2015 Environment Management System & Community Engagement Report

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1 2015 Environment Management System & Community Engagement Report March 28, 2016

2 Table of Contents Summary 1. Background 2. Communications and Community Engagement 3. Community Air Quality Monitoring 4. Emissions Reduction Initiatives 5. Environmental Community Concerns 6. Action Plan Updates 7. Contact Information 8. Appendix

3 Summary Nickel and sulphur dioxide (SO 2 ) Site Specific Standard Approvals were issued by the Ministry of Environment and Climate Change (MOECC) to Vale s Ontario Operations for its Copper Cliff Smelter Complex in 2011, 2012 and The approvals included a request to implement communication and community engagement plans and to form an Environmental Monitoring Team (EMT). This fourth annual report documents 2015 community activities and environmental accomplishments. A number of events and meetings were held in 2015 in an effort to deliver information to the community about Vale s environmental activities and initiatives. These include the annual Open House, EMT meetings and Copper Cliff Liaison Committee (CCLC) meetings. Vale s corporate website, is also an excellent resource for information about the company s environmental performance and community involvement. Current and recent environmental monitoring results as well as real-time, recent and historical monitoring results are posted on the website. Details about monitoring programs, emission reduction dust emissions controls and information on other environmental initiatives can also be found at: Concentrations of SO 2 and metals, such as nickel and cobalt, are measured at a number of monitoring stations in the community. In 2015, Vale exceeded the measured action limit and 1-hour provincial standard limit for SO 2 in the community once and exceeded the nickel site-specific standard limit in two separate instances. There were no exceedances of the SO 2 24-hour air quality standard or the cobalt air quality guideline in See Appendix for additional details. Vale received a total of 167 complaints from community members in 2015 related to stack emissions, odour, fallout, noise, fugitive emissions and other concerns, compared to 183 in 2014, representing a 10% reduction over the previous year. All complaints were documented, investigated and followed up. An analysis of these complaints and a summary of how Vale responded to them is detailed in the report that follows. Action plan updates continued to be submitted to the Ministry of Environment and Climate Change in 2015 and were posted on the website twice per year at the end of March and September.

4 1.0 Background The Vale Smelter in Copper Cliff has a number of air quality related approvals from the Ministry of Environment and Climate Change (MOECC): Amended Environmental Compliance Approval # BXPTC Nickel Site Specific Standard Approval (24-hr) # rv0 Nickel Site Specific Standard Approval (annual) # rv0 Sulphur Dioxide Site Specific Standard Approval (1-hr) # rv0 Sulphur Dioxide Site Specific Standard Approval (24-hr) # rv0 The Site Specific Standard Approvals contain a requirement to form an Environmental Monitoring Team (EMT) with representation from the community, the MOECC and Vale. The purpose of the EMT is to serve as a forum for dissemination, consultation, review and exchange of information regarding the operation of the Smelter, environmental issues such as air monitoring, analysis of monitoring data, and to review any new or amended Ministry Approvals, as required. The group was formed by inviting members of an existing community stakeholder group, the Copper Cliff Liaison Committee (CCLC), which includes representation from the MOECC, and two members of the Gatchell Community Action Network, to participate. Though the actual EMT requirements varied between the Approvals, the group decided that one EMT would be appropriate to address all community engagement. This report documents the work of the EMT and the communications activities undertaken by Vale in Communications and Community Engagement The EMT followed the communication plan it developed in 2012, which is based on the premise of providing proactive, transparent and timely communications that update current performance and the progress of Vale s action plan to meet the requirements of its Nickel Site-Specific Standard (SSS) Approval. Information was shared through the course of the year via: The environmental section of The annual Report to Community Vale s Annual Open House Annual Teachers Tour Vale s Community Concerns Line Meetings with community groups Annual speech to the Greater Sudbury Chamber of Commerce The EMT received updates of monitoring results, action plan progress, and communications initiatives at meetings in March and December of Vale s website, includes information on a number of Vale initiatives and topics. The environmental elements that fulfill the site-specific standard approval requirements can be found on the website at:

5 The air quality documents posted on this site include: Most recent and historical metals and SO 2 monitoring results (reported quarterly); Glossary of terms; Details about the monitoring and emission reduction programs; Information about dust emission controls. The website also includes information about Vale in the community as well as information about the company s water, reclamation and decommissioning management activities. Vale s annual Open House was attended by over 70 local residents on September 23 rd, 2015 at Dynamic Earth. This new earth sciences venue provided a unique and interactive opportunity for Vale to provide updates about its air monitoring networks, the Clean AER Project and its Action Plans for its site-specific standard approvals for SO 2 and nickel. Information on other environmental initiatives such as re-greening, community gardens, water management and dust control was also provided to the community for feedback. At the same time, visitors also had an opportunity to learn about mining and minerals and could go on an underground tour, compliments of Vale. Photos from the September Open House are provided below. Learning opportunities are also offered through the Teachers Tour that the Ontario Mining Association hosts in partnership with the Canadian Ecology Centre each year,

6 which Vale participates in by providing an overview of the company s environmental initiatives. See photos of the 2015 tour below Teachers Tour Teachers from across Ontario visited Vale s Ontario Operations in July of 2015 during a tour hosted by the Ontario Mining Association and Canadian Ecology Centre.

