TOXIC REDUCTION PLAN MANGANESE. PowerCor Manufacturing a Division of Linamar Holdings

Transcription

1 TOXIC REDUCTION PLAN MANGANESE PowerCor Manufacturing a Division of Linamar Holdings December 2013

2 Table of Contents 1.0 Introduction 1.1 Basic Facility Information 1.2 Statement of Intent 1.3 Objectives 1.4 Facility Description 2.0 Identification and Description 2.1 Stages and Processes 2.2 Process Flow Diagram 3.0 Tracking and Quantification 3.1 Receiving Process and Description Receiving Process (use) Tracking and Quantification Method Best Available Method (Rationale) Quantification of Toxic Substances Receiving Process (Contained in Product) Tracking and Quantification Method Best Available Method Rationale Quantification of Toxic Substances Input/Output Balance 3.2 Cutting and Machining Process Description Cutting and Machining Process (Use) Tracking and Quantification Method Best Available Method (Rationale) Quantification of Toxic Substances Cutting and Machining Process (Off site Transfers) Tracking and Quantification Method Best Available Method (Rationale) Quantification of Toxic Substances Cutting and Machining Process (Contained in Product) Tracking and Quantification Method Best Available Method (Rationale) Quantification of Toxic Substances Input/Output Balance 3.3 Shipping Process Description Shipping Process (Use) Tracking and Quantification Method Best Available Method (Rationale) Quantification of Toxic Substances Shipping Process (Contained in Product) Tracking and Quantification Method

3 Best Available Method Rationale Quantification of Toxic Substances Input/Output Balance 4.0 Facility Wide Accounting Information 4.1 Use 4.2 Creation 4.3 Transformation 4.4 Destruction 4.5 Contained in Product 4.6 Releases to Air 4.7 Releases to Land 4.8 Releases to Water 4.9 Disposals (on-site) 4.10 Disposals (off-site) 4.11 Off-site Transfers (Treatment or Recycling) 5.0 Direct/Indirect Analysis 6.0 Toxic Substances and Creation Reduction Options 6.1 Material or Feedstock Substitution Options Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility 6.2 Product Redesign or Reformulation Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility 6.3 Equipment and Process Modification Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility 6.4 Spill and Leak Prevention Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility 6.5 On-site Reuse and Recycling Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility

4 6.6 Improved Inventory Management/Purchasing Techniques Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility 6.7 Training or Improved Operating Practices Identification of Options Estimated Reductions Technical Feasibility Economic Feasibility 7.0 Options to be Implemented 8.0 Planner Recommendations and Rationale 9.0 Plan Certifications

5 PowerCor Manufacturing Toxic Reduction Plan Manganese 1.0 Introduction 1.1 Basic Facility Information Name & CAS # of Substance Manganese Company Name Facility Name Facility Identification and Site Address Linamar Holdings Inc. PowerCor Manufacturing a Division of Linamar Holdings Inc. Facility Address Physical Address: Mailing Address: (if different) Spatial Coordination of Facility 545 Elmira Road North Guelph Ontario N1K 1C2 Easting: Northing: , Number of Employees 241 NPRI ID Ontario MOE ID Number Parent Company (PC) Information PC Name & Address Percent Linamar Corporation, 287 Speedvale Avenue West, Guelph, Ontario N1H 1C5 100 percent Business Number for PC Primary North American Industrial Classification System Code (NAICS) 2 Digit NAICS Code 33 Manufacturing 4 Digit NAICS Code Motor Vehicle Manufacturing 6 Digit NAICS Code Automobile and light-duty motor vehicle manufacturing Company Contact Information Facility Public Contact Ms Allison Hipel Facility Technical Contact Allison.Hipel@linamar.com Phone: (226) X604 Fax: ((226) Mr Gino Armellini Same address as facility Gino.armellini@linamar.com Phone: (226) X602 Fax: (226) Same address as facility

