2018 Environment Management System Community Engagement … · 2019-05-31 · Page 4 of 20 Vale 2018 Environment Management System & Community Engagement Report (March 30, 2019) 2.1

2018 Environment Management System&

Community Engagement Report

March 30, 2019

Page 1 of 20

Vale 2018 Environment Management System & Community Engagement Report (March 30, 2019)

Table of Contents

A. SUMMARY .................................................................................................................................................... 2

1 BACKGROUND .............................................................................................................................................. 3

2 COMMUNICATIONS AND COMMUNITY ENGAGEMENT ................................................................................ 3

2.1 CLEAN AER PROJECT CELEBRATION ............................................................................................................................... 42.2 VALE WEBSITE ............................................................................................................................................................ 62.3 OPEN HOUSE ............................................................................................................................................................. 6

3 COMMUNITY AIR QUALITY MONITORING .................................................................................................... 7

3.1 SULPHUR DIOXIDE ....................................................................................................................................................... 73.2 NICKEL ...................................................................................................................................................................... 8

4 EMISSIONS REDUCTION PROGRAM UPDATE .............................................................................................. 10

5 ENVIRONMENTAL COMMUNITY CONCERNS ............................................................................................... 10

6 ACTION PLAN UPDATES .............................................................................................................................. 12

7 CONTACT INFO ........................................................................................................................................... 15

8 APPENDIX ................................................................................................................................................... 16

8.1 SO2 MEASUREMENTS ................................................................................................................................................ 168.2 NICKEL/ TSP MEASUREMENTS ................................................................................................................................... 18

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A. Summary

Nickel and sulphur dioxide (SO2) Site Specific Standard Approvals were issued by the Ministry ofthe Environment, Conservation and Parks (MECP) to Vale’s Ontario Operations for its Copper CliffSmelter Complex in the years between 2011 and 2014. The approvals included a request toimplement communication and community engagement plans and to form an EnvironmentalMonitoring Team (EMT). This seventh annual report documents 2018 community activities andenvironmental accomplishments.

A number of events and meetings were held in 2018 in an effort to deliver information to thecommunity about Vale’s environmental activities and initiatives. These include the annual OpenHouse, EMT meetings and Copper Cliff Liaison Committee (CCLC) meetings as well as a CleanAER Project Completion Celebration Luncheon and News Conference.

Vale’s Canadian website, www.vale.com/canada is also an excellent resource for informationabout the company’s environmental performance and community involvement. Current and recentenvironmental monitoring results as well as real-time, recent and historical monitoring results areposted on the website. Details about monitoring programs, emission reductions, dust emissionscontrols and other environmental initiatives can also be found at:

http://www.vale.com/canada/en/aboutvale/communities/sudbury/sudbury-environment/our-commitment-to-air-sudbury/pages/default.aspx

Concentrations of SO2, total suspended particulate (TSP) and metals are measured at severalmonitoring stations in the community. In 2018, there were a total of five exceedances of variousair quality standards attributable to Vale operations: one TSP exceedance, two 24hr nickelexceedances and two nickel annual exceedances. Many of the exceedances occurred on thesame day (April 14, 2018). Details are provided and discussed both in the report and in theAppendix. There were three exceedances of the 1-hour SO2 standard in 2018 measured at theSO2 monitoring stations, but none of these were attributed to Vale operations.

Vale continued to operate an Emission Reduction Program (ERP) to limit SO2 emissions from itsoperations by curtailing production on days when dispersion/weather conditions were such thatground level concentrations in the community were predicted to exceed provincial air quality limits.

Vale received less complaints from community members in 2018 compared to previous years. In2018, a total of 76 complaints were received, compared to 78 in 2017 and 171 in 2016. Allcomplaints were documented, investigated and followed up. An analysis of these complaints and asummary of how Vale responded to them is detailed in the report that follows.

Nickel Action Plan updates were submitted to Ministry of the Environment, Conservation and Parks(MECP) in March and September 2018 and were subsequently posted on the Vale Canadawebsite. The final SO2 Action Plan update was submitted in March (SO2 Site Specific StandardApproval expired end June 2018).

