are stored until being shipped by truck to customers. Ethyl acetate is not present in Shipping Stage of the final office furniture products. 5.0 ACCOUNTING See Tables in Appendix C. Spreadsheets include: a summary of quantities created, used, contained in product, released, disposed and transferred, as well as a summary of the quantification methods used. Current accounting methods are best available. No alternate cost-effective method is available. SWC November 2015 Page 10

12 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure 6.0 ANNUAL COSTS Appendix B provides a costing table for the use of ethyl acetate at the Descor facility. The tables in Appendix B also provide direct and indirect costs associated with the use of ethyl acetate, as well as a summary of the reduction potential for identified options. 7.0 REDUCTION OPTIONS 7.1 Materials or Feedstock Substitution Solvent based paints, stains, sealers and topcoats could potentially be substituted with lower VOC or water-based products. Switching all paints/stains/sealers/topcoats to products that contain no VOCs would result in a major decrease in the amount of ethyl acetate used on-site. If the Valspar and CCI/RPM paints/stains used in finishing process (NGR Application Process, Wiping Stain Application Process, Sealer Application Process, and Topcoat Application Process), were all substituted with water based products (assuming the substitutes contain no ethyl acetate), the amount of ethyl acetate used on-site could be significantly reduced. Reduction potential of this option is summarized in Appendix B. It would be technically feasible to replace some of the solvent based finishes with water based or low VOC products. However, substituting all finishing products with water based products that contain VOCs at lesser concentrations would not be economically feasible. Not all furniture finishes as per client specifications can be met with the water based or low VOC finishing products. In 2014 Descor switched to a new paint supplier (CCI/RPM). The new formulation of topcoats has resulted in the increased use of ethyl acetate over other previous reporting years. In 2015, Descor switched back to their original supplier (Valspar) for paint products. Although the accounting information is not available yet, this change is expected to result in a significant decrease of ethyl acetate used on site. However, it is also expected that amounts of other VOCs contained in the paints will increase based on the supplier s specific formulations. Other raw materials used by Descor such as wood, laminate and veneer do not contain VOCs; therefore, no reduction options are available. 7.2 Product Design or Reformulation Selling unfinished office furniture would reduce the use of ethyl acetate within the facility. However, this option is not considered to be technically feasible as it would not meet client demands and specifications. Ethyl acetate is not contained in the final product. No technically feasible options are available for product design or reformulation. SWC November 2015 Page 11

13 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure 7.3 Equipment or Process Modification HVLP (High volume low pressure) spray guns are currently used at the facility. Based on current spray gun technologies, Descor is already using the most efficient spray guns applicable to their operations. All spraying of finishes are applied in chambers whereby the emissions are filtered before being exhausted into the atmosphere. Modifying the finishing process to a staging technique whereby all products of one colour are sprayed before switching to another colour, could potentially reduce the amount of solvent used for cleaning. However, due to the specific, unique finishes required by Descor clients, this option is not considered to be technically feasible. No technically feasible options to reduce the use of ethyl acetate were identified for the equipment or process modification category. 7.4 Spill and Leak Prevention Due to the hazardous nature of the chemicals used by Descor, they currently have a spill & leak prevention plan in place. During the 2014 year, there were no spills of materials containing ethyl acetate. Therefore, no technically feasible option is identified under this category. 7.5 On-Site Reuse or Recycling Excess paints and stains are currently transferred off-site for recycling. The amount of paints/stains/sealers and topcoats purchased could be reduced where excess could be re-used on-site. However, due to the high quality of specific paint/stain required in the finishing process (i.e. final product quality specifications); it is not technically feasible for Descor to reuse the excess paints/stains on-site. Increasing off-site recycling would not result in a reduction of ethyl acetate purchased or used onsite in the paints/stains used in the finishing process. Therefore, no technically feasible option is identified under this category. 7.6 Improved Inventory Management or Purchasing Techniques Ethyl acetate used on site is currently purchased on an as required schedule. This current purchasing technique reduces the inventory of solvents and helps reduce waste. Purchasing techniques are largely based on consumer demand. In recent years, Descor has found that demand for water-based or low VOC paints/stains has increased. In order to meet this demand, Descor could substitute the paints/stains used on-site. The reductions associated with this substitution has been accounted for in option 7.1, above No other options to reduce the use of MOECC toxic materials were identified for improvement of inventory management or purchasing techniques. SWC November 2015 Page 12