6 1.0 Name & CAS # of Substance Company Coordinator Manganese Facility Identification and Site Address Contact Person who Prepared the Plan: (if different from the Coordinator) Kristin Onorato kristin.onorato@linamar.com Phone: (226) X276 Fax: (226) Same address as facility Highest Ranking Employee Planner Responsible for Making Recommendations Planner Responsible for Certification Mr. Ron Bennett - General Manager Ron.bennett@linamar.com Phone: (226) ext. 601 Fax: (226) Planner Information: Ms Melissa Gould Melissa.gould@linamar.com Phone: Fax: Ms Melissa Gould Melissa.gould@linamar.com Phone: Fax: Same address as facility Linamar Gear 32 Independence Place Guelph, Ontario, Canada, N1K 1H8 Linamar Gear 32 Independence Place Guelph, Ontario, Canada, N1K 1H8 1.2 Statement of Intent PowerCor Manufacturing a Division of Linamar Holdings Inc. (PowerCor) is committed to playing a leadership role in protecting the environment. Whenever feasible, we will reduce the use of Manganese in compliance with all Federal and Provincial Regulations. 1.3 Objectives PowerCor prides itself on technological innovation in order to produce high quality automotive parts in an environmentally responsible manner. Through this plan, PowerCor will determine the technical and economic feasibility of each option to determine which, if any, are viable for implementation at this time.

7 1.4 Facility Description PowerCor Manufacturing produces automotive parts from steel and aluminum forgings. Raw materials (steel and aluminum parts) are brought to the facility where they are machined into automotive parts, then washed and packaged for shipment. These raw materials contain the compound Manganese as a constituent material 2.0 Identification and Description 2.1 Stages and Processes Manganese is present in the raw steel and aluminum materials used in the process as a constituent compound. The stages and processes that involve Manganese are as follows: Manganese, as a constituent of the raw steel and aluminum material, is received in the Receiving Process in the Raw Material Receiving Stage, where it is stored as required by customers. It is then transferred into the Manufacturing Stage. This stage and the quantification methods for Manganese are further described in Section 3.1. In the Manufacturing Stage, the raw materials are sent through a variety of separate processes which produce the various automotive parts. The different processes which are involved in this stage are listed in the Process Flow Diagram in Section 2.2. Of these processes, Manganese is used in the Cutting and Machining Process. In the Shipping Process of the Shipping Stage, the finished products are inspected and then packaged for shipment to the various customers. Manganese is contained in the final product. In 2012, the facility operated 24 hours a day, 5 days a week plus overtime as needed 2.2 Process Flow Diagram A process flow diagram of the stages as described above is presented below (the process which involve the use of manganese are highlighted)

8 3.0 Tracking and Quantification 3.1 Receiving Process Description The Receiving Stage consists of the Receiving Process. Manganese is delivered to the facility as a constituent of the raw materials (the composition of Manganese is dependent on the material) - these deliveries (U1) are tracked by PowerCor s internal accounting systems. Once the materials are ready to be used, they are transferred (P1) to the first process in the Manufacturing Stage. Raw Material from Supplier Receiving Process To Manufacturing Stage U1 = kg P1 = kg Receiving Process (Use) Tracking and Quantification Method Quantification Method: Mass Balance - based on inventory records and concentrations of Manganese as presented on Material Specifications sheets (see below) Best Available Method Rationale Manganese concentration in raw material The Manganese which is present in each raw material used in the Receiving Process is calculated based on the total amount of manganese present in each raw material from the Material Safety Data Sheets (MSDS) and test data. MSDS information and test data showing constituent compositions are sources of data that are highly reliable. In considering other methods, it was determined that this method would yield the highest quality data. Raw Material Quantities The total amount of each raw material used in the process was determined based on purchasing and inventory records which are tracked by PowerCor's accounting system. Quantities of raw materials

9 that are used in the process are recorded through purchasing and inventory records. This data is therefore considered to be very reliable Quantification of Toxic Substances Table 1 Calculation of Manganese in Receiving Process Manganese Composition % Quantity Supplied in 2012 Total Mn Used Cold Finish Steel 0.90% H - Steel 1% Aluminum % Nodular Cast Iron MS-10373BN HB 0.90% Alluminum MS2410-D 0.90% Aluminum A % Aluminum GMW5M-AL-C-S-Si6Cu3-T7 1.00% U1 = Manganese used in receiving process in 2012 = kg U1 Mn lbs kg Receiving process (contained in product) Tracking and Quantification Method Mass Balance see section Best Available method Rationale Manganese concentration in raw materials See section

