Environment, Ontario Operations SUBJECT WASTE MANAGEMENT. Training Code: Document Owner: ENVIRONMENT DEPARTMENT

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1 Page 1 of 10 Document Owner: ENVIRONMENT DEPARTMENT Intended Users: Operational Areas within Sudbury Operations Training Code: Approved By: SENIOR SPECIALIST, ENVIRONMENT Version Control Revision Date Description of Changes Next Revision Date 00 01/04/ /04/ /06/2011 Names added to Authorization of File section 02 27/07/ Year Review 27/07/2015 Authorization of File Drafted By (print name): _Lyse Provencal Approved By (print name): _Gary Remington Approved By (signature):

2 Page 2 of CONTEXT: Regulation 347 defines subject waste as liquid industrial waste or hazardous waste. At Vale s Sudbury operations, a number of waste generated fall into this category. A few examples are but not limited to: waste oil, sludges, contaminated soil, tank cleanings and weak acid. The management of subject waste involves a number of processes that ensure regulatory requirements are met. Site personnel are responsible for managing all waste including subject waste, but in order to do so require the knowledge and understanding of what steps they must take to properly dispose of the waste. Furthermore, at Vale s Sudbury operations, certain subject wastes are permitted to be disposed of in the Copper Cliff Tailings Waste Management Facility. This is a benefit in terms of expediting timely disposal, but it also requires additional measures be put in place to ensure disposal is being done in accordance with Certificate of Approval requirements. 2. PURPOSE: Provide instructions to site personnel disposing of subject waste in order to fulfil all regulatory requirements 3. SCOPE: This procedure applies to all Sudbury operating facilities generating subject wastes and covers all aspects of subject waste management including handling, storage, classifying, manifesting and disposal. 4. LEGAL: Refer to Ontario Regulation 347 and to Certificate of Approval number PLRTW. 5. ONSITE STORAGE OF SUBJECT WASTE: Environmental protection measures need to be provided for all new and existing subject waste, chemical storage, and temporary hazardous waste storage areas; and for the replacement or reconstruction of existing facilities to prevent the uncontrolled release of materials into the environment. Refer to Appendix A for the detailed requirements to properly store subject waste onsite. 6. CLASSIFYING SUBJECT WASTE: Prior to disposal; no matter where the waste is being transported to, a subject waste must be classified as per Regulation 347. Classifying a subject waste is a coordinated effort between the site person and Environment Soil and Water where an exchange of specific information on the waste occurs to determine the waste classification. The following are the responsibilities of the site person and the Waste Material Program Coordinator (WMPC). The Site Person shall: Contact the WMPC to see if the waste has been previously classified Gather all necessary information if requested by the WMPC

3 Page 3 of 10 Collect sample as per WMPC instructions and send to laboratory for the analysis requested by the WMPC. Provide all required information and results to the WMPC Make sure that an authorized person signs the manifest on the day of shipment. Ensure waste is stored and labeled as per Appendix A The Waste Material Program Coordinator (WMPC) shall: Determine if the waste has been previously classified. Review analysis and information provided by the site person Classify the waste Provide the waste class to the site person Instruct the site on the appropriate disposal method Ensure that the subject waste is registerd on the HWIN system Arrange for disposal of the waste through the service provider Waste Classification Subject Waste is classified as per the MOE s Registration Guidance Manual for Generators of Liquid Industrial and Hazardous Waste DISPOSAL OF SUBJECT WASTES COPPER CLIFF TAILINGS WASTE MANAGEMENT FACILITY: The Copper Cliff Tailings Area Certificate of Approval number PLRTW allows for the disposal of certain subject wastes generated by Vale Sudbury operations. Appendix B outlines the requirements for properly disposing of these approved subject wastes. 8. OFFSITE DISPOSAL OF SUBJECT WASTES The most common subject waste generated by Vale facilities that must be shipped off-site for disposal is waste lubricant (oil, rope grease, oily sludge). Other examples include waste paint, biomedical waste and waste batteries. The site will ensure that an authorized waste manifest signer is available on the day of shipment to sign the MOE manifest. See Appendix C for more information and refer to the section on MOE manifesting. 9. REVISIONS: This SPI should be reviewed as required when the referenced standards or regulatory requirements change; a formal review shall be required within three years of the revision date

