2012 Environment Management System & Community Engagement Report

Transcription

1 2012 Environment Management System & Community Engagement Report March 18, 2013

2 Table of Contents 1. Background 2. Communications and Community Engagement 3. Community Air Quality Monitoring 4. Environmental Community Concerns / Complaints 5. Action Plan Updates Appendices 1. EMT Communications Plan 2. EMT Meeting Minutes 3. Emissions Reductions 4. Complaints Procedure 5. Community Complaints 6. Action Plan Updates

3 1.0 Background The Vale Smelter in Copper Cliff has a number of air- related approvals from the Ministry of Environment: Environmental Compliance Approval # QPT8 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 Each of these required the formation of an Environmental Monitoring Team (EMT) with representation from the community, the Ministry of Environment 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, and analysis of monitoring data, and the need for any new or amended Ministry Approvals. The group was formed by inviting members of an existing community stakeholder group, the Copper Cliff Liaison Committee (CCLC), which includes representation from the Ministry of Environment, 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 Environmental Monitoring Team and the communications activities undertaken by Vale in Communications and Community Engagement The Environmental Monitoring Team (EMT) formed a communications sub-committee to develop the communications plan found in Appendix 1. The sub-committee met April 3 rd, May 16 th, June 26 th and October 1 st to discuss the plan and communication initiatives. The communications plan was presented to the broader EMT group on November 22 nd, Minutes of those meetings have been included in Appendix 2. The communication plan includes context for the plan, a strategic approach and details on existing and new communication channels to be leveraged. Some of the communication channels that are detailed in the plan are: A new sustainability website The Clean AER Project website and video The new Report to Community (planned for 2013) Air monitoring station signage Walking tours of regreened areas Annual Open House Vale s Community Concerns Line Meetings with community groups

4 Execution of the communication plan will primarily occur in However, public feedback on the beta version of Vale s new website, was gathered at Vale s annual Open House in October The website went live in December As per the site specific standard approval requirements, the website includes: Semi-annual progress reports on implementation of the Action Plan and any additional actions undertaken as a result of the Root Cause Analysis and Pollution Abatement Report Semi-annual reports, submitted June 30 th and December 31 st that summarize 24- hour average ambient concentration measurements of nickel and cobalt; The postings are accompanied by an explanation to guide the public reader to understanding the reported information. The website also includes information about Vale in the community as well as information about the Company s water, air quality, reclamation and decommissioning management activities. Vale s annual Open House was attended by over 100 local residents in October It provided an opportunity for Vale to provide updates about Vale s air monitoring network, the Clean AER Project and Vale s Action Plan for the site-specific standard approval for SO 2. Information on other environmental initiatives such as regreening, water management and dust control was also provided to the community for feedback. 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 Xstrata Nickel, and operated and maintained by Bestech Ltd. In addition, the network includes the operation of 2 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. Quarterly and annual reports of SO 2 concentrations measured at the fixed stations are compiled and reported by an independent consultant. The 2012 SO 2 reports are posted on the Vale sustainability website ( as soon as they become available from the consultant. Very low SO 2 levels were measured for the majority of the year, with hourly and daily averages measured to be well below the MOE limits in all but one instance. There were no exceedances of the 1-hour SO 2 Measured Level above which, Trigger Action limit of 340 ppb, or the 24-hour provincial air quality standard of 100 ppb in There was one instance when the 1-hour SO 2 provincial air quality standard of 250 ppb was exceeded (259 ppb, at the Copper Cliff station in March), but this limit does not come into force until 2017, as stated in the Site Specific Standard Approval.

5 Vale has historically met reduced sulphur dioxide 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 presented in Appendix 3. Nickel / Cobalt Vale s particulate sampling network of 8 monitoring stations operates on a concurrent 3- 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 away to a lab for metals analysis. The operation of the monitoring network, lab analyses and reporting of the results is done by an independent consultant. Quarterly reports are posted on the Vale website as they become available (lag time for filter and data analysis). There was only one exceedance measured in 2012, and that was for the 24-hour Upper Risk Threshold (URT) limit of 2.0 ug/m 3 for nickel on August 10 th at the Venice Street station (2.2 ug/m 3 was measured). Appropriate action was taken and reported to the MOE. Provincial Air Quality standards for all of the other metals were met at all other times of the year, including the nickel 24-hour site-specific standard of 15 ug/m 3 and the levels above which trigger action for nickel and cobalt (3.0 ug/m 3 nickel, 1.2 ug/m 3 cobalt). 4.0 Environmental Community Concerns / Complaints The Environmental Compliance Approval and Nickel Site-Specific Standard Approval require Vale to make a telephone number available to the public to register environmental complaints. All complaints must be documented and followed up. Vale has had telephone numbers and a process to address community concerns for many years. For the Smelter, specifically, there is a telephone number, , that is answered by a Smelter person 24 hours per day, 7 days per week to receive and address concerns. The procedure for addressing complaints is presented in Appendix 4. The complaints received in 2012 are summarized in Appendix 5. Beginning in 2013, the Smelter s Environmental Compliance Approval requires Vale to submit a quarterly summary report to the Ministry of Environment, detailing all of the complaints received in the quarter and the follow-up on each complaint. This report will be available to the public during normal business hours, by contacting Monika Greenfield at (705) Action Plan Updates As part of its submission for site-specific standards for nickel and sulphur dioxide Vale submitted action plans to reduce its overall emissions and ground level concentrations in the community. These action plans became conditions and were appended to the sitespecific standard approvals. Vale prepares a report to update the status of its action plans semi-annually, in March and November. The March 2013 updates are attached in Appendix 6. The updates are also posted on Vale s website:

