Toxics Substance Reduction Plan Summary For Particulate Matter 10 (CAS# NA-M09)

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1 For Particulate Matter 10 (CAS# NA-M09) Heroux-Devtek Landing Gear Division 1665 Highland Road West Kitchener, Ontario N2N 3K5 December 23, 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 1665 Highland Road West, Kitchener December 23, 2013 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 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 1665 Highland Road West, Kitchener December 23, BASIC FACILITY INFORMATION Substance Information Substance Name CAS # Particulate Matter 10 NA-M09 Facility Information Company Name Facility Address Site Coordinates (main entrance of site) Heroux Devtek Landing Gear Division 1665 Highland Road West, Kitchener, ON N2N 3K5 17 T me mn NPRI ID 7643 MOE ID Number of Full-Time Employees in Digit NAICS Code n/a Manufacturing 4- Digit NAICS Code 3364 Aerospace Product and Parts Manufacturing 6-Digit NAICS Code Aerospace Product and Parts Manufacturing Facility Contact Information Public Contact Mr. Terry Darbyson Maintenance Supervisor Phone: x2739 Fax: tdarbyson@herouxdevtek.com Address: Same as facility address 2013 Pinchin Environmental Ltd. 1

4 1665 Highland Road West, Kitchener December 23, STATEMENT OF INTENT Heroux-Devtek is committed to playing a leadership role in protecting the environment, however the facility does not intend on reducing the creation of particulate matter (PM10) at this time. 3.0 OBJECTIVES OF THE PLAN & ANY TARGETS Heroux-Devtek prides itself on technological innovation in order to produce high quality products in an environmentally responsible manner. The objectives of this plan are to assess the technical and economic feasibility of options, if any are identified, and to determine which are viable for implementation. 4.0 DESCRIPTION OF WHY THE TOXIC SUBSTANCE IS USED OR CREATED The processes related to creating particulate matter with particle size of less than 10 microns (PM10) at the facility include deburring and auxiliary processes such as maintenance welding and natural gas-fired combustion equipment. Approximately 99.95% of particulate matter is created from the deburring process. Therefore, reduction options will focus on this process. Process flow diagrams and the description of each process are included in Appendix I. 5.0 OPTIONS TO BE IMPLEMENTED (OR STATEMENT THAT NONE ARE TO BE IMPLEMENTED) At this time, no opportunities for reduction can be identified, and thus no available option will be implemented. The company will continue to work with customers and suppliers to identify alternative products that meet customer specifications, and monitor technological advances that will allow it to use its raw materials more efficiently. 6.0 ESTIMATED REDUCTIONS UNDER THE OPTIONS SELECTED (IF ANY) Not applicable. 7.0 TIMELINES FOR ACHIEVING ESTIMATED REDUCTION (IF ANY) Not applicable. 8.0 CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN This Plan Summary accurately reflects the Toxic Substance Reduction Plans dated December 12, 2013, prepared for the substances listed in Section 1.0 of this Summary. 9.0 COPY OF CERTIFICATIONS 2013 Pinchin Environmental Ltd. 2

5 Toxics Substance Reduclion Plan Particulate Matter l llighland Road Wesl. Kitchener Heroux-Dcvtck Landing Cear Division Decernber 12,2013 Pinchin File: CERTIFICATION BY HIGHEST RANKING EMPLOYEE ns or D'e cannlæy, 2013, I, Dan Sidhu, certify that I have read the toxic substance reduction plan for the toxic substance referred to below and am lamiliar with its contents, and to my knowledgc the plan is lactually accurate and complies with the f(rricr Retluctiott Act, 2009 and C)ntario Regulation 455/09 (Gencral) made under that Act. Purti<:uktte Muttcr 10, Plan Praporctl December 12, 2013 cyl d)l--jt^- Dan Sidhu (iencral Managcr Heroux-Devtek Landing Gear Division C) 20l3 Pinchin Environmental l,td.

6 Toxics Substance Reduction Plan Particulate Matter Highland Road West, Kitchener December 12, CERTIFICATION BY LICENSED PLANNER As of December 23, 2013, I, Connie Lum certify that I am familiar with the processes at Heroux- Devtek that use 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 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. Particulate Matter 10, Plan Prepared December 23, 2013 Connie Lum, TSRP# 0089 Senior Project Manager Pinchin Environmental Ltd. clum@pinchin.com Pinchin Master Report Guide, Ver. 1, May 2007 W:\88000s\88994 Heroux,1665HighlandW,Kitchener,TRA\Draft TRA Plan\88994 Heroux Devtek TRA Plans.docx 2013 Pinchin Environmental Ltd. Page 6

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Toxics Substance Reduction Plan Summary For Particulate Matter (PM10) (CAS #NA M09) Particulate Matter (PM2.5) (CAS #NA M10) Eurocopter Canada Limited 1100 Gilmore Road Fort Erie, Ontario L2A 5M9 December