BASIC FACILITY INFORMATION Name & CAS # of Substance Ethylene Glycol Facility Identification and Site Address 107-21-1 Company Name Facility Name ArcelorMittal Dofasco Facility Address Spatial Coordinates of Facility Physical Address: P.O. Box 2460 1330 Burlington Street East Hamilton, Ontario L8N 3J5 Number of Employees 5,089 (End of 2013) NPRI ID 3713 Ontario MOE ID Number 5092 Zone - 17, East - 596441,West- 4790641 Parent Company (PC) Information Mailing Address: Same as physical address PC Name & Address Percent Ownership for each PC ArcelorMittal Holdings Inc. 100% Business Number for PC 873449979 4000 Route des Acieries Contrecoeur, Quebec J0L 1C0 Primary North American Industrial Classification System Code (NAICS) 2 Digit NAICS Code 33 (Primary Metal Industries) 4 Digit NAICS Code 3311 (Iron and Steel Mills and Ferroalloy Manufacturing) 6 Digit NAICS Code 331110 (Iron and Steel Mills and Ferro- Alloy Manufacturing ) Company Contact Information Tony Valeri, VP Communications and Public Affairs Facility Public Contact Tony.Valeri@arcelormittal.com Phone: (905) 548-7200 x 6452 Fax: (905) 548-4935 Lisa Marcuzzi, General Counsel and Corporate Secretary Parent Company Contact lisa.marcuzzi@arcelormittal.com Phone: (905) 548-7200 x 6692 Fax: (905) 548-4249
PLAN SUMMARY STATEMENT This Plan Summary accurately reflects the content of the Toxic Substance Reduction Plan for ethylene glycol, prepared on behalf of ArcelorMittal Dofasco (Dofasco), and dated December 18, 2014. STATEMENT OF INTENT Dofasco is committed to playing a leadership role in protecting the environment. Wherever feasible, we will eliminate, or reduce the use, creation, disposal or discharge of ethylene glycol in compliance with all Federal and Provincial Regulations. Our employees are encouraged to participate in toxic substance use reduction activities. Toxic substance use reduction will be an ongoing effort for Dofasco, and we will continue to monitor technological advancements to ensure that options which are both technically and economically viable are implemented at our facility. Dofasco has an Environmental Management System that is certified to ISO 14001. This system identifies environmental aspects and ranks their severity. Priority issues are identified and improvement plans are developed for implementation in our annual business plans. Dofasco also has a voluntary system in place to review all new products purchased for use in the company to identify toxic substances and either prohibit their purchase or restrict their use. This has been an effective process for preventing toxics from being used in purchased consumable products. As a result of the purchased product screening and EMS initiatives, Dofasco has inherently developed a system to prevent certain toxics from entering the company and reduce others from being released to the environment. REDUCTION OBJECTIVE Dofasco is committed to reducing the presence of ethylene glycol within Iron Making. This will be achieved by understanding how and why ethylene glycol enters the facility so that a better understanding is developed around this substances use. Reduction options will be explored for each of the seven reductions categories. DESCRIPTION OF SUBSTANCE Ethylene glycol is used at Dofasco to prevent the freezing of raw materials. The largest user is Ironmaking which uses ethylene glycol during the winter months to prevent the iron ore pellets and PCI coal from clumping due to freezing. The product is applied sparingly on conveyor systems that transfer the raw materials from the storage piles to local contained storage bins. All the ethylene glycol that is added to the piles is destroyed in the Blast Furnaces. However, there are some other minor products containing minimal amounts of the substance. Therefore a small portion of ethylene glycol is expected to find its way into transfers and air emissions. TOXIC SUBSTANCE REDUCTION OPTION TO BE IMPLEMENTED No technical or economically feasible reduction options were identified to reduce ethylene glycol use within the plant. Ethylene Glycol (tonnes) Used Created Contained in Product On-Site Releases Disposal Air Water Transfers On-site Off-site Baseline 28.72-24.11 0.00 2.12 0.00 0.7 0.00 0.00 Reduction 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Estimated Reduction Total 28.72-24.11 0.00 2.12 0.00 0.7 0.00 0.00 % Reduction 0.00% 0.00% N/A 0.00% N/A 0.00% N/A N/A (Note: A negative created number indicates the substance is destroyed)