6 Appendix 1. EMT Communications Plan

7 Environmental Monitoring Team Communications Plan October 2012

8 INTRODUCTION On December 28, 2011, the Ontario Ministry of the Environment issued a Nickel Site-Specific Air Standard Approval to the Vale Copper Cliff Smelter Complex (reference no L3QLF). The Approval included a number of conditions that Vale must meet. One of these conditions included the establishment of an Environmental Monitoring Team (EMT). The EMT is comprised of a Vale representative, a representative of the Ministry of the Environment, and up to 3 representatives from the communities of Copper Cliff and/or Gatchell. They meet at least twice a year to review and discuss environmental monitoring results and initiatives and help to communicate that activity to the public. PURPOSE The purpose of this communication plan is to detail the methods by which Vale will inform and engage the public about its progress in meeting the requirements of its Nickel Site-Specific Air Standard Approval. COMMUNICATION OBJECTIVES Inform the public about Vale s Action Plan for its nickel site-specific air standard approval Make information about Vale s environmental performance and initiatives more accessible to the public Build a sense of community pride in the Clean AER Project STRATEGY The strategic approach will be proactive, transparent and timely communications that continually emphasize the environmental and economic benefits of Vale s action plan to meet the requirements of its Nickel Site-Specific Air Standard Approval. Emphasis will be placed on the Clean AER Project. It is a positive story on all fronts from cleaner air to ongoing sustainability of Vale s North Atlantic operations to the largest environmental investment the local economy has ever seen. Reports on Vale s environmental performance will also be much more accessible through some of the new communication tools that are being developed as part of this communication plan (see communication channels below).

9 EXISTING COMMUNICATION CHANNELS Annual Open House events: Vale hosts annual Open House events in the Fall of each year to communicate pertinent information to the community, including environmental performance, and to solicit feedback from residents of Greater Sudbury. The entire community of Sudbury is invited to attend. These events will continue to be helpful in communicating Vale s Action Plan for its nickel site-specific air standard approval and the benefits of the Clean AER Project. It is also an excellent venue to showcase new communication tools such as websites, reports and newsletters. Public meetings: Public meetings are held as required to deliver information to stakeholders on issues of interest. It is expected that public meetings will need to be held in Copper Cliff with more frequency during peak construction periods of the Clean AER Project. Community Concern Lines: Vale s Community Concerns Lines are an excellent way for the community to provide feedback about our operations and suggestions for improvement, via direct interaction with Vale employees. (222-VALE): Vale has a community concerns line to receive concerns from the community 24/7, to be responded to within 1 business day. A fully developed internal protocol with assigned contacts has been developed to manage this process. ( ): This concerns line is specifically related to emissions concerns from the Smelter Complex. It is manned 24/7 by Smelter personnel to deal with immediately with issues. Bi-monthly Copper Cliff Liaison Committee (CCLC) meetings: The CCLC is a committee that is empowered to provide Vale with public input on how our business should be improved to better reflect the needs and priorities of the community of Copper Cliff. The Ministry of the Environment, through local representation, is a regular participant in this meeting. The Liaison Committee will continue to be important point of community contact and feedback mechanism on environmental monitoring and initiatives. The EMT includes community members from this committee as well as members representing Gatchell. Copper Cliff Community Action Network (CAN): Vale participates in monthly Copper Cliff CAN meetings to communicate pertinent information and assist on community improvement initiatives. Representatives from the City of Greater Sudbury, including the local Councilor, are regular members of the committee. One member of the EMT is also a member of this group. The Copper Cliff CAN is another important point of community contact and feedback mechanism for the Company. Annual speech through the Greater Sudbury Chamber of Commerce: The General Manager of the Ontario Operations delivers an annual speech to outline the Company s key priorities in Sudbury. This speech always attracts Sudbury s key stakeholders and tremendous media interest, and will be an important means of delivering high level messages about the benefits of the Clean AER Project. Boards & Committees: Vale s Sudbury operations leadership and key employees participate in a wide variety of local, provincial and national committees and boards to

