Copper Cliff Nickel Refinery Complex

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December 2012 Toxic Reduction Plan Summaries Copper Cliff Nickel Refinery Complex Arsenic Cadmium Chromium Cobalt Copper Dioxins, Furans and Hexachlorobenzene Lead Nickel Selenium Sulphuric Acid

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: 33-14-10 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 P0M 1N0 Facility Mailing Address: Copper Cliff Nickel Refinery, 175 Industrial Road, Copper Cliff, Ontario P0M 1N0 Number of full time employee equivalents (2011): 194 UTM x: 495755 UTM y: 5147227 Public Contact: Frank Javor, Manager Environment (Air) 705-682-6736 Central Engineering Building, 18 Rink Street, Copper Cliff, Ontario P0M 1N0 Prepared Plan: Vanessa Bonanno Environmental Analyst Environment (Air) 705-682-6111 Central Engineering Building, 18 Rink Street, Copper Cliff, Ontario, P0M 1N0

Highest ranking official: Greg Puro, Manager Operations, Copper Cliff Nickel Refinery Complex, 705-682-7364 Copper Cliff Nickel Refinery, 175 Industrial Road, Copper Cliff, Ontario, P0M 1N0 Toxic Reduction Planner and certifier: Mary Dubel Licence number: TSRP0118 Company information: Vale Canada Limited Business Number: 102475084 DUNS number: 200429306 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: 102475084 DUNS Number: 200429306 26 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 Arsenic and its compounds NA - 02 Cadmium and its compounds NA-03 Chromium and its compounds NA-04 Cobalt and its compounds NA-05 Copper and its compounds NA-06 Dioxins, Furans and Hexachlorobenzene NA-D/F, 118-74-1 Lead and its compounds NA-08 Nickel and its compounds NA-11 Selenium and its compounds NA-12 Sulphuric Acid 7664-93-9

3. 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 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. Arsenic At this time, Vale s Sudbury Operations does not intend to reduce the use of arsenic at the Copper Cliff Nickel Refinery (CCNR) Complex. A reduction option was identified, however, at this time the option was not technically feasible for the facility. The main source of arsenic at the CCNR is the feed material received from the Copper Cliff Smelter and from Vale s refinery in Clydach, Wales. Without processing this material, the CCNR would not be able to produce the final base metal products. Vale will continue its efforts to reduce the release of arsenic into the environment and reduce the loss of any feed material during processing. The primary control strategy for arsenic input at the CCNR Complex takes place at Vale s Clarabelle Mill. Ore that is high in arsenic is segregated and blended in the appropriate amount, controlling the arsenic level in the bulk concentrate entering the Smelter Complex. Since the Smelter products account for approximately 60% of the arsenic input into the Nickel Refinery Converter (NRC) Building, any change in arsenic input at the smelting stage will have a downstream affect at the CCNR Complex. 4.2. Cadmium and Lead At this time, Vale s Sudbury Operations does not intend to reduce the use of cadmium and lead at the Copper Cliff Nickel Refinery Complex. Vale s Sudbury Operations were not able to identify options to reduce the use and release of cadmium and lead at the facility. The main source of cadmium and lead at the CCNR is the feed material received from the Copper Cliff Smelter and from Vale s refinery in Clydach, Wales. Processing this Clydach residue helps to ensure environmentally safe and efficient recycling of these valuable resources. Vale will continue its efforts to reduce the release of cadmium and lead into the environment and reduce the loss of any feed material during processing. 4.3. Chromium At this time, Vale s Sudbury Operations does not intend to reduce the use of chromium at the Copper Cliff Nickel Refinery. A reduction option was identified, however, at this time the option was not technically feasible for the facility. Since a source of chromium at the CCNR is from equipment wear, reducing this wear would decrease the addition of chromium into the process stream. At the NRC plant,