10 Raw Material Quantities See section Quantification of Toxic Substances The quantification of the amount contained in product was assumed to be equal to the amount that was delivered to the facility as all the material delivered to the site entered the manufacturing stage P1 Manganese in the product at the receiving stage = kg Input/output Balance Use + Creation Transformed +Destroyed + Contained in product + onsite or offsite release (air land or water) + offsite transfers (treatment or recycling) + disposals U1-P1 = kg kg =0 0kg Unaccounted for material 3.2 Cutting and Machining Process Description The raw material after being processed in the receiving stage are transferred into the cutting and machining process of the manufacturing process (U2) The raw materials are then sent through a variety of turning, milling, grinding and various other cutting machines which remove material (as machining chips) from the raw materials. These chips are then recycled off-site by Gerdau Ameristeel (R1). The finished products from this process are then transferred to the Heat Treating process (P2). From Receiving Process Cutting and Machining Process To Heat Treat Process U2 = kg R1 = kg P2 = kg

11 3.2.1 Cutting and Machining Process (Use) Tracking and Quantification Method Quantification Method: Mass Balance The amount of Manganese used in the Cutting and Machining process was assumed to be the same as the amount contained in product following the Receiving Process (see Section ) Best Available Manganese Concentration in Raw Materials See Section Raw Material Quantities See Section Quantification of Toxic Substance The quantification of the amount used in process was assumed to be equal to the amount that was delivered to the facility, as all material delivered to the site entered the Manufacturing Stage. U2 - Manganese used in Cutting and Machining Process: kg Cutting and Machine Process (Off site Transfers) Tracking and Qualification Method Quantification Method: Mass Balance based on records of the materials transferred off-site. It is assumed that the materials transferred off-site consist of the same materials as enters the process Best Available Rationale Manganese Concentration in Recycled Quantities See Section Raw Material Quantities The total quantity of material transferred off-site is based on the total quantity material recycled off-site, which is tracked by Gerdau. These quantities are grouped together based on materials the actual amount of each product recycled is estimated. For this calculation methodology, while the amount of each raw

12 material is highly reliable (see Section ) and the amount of each recycled material is highly reliable, the actual amount of each raw material recycled is of low reliability due to the assumptions made above in how it is calculated Qualification of Toxic Substances Table 2: Calculation of Manganese Recycled Off-Site Manganese Composition % R1 Quantity recycled in 2012 Total Mn Used (R1*) Cold Finish Steel 0.90% H - Steel 1% Aluminum % Nodular Cast Iron MS-10373BN HB 0.90% Alluminum MS2410-D 0.90% Aluminum A % Aluminum GMW5M-AL-C-S-Si6Cu3-T7 1.00% R1* Mn lbs kg R1 = Manganese used in Cutting and Machining process in 2012 R1 = kg Cutting and Machining Process (Contained in Product) Tracking and Quantification Method Quantification Method: Mass Balance based on balance of materials used in process and amount sent to recycling Best Available Method Rationale Manganese Concentration in Raw Materials See Section Raw Material Quantities See Section and Qualification of Toxic Substances The quantification of the amount contained in product was calculated based on a mass balance of the amount used in the process (U2) and the amount transferred off-site from this process (R1). P2 - Manganese contained in product in Cutting and Machining Process: kg

13 3.2.4 Input/output Balance Use + Creation - Transformed + Destroyed + Contained in Product + On-Site or Off-Site Release (to Air, Land, Water) +Offsite Transfers (for treatment, recycling) + Disposals U2 - P2 + R = 0 Unaccounted Material - 0 kg 3.3 Shipping Process Description The Shipping Stage consists of the Shipping Process. After completing the Manufacturing Stage, the finished products are transferred (U3) to the shipping area, where the parts are inspected by facility personnel, then packaged and stored on-site before being shipped onto customers (P3). U3 = kg P3 = kg Shipping Process (Use) Tracking and Quantification Method Quantification Method: Mass Balance The amount of Manganese contained in the product from the Cutting and Machining process was assumed to be the same as the amount contained in product in the Cutting and Machining Process (see Section ) Best Available Method Rationale Manganese Concentration in Raw Materials See Section Raw Material Quantities See Section Quantification of Toxic Substance U3 - Manganese used in shipping process in 2012: kg Shipping Process (Contained in Product) Tracking and Quantification Method Quantification Method: Mass Balance see Section Best Available Method Rationale Manganese Concentration in Raw Materials