14 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure 7.7 Training or Improved Operating Practices Descor s current operating practices have been developed to comply with all relevant industry standards for handling hazardous materials. Revising current operating practices and their related standard operating procedures (SOPs) is part of their continuous improvement policy. The Descor facility is currently ISO14001 certified which requires it to conduct routine training programs for staff to enhance their knowledge and skills especially with regard to hazardous material handling. Increased training is not expected to further reduce the use of ethyl acetate on-site. No technically feasible options to reduce the use of MOECC toxic materials were identified for the training or improved operating practices category. 7.8 Summary of Options Table 1.1: Summary of Options # Description Reduction Potential 7.1 Substituting paints, stains, sealers and topcoats with water based products that contain no ethyl acetate 86% See Appendix A Technically Feasible? 7.2 Selling unfinished office furniture products N/A No 7.3 Reduce solvent use in cleaning through staging N/A No 7.4 No option identified N/A N/A 7.5 Increased on-site reuse of used paints/stains N/A No 7.6 No option identified N/A N/A 7.7 No option identified N/A N/A Yes 8.0 ECONOMIC FEASIBILITY ANALYSIS Table 2.1: Ethyl Acetate - Economic Analysis # Description Payback Period Anticipated Savings 7.1 Substituting current paints, stains, sealers and topcoats with water based products that contain no VOCs Possibility of increased sales Market driven payback unknown Table 2.2: List of Feasible Options None - Direct costs of substitute materials would cost more from the Supplier # Description Reduction Potential Technically Feasible? 7.1 Substituting current paints, stains, sealers and topcoats with water based products that contain no ethyl acetate. 83% See Appendix A Yes low VOC substitutes are technically feasible Economically Feasible? No costs for handling, system and disposal not significantly different. Increased costs for low VOC substitutes. SWC November 2015 Page 13

15 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure 9.0 IMPLEMENTATION No reduction options were identified to be both technically and economically feasible. Therefore, no options are being implemented at this time. As mentioned above, the amount of ethyl acetate used on-site and released to air is expected to decrease for the 2015 operational year as the facility has since switched product suppliers. The new paint, stain, sealer, and topcoat formulations are anticipated to contain less ethyl acetate but will likely contain more of other various VOCs CONCLUSIONS Descor is committed to playing a leadership role in protecting the environment as evidenced by the multiple environmental and sustainability programs that have been achieved through compliance and certification. Descor is not only committed to eliminating or reducing the use, creation and discharge of toxic substances, where feasible but it is committed to full compliance with all federal and provincial regulations associated with these compounds. Employees receive continuous training and are encouraged to participate in all types of toxic substance reduction activities. There are opportunities identified within material substitution and training or improved operating practices which could reduce or eliminate the use, creation or discharge of ethyl acetate. The material substitution of the current paint systems to lower-voc or water based systems has also been analyzed. Replacing all finishes with substitutes which contain no ethyl acetate is not technically feasible at this time. However, substituting some finishes with low VOC options is technically feasible. The economic feasibility assessment has determined that this option is not economically feasible at this time. Toxic substance reduction will be an ongoing effort at Descor, and we will continue to build on past successes and develop new technologies PLANNER RECOMMENDATIONS AND RATIONALE The Licensed Planner was involved with every step of the plan development. Any suggestions or recommendations for improvements under 18(2) were made as the plan was developed. As a result, there are no further recommendations at this time. SWC November 2015 Page 14