CERTIFICATION BY HIGHEST RANKING EMPLOYEE As of December 18, 2014, I, Sean Donnelly, 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. Ethylene Glycol Sean Donnelly President and CEO CERTIFICATION BY LICENSED PLANNER As of December 18, 2014, I, Craig McGinlay certify that I am familiar with the processes at that use or create the toxic substance referred to below, that I agree with 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 plant dated December 18, 2013, and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act. Ethylene Glycol Craig McGinlay Senior Environmental Specialist TRA Planner License #: TSRP0165
BASIC FACILITY INFORMATION Name & CAS # of 1,2,4-Trimethylbenzene Substance Facility Identification and Site Address 95-63-6 Company Name Facility Name ArcelorMittal Dofasco Facility Address Spatial Coordinates of Facility Physical Address: P.O. Box 2460 1330 Burlington Street East Hamilton, Ontario L8N 3J5 Number of Employees 5,089 (End of 2013) NPRI ID 3713 Ontario MOE ID Number 5092 Zone - 17, East - 596441,West- 4790641 Parent Company (PC) Information Mailing Address: Same as physical address PC Name & Address Percent Ownership for each PC ArcelorMittal Holdings Inc. 100% Business Number for PC 873449979 4000 Route des Acieries Contrecoeur, Quebec J0L 1C0 Primary North American Industrial Classification System Code (NAICS) 2 Digit NAICS Code 33 (Primary Metal Industries) 4 Digit NAICS Code 3311 (Iron and Steel Mills and Ferroalloy Manufacturing) 6 Digit NAICS Code 331110 (Iron and Steel Mills and Ferro- Alloy Manufacturing ) Company Contact Information Tony Valeri, VP Communications and Public Affairs Facility Public Contact Tony.Valeri@arcelormittal.com Phone: (905) 548-7200 x 6452 Fax: (905) 548-4935 Lisa Marcuzzi, General Counsel and Corporate Secretary Parent Company Contact lisa.marcuzzi@arcelormittal.com Phone: (905) 548-7200 x 6692 Fax: (905) 548-4249
PLAN SUMMARY STATEMENT This Plan Summary accurately reflects the content of the Toxic Substance Reduction Plan for 1,2,4-trimethylbenzene, prepared on behalf of ArcelorMittal Dofasco (Dofasco), and dated December 18, 2014. STATEMENT OF INTENT Dofasco is committed to playing a leadership role in protecting the environment. Wherever feasible, we will eliminate, or reduce the use, creation, disposal or discharge of 1,2,4-trimethylbenzene in compliance with all Federal and Provincial Regulations. Our employees are encouraged to participate in toxic substance use reduction activities. Toxic substance use reduction will be an ongoing effort for Dofasco, and we will continue to monitor technological advancements to ensure that options which are both technically and economically viable are implemented at our facility. Dofasco has an Environmental Management System that is certified to ISO 14001. This system identifies environmental aspects and ranks their severity. Priority issues are identified and improvement plans are developed for implementation in our annual business plans. Dofasco also has a voluntary system in place to review all new products purchased for use in the company to identify toxic substances and either prohibit their purchase or restrict their use. This has been an effective process for preventing toxics from being used in purchased consumable products. As a result of the purchased product screening and EMS initiatives, Dofasco has inherently developed a system to prevent certain toxics from entering the company and reduce others from being released to the environment. REDUCTION OBJECTIVE Dofasco is committed to reducing the presence of 1,2,4-trimethylbenzene within the entire plant. This will be achieved by understanding how and why 1,2,4-trimethylbenzene enters the facility so that a better understanding is developed around this substances use. Reduction options will be explored for each of the seven reductions categories. DESCRIPTION OF SUBSTANCE 1,2,4-Trimethylbenzene is a key ingredient of Ferrameen COG9016, which is used within