a project is being tested to modify current operating practices for the Top Blown Rotary Converters (TBRCs) in order to reduce the wear of the brick lining each vessel. The amount of wear for the brick will be equal to before the improved operating practices, however, this wear will be over a longer span of time reducing the amount of brick purchased and used on an annual basis. At this time, this option is considered technically not feasible as testing is on-going. As such, this option will not be implemented at the NRC plant for this current plan, but if successful results are achieved at the completion of the testing program, this reduction option will be considered in the future. Vale will continue its efforts to reduce the release of chromium into the environment and reduce the loss of any feed material during processing. 4.4. Cobalt, Copper, Nickel and Selenium As Vale Canada Limited is in the business of producing and supplying the world market with high quality cobalt, copper, nickel and selenium products, options to reduce the amount of cobalt, copper, nickel and selenium containing material that is processed and extracted at the Copper Cliff Nickel Refinery will not be considered. Vale will continue its efforts to reduce the release of cobalt, copper, nickel and selenium into the environment. 4.5. Sulphuric Acid At this time, Vale s Sudbury Operations does not intend to reduce the use of sulphuric acid at the Copper Cliff Nickel Refinery Complex. A reduction option was identified, however, at this time the option was not technically feasible for the facility. Through an investigation with the Process Technology group at the Electrowinning (EW) plant, it was found that sulphuric acid consumption is most correlated to the amount of nickel and cobalt that is processed at the facility. Owing to this association, the total amount of sulphuric acid used could be reduced by decreasing the amount of nickel input into the plant. At this time, there is a project underway at the CCNR Complex to increase the extraction efficiency at the Inco Pressure Carbonyl (IPC) plant, which will reduce that amount of nickel left in the residue, the feed material for EW. Since the optimization project is still in the beginning stages of testing, the ability of the IPC plant to increase nickel extractions is still unknown. As such, this option is considered technically not feasible at this time. With the successful completion of this project and continued monitoring at the EW plant, the reduction in sulphuric acid consumption will be evaluated. 4.6. Dioxins, Furans and Hexachlorobenzenes At this time, Vale s Sudbury Operations does not intend to reduce the creation of dioxins, furans and hexachlorobenzene at the Copper Cliff Nickel Refinery. Vale s Sudbury Operations were not able to identify options to reduce the creation or release of dioxins, furans, or hexachlorobenzene at the facility. Dioxins, furans and hexachlorobenzenes can be generated from the use of organic materials in the refining process. These organic materials, which contain carbon, are used for supplemental heat and as reducing agents, components of minor processing stages of refining.

5. Description of Substances 5.1. Arsenic, Cadmium and Lead Arsenic, cadmium and lead are not used at the Copper Cliff Nickel Refinery Complex. These substances are incidentally present in the feed material for the Nickel Refinery Complex, primarily nickel sulphide/oxide products from the Smelter Complex, revert material from other Vale facilities and external purchased sources. Ore, the feed material for base metal production, essentially contains the periodic table of elements, with many elements metallurgically bound to base metals of value. It is the goal of the milling, smelting and refining process to remove the unwanted components from the ore to produce a valuable base metal product, in the case of Vale s Sudbury Operations, primarily nickel, copper, cobalt and precious metals. 5.2. Chromium Primarily, chromium is incidentally present in the feed material for the Nickel Refinery Complex, nickel sulphide/oxide products from the Smelter Complex, revert material from other Vale facilities and external purchased sources. Ore, the feed material for base metal production, essentially contains the periodic table of elements, with many elements metallurgically bound to base metals of value. It is the goal of the milling, smelting and refining process to remove the unwanted components from the ore to produce a valuable base metal product, in the case of Vale s Sudbury Operations, primarily nickel, copper, cobalt and precious metals. Chromium is also present as a minor constituent in the refractory lining of the TBRCs and transfer ladles, process equipment of the NRC plant. 5.3. Cobalt, Copper, Nickel and Selenium Cobalt, copper, nickel and selenium enter the Copper Cliff Nickel Refinery Complex from the nickel sulphide/oxide feed produced at Vale s Smelter Complex, revert materials for other Vale facilities and external purchased sources. It is the goal of the milling, smelting and refining process to remove the unwanted material from the ore to produce a valuable base metal product, in the case of Vale s Sudbury Operations, primarily nickel, copper, cobalt and precious metals. Feed streams at the Copper Cliff Nickel Refinery Complex containing copper are processed to create a pure copper product for sale on the market. All feed streams containing nickel are processed at the Refinery to create a pure nickel product for sale on the market. Cobalt containing material is processed at the Electrowinning plant to create a Nickel/Cobalt slurry that is shipped to Port Colborne, Ontario for further processing. Electrolytic cobalt is produced at Vale s Port Colborne Refinery. The selenium found in the Smelter products are further processed at the Copper Cliff Nickel Refinery Complex. A TOL slurry, containing selenium, is produced and sent to Vale s the Port Colborne Precious Metals Refinery (PMR). During the precious metal refining process selenium is recovered into a cake product and is sold to market. 5.4. Sulphuric Acid Sulphuric acid is used at the Electrowinning (EW) Plant located at the Copper Cliff Nickel Refinery Complex. The Electrowinning plant produces copper plates for sale and other products which are shipped to Vale s Port Colborne Refinery for further processing. The initial process at the Electrowinning facility is the first stage leach and the second stage leach stages. The purpose of these processes is to dissolve nickel, cobalt, iron, copper and arsenic from the IPC residue and the first stage

