Toxics Substance Reduction Plan Summary For Butyl Acrylate (CAS #141-32-2) Ethylene Glycol (CAS #107-21-1) Methyl Methacrylate (CAS #80-62-6) Styrene (CAS #100-42-5) Solucor 10 Reagens Industrial Parkway Bradford, Ontario L3Z 2A4 December 10, 2013 Pinchin File: 82610.105 Copyright 2013 by Pinchin Environmental Ltd. 2470 MILLTOWER COURT, MISSISSAUGA, ONTARIO L5N 7W5 PHONE: (905) 363-0678 FAX: (905) 363-0681 ENVIRONMENTAL HEALTH & SAFETY MANAGEMENT SERVICES FROM OFFICES ACROSS CANADA www.pinchin.com 1-888-767-3330
INTRODUCTION Facility Summary Axiall Corporation operates a plastics additives manufacturing facility, Solucor, located in Bradford, Ontario. The facility manufactures products which offer customers a line of highquality additives for rigid PVC applications, which includes process aids, impact modifiers, lubricants, and stabilizers. Solucor additives have a solid track record of successful performance in their targeted applications dating back to their inception in 1992. Today, there additives are widely used in downstream Axiall operations, as well as those of other commercial customers. Solucor reported to the 2012 National Pollutant Release Inventory, and to the Ministry of the Environment (Ontario) Toxics Reduction Act under O. Regulation 455/09 for the substances Butyl Acrylate, Ethylene Glycol, Methyl Methacrylate, and Styrene, and are required to prepare a Toxics Reduction Plan. 2013 Pinchin Environmental Ltd. Page i
TABLE OF CONTENTS INTRODUCTION...I 1.0 BASIC FACILITY INFORMATION...1 2.0 STATEMENT OF INTENT...2 3.0 OBJECTIVES OF THE PLAN & ANY TARGETS...2 4.0 OPTIONS TO BE IMPLEMENTED (OR STATEMENT THAT NONE ARE TO BE IMPLEMENTED)...2 5.0 CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN...2 6.0 CERTIFICATION BY HIGHEST RANKING EMPLOYEE...3 7.0 CERTIFICATION BY LICENSED PLANNER...4 2013 Pinchin Environmental Ltd. Page ii
1.0 BASIC FACILITY INFORMATION Substance Information Butyl acrylate CAS # 141-32-2 Ethylene glycol CAS # 107-21-1 Methyl methacrylate CAS # 80-62-6 Styrene CAS # 100-42-5 Facility Information Company Facility Facility Address Site Coordinates (main entrance of site) Royal Group Inc. (Solucor) Solucor 10 Reagens Industrial Parkway, Bradford, Ontario, L3Z 2A4 17 T 611842.70 me 4885214.93 mn elev850ft NPRI ID 2011 MOE ID 6645 Number of Full-Time Employees in 2012 2-Digit NAICS Code 4-Digit NAICS Code 6-Digit NAISC Code 65 32 - Manufacturing 3252 Resin, Synthetic Rubber, Artificial and Synthetic Fibres and Filaments 325210 - Resin and Synthetic Rubber Manufacturing Parent Company Information Company Company Address Percent Ownership by Parent Company Axiall Corporation 115 Perimeter Center Place, Suite 460 Atlanta, GA, USA 30346 100% 2013 Pinchin Environmental Ltd. Page 1
Facility Contact Information Public Contact Tim Hamilton EHS Manager Phone: 905-775-5000 ext. 231 Fax: 905-775-5005 tim.hamilton@axiall.com Address same as facility 2.0 STATEMENT OF INTENT Solucor is committed to playing a leadership role in protecting the environment. The use of Butyl acrylate, Ethylene glycol, Methyl methacrylate & Styrene is an integral part of the products that we manufacture, and it is not technically or economically feasible to reduce them. We will continue to use these substances in strict accordance with all applicable environmental regulations, and as part of our on-going continuous improvement process look for new opportunities to optimize our use of these substances. With reference to the Ontario Toxics Reduction Act, the reduction objectives are outlined in Section 4.0 of this Plan Summary for the reportable substances (Butyl acrylate, Ethylene glycol, Methyl methacrylate & Styrene) at Solucor. 3.0 OBJECTIVES OF THE PLAN & ANY TARGETS Solucor 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 Butyl acrylate, Ethylene glycol, Methyl methacrylate & Styrene at the facility. No new 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 use of Butyl acrylate, Ethylene glycol, Methyl methacrylate & Styrene in the future. 4.0 OPTIONS TO BE IMPLEMENTED (OR STATEMENT THAT NONE ARE TO BE IMPLEMENTED) At this time, no new reduction options have been identified. Solucor has already dedicated significant time and resources to producing a lean manufacturing process that maximizes its use of raw materials and incorporates identification of new efficiencies into its continuous improvement processes. Solucor commits to identifying and reviewing new options and technological advances as they become available, and incorporating these, as appropriate, into future Toxic Substance Reduction Plans. 5.0 CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN This Plan Summary accurately reflects the Toxic Substance Reduction Plans dated December 10, 2013, prepared for the substances listed in Section 1.0 of this Summary. 2013 Pinchin Environmental Ltd. Page 2
7.0 CERTIFICATION BY LICENSED PLANNER As of December 17, 2013, I, Phil Girard certify that I am familiar with the processes at Solucor 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 10, 2013 and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act. Butyl acrylate, Ethylene glycol, Methyl methacrylate & Styrene Phil Girard, P.Eng., TSRP License # 0019 Vice President Pinchin Environmental Ltd. pgirard@pinchin.com Pinchin Master Report Guide, Ver. 1, May 2007 J:\82000s\82610 RoyalGroup,2013EnvironServices,CONS\82610.105 Solucor,10Reagens,Bradford,TRA\82610.105 Solucor TRA Plan Summary - Monomers & Ethylene Glycol 2013-12 16 FINAL.docx 2013 Pinchin Environmental Ltd. Page 4