16 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure 12.0 CERTIFICATIONS CERTIFICATION OF HIGHEST RANKING EMPLOYEE As of November 9, 2015, I, Chanoch Friedel, 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 Ethyl Acetate Chanoch Friedel President CERTIFICATION OF LICENSED PLANNER As of November 9, 2015, I, Beth Rhyno certify that I am familiar with the processes at Descor Industries that use or create the toxic substance 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 plan dated Dec 19, 2013 and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act Ethyl Acetate Beth Rhyno, P.Eng. Licensed Toxic Reduction Planner (Ontario): License Number TSRP0273 Compliance Team Leader Amec Foster Wheeler Environment & Infrastructure SWC November 2015 Page 15

17 Toxic Substance Reduction Plan Ethyl Acetate Amec Foster Wheeler Environment & Infrastructure 13.0 CLOSURE Written by: Rachel Hackett, Environmental Specialist Amec Foster Wheeler Environment & Infrastructure Signature: Date: Reviewed by: Beth Rhyno, P.Eng., Compliance Team Leader Amec Foster Wheeler Environment & Infrastructure Signature: Date: SWC November 2015 Page 16

18 APPENDIX A PROCESS FLOW DIAGRAMS

19 APPENDIX A: FIGURE A-1 PROCESS FLOW DIAGRAM AND QUANTIFICATION - ETHYL ACETATE A 2, A 3, A 4, A 5 DQL=A Aerosol Paint Valspar and CCI/RPM U 1 DQL=AA U 2 DQL=AA NGR/Stain, Topcoat and Sealer, Drying and Cleaning Stripping (if required) Final Touch-up Assembly Packaging A 1 DQL=A TR 1 DQL=A Solvent for cleaning U 3 DQL=A TR 2 DQL=A Finishing Stage Assembly Stage Stripper HPL Laminating Storage Glue Raw wood materials Dust Collector Shipping Receiving / Inventory Stage Cutting and Sanding Legend Storage & Shipping Stages Absence of toxic substance Onsite or offsite release, or offsite transfer of toxic substance Denotes presence of toxic substance Assembly Preparation Stage U = Use of toxic substance C = Creation of toxic substance A = onsite release of toxic substance to Air P = Substance contained in Product DIS = Onsite or offsite disposal of toxic substance D = Toxic substnace is destroyed TR = Offsite transfer of toxic substance for treatment or recycling DQL = Data Quality Level (H = High, AA = Above Average, A = Average, U = Uncertain)

20 APPENDIX A: FIGURE A-2 PROCESS FLOW DIAGRAM AND QUANTIFICATION NGR/Stain Process A 2 DQL=A A 3 DQL=A A 4 DQL=A Air filtration System Drying Oven Valspar and RPM NGR and Stain Solvent for cleaning U 2 DQL=AA U 3 DQL=A NGR/Stain, Topcoat and Sealer Drying and Cleaning A 5 DQL=A To Stripping (if required) or Assembly Stage Raw wood materials TR 1 DQL=A Finishing Stage Receiving / Inventory Stage Annual Basis Ethyl Acetate Tonnes Calculation Method U Purchase records and MSDS Purchase records and MSDS U MSDS for EZ thinner, Purchase Records Amount used - measurements collected by client A Mass Blanace Emission from air filtration system are assumed to be the remaining amount Assumed 10% of emissions to air are from the cure oven (20% total since there are Mass Balance A ovens) A Mass Balance Assumes 3% of total emissioms are from residual product in drums/cans, assumes 100% of the residual evaportaes to the air before drums are recycled. Assumes 1% of total emissions is from used rags, Assumes 100% of substance Mass Balance A evaporates before rangs are disposed of. TR Report from Recycling company Report from Recycling company

21 APPENDIX A: FIGURE A-3 PROCESS FLOW DIAGRAM AND QUANTIFICATION Touch-up Process A 1 DQL=A Aerosol Paint U 1 DQL=AA Final Touch-up Assembly Stage TR 1 DQL=A Receiving / Inventory Stage Furniture from Finishing Stage Annual Basis Ethyl Acetate Tonnes Calculation Method U Purchase records and MSDS Purchase records and MSDS A Assumes that amount not recycled, is realesed to air Mass balance TR Based on site measurements conducted by client Measured residual in drum

