2019 environment management system community engagement report

2019 Environment Management System&

Community Engagement Report

March 30, 2020

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Vale 2019 Environment Management System & Community Engagement Report (March 30, 2020)

Table of Contents

SUMMARY ............................................................................................................................................................. 2

1 BACKGROUND .............................................................................................................................................. 4

2 COMMUNICATIONS AND COMMUNITY ENGAGEMENT ................................................................................ 4

2.1 VALE WEBSITE .............................................................................................................................................. 5

2.2 REPORT TO COMMUNITY ................................................................................................................................. 5

2.3 COMMUNITY LETTER ...................................................................................................................................... 7

2.4 OPEN HOUSE ............................................................................................................................................... 8

3 COMMUNITY AIR QUALITY MONITORING .................................................................................................... 9

3.1 SULPHUR DIOXIDE ......................................................................................................................................... 9

3.2 NICKEL ..................................................................................................................................................... 12

4 EMISSIONS REDUCTION PROGRAM UPDATE .............................................................................................. 15

5 ENVIRONMENTAL COMMUNITY CONCERNS ............................................................................................... 15

6 ACTION PLAN UPDATES .............................................................................................................................. 17

6.1 SO2 COMPLIANCE ....................................................................................................................................... 17

6.2 NICKEL ..................................................................................................................................................... 17

6.3 CLEAN AER ............................................................................................................................................... 19

6.4 SUPERSTACK UPDATE ................................................................................................................................... 19

6.5 450' STACKS UPDATE................................................................................................................................... 22

7 CONTACT INFO ........................................................................................................................................... 23

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Summary

Nickel and sulphur dioxide (SO2) Site Specific Standard Approvals were issued by the Ministryof the Environment, Conservation and Parks (MECP) to Vale’s Ontario Operations for its CopperCliff Smelter Complex in the years between 2011 and 2014. The approvals included a requestto implement communication and community engagement plans and to form an EnvironmentalMonitoring Team (EMT). This seventh annual report documents 2019 community activities andenvironmental accomplishments.

Several events and meetings were held in 2019 in an effort to deliver information to thecommunity about Vale’s environmental activities and initiatives. These include the annual OpenHouse, EMT meetings and Copper Cliff Liaison Committee (CCLC) meetings as well as a CleanAER Project Completion Celebration Luncheon and News Conference.

Vale’s Canadian website, www.vale.com/canada is also an excellent resource for informationabout the company’s environmental performance and community involvement. Current andrecent environmental monitoring results as well as real-time, recent and historical monitoringresults are posted on the website. Details about monitoring programs, emission reductions, dustemissions controls and other environmental initiatives can also be found at:

http://www.vale.com/canada/en/aboutvale/communities/sudbury/sudbury-environment/our-commitment-to-air-sudbury/pages/default.aspx

Concentrations of SO2, total suspended particulate (TSP) and metals are measured at severalmonitoring stations in the community. In 2019, there were no measured exceedances of the airquality standards attributable to Vale operations.

Vale has significantly reduced the emissions of SO2 from its Sudbury area operations with theimplementation of several process changes over the years, including the Clean AtmosphericEmission Reduction (AER) Project. These process changes and modernization of Vale’sSmelter Operations have resulted in an 85% reduction in SO2 emissions. Most of the reductionis attributable to the diversion of converter off gas from the Superstack to be treated in a newConverter Wet Gas Cleaning Plant and the Acid Plant. In fact, since January 1, 2019, the onlyemissions from the Superstack have been from furnace and roaster maintenance operations.These emissions will report to the new 450’ stacks by the end of 2020 and the Superstack willno longer emit any emissions.

Vale continues to operate an Emission Reduction Program (ERP). Even though the Smeltersuperstack is no longer a significant source of SO2 emissions, the Emission Reduction Program(ERP) continues to predict and monitor dispersion conditions and to manage possible impactsthat could result in elevated ambient SO2 ground level concentrations (GLCs) of sulphur dioxidein the community attributed to Vale sources.

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Vale received 25% fewer complaints from community members in 2019 compared to previousyears. In 2019, a total of 57 complaints were received, compared to 76 (2018) and 78 (2017).Only one concern was received regarding SO2 emissions, likely due to the substantial effortsVale has made to curb SO2 emissions with the Clean AER Project.

All complaints were documented, investigated and followed up. An analysis of these complaintsand a summary of how Vale responded to them is detailed in the report that follows.

Nickel Action Plan updates were submitted to Ministry of the Environment, Conservation andParks (MECP) in March and September 2019 and were subsequently posted on the ValeCanada website.