10 interface with key stakeholders and advance business objectives. These boards and committees, such as the Greater Sudbury Chamber of Commerce and the Greater Sudbury Climate Change Consortium, will continue to provide opportunities to communicate Vale s Action Plan for its nickel site-specific air standard approval and the benefits of the Clean AER Project. Face-to-Face Meetings: Vale representatives meet with key stakeholders on a regular basis, whether it is local business leaders or association representatives such as the Sudbury Area Mining Supply and Service Sector Association (SAMSSA). These meetings will continue to be an excellent opportunity to build third party advocacy for Vale s environmental initiatives and communicate developments in Vale s environmental initiatives. Media Relations: Vale engages in frequent media relations in Sudbury, both proactively and reactively. The company will continue to provide updates to the media about the progress of the Clean AER Project as well as other aspects of the Company s site-specific standard approval action plan. Vale will also inform the media of the new communication vehicles the Company is developing (see below). Copper Cliff Newsletters: Newsletters are sent to residents in Copper Cliff to update them on various initiatives at the Company. While these newsletters aren t sent frequently now, it is recommended that newsletters be sent to the community at least bi-annually to provide updates with respect to the Clean AER Project and other local environmental initiatives. Vale Air Quality Website: ( Vale maintains this website to communicate ground level sulphur dioxide emissions in real-time. It also contains an address and Smelter Emissions Air Quality Complaints Line to receive concerns from the public. NEW COMMUNICATION CHANNELS Clean AER Project video: This 5 minute video provides an overview of the project in a way that is simple and easy to understand. It includes a number of community leaders talking about their support for the project and evokes a sense of community pride. It played at the start of every movie at a local theatre complex for during the month of July Vale s Clean AER Project Website: ( This recently launched website includes information about the project, including the environmental and economic benefits as well as supplier information such as recent contract awards, current and future contract opportunities and information about Vale s procurement process. Vale s Greater Sudbury Sustainability Website: ( This website is expected to launch in November of It communicates information about Vale s sustainability initiatives in Sudbury. It includes information about Vale in the community as well as information about the Company s water, air quality, reclamation and decommissioning management activities and reports. This website could be utilized to post additional information specific to the AER project. It will also contain the reporting of information required by the EMT.

11 Report to the Community: This new report is planned for the Spring of It will inform Greater Sudbury residents about the status of capital projects, environmental initiatives, community investments and safety performance. Air monitor station signage: These stations are located at various sites in the community surrounding Vale s Copper Cliff Smelter Complex and are often accessible to the public. This presents an excellent opportunity for signage to explain Vale s comprehensive SO 2 and particulate monitoring network as well as the Clean AER Project. Walking tours: It is recommended that Vale conduct public walking tours of regreened areas of its operations to further communicate the environmental improvements and investments it is making. REPORTING AND RESULTS MEASUREMENT Vale will report on community engagement activities that take place as a result of this communication plan in an annual Environmental Management System and Community Engagement Report. This report will also detail any environmental issues or concerns members of the local community may have had and how they have been addressed. Quantitative measurements can include: Increase/decrease of environmental concerns received from the company Website usage data Audience reach for media coverage, report to the community, newsletters, video, etc. Qualitative measurements can include: Tone analysis of recorded feedback (positive, negative, neutral) from residents at open houses and public meetings as well as feedback mechanisms built into websites, newsletters and the report to the community Tone analysis of media coverage

12 Appendix 2. EMT Meeting Minutes

13 Meeting #1 April 3 rd, 2012 Environmental Monitoring Team Meeting Minutes Frank Javor is identified as the Environmental Monitoring Team (EMT) Chairperson and welcomes everyone to the meeting. Frank asks everyone to introduce themselves. Attendees include: Frank Javor, Manager, Environment air, Vale Monika Greenfield, Senior Specialist, Environment air, Vale Tom Zanetti, Construction Manager, Clean AER Project, Vale Angie Robson, Manager, Corporate Affairs, Ontario Operations, Vale Danica Pagnutti, Corporate Affairs Specialist, Vale Ron Paolin, Senior Environmental Officer, Ministry of Environment Orville Hall, Copper Cliff Resident Wayne Manson, Copper Cliff Resident Margaret Julian, Copper Cliff Resident Colleen Zilio, Gatchell Resident and CAN Member Gerard Courtin, Gatchell Resident and CAN Member Frank reviews the agenda and the reason for the meeting with the group. He then asks Ron Paolin to provide further context for the EMT. Ron provides information about O. Reg. 419/05 and Vale s site-specific nickel air standard application. See presentation for further details. Following the presentation, Wayne Manson asks where the technical review experts came from. Ron explains it was challenging to obtain experts because some of the best experts in the world work for Vale. Ultimately, a consulting company from Detroit was chosen. Frank Javor then shares the application approval document with the group and provides a brief summary. He reviews the definitions of terms, conditions and requirements. See EMT requirements table document for details. Colleen asks about the location of particulate monitoring stations. She asks why the stations are located close to the smelter complex. She wonders if modeling has shown that these are the areas of highest concentration. Frank explains that unlike a gas like SO 2, particulate concentrations are higher closer to the source.

