Copper Cliff Smelter Complex

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December 2013 Toxic Reduction Plan Summaries Copper Cliff Smelter Complex Carbon monoxide Sulphur dioxide Particulate Matter (TSP, PM10, PM2.5) Nitrogen oxides VOCs

Toxic Substance Reduction Plan Summaries for Toxic Substances at the Copper Cliff Smelter Complex 1. Facility information NPRI identification number: 444 NAICS identification number: 33-14-10 NAICS Canada code: 33 Legal and trade name of company: Vale Canada Limited Facility Street Address: Copper Cliff Smelter 18 Rink Street, Copper Cliff, Ontario P0M 1N0 Facility Mailing Address: Copper Cliff Smelter, 18 Rink Street, Copper Cliff, Ontario P0M 1N0 Number of full time employee equivalents (2012): 492 UTM x: 493502 UTM y: 5143518 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 Intermediate Analyst Environment (Air) 705-682-6111 Central Engineering Building, 18 Rink Street, Copper Cliff, Ontario, P0M 1N0

Highest ranking official: Joe Costigan, Manager Operations, Bulk Smelter 705-682-7065 Copper Cliff Smelter, 18 Rink Street, 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 Smelter Complex and CAS # of Substance Carbon monoxide, 630-08-0 Sulphur dioxide, 7446-09-5 Particulate matter (TSP, PM10, PM2.5), NA-M08, NA-M09, NA-M10 Nitrogen oxides, 11104-93-1 VOCs NA M16 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. Carbon monoxide At this time, Vale s Sudbury Operation does not intend to reduce the creation of carbon monoxide at the Copper Cliff Smelter Complex. Reduction options were identified, however, at this time all options were not technically or economically feasible for the facility. In 2013, Vale s Sudbury Operation decided to move to a one flash furnace operation at the Copper Cliff Bulk Smelter. With the move to a one furnace operation, the facilities within the Copper Cliff Smelter Complex will be shut-down and the equipment decommissioned. The removal of these circuits is anticipated to reduce the consumption of natural gas at the Smelter Complex, in turn, reducing the creation of carbon monoxide. Vale s Sudbury Operations have committed to and completed projects that resulted in the reduction of carbon monoxide creation at the Smelter Complex. Projects starting in 2010 were implemented to reduce the natural gas usage in the Super Stack burners. The flue system at the Bulk Smelter is designed so that flue gases leaving the process through the Super Stack are at a temperature of 130 o C. This temperature is achieved through the use of natural gas burners that heat the gas before exiting the Super Stack. One project, completed in 2012, decreased the low firing rate of the flue burners by 50%, reducing the amount of natural gas consumed. This reduction in natural gas consumption reduced the creation of carbon monoxide from this source. 4.2. Sulphur dioxide At this time, Vale s Sudbury Operations does not intend to reduce the creation of sulphur dioxide at the Copper Cliff Smelter complex. Vale s Sudbury Operations were not able to identify options to reduce the creation of sulphur dioxide at the facility. The current process flow at the Copper Cliff Smelter Complex is designed to process the nickel sulphide (bulk) concentrate at the Flash Furnaces. The exothermic reaction produced by the combustion of iron and sulphur maintains the heat balance needed for the smelting process. Sulphur dioxide capture and abatement continue to be the focus of Vale s Sudbury Operations for the reduction of sulphur dioxide emissions from the facility. 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 Smelter will be reduce by over 70% from current levels. The Clean AER project is designed primarily to capture sulphur bearing gases from the Smelter s converter aisle that currently report to the Super stack and convert these emissions into sulphuric acid. In 2013, Vale s Sudbury Operation decided to move to a one flash furnace operation at the Copper Cliff Bulk Smelter. With the move to a one furnace operation, a reduction in SO 2 creation from the flash furnace is expected.