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1 Background

At the end of 2019, the following air quality related approvals from the Ministry of theEnvironment, Conservation and Parks (MECP) were in effect at the Vale Copper Cliff Smelter:

· Amended Environmental Compliance Approval # 6785-9BXPTC (issued January 2014)· Nickel Site Specific Standard Approval (annual) # 502-11-rv0 (issued December 2011)

The site-specific standard approval contains a requirement to form an Environmental MonitoringTeam (EMT) with representation from the community, the MECP and Vale. The purpose of theEMT is to serve as a forum for dissemination, consultation, review and exchange of informationregarding the operation of the Smelter, environmental issues such as air monitoring, analysis ofmonitoring 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, theCopper Cliff Liaison Committee (CCLC), which includes representation from the MECP, and twomembers of the Gatchell Community Action Network, to participate. The EMT received updatesof monitoring results, Action Plan progress, and communications initiatives at meetings held inMarch and November of 2019.

This report documents the work of the EMT and the communications activities undertaken byVale in 2019.

2 Communications and Community Engagement

The EMT followed the communication plan it developed in 2012, which is based on the premiseof providing proactive, transparent and timely communications that update current performanceand the progress of Vale’s Action Plan to meet the requirements of its Site-Specific Standard(SSS) Approvals.

Information was shared through the course of the year via:

· The environment section of www.vale.com/canada· The Clean AER Project website:

http://www.vale.com/canada/EN/aboutvale/communities/sudbury/Clean-AER/Pages/default.aspx

· The Annual Report to Community· Vale’s Annual Open House· Meetings with community groups

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2.1 Vale Website

In addition to the Clean AER Project web page, Vale’s website, www.vale.com/canada, alsoincludes air quality information that further fulfill its site-specific standard approval requirementshere:

http://www.vale.com/canada/EN/aboutvale/communities/sudbury/sudbury-environment/environmental-reporting-sudbury/air-quality-monitoring-results/Pages/default.aspx

The air quality documents posted on this site include:· Most recent and historical metals and SO2 monitoring results (reported quarterly)· Glossary of terms· Details about the monitoring and emission reduction programs, and· Information about dust emission controls

The website also includes information about Vale in the community as well as information aboutthe company’s water, reclamation and decommissioning management activities.

2.2 Report to Community

The annual Report to the Community was posted to Vale’s website in December of 2019 alongwith the reports from its other Canadian operating sites here:

http://www.vale.com/canada/en/aboutvale/communities/pages/community-reports.aspx

Postcards were sent to all homes and businesses in Greater Sudbury with a QR code link to thereport. The postcard also provided an opportunity for residents to provide feedback by mailingthe card back to Vale. The company’s community concerns line phone number and an emailaddress to provide feedback electronically was also provided on the postcard.

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Vale’s annual Report to the Community was posted to the company’s website in December of 2019.

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2.3 Community Letter

A community letter from the Smelter manager was provided to residents of Copper Cliff in Julyof 2019 to keep them informed of Vale’s progress on its Surface Facilities Upgrade project andthe tie-in of the new stacks, as per the below.

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2.4 Open House

Vale’s annual Open House at Dynamic Earth on September 18th, 2019 had its highest everattendance, with over 460 visitors interested in the Company’s Sudbury Operations andenvironmental initiatives. A totalof 156 participants were fromschools near Copper Cliffoperations and SagamokAnishnawbek First Nationschool.

Invitations to the event weredistributed throughout Vale’snetwork of community andindustry partners. The event isfree to the public and widelyadvertised on local radio stations,electronic media and to localschools. Attendees reportedlearning about the Open Houseprimarily through radio (18%) andnewspaper (15%) advertising,school (10%) and at theworkplace (8%)

Visitors also had the opportunityto go on an underground tour,compliments of Vale.

Participants provided feedbackon the Open House. Almost 97%of all participants gave the Open House a score of 8 and higher (scale of 1-10 range) whenasked how informative they found the Open House. Some suggestions for topics for the 2020Open House from attendees, included:

• Vale global operations• New technologies• New projects• Future of the Superstack Stack demolition• More interactive activities

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Photos from the September Open House are provided below.

James Hodgson Photography James Hodgson PhotographyStudent listens to a Vale Environment Future Vale employee in the making showing anAdvisor speak about her project early interest in mining exploration!

James Hodgson Photography James Hodgson PhotographyStudents from Rainbow District School Board learn Vale’s subject matter experts bring poster contentmore about Vale’s operations. to life by answering questions and providing

explanations.