14 Frank explains that site-specific approvals are for a 10 year period. There are actually 2 documents, the first expiring in June, 2016 and the second expiring in December, This was required because in 2016 the nickel standard will change. Right now it s a 24 hr standard - 2 micrograms per cubic metre. By 2016, it s going to become an annual standard. Our site specific standard is currently 15 micrograms per cubic metre. In July 2015 when we complete the Clean AER Project, our site specific standard will drop 3 micrograms per cubic metre, still slightly above the standard of 2 micrograms per cubic metre. We re still working on that because, as you can imagine, modeling changes every time you change some parameters. We have a lot of design criteria but when we actually build the Clean AER Project and test all of the changes, we expect that some of the equipment, such as the new baghouses, we will be installing will perform much better than the specifications. Vale is hoping that we will be much closer to two micrograms per cubic metre by the end of Clean AER Project. In 2016, the standard drops to 0.04 micrograms per cubic metre on an annual basis. Right now our site specific standard is 1 microgram per cubic metre. We also think we will perform better than that. Annual standards are also new for the Ministry and the methodology for annual modeling is under discussion with Industry. Gerard asks, if you are looking at a standard that is 4% of the site specific standard, how would you expect to meet that? Frank explains that is the reason for the site-specific standard being 1 microgram per cubic metre. That is the number that Vale is required to meet. We believe we re going to do better than that. Franks says that in Ontario, the standards are always being set lower, getting closer and closer to zero. As a consequence, these standards, close to background levels when nothing is operating are getting much harder to achieve in older industrial settings. That will definitely be the next challenge. Tom Zanetti says the industry is struggling with the new standards. The technology is just not out there to achieve these standards. Vale is installing the best known current technology for the Clean AER Project. Frank explains that Ontario has among the strictest standards for air concentrations. The Ministry realizes that companies may not be able to meet these standards. That s why they ve created alternative compliance mechanisms such as the site-specific standard and technical standards (for some industry sectors, eg. pulp and paper industry). One member of the team asks if a technical standard is being worked on for the mining industry. Frank replies that the Ontario Mining Association is looking at

15 that with the Ministry but it s for mines only, not for smelters. There are very few smelters in Ontario and they are very different. Most of these technical standards were developed for industries where there are numerous similar plants, technologies and equipment. Frank goes on to explain that the reason for the condition of the EMT was sharing of information with the community. The way the clause reads (section 25 page 5), essentially they wanted to have three members from the community, some representatives from Vale and the MOE. Vale already had the Copper Cliff Community Liaison Committee so Wayne, Margaret and Orville are here as a sub-committee of that group to work on a communications plan. There are supposed to be at least semi-annual meeting of the EMT. There will be more in the beginning until we get things set up. As part of that communication we are to get updates on the results of the action plan, projects and studies. We are to hear how things are moving along and monitoring results. We are to develop a communication plan specific to nickel but we will probably expand that to include SO 2 as well. The plan might include newsletters, presentations, websites, open houses, etc. Vale wants to get your input on the best way to communicate with the public. We also have to prepare an annual environment management system and community engagement report. So that s how the EMT is defined in the approval and its particular function. The function is really to help the company best communicate with the public so that they know what s going on and how we re moving ahead. That s part of the Ministry requirement they want everything to be transparent. So, our proposal for this team was 3-5 Vale representatives, members of the Copper Cliff Liaison Committee and two members of the Gatchell community and a MOE representative. Initially, we plan to have an EMT update as a formal, standing agenda item at every second Copper Cliff Liaison Committee meeting. Colleen says that from a citizen s perspective, she thinks the first question people will have is about how things may affect them where they live. She thinks they will want to see the modeling and the results of the data over the years to see what areas are affected. The second question will be that if someone is affected, how will this affect their health? For example, they will say: If there is nickel in my environment how does that impact my health? Ron Paolin says that if a citizen contacted him at the Ministry with those questions he would say that he would have to look at the monitoring results. From what he has seen in 2011 we don t have any impacts that would be of concern.

16 Hopefully, in the future, there will be something like a website that if people have a concern they can find out what the monitors are saying. Angie shares with the group what Vale is doing in terms of communication now on these topics. Angie explains that the company tries to be as inclusive as possible with the community. It s our responsibility to interface with the community, especially on major environmental projects such as the Clean AER Project. Angie provides an overview of existing communication channels and reviews Clean AER communications plan. She also reviews what items are to be developed with the group. See presentation for details. Wayne asks about dust impacts and Tom Zanetti and Frank Javor explain that there are dust management plans in place. Suggestions such as: third party endorsement to be included on website and the creation of a two minute video that explains the scope of the project are made by group members. Gerard says he presumes that Vale reclaims the particulates and they go back through the smelter. Tom explains that the design is to recycle the particulates and put them directly back into the furnaces. Tom also points out that Vale will also have new material handling facilities that should reduce particulate in the environment. A member of the team asks if workers will be present in those material handling facilities. Tom explains that there will be employees in those facilities and they will be equipped with appropriate personal protection equipment. Track out controls will also be in place. Orville asks how many baghouses will be in operation at one time after the completion of the Clean AER Project. Frank explains that there are 40 baghouses in the smelter now and Vale will be adding 13 more. Frank concludes the meeting by asking team members to think about the EMT and the group can work on items to be developed at the next meeting. He also asks members to check out Vale s air quality website at: The next EMT meeting will be Wednesday, May 16 th at 3:00 at the Copper Cliff Club.