7 3.0 Community Air Quality Monitoring Sulphur Dioxide There are 18 fixed continuous SO 2 monitoring stations located in the community, owned by Vale and Sudbury Integrated Nickel Operations (Glencore-Xstrata), and operated and maintained by Bestech Ltd. In addition, the network includes the operation of two meteorological towers and Vale s mobile SO 2 monitoring unit. The mobile unit is used to measure ground level concentrations of SO 2 in areas of the community not covered by the 18 fixed stations. A map indicating the location of the stations is provided below. In addition to the real time monitoring data, quarterly and annual reports of SO 2 concentrations measured at the fixed stations are compiled and reported by an independent consultant and submitted to the MOECC. The reports are then posted on the Vale website on a quarterly basis. Results from the monitoring network indicated that in 2015, Vale exceeded the measured action limit and 1-hour provincial standard limit for SO 2 in the community once at the Union Street station in November, determined to be attributable to fugitive emissions from the smelter. There were no exceedances of the 24-hour SO 2 limit. See attached appendix for additional details.

8 Nickel / Cobalt Vale s particulate sampling network of 8 monitoring stations operates on concurrent 3day or 6-day sampling schedule, with several stations operating multiple monitors to collect different size fractions of particulate matter on filters over a 24-hour period. The filters are sent to an independent lab for metals analysis and reporting. Quarterly reports are posted on the Vale website referenced above as they become available (lag time for filter and data analysis). A map showing the location of the monitoring stations is provided below. The nickel site-specific standard of 15 µg/m3 decreased to 3 µg/m3 on July 1, 2015, as per the smelter Site-specific Standard Approval. There was one day at the end of September when the 3 µg/m3 SSS level and the URT limit of 2 µg/m3 were exceeded at the Venice Street station and one day in January when the nickel URT of 2 µg/m3 was exceeded at Union Street. The cobalt air quality guideline of 0.1 µg/m3 was not exceeded in Nickel concentrate handling inside the screening plant was determined to be the cause of the September exceedance, and material handling of vacuumed dust was determined to be the cause of the January exceedance. All of these events have been scrutinized and analyzed with management at the smelter, with the aim of preventing future occurrences from these sources. Future emphasis will be on increased efforts to curb handling activities on windy days, controlling dust track-out of working areas, better road cleaning, and maintaining best operational practices for handling dusty materials.

9 Nickel and cobalt monitoring data for 2013, 2014 andd 2015 for the 8 air quality monitoring stations are presented in the two graphs that follow. The most recent detailed monitoring results that are available for these and otherr metals measured at thesee stations are posted on the Vale website.

10 4.0 Emissions Reduction Initiatives Emissions Reduction Program Vale s Emissions Reduction Program (ERP) is a significant contributor to the company s positive emissions performance. This program limits SO 2 emissions to the atmosphere by curtailing production at the smelter when dispersion conditions are such that unacceptable ground level concentrations of SO 2 are anticipated or experienced in the communities located around the smelter property. ERP Operators monitor operating conditions 24 hours per day, 7 days a week and control smelter production accordingly. Clean AER Project Vale s Clean AER Project is the largest single environmental investment in the history of Sudbury. The $1 billion investment will reduce SO 2 by 85% from current levels and metals and particulate emissions by 35 to 40%. AER stands for stands for Atmospheric Emissions Reduction, which simply means cleaner air. Following the completion of the project, Vale s total SO 2 emissions will be reduced from 150 kilotonnes currently to approximately 20 kilotonnes per year. This reduction is in addition to the 90% reduction in SO 2 emissions Vale has incorporated since By reducing natural gas consumption and modifying certain processes, the Clean AER Project will also reduce greenhouse gas emissions by 40%, from 270 kilotonnes of carbon dioxide to 150 kilotonnes. Vale has historically met reduced SO 2 emission targets for total SO 2 emitted from the Smelter, and has achieved significant SO 2 reductions over the years. A graph of these reductions is provided below.

11 5.0 Environmen tal Community Concerns The Smelter Environmental Compliance Approval and Nickel Site-Specific Standard Approvals requiree Vale to make a telephone numberr available to the public to register environmental complaints, and also require that all complaints be documented and followed up. Vale has had telephone numbers and a process to address community concerns for many years. For the smelter, there is a telephone number, , that is answered by a Smelter employee 24 hours per day, 7 days per week to receive and address concerns. Vale also has a general community concerns line at VALE that is also answered 24 hours per day, 7 days of the week by an answering service; Vale employees respond to the concerns received on this line within 48 hours. A summary graph of community concerns for 2013, 2014 and 2015 is provided below. Theree were a total of 166 community concerns logged in 2015, compared to 183 in 2014 and 122 in The concerns have been sorted byy type in the graph. The majority of the concerns in 2015 were about SO 2 stack emissions, followed by odour complaints related to the fluid bed dryer emissions (less in 2015 than the previous year) ). Theree were some fallout claims (less in 2015 than 2014), a few about SO 2 fugitive emissions (from buildings and small vents), and onlyy 1 or 2 about noise. The unknown category includes concerns from residents that did not correspond with the wind directions from the smelter. The last category of other includes concerns about the appearance of the plume, odours not related to the fluid bed dryer and vegetation damage. There were a number of calls about the August 13, 2015 acid plant emergency alert and those are also reflected in the graph in the Emergency Alarms category.