Cokemaking. Ferrameen is added to coke oven gas pipelines in order to breakdown solid build-up within the pipelines. The Ferrameen along with the broken down solids are collected in drip legs and transferred to one of our by-products sumps to eventually be biologically treated. All 1,2,4-trimethylbenzene during this process is destroyed; a percentage is destroyed/used-up within the coke oven gas pipelines and the remainder is biologically destroyed in one of our byproducts plants. TOXIC SUBSTANCE REDUCTION OPTION TO BE IMPLEMENTED No technical or economically feasible reduction options were identified to reduce 1,2,4-trimethylbenzene use within the plant. 1,2,4-Trimethylbenzene (tonnes) Used Created Contained in Product (Note: A negative created number indicates the substance is destroyed) On-Site Releases Disposal Air Water Transfers On-site Off-site Baseline 10.75-10.55 0.00 0.20 0.00 0.00 0.00 0.00 Reduction 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Estimated Reduction Total 10.75-10.55 0.00 0.20 0.00 0.00 0.00 0.00 % Reduction 0.00% 0.00% N/A 0.00% N/A N/A N/A N/A
CERTIFICATION BY HIGHEST RANKING EMPLOYEE As of December 18, 2014, I, Sean Donnelly, 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. 1,2,4-trimethylbenzene Sean Donnelly President and CEO CERTIFICATION BY LICENSED PLANNER As of December 18, 2014, I, Craig McGinlay certify that I am familiar with the processes at that use or create the toxic substance referred to below, that I agree with 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 plant dated December 18, 2013, and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act. 1,2,4-trimethylbenzene Craig McGinlay Senior Environmental Specialist TRA Planner License #: TSRP0165
BASIC FACILITY INFORMATION Name & CAS # of Hydrotreated light distillates, petroleum Substance Facility Identification and Site Address 64742-47-8 Company Name Facility Name ArcelorMittal Dofasco Facility Address Spatial Coordinates of Facility Physical Address: P.O. Box 2460 1330 Burlington Street East Hamilton, Ontario L8N 3J5 Number of Employees 5,089 (End of 2013) NPRI ID 3713 Ontario MOE ID Number 5092 Zone - 17, East - 596441,West- 4790641 Parent Company (PC) Information Mailing Address: Same as physical address PC Name & Address Percent Ownership for each PC ArcelorMittal Holdings Inc. 100% Business Number for PC 873449979 4000 Route des Acieries Contrecoeur, Quebec J0L 1C0 Primary North American Industrial Classification System Code (NAICS) 2 Digit NAICS Code 33 (Primary Metal Industries) 4 Digit NAICS Code 3311 (Iron and Steel Mills and Ferroalloy Manufacturing) 6 Digit NAICS Code 331110 (Iron and Steel Mills and Ferro- Alloy Manufacturing ) Company Contact Information Tony Valeri, VP Communications and Public Affairs Facility Public Contact Tony.Valeri@arcelormittal.com Phone: (905) 548-7200 x 6452 Fax: (905) 548-4935 Lisa Marcuzzi, General Counsel and Corporate Secretary Parent Company Contact lisa.marcuzzi@arcelormittal.com Phone: (905) 548-7200 x 6692 Fax: (905) 548-4249
PLAN SUMMARY STATEMENT This Plan Summary accurately reflects the content of the Toxic Substance Reduction Plan for hydrotreated light distillates, petroleum, prepared on behalf of ArcelorMittal Dofasco (Dofasco), and dated December 18, 2014. STATEMENT OF INTENT Dofasco is committed to playing a leadership role in protecting the environment. Wherever feasible, we will eliminate, or reduce the use, creation, disposal or discharge of hydrotreated light distillates, petroleum in compliance with all Federal and Provincial Regulations. Our employees are encouraged to participate in toxic substance use reduction activities. Toxic substance use reduction will be an ongoing effort for Dofasco, and we will continue to monitor technological advancements to ensure that options which are both technically and economically viable are implemented at our facility. Dofasco has an Environmental Management System that is certified to ISO 14001. This system identifies environmental aspects and ranks their severity. Priority issues are identified and improvement plans are developed for implementation in our annual business plans. Dofasco also has a voluntary system in place to review all new products