FRANKE KINDRED CANADA LIMITED 1000 Kindred Road, Midland, Ontario L4R 4K9

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1 FRANKE KINDRED CANADA LIMITED 1000 Kindred Road, Midland, Ontario L4R 4K9 Toxic Substance Reduction Plan Summary: Nickel Toxics Reduction Act & O. Reg. 455/09 C 2013 ENVIRONMENTAL REPORTING SYSTEMS LIMITED Suite 819, 80 Bradford Street, Barrie, Ontario, L4N 6S7 Tel (705) Fax (705) webmail@erslimited.com

2 FRANKE KINDRED CANADA LIMITED 1000 Kindred Road, Midland, Ontario L4R 4K9 Toxic Substance Reduction Plan Summary: Nickel Toxics Reduction Act & O. Reg. 455/09 For: Ron Columbus Environmental, Health & Safety Supervisor Franke Kindred Canada Limited June 20, 2013 Suite 819, 80 Bradford Street, Barrie, Ontario, L4N 6S7 Tel (705) Fax (705)

3 Basic Facility Information Toxic Substance Reduction Plan Summary - Nickel Toxics Reduction Act & Ontario Regulation 455/09 Franke Kindred Canada Limited (Franke) manufactures Stainless Steel sinks for retail and commercial sale. The main facility activities include cutting, pressing, welding, undercoating, cleaning, buffing and packaging. Ancillary activities include shipping and receiving, storage, quality control, dust collection and heating/cooling systems. The Facility is approximately 9,680 square metres in size on a site approximately 39,300 square metres. It operates 16 hrs per day, 5 days per week, 48 weeks per year, with statutory holidays and occasional shutdown periods. In 2011 there were no reported shutdown periods. Franke produces sink products to industry standards (ASME & CSA). The inclusion of metal elements is vital to the effectiveness and functionality of Franke s steel products and necessitates the presence and use of the prescribed toxic substances; Chromium, Manganese and Nickel. This plan addresses Nickel. Facility Name: Franke Kindred Canada Limited (Franke) Location: 1000 Kindred Road, Midland, Ontario, L4R 4K9 NPRI Identification Number: 1555 Two Digit NAICS Code: 33 Four Digit NAICS Code: 3329 Six Digit NAICS Code: All Other Misc. Fabricated Metal Product Mfg. Number of Full-time Employees: 120 UTM Spatial Coordinates (NAD83): Zone m E; m N (physical location of main entrance) Operator Name: Franke Kindred Canada Limited Address: 1000 Kindred Road, Midland, Ontario, L4R 4K9 Substance 1: Chromium (and its compounds) Substance 2: Manganese (and its compounds) Substance 3: Nickel (and its compounds) CAS Number: NA-04 CAS Number: NA-09 CAS Number: NA-11 Public Contact Name: Ronald Columbus, Environmental, Health & Safety Supervisor Address: 1000 Kindred Road, Midland, Ontario, L4R 4K9 Phone Number: (705) ext. 236 Fax Number: (800) ronald.columbus@franke.com Franke TSRP Summary - Nickel

4 Statement of Intent Manganese, Chromium and Nickel are found in stainless steel used by Franke in the production of kitchen products. The substances are essential elements in the steel. We intend to explain why a reduction in the substances used does not comply with the facility purposes, as well as defend why reducing the substance disposal and air emissions is impractical. This facility does not create or transform Manganese, Chromium or Nickel and therefore this plan will not address reducing their creation or transformation. Objective of the Plan The plan objective is to assess any potentially viable options for the reduction in use of Chromium, Manganese and Nickel at the facility. Further, this plan will determine the technical and economic feasibility of each option to determine which, if any, are practical for implementation. Target & Timeline Franke does not intend to reduce the use of substances, Manganese, Chromium and Nickel. The plan considers the reduction of the release to air of the toxic substances but will not establish a target or timeline. Description of Toxic Substance Use The toxic substances are present in the Receiving Stage, the Production Stage, and the Shipping Stage. In the receiving stage the substances arrive in shipments of stainless steel coils. Coils are loaded onto stamping machines in the production stage. It is here in the production stage where scrap and emissions are generated. The product is stored for a short period before it begins the shipping process. Franke stamps stainless steel to form sink bowls. Any one of three grades of steel could be loaded to the press, dependent on the customer order. The substances; Manganese, Chromium and Nickel are functional components of the steel. The substances presence is required by Standard for its contribution of desired physical and chemical properties in the metal and finished product. The three steel types average to the following substance compositions, by use; Manganese at 1.77 %, Chromium at % and Nickel at 6.56 %. These three Substances are prescribed (Phase 1) toxic substances found in a concentration equal or greater than one percent and are used in a quantity more than 10 tonnes per year. The processes that use the prescribed toxic substances are; stamping, welding, grinding and faucet punching. Stamping and faucet punching generate the bulk majority of recycled materials containing the substances. Welding and grinding generate the majority of substance emissions to air and substance disposal to landfill; which are captured by the dust collection system. The Substances are also contained in product. Franke TSRP Summary - Nickel

5 TRA Summary Table Toxics Reduction Act 2012 Public Reporting - Franke Kindred Canada Limited, Midland Substance CAS # Use Used Released Disposed Recycled Contained in Product Sheet Metal for Nickel (and its compounds) NA forming bow ls. Description of Options Units : tonnes Franke product specifications and clients needs greatly limit the technical feasibility of options. The only option that made it to the economic feasibility assessment would not reduce the use of the Substance and is strictly a method of pollution control that provides no further benefit to substance reduction or market competitiveness. As a result, the implementation of the option will not be made under this plan but may be considered for its value. Implementation of Option The only option remaining from the technical feasibility assessment does not provide a reduction in the use of the Substance and adds to the cost of each item produced. Therefore, this option is not economically feasible and this plan will not be implemented. This Toxic Substance Reduction Plan Summary accurately reflects the Plan it summarizes. Franke TSRP Summary - Nickel

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