14 See Section Raw Material Quantities See Section Quantification of Toxic Substances The quantification of the amount contained in product was assumed to be equal to the amount used in the process, as no material is transferred out of this process. P3 - Manganese contained in product in Shipping Process: kg Input/Output Balance Use + Creation - Transformed + Destroyed + Contained in Product + On-Site or Off-Site Release (to Air, Land, Water) +Offsite Transfers (for treatment, recycling) + Disposals Note: This stage only contains materials used and material contained in product (to next stage) U3 - P = 0 Unaccounted Material - 0 kg 4.0 Facility Wide Accounting Information 4.1 Use The total facility wide use is equal to the amount of Manganese which is contained in the raw materials which is received from the suppliers in Facility Wide Use - U1 = kg 4.2 Creation There were zero creations of Manganese on-site in Transformation There were zero transformations of Manganese on site in Destruction There were zero destructions of Manganese on site in 2012

15 4.5 Contained in Product The total facility wide amount of Manganese contained in product in 2012 is equal to the amount contained in the each product which is shipped off site. Facility Wide Contained in Product - P3 = kg 4.6 Release to Air There were zero releases to air of Manganese on-site in Release to Land There were zero releases to land of Manganese on-site in Release to Water There were zero releases to water of Manganese on-site in Disposals (ON-SITE) There were zero on-site disposals of Manganese in Disposals (OFF-SITE) There were zero off-site disposals of Manganese in Off site transfers (Treatment or Recycling) The total amount transferred off-site is equal to the amount contained in the material sent for recycling, as documented in Section 3.2. Facility Wide Offsite Transfers (Recycling) - R1 = kg 5.0 Direct and Indirect Cost Analysis Of the costs associated with the Manufacturing process, the only cost which can be directly associated with Manganese is the material cost. Of this cost, PowerCor has calculated a cost of $171, which is associated with Manganese. For all other direct and indirect costs (equipment maintenance, utilities, labour, etc.), the total associated cost would be incurred regardless if Manganese was present or not and it would not be affected by the presence or lack-thereof of Manganese in the products. These values were obtained from the accounting department at the close of the month of December in 2012.

16 6.0 Toxic Substance Use and Creation Reduction Options 6.1 Material and or feedstock substitution options Identification of Options PowerCor identified that a possible material or feedstock substitution reduction option would be to work with suppliers to reduce foundry defects received as these materials are immediately disposed for recycling, removing these foundry defects would reduce both the Manganese used and the Manganese transferred for recycling Estimated Reductions Currently, approximately 2.29 percent of all raw materials which are received by PowerCor are considered foundry defects, and are sent off-site for recycling. PowerCor has targeted reducing this percentage to 2.00% percent, a reduction of 0.29 percent. Therefore, based on kg of Manganese which enters the process, this will result in a reduction of 68.19kg Manganese used. This reduction would also then apply to the Manganese recycled off site. There would be no reduction in Manganese contained in product Technical Feasibility Reduction of foundry defects received: As these materials would not be used in the process in any case and would just be recycled, this potential change is technically feasible Economic Feasibility Reduction of foundry defects received: As this option does not involve any changes to the process, there are no associated costs with its implementation. The total cost of the materials on average is $1.07/kg, so reducing the amount of materials by 68.19kg results in an annual savings of $72.96/year, with an immediate payback period. Therefore, this option is economically feasible. 6.2 Product Re-design or re-formulation Identification of Options It was identified that a potential reduction option would be to reduce the size and/or the weight of the turbine shaft product. This would therefore reduce the amount of raw material delivered to the facility and therefore, the amount used and the amount recycled Estimated Reductions PowerCor has identified that the Turbine Shaft raw material dimensions can be modified such that its average weight can be reduced by kg/part (from kg to kg). In 2012, 184,160 parts were produced this results in a total reduction of kg in raw materials used. With the material having an average Manganese concentration of 0.90 percent, this results in the total Manganese reduction equaling kg.