12 When community calls are received, they are routed to the appropriate department and the caller is contacted directly by the Vale representative. A complaint log form is filled out that records the date, time, name, address and phone number of the person, along with the wind direction at the time of the incident (available from Vale s meteorological records). Specific details about the complaint are also logged in the form. Within one week of receiving the complaint, the following information is entered into the log: Actions taken to investigate the cause of the complaint and result Recommendations for remedial measures Managerial/operational changes to avoid recurrence Feedback given to the caller The Smelter Environmental Compliance Approval (ECA) requires Vale to keep the complaint records on file for 7 years, and also to submit quarterly reports to the MOECC summarizing the information about the complaints, including follow-up details. Four reports were submitted to the MOECC with this information in Feedback on community concerns is also actively sought and logged at Vale s annual Open House and through its annual Report to the Community. The company invites the public to express their concerns through a variety of methods (phone lines, , feedback forms and in person). Vale also actively seeks feedback on the manner in which it communicates with the public, often seeking input on opportunities for improvement. For example, the EMT provided feedback for this Community Engagement Report suggesting that longer technical descriptions related to compliance should be moved to the appendix. Readers will note that this change has now been made to the report. Vale also received a suggestion that it would be beneficial to include greater detail on how it responds to community concerns so that information has been included in this report as well. 6.0 Action Plan Updates As part of its submission for site-specific standards for nickel and SO 2, Vale submitted action plans to the MOECC to reduce its overall emissions and ground level concentrations in the community. These action plans became conditions and were appended to the site-specific standard approvals. Vale prepares a report to update the status of its action plans semi-annually, in March and September. The updates are posted on Vale s website at: The primary ongoing action item is the Clean-AER project. In 2015, work continued to be focused on executing the revised Clean AER project plan that was developed in 2014 on the basis of a future single furnace operation. At the close of 2015, the project s progress was: Engineering 95% complete Procurement and fabrication 65% complete

13 Construction 35% complete Commissioning 25% complete Construction work completed in 2015 included: Fluid bed roaster baghouse Slag skull area wind fencing Weak acid treatment plant SO 2 scrubber Clarabelle Mill oxidation circuit Material handling facility at the Nickel Refinery Converter #10 structural steel Mobile equipment shop Converter gas plant piling and foundation work started The following photos show some of the work progress in 2015.

14 Photos Material Handling Building at Nickel Refinery Converter Wet Gas Cleaning Construction Site Converter #10 Shell & Structural Steel

15 Converter Wet Gas Cleaning & Flue System Secondary Baghouse and Fan Building

16 7.0 Contact Info For more information or to discuss this report, contact Frank Javor, Manager Environment Air, Vale Ontario Operations, at ,

17 8.0 Appendix SO 2 Measurements Summary graphs of the SO 2 measurements taken at the 18 stations in 2015 are provided in this Appendix. Low SO 2 concentrations were measured for the majority of the year as in the previous year, and all stations were calculated to have annual arithmetic mean concentrations that were less than 4 ppb in Based on the standard methodology of reporting on the clock hour (e.g. at 11:00, 12:00, 1:00), there was one instance when the 1-hour SO 2 Measured Level above which, Trigger Action limit of 340 ppb was exceeded in November at the Union Street station (value of 375 ppb), which also triggered an exceedance of the 1-hour standard of 250 ppb as the emissions were from fugitive, non-stack sources at the Smelter. Although not shown on the graphs, there were also no exceedances of the 24-hour provincial air quality SO 2 standard of 100 ppb in In addition to the provincial standard clock hour basis, Vale is also required to calculate a rolling-1-hour average. This consists of the average 1-hour concentration calculated and recorded every 5 minutes (eg. 1-hour average recorded at 11:45 represents the average of all readings taken during the period from 10:46 to 11:45; 1-hour averaged recorded at 11:50 represents the average of readings taken from 10:51 to 11:50, etc.), resulting in 24 x 12 = hour rolling averages recorded each day at each station. There was one rolling 1-hour average exceedances of the 250 ppb limit for fugitive, nonstack emissions in 2015 the same incident as described above at the Union Street station (value of 390 ppb recorded in the hour from 3:40 to 4:40 pm). There were 3 instances when the clock-hour 1-hour average of the SO 2 provincial air quality standard (250 ppb) was exceeded (once each at the Science North (260 ppb), Kelly Lake (274 ppb) and Union Street (375 ppb; discussed above and reported as an exceedance) stations. This limit does not currently apply to the Smelter; it will begin to apply in The level above 250 ppb measured at the Coniston station has been attributed to Glencore Smelter emissions. The graphs provided on the next page provide a summary of the 2015 hourly (clock) SO 2 values.

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