TOXIC SUBSTANCE REDUCTION PLAN SUMMARY

As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility’s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement.
 

A statement of the Facility’s intent to reduce its “creation” or “use” of the Toxic Substance has not been included as a part of this Plan.

 

The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to two activities at the Facility, one of which is defined as a “use” under the TRA Framework and another which is interpreted as a “creation” of the Toxic Substance under the TRA framework.

 

The activity that has been classified as a “use” of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance is the use of spray paint cans which contain the Toxic Substance. The Facility is of the opinion that it has previously optimized its use of products containing the Toxic Substance to greatest extent that can reasonably be expected and therefore a statement of the Facility’s intent to reduce use of the Toxic Substance has not been included as a part of this Plan.

 

The activity that has been classified as a “creation” of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substances is the generation and subsequent release of the Toxic Substance as a by-product of natural gas combustion. It should be noted that the quantity “created” by this means contributed less than 10% of the total TRA reportable use/creation quantity for the 2013 baseline reporting year.

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