4.3. Particulate matter At this time, Vale s Sudbury Operations does not intend to reduce the creation of particulate matter emissions at the Copper Cliff Smelter complex. Reduction options were identified, however, at this time all options were not technically or economically feasible for the facility. Abatement of particulate matter emissions has been a long standing objective at the Copper Cliff Smelter. Part of Vale s continued initiatives to reduce metals and particulate matter emissions. 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, particulate matter emissions for the Smelter will be reduced to meet the Federal Pollution Prevention Planning emissions targets. Engineering and procurement for Smelter upgrade work is currently underway at the facility. 4.4. Nitrogen oxides Vale s Sudbury Operations does not intend to reduce the creation of nitrogen oxide at the Copper Cliff Smelter Complex. Reduction options were identified, however, at this time all options were not technically or economically feasible for the facility. In 2013, Vale s Sudbury Operation decided to move to a one flash furnace operation at the Copper Cliff Bulk Smelter. With the move to a one furnace operation, the facilities within the Copper Cliff Smelter Complex will be shut-down and the equipment decommissioned. The removal of these circuits is anticipated to reduce the consumption of natural gas at the Smelter Complex, in turn, reducing the creation of nitrogen oxides. Vale s Sudbury Operations have committed to and completed projects that resulted in the reduction of nitrogen oxides creation at the Smelter Complex. Projects starting in 2010 were implemented to reduce the natural gas usage in the Super Stack burners. The flue system at the Bulk Smelter is designed so that flue gases leaving the process through the Super Stack are at a temperature of 130 o C. This temperature is achieved through the use of natural gas burners that heat the gas before exiting the Super Stack. One project, completed in 2012, decreased the low firing rate of the flue burners by 50%, reducing the amount of natural gas consumed. This reduction in natural gas consumption reduced the creation of nitrogen oxides from this source. As part of Vale s policy of zero harm, all new and replacement natural gas heaters/burners at the Smelter Complex must meet a low NO x specification as part of Vale s engineering standards. 4.5. VOCs At this time, Vale s Sudbury Operations does not intend to reduce the creation of VOCs. Vale s Copper Cliff Smelter Complex was not able to identify new options to reduce the creation and release of VOCs. Vale s Sudbury Operations have committed to and started to deploy projects that will reduce the creation of VOCs. The Clean AER (Atmospheric Emissions Reduction) project will make several significant changes to the consumption of natural gas at the Smelter Complex, the source for the creation of VOCs. 5. Description of Substances 5.1. Carbon monoxide

Carbon monoxide is created from the incomplete combustion of natural gas in heaters and burners used throughout the Smelter complex. Natural gas is used in burners/heaters for supplementary heat in the process, heating of process gas and equipment and, in some areas, provide heat for the workroom environment. 5.2. 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 Smelter with bulk (nickel) concentrate from the Mill being the primary source. It is the goal of the smelting and refining process to remove the undesirable impurities 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. Sulphur is a necessary component in the feed material for the flash furnaces. The exothermic reaction caused by the creation of sulphur dioxide is needed in order for the feed material to flash smelt and turn into a molten material. To reduce the emissions of sulphur dioxide to the atmosphere, the process gases from the Smelter Complex are captured and the sulphur recovered into the form of sulphuric acid. 5.3. Particulate matter Particulate matter is created during the processing of the metals concentrate through high temperature chemical processes to recover metals. Volatile metal oxides and sulphides are produced during the metallurgical processes and enter the off-gas stream, collected and sent to pollution control equipment. Fugitive particulate matter emissions can occur during charging of materials and by the movement of materials. 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. PM 10 and PM 2.5 are particle size fractions of the total particulate matter produced and emitted. PM 10 dust particles are approximately 10 micrometers in size or less and PM 2.5 are particle size of approximately 2.5 micrometers or less. 5.4. Nitrogen oxides Nitrogen oxides are produced from the combustion of natural gas in heaters and burners used for supplementary heat in the process, heating of process gas and equipment and, in some areas, provide heat for the workroom environment throughout the Smelter Complex. NO x is created through the thermal dissociation and subsequent reaction of nitrogen (N 2 ) and oxygen (O 2 ) molecules in the combustion air. 5.5. VOCs VOCs are created from natural gas combustion at the Smelter Complex. Natural gas is used for supplementary heat in the process, heating of process gas and equipment, and, in some cases, to provide heat for the workroom environment.