4 Page 4 of 10 APPENDIX A SUBJECT WASTE STORAGE PROCEDURE INTRODUCTION Environmental protection measures need to be provided for all new and existing hazardous waste, chemical storage, and temporary hazardous waste storage areas; and for the replacement or reconstruction of existing facilities to prevent the uncontrolled release of materials into the environment. Procedures should include the safeguarding of employees against health exposure and to increase safety awareness to minimize risk and eliminate potential incidents. Refer to the Gas handling Act, Fire Code, TDGA, and the Ministry of Environment s Guidance Manual Guidelines for Environmental Protection Measures at Chemical and Waste Storage Facilities for proper storage container compatibility. PURPOSE Ensure hazardous and liquid industrial waste storage is done in accordance with all applicable regulatory requirements. SCOPE The following procedure applies to facilities that store hazardous waste and liquid industrial waste and includes measures to safeguard the environment for temporary hazardous waste storage areas. PROCEDURE ONSITE STORAGE OF HAZARDOUS WASTE Under regulation 347, hazardous wastes are permitted to be stored onsite for up to 90 days. Continued storage past 90 days requires that a notice must be given to the MOE Regional Director by completing the notice of storage form. The purpose of the form is to fulfil the Regulatory requirements of storing hazardous waste at a generating facility for more than a 3-month period. This form is to be filled out by the Waste Program Administrator and sent to the Regional Director. Paragraph 3, Section 17.2 of Regulation 347 states: The first time that subject waste is stored at the waste generation facility for more than 90 days, a notice must be given to the Regional Director, within five business days after the 90th day of storage, that, i. Describes, as accurately as possible, the nature, amount and location of subject waste stored, or expected to be stored in the future, at the waste generation facility for more than 90 days, and ii. Indicates how frequently subject waste is expected to be stored in the future at the waste generation facility for more than 90 days. Notice of Storage Form Send the Notice of Storage Form to: Regional Director Ministry of the Environment Northeastern Region

5 Page 5 of Larch St. 11th Floor Sudbury, Ontario P3E 5P9 Fax (705) Storage facilities are not to be placed in a location where in the event of a spill; The hazardous waste may enter a natural water course or drainage system, Contaminate potable surface or groundwater supplies, or Contribute to air contamination WASTE OIL STORAGE USE OF DRUMS/CONTAINERS Drums or other containers shall be clearly marked and labelled as to their contents and arranged within the storage facility and grouped by compatibility. Stack heights shall be limited. The storage area shall be kept free of combustible material and have containment to protect against spills. The hazardous waste disposal contract is setup to ensure that the wastes are disposed of in an appropriate timeframe to guard against exceeding the capacity of the storage area. STORAGE TANKS Permanent subject waste storage tanks must have a dyked containment system that at the very least meets the local requirements for volume, permeability and regular maintenance. The containment should have the dimensions that ensures that the volume of liquid it will contain is equal to i) 110 % of the capacity of one tank ii) Where the containment contains more then one tank the capacity of the largest tank plus % of the aggregate capacity of all the other tanks or 110% of the largest tank whichever is greater. The containment should meet engineering specifications. The containment should be designed to allow spilled subject wastes to be safely collected and removed. The site will develop a system to ensure the storage tank(s) is inspected regularly and is emptied at a frequency that complies with the onsite storage requirements. TEMPORARY HAZARDOUS WASTE STORAGE At times it may be necessary to temporarily store hazardous wastes onsite prior to disposal to a licensed waste disposal site (contaminated soil from a leak, sludges). Note that storage beyond 90 days requires a notice of storage to be submitted to the MOE. Steps are to be taken to safeguard against spills and leachate migration into the ground and/or surface water courses through the use of proper containment. i. Contaminated soils or other solids: a. construct a containment area sized appropriately for the expected amount of waste to be generated

6 Page 6 of 10 b. in the case of where leachate formation is likely from exposure to precipitation; berm the containment area and install an impermeable liner. Additional steps that can be taken include covering the material with an impermeable liner. ii. Liquids and Sludges a. select appropriate containers for the material. Obtain guidance from the waste service provider. b. store the containers in an appropriate area away from high traffic areas so as to minimize the risk of being struck by mobile equipment. Label the containers. c. move the labelled containers to the waste oil storage facility or contact the service provider for removal of waste as soon as possible. LABELLING All waste containers must be labelled as to their contents while in storage. Unlabeled waste will not be able to be picked-up by the service provider. In addition, unidentified subject wastes will have to be sampled and analyzed for chemical composition in order to properly identify and classify the waste. WASTE/CHEMICAL COMPATIBILITY Compatibility of materials must be established to ensure that the potential for violent reactions between 2 or more chemicals or between fuels and chemicals do not exist. Refer to the Chemical Compatibility Chart. WASTE/CHEMICAL/ SEGREGATION Separate explosive and flammable from sources of heat and ignitions Physical separations of chemically compatible materials Control of conditions leading to spontaneous combustion of certain materials Protect from contact with water, especially materials that are dangerous when wet Separate oxidizers from organic material Provide engineering control to prevent piles of bulk materials from creating a health risk in the environment Segregate hazardous waste containers from non-hazardous waste containers Isolate liquid wastes from solid wastes EMERGENCY PROCEDURES Provide adequate ventilation for handling of gases Provide level gauges and warning devises where needed Maintain storage areas closed except when adding or removing materials Refer to fire code and gas handling act for storage Written procedures outlining actions to be taken by employees in the event of a spill, leak, fire or explosion; available equipment Provide engineering control and proper PPE when handling of hazardous material Have impact protection

7 Page 7 of 10 PREVENTIVE MAINTENANCE Routine inspection and testing on containment to assure their structural integrity, on alarms and controls to ensure proper operations SPILL CONTINGENCY Develop a spill contingency plan Have spill clean up kit for the materials being stored Provide adequate corrosion protection and leak detection systems for underground storage tanks 6.0 TRAINING Emergency response employees shall be trained in the use of emergency equipment and action to be taken in the event of a spill. All employees handling the material should be made aware of the hazards to people, safety and the environment.