3 Community Air Quality Monitoring

3.1 Sulphur Dioxide

There are 18 fixed continuous SO2 monitoring stations located in the community, owned by Valeand Sudbury Integrated Nickel Operations, a Glencore Company and operated and maintainedby BESTECH Ltd. In addition, the network includes the operation of three meteorological towersand Vale’s mobile SO2 monitoring unit. A map indicating the location of the stations is provided(see figure 1).

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In addition to the real-time monitoring data, quarterly and annual reports of SO2 concentrationsmeasured at the fixed stations were compiled and reported by an independent consultant andsubmitted to the MECP. The reports are posted on the Vale website on a quarterly basis.

Vale has significantly reduced the emissions of SO2 from its Sudbury area operations with theimplementation of several process changes over the years. Improved milling techniques haveremoved more sulphides from the ore before it reaches the Smelter. Sulphur dioxide gas iscaptured from several different areas in the facility and processed at the Acid Plant to producemarketable sulphur products. In 2017, the Smelter Complex transitioned to a single furnaceoperation and two older converters were decommissioned. Beginning in 2018, sulphur dioxidegases from the converter aisle began to be treated in the new Converter Wet Gas CleaningPlant and the Acid Plant, which further reduced the emissions from the Superstack to theenvironment. Since January 2019, the converter aisle was completely disconnected from theSuperstack such that the only emissions from the Superstack are from periodic furnace androaster maintenance operations.

Figure 1: Sudbury SO2 Monitoring Network

Results from the monitoring network indicate that annual mean SO2 concentrations were wellbelow the annual AAQC of 20 ppb SO2 in 2019 at all stations. The highest annual average for

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2019, at any of the Vale stations, was measured at the Union Street station. This shows animprovement over levels that were already low in 2018.

Low SO2 concentrations were measured at all stations during 2019; all stations were calculatedto have annual arithmetic mean concentrations that were less than 2 ppb SO2; with measuredvalues at all Vale stations aligned with or less than 2018 values (see Figure 2).

Note: Vale stations highlighted in grey.Figure 2: SO2 Annual Mean Concentrations: All Stations 2017 to 2019

There were no exceedances of the 1-hour SO2 Ontario Regulation 419 standard of 250 ppb in2019 measured at the SO2 monitoring stations. The highest maximum 1-hour SO2 measured in2019 at any of the Vale stations was measured at the Union Street station, at 150 ppb. Thegraph below shows the 2017 to 2019 maximum 1-hour SO2 concentrations for all the stations.

The maximum 1-hour values for each station (presented in Figure 3) also exhibit a downwardtrend, with significantly lower maximum 1-hr SO2 concentrations than in previous years forVale’s stations.

The graph below provides a summary of the 2017, 2018 and 2019 hourly (clock) maximum andmean SO2 values.

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Note: Vale stations highlighted in grey.Figure 3: SO2 Maximum 1-hour and Annual Mean Concentrations

3.2 Nickel

Vale’s particulate sampling network operates on concurrent 3-day or 6-day sampling schedules,with 9 stations operating monitors that collect particulate matter on filters over a 24-hour period.The filters were sent to an independent lab/consultant for gravimetric and metals analyses andreporting in 2019.

Quarterly reports are posted on the Vale website as they become available (several months lagtime required for filter and data analysis). A map showing the location of the monitoring stationsis provided below. The map shows 9 stations, including the newest station at Fielding Road,installed in the summer of 2017.

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Figure 4: Vale’s particulate sampling network

In 2019, the following nickel standards were in effect:

· 24-hr Upper Risk Threshold (URT) of 2 µg/m3 nickel.· Annual average standard of 0.04 µg/m3 for Fielding Road monitoring station.· Annual average standard of 1.0 µg/m3 for the remaining monitoring stations as per the

site-specific standard in effect until December 2021.

In addition, there is a 24-hour standard for Total Suspended Particulate of 120 µg/m3. Therewere no nickel exceedances or TSP exceedances (attributed to Vale operations) measured in2019 at any of our monitoring stations.

Nickel monitoring data for 2017, 2018 and 2019 for the 9 air quality monitoring stations arepresented in the two graphs that follow. The most recent and historical detailed monitoringresults for these and other metals measured at these stations are posted on the Vale website.