purchased for use in the company to identify toxic substances and either prohibit their purchase or restrict their use. This has been an effective process for preventing toxics from being used in purchased consumable products. As a result of the purchased product screening and EMS initiatives, Dofasco has inherently developed a system to prevent certain toxics from entering the company and reduce others from being released to the environment. REDUCTION OBJECTIVE Dofasco is committed to reducing the presence of hydrotreated light distillates, petroleum within the entire plant. This will be achieved by understanding how and why hydrotreated light distillates, petroleum enters the facility so that a better understanding is developed around this substances use. Reduction options will be explored for each of the seven reductions categories. DESCRIPTION OF SUBSTANCE Products which contain hydrotreated light distillates, petroleum are used by the business units for various applications. These applications include lubricants, flocculants, and spray paints. The largest usage of hydrotreated light distillates, petroleum is found within the product POLYFLOC AE1703 (1049 KG TOTE). This product is a commonly used flocculent throughout the plant. All of the hydrotreated light distillates, petroleum used throughout the plant is either released into the air or released via transfers. TOXIC SUBSTANCE REDUCTION OPTION TO BE IMPLEMENTED No technical or economically feasible reduction options were identified to reduce hydrotreated light distillates, petroleum use within the plant. Hydrotreated light distillates, petroleum (tonnes) Used Created Contained in Product On-Site Releases Disposal Air Water Transfers On-site Off-site Baseline 14.61 0.00 0.00 0.33 0.00 14.28 0.00 0.00 Reduction 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Estimated Reduction Total 14.61 0.00 0.00 0.33 0.00 14.28 0.00 0.00 % Reduction 0.00% N/A N/A 0.00% N/A 0.00% N/A N/A (Note: A negative created number indicates the substance is destroyed)
CERTIFICATION BY HIGHEST RANKING EMPLOYEE As of December 18, 2014, I, Sean Donnelly, 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. Hydrotreated light distillates, petroleum Sean Donnelly President and CEO CERTIFICATION BY LICENSED PLANNER As of December 18, 2014, I, Craig McGinlay certify that I am familiar with the processes at that use or create the toxic substance referred to below, that I agree with 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 plant dated December 18, 2013, and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act. Hydrotreated light distillates, petroleum Craig McGinlay Senior Environmental Specialist TRA Planner License #: TSRP0165
BASIC FACILITY INFORMATION Name & CAS # of Substance Lithium Carbonate Facility Identification and Site Address 554-13-2 Company Name Facility Name ArcelorMittal Dofasco Facility Address Spatial Coordinates of Facility Physical Address: P.O. Box 2460 1330 Burlington Street East Hamilton, Ontario L8N 3J5 Number of Employees 5,089 (End of 2013) NPRI ID 3713 Ontario MOE ID Number 5092 Zone - 17, East - 596441,West- 4790641 Parent Company (PC) Information Mailing Address: Same as physical address PC Name & Address Percent Ownership for each PC ArcelorMittal Holdings Inc. 100% Business Number for PC 873449979 4000 Route des Acieries Contrecoeur, Quebec J0L 1C0 Primary North American Industrial Classification System Code (NAICS) 2 Digit NAICS Code 33 (Primary Metal Industries) 4 Digit NAICS Code 3311 (Iron and Steel Mills and Ferroalloy Manufacturing) 6 Digit NAICS Code 331110 (Iron and Steel Mills and Ferro- Alloy Manufacturing ) Company Contact Information Tony Valeri, VP Communications and Public Affairs Facility Public Contact Tony.Valeri@arcelormittal.com Phone: (905) 548-7200 x 6452 Fax: (905) 548-4935 Lisa Marcuzzi, General Counsel and Corporate Secretary Parent Company Contact lisa.marcuzzi@arcelormittal.com Phone: (905) 548-7200 x 6692 Fax: (905) 548-4249