8 Page 8 of 10 APPENDIX B SUBJECT WASTE DISPOSAL IN THE COPPER CLIFF TAILINGS WASTE MANAGEMENT FACILITY PROCEDURE APPROVED SUBJECT WASTE CLASSES The following is a list of approved waste classes in Schedule B of the Certificate of Approval PLRTW for disposal into the PQ area and/or the Tailings area landfill. 112 Acid solution, sludge and residues. 113 Other inorganic acid waste. 122 Alkaline solutions, sludge and residues containing other metals. 132 Neutralized solutions, sludge and residues containing metals. 142 Primary Smelting wastes. 146 Other specified inorganic. Communication with the Waste Management Program Administrator is required to verify whether the subject waste can be disposed of in the landfill or the P/Q trench. Doing so will ensure that Vale is within its annual limits for each waste class. TRANSPORTATION AND MANIFEST REQUIREMENTS In order to properly manifest subject waste, a waste classification must be assigned. Transportation on Public Roads- Manifesting Requirements Even for disposal in the Copper Cliff Tailings Area, whenever the subject waste must be transferred on a public road to get to the tailings area, a licensed carrier must be used and an MOE manifest must be completed to comply with Regulation 347 in addition to a completed internal manifest. Within Sudbury operations, the following facilities will always require a licensed carrier and MOE manifest for disposal of subject wastes in the tailings area: Garson Mine, Coleman Mine, Frood- Stobie Mine, Totten, Whistle Mine. The licensed carrier that is going to dispose of the waste will have an MOE manifest with them to complete. See Appendix C below for the distribution requirements for the MOE manifest as prescribed by Regulation 347. The internal manifest must also be completed and sent to the landfill with the carrier. See the following for instructions on the internal manifest. Internal Manifesting In order to dispose of the subject waste in the tailings area an internal manifest must be completed by a Vale employee and provided to the carrier to give to the landfill attendant prior to disposal. If there is no waste classification entered on the manifest then the load will not be accepted by the William Day landfill attendant and must be returned to the sender. For additional information on the internal manifest procedure please refer to the internal manifest form. The internal manifest form is also available on the Environment intranet site. Please contact the Waste Management Program Administrator if assistance is required.

9 Page 9 of 10 APPENDIX C MOE Manifest Distribution Procedure SCOPE LEGAL This procedure applies to facilities where waste is sent for disposal via a waste transportation system for off-site disposal within Ontario. Section 23 (2) of Regulation 347 requires the Generator to complete section A of the manifest at the time of the transfer. Copy 1 (white) must be returned to the Director within 3 working days after the transfer, Copy 2 (Green) must be retained by the Generator for 2 years. The remaining 4 copies are to be returned to the carrier at the time of the transfer. DOCUMENT CONTROL Vale Sudbury Operations Manifest Distribution Procedure The Waste Management Plant Contact or Manifest signer shall: 1. Complete the manifest ensuring that the mailing address is for the Engineering building, Environment Department and the shipping site address is for the shipping site (i.e. Creighton Mine, Smelter etc). This will ensure that all follow-up communications will go through the Central Environment Department. 2. Scan or photocopy the manifest and keep for your records for two years. Scanning would be better as you would have an electronic copy and won t need to file paper. 3. Send copy 1 (white) directly to the MOE within 3 business days (legal requirement). Put it in an envelope and address it to: Ministry of the Environment Environmental Monitoring and Reporting Branch, Area M 135 St. Clair Avenue West Toronto ON M4V 1P5 4. At the same time, send copy 2 (green) to Engineering Building-Environment Department- Attention Lyse Provencal- through inter-office mail. 5. All other copies of the manifest shall be given to the Carrier at the time of transfer. The Central Environment Department shall: 1. Maintain the Manifest Database 2. Make sure the brown copies of the manifests are returned to Vale within four weeks to confirm delivery to the intended receiving facility. 3. Keep all green and brown copies for minimum of two years 4. Maintain HWIN and do the reporting to the MOE

10 Page 10 of 10 The following example is to summarize the above: Vale is the Generator, the transportation of the waste remains within Ontario, and the receiving facility is located in Ontario. Vale as the Generator must complete Part A of the manifest. Example: Vale generates solvent waste and the solvent waste is transferred to K.R.Thompson. Copy 1 (white) Copy 2 (green) Copy 3 (yellow) Copy 4 (pink) Copy 5 (Blue) Copy 6 (Brown) To MOE within 3 working days after the transfer of waste Vale facilities to Vale Central Environment Department Receiver to MOE Return to carrier at the time of transfer Receiver retains for 2 years Receiver return to Vale Central Environment Department