17 6.2.3 Technical Feasibility PowerCor has determined that while some changes to the process would be required to ensure that the materials can still be made to customer specifications, this option is technically feasible Economic Feasibility As this option would require PowerCor to pay for the re-tooling at the casting company as well as a replacement of the loading chucks, costing approximately $ this option is not economically feasible 6.3 Equipment or Process Modifications Identification of Options The equipment and processes involved are optimized to a degree to ensure that a minimum amount of scrap is produced. Therefore, no possible reduction options were identified in this category that would result in a reduction in the use of Manganese Estimated Reductions Not applicable Technical Feasibility Not applicable Economic Feasibility Not applicable. 6.4 Spill and Leak Prevention Identification of Options All Manganese used in the raw materials at the Facility is contained in metals. Spill and leak prevention is not a concern and no possible reduction options were identified in this category that would result in a reduction in the use of Manganese Estimated Reductions Not applicable Technical Feasibility Not applicable Economic Feasibility

18 Not applicable. 6.5 On-site Re-use and Recycling Identification of Options All metal scrap generated at the Facility is recycled. The metal scrap cannot be reused in the process as it is not in a form which would allow it to be used (i.e., it is too small or it is misshaped). Therefore, no possible reduction options were identified in this category that would result in a reduction in the use of Manganese Estimated Reductions Not applicable Technical Feasibility Not applicable Economic Feasibility Not applicable. 6.6 Improved Inventory Management/Purchasing Techniques Identification of Options The metal products do not have an expiry date, so no materials will be disposed as a result of expired inventory. All purchased materials are used within the process. Therefore, no possible reduction options were identified in this category that would result in a reduction in the use of Manganese Estimated Reductions Not applicable Technical Feasibility Not applicable Economic Feasibility Not applicable.

19 6.7 Training and Improved Operating Practices Identification of Options A potential option that was identified was to implement improved procedures and practices amongst the machine operators which would increase consistency amongst the machine operators, thus reducing the amount of raw materials which are scrapped Estimated Reductions In 2012, 8 percent of all material PowerCor was recycled as machine scrap. This resulted in kg of recycled Manganese. PowerCor has targeted reducing this percentage to 1.5 percent, a reduction of 6.5% percent overall. Therefore, based on the 2012 total amount of machine scrap produced at PowerCor is calculated be a reduction in Manganese of kg Technical Feasibility Development of these training procedures and organizing sessions to facilitate communication between the operators and production managers is technically feasible with very few additional resources required Economic Feasibility As this option does not involve any changes to the process, there are no associated costs with its implementation. The total cost of the materials on average is $1.07/kg, so reducing the amount of materials by kg results in an annual savings of $677.54/year, with an immediate payback period. Therefore, this option is economically feasible. 7.0 Options to be implemented The following options have been identified for implementation to reduce the use and/or amount of Manganese transferred: Work with suppliers to reduce foundry defects received Implement training practices/procedures amongst machine operators to reduce scrap materials Work with suppliers to reduce foundry defects received. This option is an on-going procedure at PowerCor, with annual reduction targets that will change from year to year. The schedule for this reduction option is given below: Step Description Estimated Timelines 1 Discussions with foundry January Ongoing supplier 2 Implement improvements to inventory management system January 2014 Ongoing

20 3 Timeline for implementation of manganese reductions End of January 2015 Implement training practices/procedures amongst machine operators to reduce scrap materials This option is an on-going procedure at PowerCor, with annual reduction targets that will change from year to year. The schedule for this reduction option is given below: Step Description Estimated Timelines 1 Review scrap procedures and January 2014 ongoing identify improvement opportunities 2 Provide Training Sessions to Annually Operators on handling scrap 3 Timeline for implementation of Manganese Reductions End of 2015 PowerCor has carefully reviewed the toxic substance use reduction options to ensure that there is no net negative impact to the environment or public health. The selected options will serve to reduce the amount of Manganese used in the process, and will not create any toxic by-products. 8.0 Planner Recommendations and Rationale The Planner's recommendations and rationale for these recommendations have been attached

21 9.0 Plan Certifications CERTIFICATION BY HIGHEST RANKING EMPLOYEE As of December 16, 2013, I, Gino Armellini, 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. Manganese Gino Armellini Operations Manager PowerCor Manufacturing a Division of Linamar Holdings Inc. CERTIFICATION BY LICENSED PLANNER As of December 16, 2013, I, Melissa Gould, certify that I am familiar with the processes at PowerCor 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 December 16, 2012 and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act. Manganese Melissa Gould [Planner License #] EHS Specialist Linamar Gear a Division of Linamar Holdings Inc.