PLAN SUMMARY STATEMENT This Plan Summary accurately reflects the content of the Toxic Substance Reduction Plan for lithium carbonate, prepared on behalf of ArcelorMittal Dofasco (Dofasco), and dated December 18, 2014. STATEMENT OF INTENT Dofasco is committed to playing a leadership role in protecting the environment. Wherever feasible, we will eliminate, or reduce the use, creation, disposal or discharge of lithium carbonate in compliance with all Federal and Provincial Regulations. Our employees are encouraged to participate in toxic substance use reduction activities. Toxic substance use reduction will be an ongoing effort for Dofasco, and we will continue to monitor technological advancements to ensure that options which are both technically and economically viable are implemented at our facility. Dofasco has an Environmental Management System that is certified to ISO 14001. This system identifies environmental aspects and ranks their severity. Priority issues are identified and improvement plans are developed for implementation in our annual business plans. Dofasco also has a voluntary system in place to review all new products purchased for use in the company to identify toxic substances and either prohibit their purchase or restrict their use. This has been an effective process for preventing toxics from being used in purchased consumable products. As a result of the purchased product screening and EMS initiatives, Dofasco has inherently developed a system to prevent certain toxics from entering the company and reduce others from being released to the environment. REDUCTION OBJECTIVE Dofasco is committed to reducing the presence of lithium carbonate within the entire plant. This will be achieved by understanding how and why lithium carbonate enters the facility so that a better understanding is developed around this substances use. Reduction options will be explored for each of the seven reductions categories. DESCRIPTION OF SUBSTANCE Lithium carbonate is added to the steelmaking process as mould powder. Mould powder is placed on top of the molten steel as it is poured into the mould. Oscillations by the mould force the powder down along the sides of the molten steel as it goes through the casting process. The mould powder provides lubrication, and also prevents lubrication. The mould powder also provides a thermally conductive layer that helps cool the steel. The high pressure and heat of this environment causes the lithium carbonate within the powder to breakdown into other compounds. It is estimated that all lithium carbonate is completely transformed and therefore not, in any way, released from the plant. TOXIC SUBSTANCE REDUCTION OPTION TO BE IMPLEMENTED No technical or economically feasible reduction options were identified to reduce lithium carbonate use within the plant. Lithium Carbonate (tonnes) Used Created Contained in Product On-Site Releases Disposal Air Water Transfers On-site Off-site Baseline 48.94-48.94 0.00 0.00 0.00 0.00 0.00 0.00 Reduction 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Estimated Reduction Total 48.94-48.94 0.00 0.00 0.00 0.00 0.00 0.00 % Reduction 0.00% 0.00% N/A N/A N/A N/A N/A N/A (Note: A negative created number indicates the substance is destroyed)
CERTIFICATION BY HIGHEST RANKING EMPLOYEE As of December 18, 2014, I, Sean Donnelly, 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. Lithium Carbonate Sean Donnelly President and CEO CERTIFICATION BY LICENSED PLANNER As of December 18, 2014, I, Craig McGinlay certify that I am familiar with the processes at that use or create the toxic substance referred to below, that I agree with 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 plant dated December 18, 2013, and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act. Lithium Carbonate Craig McGinlay Senior Environmental Specialist TRA Planner License #: TSRP0165