17 Meeting #2 May 16 th, 2012 Environmental Monitoring Team Meeting Minutes Meeting Chair: Frank Javor, Manager, Environment Air, Vale Minutes Recorded by: Danica Pagnutti, Corporate Affairs Specialist, Vale Attendees include: Monika Greenfield Senior Specialist, Environment Air, Vale Ron Paolin Senior Environmental Officer, Ministry of Environment Orville Hall Resident Wayne Manson Resident Margaret Julian Resident Colleen Zilio Resident Gerard Courtin Resident Frank welcomes everyone and says the purpose of the meeting is to obtain detailed input from the group on how to best communicate with the public regarding Vale s SO 2 Action Plan and the communication requirements set out by the Ministry of Environment in Vale s site-specific air standard for SO 2. Frank displays Vale s Sudbury air quality website at: and shows the group the content that is available there. Frank indicates that a reporting section is planned where regular, required reports can be loaded to the site for the public to read. The company also plans to include information about Vale s local water management system. This would expand the scope of the website so it would likely be renamed Vale s Sudbury Sustainability Site or something to that effect. The new site will likely include a tab for SO 2 monitoring, a tab for water quality, a tab for biodiversity/reclamation and a tab for reporting so that people can easily find the information they are most interested in. The purpose of expanding the website is to make information more accessible to people around the world. Wayne Manson asks if Vale is considering posting dust monitoring reports. Frank says he brought along copies of Vale s annual and quarterly particulate monitoring reports. He is interested in hearing how much information from these reports the EMT thinks the public will be interested in. Frank explains that the company is required to post community nickel concentration data, but Vale

18 actually monitors several different elements and is intending to post those reports and make all of the information publicly available. Frank asks for feedback from the group on if the reports that Vale currently produces are in a format that the general public can understand. Ron Paolin asks if a map of particulate stations could be included on an existing map on the website. Frank suggests it would be better to include that information on a separate map because all of that information would be too busy to include in a singular map, with most of the stations being right around Copper Cliff. Frank also explains that the current map is from a supplier s independent system so it would be difficult to overlay information on their existing maps and systems. So Vale would prefer to have SO 2 and particulate monitoring shown separately. Wayne Manson says getting information to the public is difficult. The Internet is a great way to reach people but he expects the information may only reach 2,000-3,000 people in Sudbury, which isn t a lot but he expects there isn t much that can be done about that. Frank explains the website isn t the only way Vale plans to reach the public with this information. The company still plans to host its annual Open House where the information will be shared. The company has also talked about circulating a sustainability report in the community and that may be another opportunity to share the information. Danica clarifies that the report may actually be called a Report to the Community because a sustainability report is often much more in depth than what the company is currently planning to produce. This report will include interesting facts, figures and stories across Sudbury s operations. Danica suggests that Vale can do little copy pop-outs that say what kind of data can be found on the website and include a few interesting facts and figures. Frank reviews the EMT requirements with the group and notes that the first report for 2012 is due March 31 st, (See requirements document attached). Vale views the requirements as the minimum required but the company hopes to do even more. Frank explains that the communication plan is the first part of the requirements. He shows the group the annual technical report that Vale currently submits to the Ministry of Environment on particulate monitoring. He asks the group what they think of Vale posting the report on the website with some information about how to interpret the data. Wayne Manson says it s a good idea to have the information available and then people can decide if they want to look at it or not. He suggests that if someone

19 was doing a research project on the subject, the information could be of excellent value. However, the general public is unlikely to read it. Danica suggests that we could try posting different information and reports and have Vale s IT department track what information and documents are actually being viewed. In that way, we can track what is of value and what is not. If some items are not being viewed and developing them is a drain on resources we can evaluate that after a certain period of time. Frank cautions that the annual report is a requirement so it would always be posted. He explains that the annual report does come with a simple executive summary at the front, which may be of greater value to the general public. Vale can also create an archive of annual reports on the website so that people can track data over time. Dr. Courtin suggests that the executive summary be extracted from the report and /or a graphical presentation of the data be posted on the website with a link to the entire report, so that people can download the level of detail that interests them. Frank will get sample graphical presentations of the data prepared for the next meeting. Danica is asked to lead the discussion on the communications plan. Danica asks the group to brainstorm and provide input on the communications plan. She says things that Vale will include in the plan are objectives, key messages, communications tools and tactics (as well as timelines) and how we will measure success. Danica also reviews with the group Vale communication tools/vehicles that are currently available to us such as the annual open house, community group participation (i.e. CAN groups, Clean Air Sudbury), PSA s, etc. Dr. Courtin advises that Vale should keep the information simple. People want to know is the air/water good for me or not? Colleen Zilio suggests that the air quality, or soon to be sustainability, website be optimized on Google. She can find it when she types Sudbury air quality but not when she types Clean AER Project. Ron Paolin says that the posting of quarterly reports would be helpful to respond to public inquiries as the public is looking for recent data and analysis. He also says the charts are useful and the transparency is appreciated by the public. Frank replies that is good feedback because the purpose of the EMT is to make things even more transparent. Colleen suggests that a great way to tell the Clean AER story clearly and succinctly would be to put a five minute video about it on the website.