22 Plan Summary PowerCor Manufacturing a Division of Linamar Holdings Guelph Ontario Name & CAS # of Substance Manganese Company Name Facility Name Facility Identification and Site Address Linamar Holdings Inc. PowerCor Manufacturing a Division of Linamar Holdings Inc. Facility Address Physical Address: Mailing Address: (if different) Spatial Coordination of Facility 545 Elmira Road North Guelph Ontario N1K 1C2 Easting: Northing: , Number of Employees 241 NPRI ID Ontario MOE ID Number Parent Company (PC) Information PC Name & Address Percent Linamar Corporation, 287 Speedvale Avenue West, Guelph, Ontario N1H 1C5 100 percent Business Number for PC Primary North American Industrial Classification System Code (NAICS) 2 Digit NAICS Code 33 Manufacturing 4 Digit NAICS Code Motor Vehicle Manufacturing 6 Digit NAICS Code Automobile and light-duty motor vehicle manufacturing Company Contact Information Facility Public Contact Ms Allison Hipel Facility Technical Contact Allison.Hipel@linamar.com Phone: (226) X604 Fax: ((226) Mr Gino Armellini Same address as facility Gino.armellini@linamar.com Phone: (226) X602 Fax: (226) Same address as facility

23 Plan Summary Statement This plan summary reflects the content of the toxic substance reduction plan for PowerCor Manufacturing a Division of Linamar Holdings Inc. for Manganese. Statement of Intent Objectives PowerCor Manufacturing a Division of Linamar Holdings Inc. (PowerCor) is committed to playing a leadership role in protecting the environment. Whenever feasible, we will reduce the use of Manganese in compliance with all Federal and Provincial Regulations. PowerCor prides itself on technological innovation in order to produce high quality automotive parts in an environmentally responsible manner. Through this plan, PowerCor will determine the technical and economic feasibility of each option to determine which, if any, are viable for implementation at this time. Reduction Options to be implemented The following options have been identified for implementation to reduce the use and/or amount of Manganese transferred: Work with suppliers to reduce foundry defects received Implement training practices/procedures amongst machine operators to reduce scrap materials Work with suppliers to reduce foundry defects received. This option is an on-going procedure at PowerCor, with annual reduction targets that will change from year to year. The schedule for this reduction option is given below: Step Description Estimated Timelines 1 Discussions with foundry January Ongoing supplier 2 Implement improvements to January 2014 Ongoing inventory management system 3 Timeline for implementation of manganese reductions End of January 2015

24 Implement training practices/procedures amongst machine operators to reduce scrap materials This option is an on-going procedure at PowerCor, with annual reduction targets that will change from year to year. The schedule for this reduction option is given below: Step Description Estimated Timelines 1 Review scrap procedures and January 2014 ongoing identify improvement opportunities 2 Provide Training Sessions to Annually Operators on handling scrap 3 Timeline for implementation of Manganese Reductions End of 2015 PowerCor has carefully reviewed the toxic substance use reduction options to ensure that there is no net negative impact to the environment or public health. The selected options will serve to reduce the amount of Manganese used in the process, and will not create any toxic by-products.

25 CERTIFICATION BY HIGHEST RANKING EMPLOYEE As of December 16, 2013, I, Gino Armellini, 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. Manganese Gino Armellini Operations Manager PowerCor Manufacturing a Division of Linamar Holdings Inc. CERTIFICATION BY LICENSED PLANNER As of December 16, 2013, I, Melissa Gould, certify that I am familiar with the processes at PowerCor 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 December 16, 2012 and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act. Manganese Melissa Gould [Planner License #] EHS Specialist Linamar Gear a Division of Linamar Holdings Inc.

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