Copper Cliff Nickel Refinery Complex

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1 December 2013 Toxic Reduction Plan Summaries Copper Cliff Nickel Refinery Complex Carbon monoxide Iron pentacarbonyl Particulate matter (TSP, PM10, PM2.5) Nitrogen oxides Sulphur dioxide

2 Toxic Substance Reduction Plan Summaries for Toxic Substances at the Copper Cliff Nickel Refinery Complex 1. Facility information NPRI identification number: 1467 NAICS identification number: NAICS Canada code: 33 Legal and trade name of company: Vale Canada Limited Facility Street Address: Copper Cliff Nickel Refinery 175 Industrial Road, Copper Cliff, Ontario Facility Mailing Address: Copper Cliff Nickel Refinery, 175 Industrial Road, Copper Cliff, Ontario Number of full time employee equivalents (2012): 232 UTM x: UTM y: Public Contact: Frank Javor, Manager Environment (Air) Central Engineering Building, 18 Rink Street, Copper Cliff, Ontario Prepared Plan: Vanessa Bonanno Intermediate Analyst Environment (Air) Central Engineering Building, 18 Rink Street, Copper Cliff, Ontario,

3 Highest ranking official: Greg Puro, Manager Operations, Copper Cliff Nickel Refinery Complex, Copper Cliff Nickel Refinery, 175 Industrial Road, Copper Cliff, Ontario, Toxic Reduction Planner and certifier: Mary Dubel Licence number: TSRP0118 Company information: Vale Canada Limited Business Number: DUNS number: Street Address: 200 Bay Street, Suite 200, South Tower, P.O. Box 70 Toronto, Ontario M5J 2K2 Parent Company: Companhia Vale Do Rio Doce (Vale) Business Number: DUNS Number: Graça Aranha Avenue, Rio de Janeiro, Brazil 2. List of Toxic Substances used and created at the Copper Cliff Nickel Refinery Complex and CAS # of Substance Carbon monoxide, Iron pentacarbonyl, Particulate matter (TSP, PM10, PM2.5), NA-M08, NA-M09, NA-M10 Nitrogen oxides, Sulphur dioxide, Toxic Reduction Policy Statement of Intent At Vale s Sudbury Operations, we are committed to sustainable development meeting the needs of the present without compromising the ability of future generations to meet their own needs. Vale believes in zero harm, to our people, to our workplaces, to the communities in which we operate and to the natural environment. Vale Canada Sudbury Operation s is committed to playing a leadership role in protecting the environment. While, for milling, smelting and refining, this primarily means reducing toxic substances end-of-pipe emissions, wherever feasible, Vale will adopt safer alternatives and

4 technologies to reduce the use and release of toxic substances. Toxic substance reduction will be a continuing effort in our company and new technologically and economically feasible reduction options will be considered if opportunities become available in the future and are in compliance with all federal and provincial regulations. 4. Objectives 4.1. Iron pentacarbonyl As Vale Canada Limited is in the business of producing and supplying the world market with high quality ferronickel products, options to reduce the amount of iron pentacarbonyl created during process of ferronickel production at the IPC building of the Copper Cliff Nickel Refinery (CCNR) will not be considered. The processes at the Inco Pressure Carbonyl (IPC) Plant occur within closed reactor vessels with no emissions of iron pentacarbonyl gas. Once the iron pentacarbonyl is produced, it is then transformed into ferronickel pellets. Vale will continue to strive to be an industry leader by incorporating the concept of zero harm in every aspect of our business Carbon monoxide At this time, Vale s Sudbury Operations do not intend to reduce the creation of carbon monoxide gas at the Copper Cliff Nickel Refinery Complex. Vale s Sudbury Operations were not able to identify options to reduce the consumption of natural gas at the facility. In the future, Vale will continue to explore any natural gas reduction options for the facility, which would not only result in a reduction in carbon monoxide gas creation, but also result in a cost savings for the facility Sulphur dioxide Abatement of SO 2 emissions has been a long standing objective at the Sudbury Operations. Part of Vale s continued initiatives to reduce sulphur dioxide emissions and to comply with Ontario Regulations 194/05 and Ontario Regulation 419/05 Vale s Sudbury Operations have begun construction on the Clean AER (Atmospheric Emission Reduction) project. With the implementation of the Clean AER project, in conjunction with the move to a one flash furnace operation, sulphur dioxide emissions for the Sudbury Operations will be reduce by over 70% from current levels. At this time, Vale s Sudbury Operations does not intend to reduce the creation of sulphur dioxide at the Copper Cliff Nickel Refinery complex. The removal of sulphur from the feed material during the initial process stage at the NRC building is essential to producing a high quality nickel product. At this time, SO 2 capture and abatement is not feasible for the gas stream produced at this facility. Vale will continue its efforts to control the release of SO 2 into the environment to maintain the appropriate concentration of downwind community ground level SO 2 gas through the Emissions Reduction Program (ERP) in place for the Copper Cliff Smelter and Copper Cliff Nickel Refinery Particulate Matter (TSP, PM 10, PM 2.5 ) At this time, Vale s Sudbury Operations does not intend to reduce the creation of particulate matter at the Copper Cliff Nickel Refinery Complex. Vale s Sudbury Operations was able to identify a reduction option to reduce the creation and release of particulate matter at the facility, however, this option was deemed to be not technically feasible at this time.