20 One member of the team suggests a Clean Air Sudbury link be added to the website. Another team member suggests a glossary of terms and FAQ s would be helpful additions to the website. Wayne asks if Vale is planning to produce periodic reports about the Clean AER Project to the community. Danica says there are likely some reports planned. She will check with Angie and get back to the group with details. It is also suggested that a brochure be distributed to the public to explain the Clean AER Project. Another suggestion is to put up some outdoor signage to explain the project and SO 2 monitoring stations. Colleen says it s important to get people to want to be a part of the Clean AER Project. How about developing an interactive and informative display at Dynamic Earth and/or Science North about the project? Another team member suggests it will be important to gain service and supply sector support from area associations such as SAMSSA. Someone else suggests that Vale make a presentation at the CAN Summit. Colleen suggests that the Open House needs to be made more exciting. How about adding a bike/ride element to it? Perhaps partner with Rainbow Routes? She also suggests inviting students from the Gatchell public school to attend the Open House. The group then discusses timelines for the communication plan and it is determined that a draft should be developed by Corporate Affairs for the EMT to review at its September meeting (date TBD). Next meeting: June 26, 2012 from 3:00 4:00 pm at the Copper Cliff Club

21 Environmental Monitoring Team Meeting Minutes June 26, 2012 Attendees: Frank Javor, Manager, Environment air, Vale Tom Zanetti, Manager operations Rep and Ramp-up, Clean AER Project, Vale Marg Julian Orville Hall Dr. Gerard Courtin Danica Pagnutti 1. Particulate monitoring data for website to include: Map of monitoring station locations Photographs and explanation of how monitors work Glossary of terms simplification of industry terms Graphs of monitoring results with links to full quarterly reports to MOE Brief layperson s explanation of reports Frank shows a number of different chart options and asks for feedback on the various charts. Tom Zanetti says 24-hour limit display skews data to display a flat line. Dr. Courtin says the chart shows Vale is well below the 24 hour limit. Perhaps a preamble right on the graph would be useful. i.e. At no time were the levels above X amount. The images are powerful. He says Vale needs to clearly define the message it wants to get across. He also suggests that it s important to test the message on the average person to see if they understand. 2. Open House Danica provides an overview of the plans for the Open House in October (Oct ) 1-7 pm each day Inviting students from Copper Cliff and Gatchell schools Plan to provide nickel site-specific standard action plan update Will provide status of SO2 site-specific standard application Will have mobile SO2 monitoring unit at event May open up greenhouse to public Emergency preparedness display will include demonstration of SAFER system this year

22 Dr. Courtin suggests that Vale invite St. Francis students. Margaret Julian suggests that if the digital sign on the library is installed by that time, Vale should advertise the Open House there. Orville asks if there are plans to monitor the smell from the baghouse. Frank says there is a large capital project to install a monitor in the flue to the Fluid Bed Drier stack for that purpose in Margaret also says she would be interested in learning more about the Totten Mine IBA with Sagamok First Nation at the Open House. 3. CCLC Agenda The group also discussed the agenda for November CCLC/EMT meeting. It was decided that the agenda would include: Action plan progress/update Ni/Co monitoring report (including results of any investigations) Environmental complaints review Communications plan Website review Open discussion 4. Clean AER video Margaret says the video was really good and very professional. Dr. Courtin suggests that Vale put it on YouTube. He also suggests that we make it available to Peter Beckett s class at L.U. Mineral exploitation in the biosphere Tom also makes a suggestion to create a Dynamic Earth or Science North display. Danica says plans are just beginning to formulate around that and she invites the group to participate in a brainstorming session with Mia Boiridy, Executive Director, Dynamic Earth. Danica will let everyone know when and where the meeting will take place. Next meeting Wednesday, September 19 th at 3:00 4:30