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Figure 5: 24-hour Measured Nickel in TSP – all stations 2017 to 2019

Note: The Fielding Road station is not included in the nickel Site-specific Standard (SSS) for the Copper Cliff Smelter and assuch fall under the Ontario annual standard limit of 0.04µg/m3.Figure 6: Annual averaged Nickel concentrations – all stations 2017 to 2019

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4 Emissions Reduction Program Update

Vale’s Emissions Reduction Program (ERP) has always been a significant contributor to thecompany’s positive SO2 emissions performance. The program has been evolving and adaptingto operational changes to ensure compliance to the Environmental Compliance Approval (ECA).Even though the Smelter superstack is no longer seen as a significant source of SO2 emissions,the Emission Reduction Program (ERP) continues to be implemented. The ERP program wasextensively restructured in 2019 to align with operational changes but the purpose of the ERPstill is to predict and monitor dispersion conditions and to manage possible impacts that couldresult in elevated ambient SO2 ground level concentrations of sulphur dioxide in the communityattributed to Vale sources. The ERP operators remain available 24 hours per day, 7 days aweek.

5 Environmental Community Concerns

The Smelter ECA and Nickel Site-Specific Standard Approvals require Vale to make a telephonenumber available to the public to register environmental complaints and requires all complaintsbe documented and followed up. Vale has had a process in place to address communityconcerns for many years. For the Smelter, there is a telephone number, 705-682-8283, that isanswered by a Smelter employee 24 hours per day, 7 days per week. Vale also has a generalcommunity concerns line at 705-222-VALE that is also answered 24 hours per day, 7 days aweek by an answering service; Vale employees respond to the concerns received on this linewithin 48 hours.

The Smelter Environmental Concerns Summaries for 2017, 2018 and 2019 are presented in thefollowing graph. There was a total of 57 community concerns logged in 2019, compared to 76in 2018 and 78 in 2017. The figure below depicts the number of complaints received per annum,categorized by type.

It is important to note that the decreasing trend in the number of complaints received continuedin 2019, with lower totals in multiple categories. There was however an increase in the numberof “other” complaints received i.e. most of these associated with odour complaints not attributedto the Fluid Bed Dryers.

The number of “Fluid Bed Dryer Odour” calls were comparable to the previous years. TheAction Plan which was developed and shared with the MECP in December of 2017, to addressodour concerns continued to be implemented throughout 2019. The Plan involves dedicatedcommunity odour patrols on nights when easterly winds are predicted with cut-back of feeddrying rates when any odour is detected as well as precautionary cutbacks of feed drying ratesunder specific meteorological conditions.

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Figure 7: Vale Smelter Environmental Concerns Summary for 2017 to 2019

The tie-in of the FBD stack to the taller 450’stack in October 2019 has seen a marked decreasein the number of odour complaints and the instances when odour was reported by the variouspatrollers in Little Italy. For the near future the implementation of the FBD odour protocol willcontinue to monitor if operational changes have a positive impact on the odour observed.

When community concern calls are received, they are routed to the appropriate department andthe caller is contacted directly by a subject matter expert from Vale. A complaint log form isfilled out that records the date, time, name, address and phone number of the person, alongwith 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 receivingthe complaint, the following information is entered in 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 ECA requires Vale to keep the complaint records on file for seven years, and tosubmit quarterly reports to the MECP summarizing the information about the complaints,

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including follow-up details. This information was submitted to the MECP in Q1, Q2, Q3 and Q4of 2019.

Feedback on community concerns is also actively sought and logged at Vale’s annual OpenHouse and through its annual Report to the Community. The company invites the public toexpress their concerns through a variety of methods (phone lines, email, feedback forms and inperson).

6 Action Plan Updates

The site-specific standards (SSSs) for SO2 expired on June 30, 2018. All items in theassociated Action Plan are now complete, most significantly the capture and treatment ofconverter off gases.

As part of its submission for site-specific standards for nickel, Vale submitted an Action Plan tothe MECP to reduce its overall emissions and ground level concentrations in the community.This Action Plan 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 andSeptember. The updates are posted on Vale’s website at:

http://www.vale.com/canada/EN/aboutvale/communities/sudbury/sudbury-environment/environmental-reporting-sudbury/air-quality-monitoring-results/Pages/default.aspx

6.1 SO2 Compliance

· With the completion of the Clean AER Project, which was an investment of over 1 billiondollars (specifically diverting the converter off gas to the Acid Plant), the Smelter nowmeets the current provincial 1hr SO2 standard of 690µg/m³, both modelled andmeasured.

· Effective mid-2023, the Ministry of Environment, Conservation and Parks (MECP) willreduce the 1hr SO2 standard to 100µg/m³ (40ppb).

· Over the past year, Vale and Glencore have been working with the MECP to develop anIndustry Technical Standard to provide an alternative compliance mechanism to the new1hr SO2 standard for the Vale Smelter, the Vale Nickel Refinery and the GlencoreSmelter.