22 APPENDIX B TOXIC SUBSTANCES COSTING

23 Appendix B: Table B-1 Costing Table for Toxics Item Source Total Cost per year Scaling for Toxic Ethyl Acetate CCI/RPM Sealer and Topcoat Purchase records $101, Based on quantity of toxics as provided by supplier $11, Valspar Products Purchase records $232, Based on quantity of toxics as provided by supplier $4, Dover Aerosol Paints Purchase records $4, Based on percentage of toxics contained as identified on the MSDS $ no direct cost associated with toxics. Paint booth operation still needed for Internal transportation costs MOECC non-toxic components. Would not change if no toxics present or replaced $0.00 with non-toxics. Disposal - $0.00 No toxics are disposed of $0.00 Off-site Recycling costs Company records $8, Recycling report identifies quantity of toxics recycled. Use % of total to calculate cost specific $ to ethyl acetate. Building Utilities - water not applicable $0.00 Building Utilities - waste water not applicable $0.00 Building Utilities - electricity not applicable $0.00 No direct cost associated with toxics. Paint booth operation still needed for Labour cost to operate paint booths MOECC non-toxic components. Would not change if no toxics present or replaced $0.00 with non-toxics. OHS No direct costs assoiciated with the use of ethyl acetate. $0.00 No direct cost associated with toxics. Permitting/reporting still needed for MOECC Environmental Permitting/Reporting non-toxic components. Would not change if no toxics present or replaced with nontoxics. $0.00 TRA Cost Amec Foster Wheeler cost and hours ($2500) + time and labour rate for Descor ($1500) $4, Total cost - TRA Planning required for only one substance in 2014 $4, Insurance No direct costs associated with MOECC Toxic Substances $0.00 Other None identified $0.00 Total Costs per Toxic $9,351.79

24 Appendix B: Table B-2 Estimated Reductions (in tonnes) Following Materials Substitution Used Ethyl Acetate (tonnes) Baseline New Estimated Amount* Reduction % Reduction 86% * assuming substitutes contain no toxics

25 Appendix B: Table B-3 Economic Feasibility Analysis - Materials Substitution Cost of Current Materials (NGR, stain, sealer and topcoat) Solvent / WB Supplier $ / L Volume (L) / unit (app) Avg units / day Solvent Valspar 45 NGR stain $304 Wiping stain $219 $522 Total stain / day Sealer $47 Topcoat $50 $97 Total topcoat / day $619 Grand Total daily 240 days / year $148,638 per annum Cost of Materials if Substituted with low VOC option Water Based Valspar Water Based Valspar NGR stain $401 Wiping stain $289 $690 Total stain / day Sealer $62 Topcoat $66 $128 Total topcoat / day $817 Grand Total daily 240 days / year $196, per annum

26 APPENDIX C TOXIC SUBSTANCE ACCOUTNING

27 APPENDIX C: FIGURE C-1 NPRI/TRA ACCOUNTING SUMMARY TRA Inc Priority Substances to Report Does the facility fall under the NAICS Code starting with 31, 32, 33, or 212? Otherwise, not required to report Yes If yes, proceed to complete the report below. List of substances meeting TRA thresholds for current year: CAS Substance Description of Processes that Use or Create Substance Reporting under NPRI Part NPRI Threshold (tonnes) Used (tonnes) Created (tonnes) Contained In Product (tonnes) Released (to air) Recycled Quantification Method(s) Used Rationale for Using Selected Method(s) Ethyl Acetate 1 Activity based threshold, not based on use or emissions. Valspar and RPM paints, aerosol paints MB No monitoring data available. Current accounting methods are best available. No alternate cost-effective method is available

28 APPENDIX C: FIGURE C-2 PROCESS QUANTIFICATION SUMMARY Quantification Summary* Ethyl Acetate CAS # (tonnes) Pro-finish (Dover) Aerosol U Valspar and RPM NGR/Wiping Stain U Solvent for Cleaning U Emissions to air - from aerosol cans Emissions to air - from filtration system in the finishing process A A Emissions to air - from drying oven Emissions to air - from used paint cans Emissions to air - from used rags Transfer for Recycling - Residual paints in aerosol cans Transfer to Recycling - residual paints and solvents from painting process A A A TR TR Total Used U Total Created C Total Contained in Product P Total Released to Air A Total Released to Water W Total Released to Land L Total Recycled TR Total Destroyed D Total Inputs Total Outputs * also see NPRI calculation tabs for more detailed quantifications for substances and associated products.