5 Abatement of particulate matter emissions has been a long standing objective at the Copper Cliff Nickel Refinery Complex. Part of Vale s continued initiatives, to reduce particulate matter emissions and to meet changes to environmental regulations in 2016 (Federal emissions standards), study and design work are currently underway at the CCNR Complex to improve pollution control equipment at the NRC and IPC buildings. Over the next few years, Vale has committed to upgrading or changing baghouses at both the Nickel Refinery Converters (NRC) and IPC buildings, to meet the current industry standard of 2 mg/m 3 dust outlet emissions. Vale and its employees are committed to the continual improvement of all facilities at the Copper Cliff Nickel Refinery, striving to operate in a manner that is sustainable Nitrogen oxides At this time, Vale s Sudbury Operations does not intend to reduce the creation of nitrogen oxide at the Copper Cliff Nickel Refinery Complex. A reduction option was identified, however, at this time this option is not economically feasible for the facility. As part of Vale s policy of zero harm, all new and replacement natural gas heaters/burners must meet a low NO x specification as part of Vale s engineering standards. 5. Description of Substances 5.1. Iron pentacarbonyl The ore, which is processed at Clarabelle Mill, naturally contains many elements, including nickel, copper, cobalt, and iron. The valuable metals are concentrated into a product that is smelted and further refined to remove the unwanted material to produce a pure metal product for sale. The majority of the iron found in the Clarabelle Mill concentrate is removed at the Copper Cliff Smelter, however, iron still remains as a minor component of the feed material processed at the CCNR. The remaining iron is extracted at the Inco Pressure Carbonyl (IPC) Plant of the CCNR, through the creation and decomposition of iron pentacarbonyl to produce a ferronickel product that is sold to market Carbon monoxide Carbon monoxide is created from the incomplete combustion of natural gas in heaters and burners used throughout the complex. Natural gas is used in burners/heaters for supplementary heat in the process, heating of process gas and equipment, and for heating the workroom environment. Carbon monoxide gas is also created as a reagent for carbonyl gas production at the IPC plant to create nickel and ferronickel products. The carbon monoxide gas is purified and recycled in the process. Carbon monoxide gas is created from natural gas to replenish this process gas stream as needed Sulphur dioxide The ore, which is processed at Clarabelle Mill, naturally contains many elements, including nickel, copper, cobalt, precious metals and sulphur. Sulphur is a component of the feed materials processed at the CCNR with nickel sulphides from the Smelter Complex being the primary source. It is the goal of the smelting and refining process to remove the undesirable impurities, such as sulphur, to produce a pure base metal product. In the presence of heat and oxygen, the sulphur found within the feed is converted into sulphur dioxide.

6 5.4. Particulate matter Particulate matter is created during all processing stages at the CCNR Complex through. Feed materials, including nickel sulphide/oxide material, tolls and reverts and other reagents (Petroleum Coke), are distributed to the process vessels of the NRC building via a series of hoppers, conveyors and bins. This movement of material creates airborne dust emissions. Volatile metal oxides and sulphides are also produced during the metallurgical processes and enter the off-gas stream. Particulate matter is defined as microscopic solid and liquid particles that remain suspended in the air. Total particulate matter is any airborne particulate matter with a diameter less than 100 microns. PM10 and PM2.5 are particulate size fractions of the total particulate matter produced and emitted. PM10 are particle size of approximately 10 micrometers or less and PM2.5 are particle size of approximately 2.5 micrometers or less Nitrogen oxides Nitrogen oxides are produced from the combustion of natural gas in heaters and burners used throughout the Nickel Refinery Complex. Nitrogen oxides are created from the combustion of natural gas in burners/heaters used for supplementary heat in the process, heating of process gas and equipment and, and to provide heat for the workroom environment. NO x is created through the thermal dissociation and subsequent reaction of nitrogen (N 2 ) and oxygen (O 2 ) molecules in the combustion air. 6. Rationale as to Why No Reduction Options Were Selected 6.1. Iron pentacarbonyl As Vale Canada Limited is in the business of producing and supplying the work market with high quality nickel and ferronickel products, options to reduce the amount of iron pentacarbonyl created and processed at the Copper Cliff Nickel Refinery Complex will not be considered. The use of carbonyl gas is an essential component of finished nickel and ferronickel production at Vale s IPC building. All carbonyl gas is processed in an enclosed system with no emissions to the atmosphere. Vale will continue to strive to be an industry leader by incorporating the concept of zero harm in every aspect of our business Carbon monoxide At this time, Vale s Sudbury Operations were not able to identify options to reduce the creation and release of carbon monoxide at the Nickel Refinery Complex. As Vale Canada Limited is in the business of producing and supplying the world market with highly pure nickel and ferronickel products, options to reduce the amount of carbon monoxide gas created at the Copper Cliff Nickel Refinery will not be considered for the IPC process. The production and use of carbon monoxide gas is a vital for the extraction of the nickel and iron to create high quality nickel and ferronickel products. Maintaining appropriate levels of process gas is critical to the proper functioning of the reactor/decomposition process at the IPC building. At Vale, the concept of sustainability has been incorporated into our milling, smelting and refining practices in Ontario, with a focus on end-of-pipe pollution prevention. Vale will continue to strive to be an industry leader by incorporating the concept of zero harm in every aspect of our business.