6.2 Nickel

· Two nickel Site-specific Standard (SSS) approvals were issued for the Smelter by theMinistry of Environment, Conservation and Parks (MECP) in 2011, each appended withan Action Plan.

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· As a condition of the SSS, Vale completed a Technology Benchmarking Report in 2019.The study determined that further road dust management controls, as well as buildingand equipment maintenance at the Furnace, FBR and Casting and Crushing Buildingscould further reduce the Smelter’s nickel impact in the community.

· Vale intends to submit a new application for a site-specific annual nickel standard for theSmelter September 30, 2020.

· Part of the SSS application process is public consultation, which will occur at Vale’sannual Open House in mid-September.

· Fugitive Dust management practices at the Smelter continued as per requirements setout in the Fugitive Dust Management Practices manual (updated annually and submittedto MECP every spring).

· Smelter Material Handling Relocation Project• Detailed engineering (FEL3) will be completed by Q1 2020• Construction will follow and is scheduled to be complete by March 2021.• Project scope includes:

• New Material Handling Facility at North Mine.• Moving Reverts Handling activities and vacuumed materials handling

to the new facility at North Mine.• Converter scrap handling will remain at the Smelter Property, but at

a distance over 1km from the community.• Changes to trucking routes, road cleaning operations/schedules will

be adjusted accordingly.

Figure 8: Relative location of current material handling at Smelter to be relocatedto North Mine

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6.3 Clean AER

The Clean AER Project is now complete. The converter off gas collection system and converterwet gas cleaning plant have been operating without major issues since startup, which haseffectively reduced Vale’s Sudbury SO2 emissions from +150,000 tonnes annually to15,055 tonnes in 2019.

The Secondary Baghouse experienced blinding issues upon startup in 2018 but was fitted witha lime injection system and new bags in 2019 and has been operating without major issuessince.

Ongoing operational observations, modifications and improvements to SO2 emissions and itscontrol equipment are integral to Vale’s Sudbury Operations.

6.4 Superstack Update

· Historically the dominant source of the plume from the Superstack was from converterblowing operations. With the completion of the Clean AER Project, there are no longerany converter off-gases reporting to the Superstack.

· The only plume from the Superstack is from maintenance work on the furnace and fluidbed roasters.

· In 2020, these two streams will be diverted to the 450' Stacks and at that point theSuperstack will no longer emit as it will be physically blanked off from any source ofemissions.

· Note however, there will be a ramp-up / testing period during which tie-ing the FBRbypass back into the Super Stack may be deemed temporarily necessary – this is toensure the safety of Vale’s workers and minimal impact to the community.

· Once the two new stacks are commissioned, the Superstack liner will be removedDemolition of the concrete liner will follow in a carefully controlled manner in subsequentyears.

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Figure 9: Smelter Skyline: Before and After

Figure 10: Smelter Processes Reporting to Tall Stacks - Early 2018

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Figure 11: Smelter Processes Reporting to Tall Stacks - August 2018 to Present

Figure 12: Smelter Processes Reporting to Tall Stacks - Post 2020 Shut Down

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6.5 450' Stacks Update

Construction is now substantially complete on the two new 450' stacks. Because the majorityof the Superstack plume was diverted through the new Wet Gas Cleaning Plant and onward tothe Acid Plant, these stacks are not direct replacements for the Superstack. They consist (seeFigure 13 ) of:

1. 450' Fluid Bed Dryer (FBD) and Flash Furnace Stack, two separate liners for:• the constant emissions from the FBD (tie-in occurred on October 2019)• the periodic emissions from maintenance on the furnace (tie-in to occur in the

July 2020 PMP)•

2. 450' Secondary Baghouse & Fluid Bed Roaster Stack, two separate liners for:• the constant emissions from the Secondary Baghouse – the Secondary

Baghouse filters fugitive (secondary) off-gases from the furnace and converters,as well as the converter nitrogen blows (tie-in to occur in the July 2020 PMP)

• the periodic emissions from maintenance on the fluid bed roasters (tie-in to occurin the July 2020 PMP, however, to protect worker safety and prevent any impactin the community, the ability to tie-back into the Super Stack will remain duringthe subsequent ramp-up/testing period)

Figure 13: New 450’ Stacks Cement Shells & Two Steel Liners

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7 Contact Info

For more information or to discuss this report, contact Gary Remington, Superintendent –Environment, Ontario Operations, Vale Canada Limited at: [email protected] or 705-682-6866.

2019 environment management system community engagement report

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