29 APPENDIX D PLAN SUMMARY AND PLAN CHECK LIST

30 Toxic Substance Reduction Plan Summary Checklist Basic Facility Information Substance name and Chemical Abstracts Service Registry number, if any The National Pollutant Release Inventory (NPRI) identification number The identification number assigned by the ministry for the purposes of Ontario Regulation 127/01 (Airborne Contaminant Discharge Monitoring and Reporting), if one has been assigned. The legal and trade names of the owner and the operator of the facility, the street address of the facility and the mailing address, if different The number of full-time employee equivalents at the facility The two- and four-digit North American Industry Classification System (NAICS) codes and the six-digit NAICS Canada code for the facility If applicable, the name, position and telephone number of the individual who is the contact at the facility for the public. The spatial coordinates of the facility expressed in Universal Transverse Mercator (UTM) within a North American Datum 83 (NAD83) datum In respect of the Canadian parent company of the facility, if applicable, i. the legal name of the company, ii. the street and mailing address of the company, if different from the facility iii. if available, the company's percentage of ownership of the facility Other Mandatory Information List all other substances for which plans have been prepared at the facility Statement of intent to reduce the use and/or creation of toxic substance (or reasons for not including one) Objectives of the plan and any targets (targets are optional) Description of why the toxic substance is used and/or created Description of options to be implemented, or, if no options have been selected for implementation, a rationale for why not Estimated reductions for each option selected (if any) Timelines for achieving the estimated reduction in use and/or creation (if any) Statement that the plan summary accurately reflects the plan Copies of the certification statements Planner license number for the planner who provided recommendations (or rationale for no recommendations) Planner license number for the certifying planner Optional Information Rationale for why implementation options were selected Additional actions taken by the facility to reduce the toxic substance

31 Toxic Substance Reduction Plan Checklist Basic Facility Information Substance name and Chemical Abstracts Service (CAS) Registry number, if any The National Pollutant Release Inventory (NPRI) identification number and the identification number assigned by the ministry under Ontario Regulation 127/01 (Airborne Contaminant Discharge Monitoring and Reporting), if assigned The legal and trade names of the owner and the operator of the facility, the street address of the facility and the mailing address of the facility, if different The number of full-time employee equivalents at the facility The two- and four-digit North American Industry Classification System (NAICS) codes and the six-digit NAICS Canada code If applicable, the name, position and telephone number for the following individuals, and mailing addresses, if different: public contact technical contact the person who is responsible for coordinating plan preparation the person who prepared the plan, if different from the coordinator highest ranking employee at the facility who has management responsibilities relating to the facility and who is responsible for making the certification The spatial coordinates of the facility expressed in Universal Transverse Mercator (UTM) within a North American Datum 83 (NAD83) datum. For each Canadian parent company of the facility, if applicable, the legal name of the company the street and mailing address of the company, if different from the facility if available, what percentage of the facility is owned by the parent company business number assigned by the Canada Customs and Revenue Agency Other Mandatory Information Planner license number for the planner who provided recommendations (or rationale for no recommendations) Planner license number for the certifying planner Statement of intent to reduce the use and/or creation of toxic substance (or reasons for not including one) Objectives of the plan and any targets (targets are optional) Records identifying and describing stages Record identifying and describing processes including: descriptions of how, when, where & why the substance is used and/or created process flow diagrams Toxic substance accounting information quantifications at process level for previous year

