Toxics Substance Reduction Plan Summary For PM 2.5 Particulate Matter (CAS #NA-M10)

Transcription

1 Toxics Substance Reduction Plan Summary For PM 2.5 Particulate Matter (CAS #NA-M10) KTH Shelburne Manufacturing Inc. 300 Second Line Shelburne, Ontario L0N 1S0 Prepared for: Jim Clayton EHS Associate November 21, 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 EXECUTIVE SUMMARY KTH Shelburne Manufacturing Inc. operates an automotive parts manufacturing facility at 300 Second Line in Shelburne. The parts manufactured at the facility consist primarily of frames for light passenger vehicles and sport utility vehicles. The facility processes steel coils and bar stock in a variety of punching, bending, and stamping lines, and welds assemblies together before sending them on to other automotive parts manufacturers. This Toxics Substance Reduction Plan was prepared, in compliance with the Toxics Reduction Act and Ontario Regulation 455/09, to identify and review potential opportunities to reduce the use and creation of particulate matter (PM) 2.5 at the facility. PM 2.5 is created by the various welding processes of the steel alloys after the materials have been stamped and bent into shape. PM 2.5 is also created by grinding and by the combustion of natural gas, and a wet cooling tower for cooling process water. The composition of these raw materials cannot be altered to reduce the releases of the PM 2.5. Steel raw materials and welding wire is specified by KTH s customers, and cannot be changed. KTH prides themselves as a major Tier I Automotive parts supplier and will continue to monitor new reduction opportunities and technological advances as they become available Pinchin Environmental Ltd. Page i

3 TABLE OF CONTENTS EXECUTIVE SUMMARY...I 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 CERTIFICATION BY HIGHEST RANKING EMPLOYEE CERTIFICATION BY LICENSED PLANNER Pinchin Environmental Ltd. Page ii

4 1.0 BASIC FACILITY INFORMATION Substance Information CAS # NA-M10 PM 2.5 Particulate matter Facility Information Company Name Facility Address UTM Co-ordinates KTH Shelburne Manufacturing Inc. 300 Second Line, Shelburne, ON, L0N 1S0 17T mE mN elev1623ft NPRI ID 7039 MOE ID Number of Full-Time Employees in Digit NAICS Code 4-Digit NAICS Code 6-Digit NAICS Code Manufacturing 3363 Motor Vehicle Parts Manufacturing Motor Vehicle Metal Stamping Facility Contact Information Public Contact Jim Clayton Environmental Health & Safety Associate Phone x 2212 Fax jim.clayton@ksm.kth.net Address same as facility 2.0 STATEMENT OF INTENT KTH Shelburne Mfg. Inc. is committed to playing a leadership role in protecting the environment. The use of steel alloys, welding rods, and copper electrodes are an integral part of the products that we manufacture, and it is not technically or economically feasible to reduce the use of these materials to reduce the PM 2.5 emissions. We will continue to use these substances in strict accordance with all applicable environmental regulations. With reference to the Ontario Toxics Reduction Act, the reduction objectives are outlined in Section 3.0 of this Plan Summary for the reportable substance PM 2.5 at KTH Shelburne Manufacturing Pinchin Environmental Ltd. Page 1

5 3.0 SUBSTANCES REQUIRING PLANS The following substance requires a plan based on 2012 Toxics Reduction Act accounting information. PM 2.5 Particulate matter. The substance is created as a by-product from certain welding processes at KTH. PM 2.5 is also created by grinding processes, combustion of natural gas for comfort heat, and from the operation of a wet cooling tower for cooling process water. 4.0 OBJECTIVES OF THE PLAN & ANY TARGETS KTH Shelburne Mfg. Inc. 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 materials that create PM 2.5 at the facility. No options have been identified, and as part of the continuous improvement practices at the facility, technical advances will be monitored for new opportunities to reduce the creation and release of PM 2.5 in the future. 5.0 OPTIONS TO BE IMPLEMENTED (OR STATEMENT THAT NONE ARE TO BE IMPLEMENTED) KTH has a strong commitment to continuous improvements in quality, health, safety, and environmental issues. The result in KTH s commitment to continuous improvements is less use and creation of particulate matter. Furthermore, KTH s customers provide the specifications for the raw materials processed at the facility which means that there are no additional options for KTH to implement at this time. 6.0 CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN This Plan Summary accurately reflects the Toxic Substance Reduction Plans dated November 21, 2013, prepared for the substances listed in Section 1.0 of this Summary Pinchin Environmental Ltd. Page 2

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7 8.0 CERTIFICATION BY LICENSED PLANNER As of December 18, 2013, I, Robin Brown certify that I am familiar with the processes at KTH Shelburne Manufacturing Inc. 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. [Toxic Substance for this TRA plan, dated November 21, 2013: PM (2.5) Particulate matter] Robin Brown, TSRP # 0018 Operations Manager Pinchin Environmental Ltd. rbrown@pinchin.com 2013 Pinchin Environmental Ltd. Page 4