6. Rationale as to Why No Reduction Options Were Selected 6.1. Carbon monoxide Even though several reduction options were identified for carbon monoxide, at this time, these options were not selected for implementation. At the moment it is impossible to provide an absolute reduction estimate for the creation of carbon monoxide at the Smelter Complex, as the process flow for the move to a one furnace operation is still being developed. Until the process flow is finalized, the anticipated reduction of natural gas usage and establishing a definitive timeline cannot be made at this time. 6.2. Nitrogen oxides Even though several reduction options were identified for nitrogen oxides, at this time, these options were not selected for implementation. At the moment it is impossible to provide an absolute reduction estimate for the creation of nitrogen oxides at the Smelter Complex, as the process flow for the move to a one furnace operation is still being developed. Until the process flow is finalized, the anticipated reduction of natural gas usage and establishing a definitive timeline cannot be made at this time. 6.3. Particulate matter Even though several reduction options were identified for particulate matter, at this time, these options were not selected for implementation. The options presented did not meet the technical or economic feasibility criteria established by the facility. Abatement of particulate matter emissions has been a long standing objective at the Copper Cliff Smelter. Part of Vale s continued initiatives to reduce metals and particulate matter emissions. 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, particulate matter emissions for the Smelter will be reduced to meet the Federal Pollution Prevention Planning emissions targets. Engineering and procurement for Smelter upgrade work is currently underway at the facility. 6.4. Sulphur dioxide Vale s Sudbury Operations were not able to identify options to reduce the creation of sulphur dioxide at the facility. The current process flow at the Copper Cliff Smelter Complex is designed to process nickel sulphide (bulk) concentrate at the Flash Furnaces. The exothermic reaction produced by the combustion of iron and sulphur maintains the heat balance needed for the smelting process. Sulphur dioxide capture and abatement continue to be the focus of Vale s Sudbury Operations for the reduction of sulphur dioxide emissions from the facility. Abatement of SO 2 emissions has been a long standing objective at the Copper Cliff Smelter. Historically, Vale has met improved annual emission targets and has achieved significant SO 2 reductions since the late 1970s. With decreasing SO 2 emission allowances in Ontario, in the early 1990s the Copper Cliff Smelter examined many alternative SO 2 abatement technologies and flowsheets before adopting the current process flow. This strategy for SO 2 abatement consists of optimizing the use of the chemical energy that is generated by oxidation of the iron sulphide species found in the bulk concentrate. Using the available oxygen technology, a new flash furnace was designed and constructed at the Copper Cliff Bulk Smelter leading to high SO 2 off-gas streams amenable to economic fixation through utilizing a Sulphuric Acid Plant and Liquid SO 2 Plant. The main fuel for the Flash Furnace is pyrrhotite (FeS) found in the bulk concentrate, which contains the highest

amount of iron and sulphur. The combustion of the iron and sulphur is an exothermic reaction within the Flash Furnace free board. When the sulphur flashes in the furnace the reaction with oxygen converts the sulphur into sulphur dioxide and heat. Within the bulk converters, the reaction of pyrrhotite (FeS) and oxygen also provides the necessary heat for the converting process. The conversion of sulphur dioxide from the off-gas to sulphur products at the Sulphuric Acid Plant is a necessary stage in the smelting process providing pollution control required to operate the facility with current environmental regulations and targets. Mid-2013, the Liquid SO 2 plant was shut-down, stopping the creation of liquid SO 2 on property. 6.5. VOCs Even though a reduction option was identified for creation of VOCs, 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. Due to possible construction and cash-flow restrictions associated with the construction and commissioning of the Clean AER (Atmospheric Emissions Reduction) project, the reduction of natural gas combustion at the Smelter Complex due to the Clean AER will only be considered for implementation once the Clean AER project is undergoing the commissioning phase of the project. 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 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 carbon monoxide, nitrogen oxides, particulate matter, sulphur dioxide and VOCs creation at the Copper Cliff Smelter Complex, Sudbury Operations, prepared for Vale Canada Limited, dated December 2013. The content of the summary is up to date and reflects the current version of the toxic substance reduction plan.