23 Environmental Monitoring Team Meeting Minutes October 1, 2012 Attendees: Frank Javor, Manager, Environment Air, Vale Monika Greenfield, Senior Specialist, Environment Air, Vale Danica Pagnutti, Corporate Affairs Specialist, Vale Ron Paolin, Ministry of the Environment Colleen Zillio Orville Hall Wayne Manson 1. Website Overview Monika reviewed elements of the sustainability website that Vale is developing with the group and requested feedback. She indicated she would further develop the glossary of terms for the website and circulate to the group for feedback. Monika invited the group to share any feedback they have on the website with her or Frank. These can be submitted to them via . The website is under development and can be found at: Please contact Monika to obtain a username and password to view the site while it is under development. 2. Open House Danica provided an overview of planned activities for the Open House. She asked if any members of the EMT would like to attend. Ron and Wayne said they planned to attend. Danica indicated she would send an invitation to other members of the group. It was suggested that the Environmental Monitoring Team should be featured and/or represented at the Open House next year. 3. Environmental Monitoring Team Communications Plan Danica presented a draft communications plan to the group. Feedback on the communications plan was positive and supportive. Colleen suggested that public walking tours of regreened areas be added to the communications plan. Danica said that she would include that idea in the plan. Danica is to send the revised communications plan to the EMT for final approval by . Danica will present the final plan at the next meeting, which will be at the Copper Cliff Liaison Committee. 4. Next Meeting The next meeting will take place on Thursday, November 22 nd at 6 pm at the Copper Cliff Club. It will be part of the regular Copper Cliff Liaison Committee Meeting and will include the first report out on the items detailed in item 3 of our June 26, 2012 meeting minutes.

24 Excerpt from Nov. 22, 2012 Copper Cliff Liaison Committee Meeting where EMT business discussed Attendees: Community Martin Carey Orville Hall Wayne Manson Margaret Julian Don Taylor Tom White Ron Paolin Colleen Zilio Gerard Courtin Vale Angie Robson Manager, Corporate Affairs, Ontario Ops Dave Duncan Manager, Copper Cliff Mine Wayne Cassidy Chief Mine Engineer, Copper Cliff Mine Farid Malek Chief Engineer Drill and Blast Ken Clausen Structural Engineer Ray Tremblay Superintendent, Transportation Charles Arlauskis Superintendent, Oxygen Plant Monika Greenfield Senior Specialist, Environment - Air Tom Zanetti Construction Manager, Clean AER Project Gary Remington Senior Environment Specialist soil, water Randy Donato Tailings Engineer Danica Pagnutti Corporate Affairs Specialist

25 EMT Update Frank Javor Frank Javor provides context to the group about the purpose of the EMT and what information will be provided at future CCLC meetings. Frank provides an action plan progress update and Tom Zanetti provides an update on key communication activities for the Clean AER project. Tom explains the Clean AER Project schedule has been adjusted to better manage project risk and address cash flow constraints. The end result will mean that the Clean AER Project will be completed in 2016 instead of the end of Tom provides details on current project activities and planned activities for Tom White asks about tie-ins and asks if they are related to the blow off at the smelter. Tom White asks when the new the blowers will be installed. Tom Zanetti explains that by the end of 2015 a new substation will be fully installed and commissioned to rectify the blow off situation. Frank goes on to explain where Vale has air monitoring stations and shares the monitoring results with the group. The monitoring report and data will be posted on Vale s new sustainability website quarterly along with a glossary of terms. Wayne Manson wonders why copper levels are so much lower than nickel. Frank Javor says that has been the case historically. Tom White asks about Balsam Bridge along the highway. He says nothing grows there and wonders if Vale can put an air monitoring station there. Monika says Vale tries to locate them near residential areas. Tom says regardless, it s a low lying area and he expects there would be higher concentrations there. He suggests a temporary monitor to investigate. Dr. Courtin suggests consulting with VETAC and Dr. Beckett because the lack of vegetation in that area could be soil related but might not be related to fugitive emissions. Frank says he can bring that idea to Lisa Lanteigne for her reclamation team to consider. A new monitoring station has been installed on Union Street, which is beginning operations this week. This continuous monitor will be used in a monitoring study in an attempt to identify causes for any periodic measured exceedences of nickel and the significance of any exceedences in conjunction with the results of fine particulate monitoring.

26 Frank shows a chart illustrating the nature of complaints Vale has received this year. Frank explains that every complaint is responded to and action taken where applicable. Orville Hall asks if the mobile unit runs 24/7. Frank explains that it is in operation 7 days a week during day-time hours. Frank also tells Orville there is now an SO 2 monitor in Little Italy. Colleen asks if there are plans to put SO 2 monitors at all of the monitoring stations. Frank explains there are 17 SO 2 monitors between Vale and Xstrata at various locations across the City. Danica takes the group through the communications plan. Monika takes the group through the new sustainability website. The website is expected to go live before the end of Tom White asks if there is an address to send complaints. Monika shows the contact us page, which includes an address. Margaret says she can see a lot of work has gone into the website.

