Toxics Substance Reduction Plan Summary for Isopropyl Alcohol, Methyl Isobutyl Ketone, Cycloheptane (all isomers), and Light Aromatic Solvent Naptha 1700 Mitchell Road South Listowel, ON N4W 3H4 Prepared for: Joan Broughton, Process Quality 1700 Mitchell Road South Listowel, ON N4W 3H4 December 15, 2014 Pinchin File: 91187 2014 Pinchin Ltd. 2470 Milltower Court, Mississauga, ON L5N 7W5
EXECUTIVE SUMMARY Listowel Technology Inc. (LTI), located in Listowel, Ontario is a leading manufacturer of plastic molded car parts for a major automotive manufacturer. LTI produces over 120 different car parts and their main processes include injection molding, painting, and final assembly. The company reported to the National Pollutant Release Inventory (NPRI), for the substances isopropyl alcohol, methyl isobutyl ketone, cycloheptane (all isomers), and light aromatic solvent naphtha. The company must also report to the Ontario Ministry of the Environment under the Toxics Substance Reduction plan, O. Reg. 455/09, a plan to reduce the amounts of the reportable toxic substances named above that are used at the facility. 2014 Pinchin Ltd. Page i
TABLE OF CONTENTS 1.0 BASIC FACILITY INFORMATION... 1 2.0 STATEMENT OF INTENT... 2 3.0 SUBSTANCES REQUIRING PLANS... 2 4.0 OBJECTIVES OF THE PLAN & ANY TARGETS... 2 5.0 OPTIONS TO BE IMPLEMENTED (OR STATEMENT THAT NONE ARE TO BE IMPLEMENTED)... 2 6.0 CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN... 3 7.0 CERTIFICATION BY HIGHEST RANKING EMPLOYEE... 4 8.0 CERTIFICATION BY LICENSED PLANNER... 5 2014 Pinchin Ltd. Page ii
1.0 BASIC FACILITY INFORMATION Substance Information Substance 1 Isopropyl Alcohol (CAS# 67-63-0) Substance 2 Methyl Isobutyl Ketone (CAS# 108-10-1) Substance 3 Cycloheptane (all isomers) (CAS# NA-25) Substance 4 Light Aromatic Solvent Naphtha (CAS# 64742-95-6) Facility Information Company Name Facility Address Site Coordinates (main entrance of site) 1700 Mitchell Road South, Listowel, ON 502089 m E, 4840887 m N; Zone 17 NPRI ID 5894 MOE ID Number of Full-Time Employees in 2013 2-Digit NAICS Code 4-Digit NAICS Code 6-Digit NAICS Code Not Available 386 33 Manufacturing 3363 Motor Vehicle parts mfg. 336390 Other motor vehicle parts mfg. Parent Company Information Company Name Moriroku Technology Company Address 18F, Higashi-kan, Shin-Aoyama Building 1-1-1, Percent Ownership by Parent Company Minami-Aoyama, Minato-ku, Tokyo 107-0062, Japan Company Name 70% Company Address Percent Ownership by Parent Company Greenville Technology 5755 State Route 571, Greenville, OH 45331. 2014 Pinchin Ltd. Page 1 of 5
Facility Contact Information Public Contact Blair Burns Human Resources Manager Phone #519-291-9900 X 361 Fax # 519-291-4821 Blair_burns@listech.on.ca Address: 1700 Mitchell Road, South Listowel, ON N4W3H4 2.0 STATEMENT OF INTENT is a Tier One automotive supplier who manufactures molded and painted plastic parts. They are committed to protect the environment in which they work and comply with all legal and regulatory requirements. They are committed to continually improve the environment through prevention of pollution, conservation of natural resources, and reduction of waste while complying with all legal and regulatory requirements. Whenever feasible, we will reduce the use and releases of isopropyl alcohol, methyl isobutyl ketone, cycloheptane (all isomers), and light aromatic solvent naphtha in compliance with all Federal and Provincial regulations. 3.0 SUBSTANCES REQUIRING PLANS The following substance requires a plan isopropyl alcohol, methyl isobutyl ketone, cycloheptane (all isomers), and light aromatic solvent naphtha based on 2013 Toxics Reduction Act accounting information. These substances are found in the paints, catalysts and cleaning agents used at the facility. 4.0 OBJECTIVES OF THE PLAN & ANY TARGETS prides itself on technological innovation in order to produce high quality products in an environmentally responsible manner. We will strive to reduce the use of isopropyl alcohol, methyl isobutyl ketone, cycloheptane (all isomers), and light aromatic solvent naphtha at the facility. Further, this plan will determine the technical and economic feasibility of each option to determine which, if any, are viable for implementation at this time. 5.0 OPTIONS TO BE IMPLEMENTED (OR STATEMENT THAT NONE ARE TO BE IMPLEMENTED) has performed testing of improved paint guns and hard lines to increase efficiency of paint application, and reduce waste and lower both paint usage and air emissions. The reductions have been summarized below: 2014 Pinchin Ltd. Page 2 of 5
Reduction (kg) Reduction (%) Substance Category Isopropyl Alcohol Use 50.0 2.9% (CAS# 67-63-0) Emissions to Air 50.0 2.9% Methyl Isobutyl Ketone Use 42.3 2.9% (CAS# 108-10-1) Emissions to Air 42.3 2.9% Cycloheptane (all Use 33.2 2.9% isomers) (CAS# NA-25) Emissions to Air 33.2 2.9% Light Aromatic Solvent Use 47.6 2.9% Naphtha (CAS# 64742-95-6) Emissions to Air 47.6 2.9% As testing of the reduction option has begun in 2014, the implementation timeline can be considered immediate. 6.0 CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN This Plan Summary accurately reflects the Toxic Substance Reduction Plans dated December 15, 2014, prepared for the substances listed in Section 1.0 of this Summary. 2014 Pinchin Ltd. Page 3 of 5
8.0 CERTIFICATION BY LICENSED PLANNER As of December 15, 2014, I, Ajay Madan, TSRP# 0010 certify that I am familiar with the processes at 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. isopropyl alcohol, methyl isobutyl ketone, cycloheptane (all isomers), and light aromatic solvent naphtha December 15, 2014 Ajay Madan, TSRP# 0010 Senior Project Engineer Pinchin Ltd. amadan@pinchin.com J:\91000s\91187 ListowelTech,1700Mitchell,Listowel,ENRPT\91187.001 ListowelTech,1700Mitchell,Listowel,ENRPT\TRA Planning Report\91187 - Listowel Tech TRA Plan Summary - VOC.docx Template: Master Report for Toxics Substance Reduction Summary, ERC, September 16, 2014 2014 Pinchin Ltd. Page 5 of 5