leach residue. Sulphuric acid is added at the first stage leach by mixing the IPC residue with Tankhouse spent electrolyte and 2 nd stage pregnant electrolyte, both recycled solutions within the EW plant containing sulphuric acid. Additional sulphuric acid is added as needed to maintain the acid strength required by the process. Spent electrolyte is also added to the second stage leach. The sulphuric acid, in solution, is carried throughout the processes stages at the Electrowinning facility where it is used as part of the electrolyte solution used at the Electrowinning Tankhouse or neutralized during the production of the nickel cobalt slurry that is shipped to Port Colborne for further processing. 5.5. Dioxins, Furans and Hexachlorobenzenes Dioxins, furans and hexachlorobenzene are not used at the Copper Cliff Nickel Refinery Complex. Dioxins, furans and hexachlorobenzenes can be generated (created) by the combustion of organic material during the industrial process at the Nickel Refinery Complex. The primary source of organics at the Nickel Refinery are material used for supplemental heat, such as natural gas, and reducing reagents, such as Petroleum Coke. Based on source testing of the NRC Stack air emissions, the quantity of dioxins, furans and hexachlorobenzene are below the level of quantification (LoQ), as set by the federal NPRI guideline. 6. Rationale as to Why No Reduction Options Were Selected 6.1. Arsenic Even though a reduction option was identified for arsenic, 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. The main source of arsenic is the intermediate nickel products from the Matte Processing plant at the Smelter Complex. In addition to this feed material, recycled materials, both internal to Vale and external sources, containing high arsenic levels are also processed at the NRC building. It is in the best interest of Vale to process these secondary feed materials in order to extract the profitable metals, helping ensure environmentally safe and efficient recycling of these valuable resources. 6.2. Cadmium and Lead At this time, Vale s Sudbury Operations were not able to identify options to reduce the use and release of cadmium and lead at the Nickel Refinery Complex. The primary source of cadmium and lead into the CCNR is the feed products from the Smelter Complex and the Clydach residue from Vale s refinery in Wales. The CCNR provides a method to process this residue from the Clydach Refinery extracting the profitable metals, helping to ensure environmentally safe and efficient recycling of these valuable natural resources. 6.3. Chromium Even though a reduction option was identified for chromium, 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.

6.4. Cobalt, Copper, Nickel and Selenium Vale Canada Limited is in the business of producing and supplying the world market with high quality cobalt, copper, nickel and selenium products. Options to reduce the amount of cobalt, copper, nickel and selenium processed and extracted at the Copper Cliff Nickel Refinery Complex will not be considered as these are our products. 6.5. Sulphuric acid Even though a reduction option was identified for sulphuric acid, 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. 6.6. Dioxins, Furans and Hexachlorobenzenes Reduction options for the Copper Cliff Nickel Refinery Complex were not identified since the dioxins, furans and hexachlorobenzenes emissions were below the LoQ. The creation of any dioxins, furans, and hexachlorobenzens are due to very small amounts of organic material added to the process. Organic materials used for supplemental heat and as a reducing agent are very minor components of the refining process. 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. The new CORe (Challenging Ore Recovery) project at the Clarabelle Mill is expected to result in increased metals extractions, while removing impurities, from the concentrate product. This will have a positive effect on downstream facilities in Sudbury, such as the Nickel Refinery Complex, with less impurities being carried through the process. 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 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. 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 arsenic, cadmium, chromium, cobalt, copper, dioxins, furans, hexachlorobenzenes, lead, nickel, selenium and sulphuric acid use at the Copper Cliff Nickel Refinery Complex, Sudbury Operations, prepared for Vale Canada Limited, dated December 2012. The content of the summary is up to date and reflects the current version of the toxic substance reduction plan.