32 record of method(s) and rationale for selecting each method used to track and quantify toxic substance if applicable, record of explanation of "no approximate balance" of inputs and outputs for each process Estimate of direct and indirect annual costs associated with the toxic substance being used, created, released, disposed, transferred for recycling and contained in product Options considered for reduction identification of at least one toxic reduction option in each of the seven toxic reduction categories as listed in O. Reg. 455/09 or an explanation of why no option could be identified estimate of potential reductions in use, creation, contained in product, release (air, land and water), disposal, and transfer of toxic substances achieved if option was implemented identification of technically feasible options analysis of economic feasibility of technically feasible options, including anticipated savings and anticipated payback period For each option to be implemented a description of implementation steps and a timetable for implementation estimate of reduction in use, creation, releases, disposals, transfers for recycling, and/or contained in product (as a percentage and unit of measurement) and the information used to develop the estimate anticipated dates for achieving use and creation reductions OR If no options are to be implemented provide the rationale for this decision Planner recommendations and rationale (or reasons for no recommendations) Certifications by the highest ranking employee and the toxic substance reduction planner

33 APPENDIX E PLAN SUMMARY

34 DESCOR INDUSTRIES: TRA PLAN SUMMARY TOXIC REDUCTION POLICY STATEMENT OF INTENT Descor is committed to playing a leadership role in protecting the environment. Wherever feasible, we will eliminate or reduce the use, creation and discharge of toxic substances in full compliance with all federal and provincial regulations. Our employees are encouraged to participate in all types of toxic substance reduction activities. Toxic substance reduction will be an ongoing effort at Descor, and we will continue to building on past successes and develop new technologies. REDUCTION OBJECTIVES No reduction options were identified to be both technically and economically feasible. Therefore, no options are being implemented at this time. Potential options will continue to be monitored and revaluated as costs, market demands and production requirements change. PLAN SUMMARY STATEMENT This plan summary accurately reflects the content of the toxic substance reduction plan prepared on behalf of dated November 3, 2015 for one (1) TRA prescribed substance (as follows): Ethyl Acetate BASIC FACILITY INFORMATION Company Name: Contact Information: Highest Ranking Employee: Chanoch Friedel President Chanoch_Friedel@globalcontract.com Technical Contact: Certified Planner: Larry Laycock QA/EHS Manager Larry_Laycock@globalcontract.com Beth Rhyno P.Eng. License Number TSRP0273 Compliance Team Leader Amec Foster Wheeler Environment & Infrastructure beth.rhyno@amecfw.com

35 Parent Company: Address: UTM Coordinates (NAD83): Global Upholstery 560 Supertest Road, Downsview 95% Ownership 15 Riviera Drive Markham, Ontario L3R 5M1 Zone 17T m E, m N Business Number: Descor Global Upholstery The facility s NPRI ID: In 2014, Descor employed about 120 full time employees (equivalent). The NAICS codes applicable to the facility are: 33 Manufacturing 3372 Office Furniture (Including Fixtures) Manufacturing Wood Office Furniture Manufacturing In 2014, the site used ten (10) MOECC Toxic compounds at concentrations greater than the reporting threshold. Two of these substances, methanol and toluene, were Phase I substances and therefore required plans in The TRA Plan and Plan Summary were completed, with the TRA Plan Summary and associated reporting completed as per regulatory requirements. In 2012 additional TRA plans were created for acetone, butyl acetate, ethanol, methyl ethyl ketone, methyl isobutyl ketone, mineral spirits, naphtha, xylene, PM10 and P2.5. The mandatory TRA Plan was completed and the TRA Plan Summary submitted and associated reporting completed as per regulatory requirements. In 2013, stoddard solvent met the reporting threshold for the first. Therefore, the TRA Plan for stoddard solvent was created and the TRA Plan Summary submitted with appropriate reporting completed prior to the December 31, 2014 deadline. For the 2014 NPRI/TRA annual reporting period, ethyl acetate use met reporting thresholds for the first time. Descor switched topcoat suppliers and products which resulted in the increased use of ethyl acetate. A TRA Plan is now required for ethyl acetate and the TRA Plan Summary is due by December 31, TRA Plan Summary 2014 Page 2 of 3