7 Carbon monoxide is also created through the combustion of natural gas for supplementary heat in the process, heating of process gas and equipment and to provide heat for the workroom environment. Due to the nature of some of the materials used in the IPC process, maintaining the temperature of the IPC building is necessary to ensure the proper functioning of the process equipment Sulphur dioxide At this time, Vale s Sudbury Operations were not able to identify options to reduce the creation and release of sulphur dioxide at the Copper Cliff Nickel Refinery Complex. Sulphur dioxide is created by the oxidation of sulphur found in the feed material in the oxygen rich environment of the TBRCs. The removal of sulphur from the feed material during the initial process stage at the NRC building is essential to producing a high quality nickel product. At this time, SO 2 capture and abatement is not feasible for the gas stream produced at this facility. Vale will continue its efforts to control the release of SO 2 into the environment, to maintain the appropriate concentration of downwind community ground level SO 2 gas through the Emissions Reduction Program (ERP) in place for the Copper Cliff Smelter and Copper Cliff Nickel Refinery. Abatement of SO 2 emissions has been a long standing objective at the Sudbury Operations. Part of Vale s continued initiatives to reduce sulphur dioxide emissions and to comply with Ontario Regulations 194/05 and Ontario Regulation 419/05 Vale s Sudbury Operations have begun construction on the Clean AER (Atmospheric Emission Reduction) project. With the implementation of the Clean AER project in conjunction with the move to a one flash furnace operation, sulphur dioxide emissions for the Sudbury Operations will be reduce by over 70% from current levels Particulate Matter Even though a reduction option was identified for particulate matter, at this time, this option was not selected for implementation. The option presented in the plan did not meet the technical feasibility criteria established by the facility Nitrogen oxides Even though a reduction option was identified for nitrogen oxides, at this time, this option was not selected for implementation. The option presented in the plan did not meet the economic feasibility criteria established by the facility. Additional Information Vale has incorporated the concept of sustainability into the mining, milling, smelting and refining practices in Ontario, endeavoring to achieve zero harm to our people, to our workplaces and to the natural environment. For the Base Metals Industry, this is primarily accomplished through pollution control of end-of-pipe emissions. For the Sudbury Operations, past pollution control projects have reduced property source fugitive air emissions and reduced process air emissions, which included the construction of new storage handling facilities for feed material, re-vegetation of property boundary areas, and the installation of new baghouses and electrostatic precipitators to capture dust emissions. Vale is undertaking its Clean AER (Atmospheric Emissions Reduction) project to reduce sulphur dioxide emissions by a further 70%, to significantly reduce particulate and metal emissions and improve

8 local air quality. As part of the Clean AER (Atmospheric Emissions Reduction) project, the current outdoors Feed and Material Handling area, located at the Copper Cliff Smelter Complex, will be moved into vented buildings with dust capture. By enclosing the dry feed material, environmental forces, such as wind erosion, will no longer act on the material reducing the material loss to the environment. At the Copper Cliff Nickel Refinery Complex, nickel sulphide material from the Smelter Complex will be stored in a vented building. These projects will ensure Vale s Sudbury Operations will continue to contribute decades of employment, economic growth and community support. 8. Plan Summary Statement This plan summary is an accurate synopsis of the content of the toxic substance reduction plan for carbon monoxide, iron pentacarbonyl, particulate matter, nitrogen oxides and sulphur dioxide creation at the Copper Cliff Nickel Refinery Complex, Sudbury Operations, prepared for Vale Canada Limited, dated December The content of the summary is up to date and reflects the current version of the toxic substance reduction plan.

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