27 Appendix 3. Emissions Reductions

28 Vale has historically met improved annual emission targets and has achieved significant SO 2 reductions over the years 5 Historical SO2 Emissions & Limits Reductions projects and initiatives: 2,500 2,000 Emissions Limit 1 1. Coniston smelter closed and super stack built 2. Mill upgrades - pyrrhotite rejection 3. SO 2 Acid Plant #1 4. Fluid Bed Roaster Gas Capture 5. AER Project Kilotonnes of SO 2 1,500 1,000 2 Note: are forecast data Year

29 Appendix 4. Complaints Procedure

30 Responsible Person: Frank Javor (Environment) Target Audience: Operating Management and Supervision, Environment, Corporate Affairs Training Code: Not Applicable Key words: complaint, log Revision # DATE NATURE OF CHANGE PAGE INSERTED, REPLACED, REVISED OR CANCELLED R1 March 6, 2013 Log circulation update Section 5.4 and Appendix 1 circulation updated Communication of Document: Please indicate ONE of the following: Communication as per Communication Matrix Communication Not Required. Please indicate reasoning: Other (please specify): Operating and Services General Managers and Managers, Corporate Affairs, Environment Department Authorization of Updated Document: Procedure for Receiving and Responding to Community Complaints (Environment) Reviewed By (Print Name): Frank Javor Responsible Person (Print Name): Frank Javor Responsible Person (Signature): Date: March 6, 2013

31 Responsible Person: Frank Javor (Environment) Target Audience: Operating Management and Supervision, Environment, Corporate Affairs Training Code: Not Applicable Key words: complaint, log 1. PURPOSE To establish a formal methodology to log, follow up and respond to community environmental complaints. 2. SCOPE This procedure applies to all Sudbury Operations, Services and Support departments. 3. REFERENCES SHE MS 9: SHE Management System Specification - Communication Specific Facility Environmental Compliance Approvals and Permits 4. DEFINITIONS Complaint: In this context, a complaint is a notification received about an environmental concern related to Vale operations from a person external to Vale government official, member of the public, Non-governmental organization, etc. It does not include concerns initiated by Vale employees or contractors while working for Vale. 5. COMPLAINTS METHODOLOGY 5.1 Complaint Receipt From time to time, complaints are received from the public in regards to Vale Operations. In order to be responsive to community concerns, Vale has established a number of routes by which public concerns can be directed for investigation and follow up. The following contact numbers are contained in the Sudbury Phone Book: 24hr. Community Concerns Line ( answering service records information and sends to designated areas for follow up) Smelter Emissions Reporting Line ( hr. manned by either ERP Operator in daytime or Copper DCS Control Room Operator at night) Information regarding the complaints as received on these lines is directed to the operating area where the issue is believed to originate. Occasionally, complaints are received via other routes such as the Ministry of Environment, Vale Plant Security Offices or via other phone lines. Complaints received in this manner are to be directed to the operating area for follow up.

32 5.2 Complaint Response It is the responsibility of the operating area who receives a complaint notification to follow up on the complaint in a timely manner and to resolve any operating issues that may be identified as requiring remediation. This follow up includes contacting the complainant to inform them of the situation. Environment will assist, as appropriate in the situation, in consultation with the operating area. 5.3 Complaint Tracking Our mine and plant Environmental Compliance Approvals (ECA), and terms and conditions of other plans and permits, require that a procedure be in place for receiving and following up on public complaints, with records to be kept in this regard. Information to be recorded includes: 5.4 Complaint Log Form - Contact information for the complainant; - Contact information for the person responding to the complaint; - Nature of the complaint, including the specific time(s), duration and quantitative/qualitative description of any occurrences that gave rise to the complaint; - Wind Direction; - Actions taken to determine the cause of the complaint, and the result; - What corrective measures, if any, were taken to alleviate the cause and prevent its recurrence; and - Follow up with the complainant. The attached Complaint Log Form is to be utilized where a suitable established alternative complaint tracking system does not exist for the purposes of recording and reviewing information about complaints received (examples would be the Smelter Emission Reduction Program Manual, the Spanish/Vermilion Rivers Water Management Plan, vegetation claims management). The completed form shall be forwarded to the area s environmental department contact (refer to Service Level Agreement), with a copy to the Safety, Health and Environment administrator. The Environment Department will keep the official record for all facilities and make them available to the Ministry. 5.5 Complaints Originating as the Result of a Potential Non-Compliance Situation If, during the complaint follow up, operations personnel discover a potential environmental noncompliance situation they should follow the applicable procedures, such as those contained in the facility s Spill Prevention and Contingency Plan, and notify the Environment On-Call. If a spill or discharge is confirmed a SAF-079 must also be initiated. 5.6 Complaints Resulting from Contractor or Other Activity on Vale Property If, during the course of the follow up to the complaint, it is discovered that the potential cause of the complaint originates with a contractor or other entity conducting approved business on Vale property, then a supervisor of that entity/activity shall be contacted by the relevant Vale operating area to implement the follow up. The follow up shall be monitored and logged by the Vale operating area. Unapproved activity and trespassers on Vale property should be reported to Plant Protection.