BASIC FACILITY INFORMATION Name & CAS # of Substance Molybdenum trioxide Facility Identification and Site Address 1313-27-5 Company Name Facility Name ArcelorMittal Dofasco Facility Address Spatial Coordinates of Facility Physical Address: P.O. Box 2460 1330 Burlington Street East Hamilton, Ontario L8N 3J5 Number of Employees 5,089 (End of 2013) NPRI ID 3713 Ontario MOE ID Number 5092 Zone - 17, East - 596441,West- 4790641 Parent Company (PC) Information Mailing Address: Same as physical address PC Name & Address Percent Ownership for each PC ArcelorMittal Holdings Inc. 100% Business Number for PC 873449979 4000 Route des Acieries Contrecoeur, Quebec J0L 1C0 Primary North American Industrial Classification System Code (NAICS) 2 Digit NAICS Code 33 (Primary Metal Industries) 4 Digit NAICS Code 3311 (Iron and Steel Mills and Ferroalloy Manufacturing) 6 Digit NAICS Code 331110 (Iron and Steel Mills and Ferro- Alloy Manufacturing ) Company Contact Information Tony Valeri, VP Communications and Public Affairs Facility Public Contact Tony.Valeri@arcelormittal.com Phone: (905) 548-7200 x 6452 Fax: (905) 548-4935 Lisa Marcuzzi, General Counsel and Corporate Secretary Parent Company Contact lisa.marcuzzi@arcelormittal.com Phone: (905) 548-7200 x 6692 Fax: (905) 548-4249
PLAN SUMMARY STATEMENT This Plan Summary accurately reflects the content of the Toxic Substance Reduction Plan for molybdenum trioxide, prepared on behalf of ArcelorMittal Dofasco (Dofasco), and dated December 18, 2014. STATEMENT OF INTENT Dofasco is committed to playing a leadership role in protecting the environment. Wherever feasible, we will eliminate, or reduce the use, creation, disposal or discharge of molybdenum trioxide in compliance with all Federal and Provincial Regulations. Our employees are encouraged to participate in toxic substance use reduction activities. Toxic substance use reduction will be an ongoing effort for Dofasco, and we will continue to monitor technological advancements to ensure that options which are both technically and economically viable are implemented at our facility. Dofasco has an Environmental Management System that is certified to ISO 14001. This system identifies environmental aspects and ranks their severity. Priority issues are identified and improvement plans are developed for implementation in our annual business plans. Dofasco also has a voluntary system in place to review all new products purchased for use in the company to identify toxic substances and either prohibit their purchase or restrict their use. This has been an effective process for preventing toxics from being used in purchased consumable products. As a result of the purchased product screening and EMS initiatives, Dofasco has inherently developed a system to prevent certain toxics from entering the company and reduce others from being released to the environment. REDUCTION OBJECTIVE Dofasco is committed to reducing the presence of molybdenum trioxide within Steel Making. This will be achieved by understanding how and why molybdenum trioxide enters the facility so that a better understanding is developed around this substances use. Reduction options will be explored for each of the seven reductions categories. DESCRIPTION OF SUBSTANCE Molybdenum is added to the steelmaking process for specific grades of steel. In this environment the molybdenum trioxide is completely transformed into molybdenum. The molybdenum then leaves the process as part of the final product. Molybdenum trioxide is completely consumed and therefore not, in any way, released from the plant. TOXIC SUBSTANCE REDUCTION OPTION TO BE IMPLEMENTED No technical or economically feasible reduction options were identified to reduce molybdenum trioxide use within the plant. Molybdenum Trioxide (tonnes) Used Created Contained in Product On-Site Releases Disposal Air Water Transfers On-site Off-site Baseline 244.37-244.37 0.00 0.00 0.00 0.00 0.00 0.00 Reduction 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Estimated Reduction Total 244.37-244.37 0.00 0.00 0.00 0.00 0.00 0.00 % Reduction 0.00% 0.00% N/A N/A N/A N/A N/A N/A (Note: A negative created number indicates the substance is destroyed)
CERTIFICATION BY HIGHEST RANKING EMPLOYEE As of December 18, 2014, I, Sean Donnelly, 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. Molybdenum trioxide Sean Donnelly President and CEO CERTIFICATION BY LICENSED PLANNER As of December 18, 2014, I, Craig McGinlay certify that I am familiar with the processes at that use or create the toxic substance referred to below, that I agree with 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 plant dated December 18, 2013, and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act. Molybdenum trioxide Craig McGinlay Senior Environmental Specialist TRA Planner License #: TSRP0165