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1 Background

At the end of 2018, the following air quality related approvals from the Ministry of the Environment,Conservation and Parks (MECP) were in effect at the Vale Copper Cliff Smelter:

· Amended Environmental Compliance Approval # 6785-9BXPTC (issued January 2014)· Nickel Site Specific Standard Approval (annual) # 502-11-rv0 (issued December 2011)

Note:Ø Sulphur Dioxide Site Specific Standard Approvals (1-hr) # 503-12-rv1 and (24-hr) # 504-

12-rv1 (revised April 10, 2017) were only valid until June 30, 2018; on July 1st, limitsreverted to “regular” Ontario air quality standards.

The site-specific standard approval contains a requirement to form an Environmental MonitoringTeam (EMT) with representation from the community, the MECP and Vale. The purpose of the EMTis to serve as a forum for dissemination, consultation, review and exchange of information regardingthe operation of the Smelter, environmental issues such as air monitoring, analysis of monitoringdata, and to review any new or amended Ministry approvals, as required.

The group was formed by inviting members of an existing community stakeholder group, the CopperCliff Liaison Committee (CCLC), which includes representation from the MECP, and two membersof the Gatchell Community Action Network, to participate. The EMT received updates of monitoringresults, Action Plan progress, and communications initiatives at meetings held in March andNovember of 2018.

This report documents the work of the EMT and the communications activities undertaken by Valein 2018.

2 Communications and Community Engagement

The EMT followed the communication plan it developed in 2012, which is based on the premise ofproviding proactive, transparent and timely communications that update current performance andthe progress of Vale’s Action Plan to meet the requirements of its Site-Specific Standard (SSS)Approvals.

Information was shared through the course of the year via:

· A Clean AER Project Celebration Luncheon and News Conference· The environment section of www.vale.com/canada· The Annual Report to Community· Vale’s Annual Open House· Meetings with community groups

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2.1 Clean AER Project Celebration

In September 2018, Vale celebrated the completion of its $1 billion Clean AER Project and the85% reduction in SO2 that it achieved as well as the 40% reduction in metals particulate and GreenHouse Gas emissions. Local media, politicians and environmental experts were invited to Vale’sCopper Cliff Smelter Complex to learn about the project, see some of the facilities first hand and todiscuss the project’s air quality improvements and community impact. News conference attendeesalso participated in a butterfly release to symbolize the transformation that has taken place at theSmelter with the completion of the Clean AER Project. Extensive media coverage resulted fromthe news conference.

Following the news conference, participants joined community leaders for a luncheon in CopperCliff to celebrate the completion of the Clean AER Project. A key highlight of the event was a videoabout the Clean AER Project, which focused on its community impact. The video played at thestart of every film presentation at the Sudbury Silver City Cinema during the month of Septemberand October. It was also shared through Vale’s social media channels and continues to beavailable on the Company’s Clean AER Project web page here:

http://www.vale.com/canada/EN/aboutvale/communities/sudbury/Clean-AER/Pages/default.aspx

Clean AER Project Celebration• Hosted a news conference by the

new Wet Gas Cleaning Plant andluncheon at Bryston’s September 14th

• Earned media generated nearly 17million positive media impressions!

• Paid advertising generated a totalreach of over 1.3 million impressions

• Dozens of key communitystakeholders directly engaged andinformed about the completion of theClean AER Project

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2.2 Vale Website

In addition to the Clean AER Project web page, Vale’s website, www.vale.com/canada, alsoincludes air quality information that further fulfill its site-specific standard approval requirementshere:

http://www.vale.com/canada/EN/aboutvale/communities/sudbury/sudbury-environment/environmental-reporting-sudbury/air-quality-monitoring-results/Pages/default.aspx

The air quality documents posted on this site include:· Most recent and historical metals and SO2 monitoring results (reported quarterly)· Glossary of terms· Details about the monitoring and emission reduction programs, and· Information about dust emission controls

The website also includes information about Vale in the community as well as information aboutthe company’s water, reclamation and decommissioning management activities.

2.3 Open House

Vale’s annual Open House on September 19th, 2018 was its best ever with over 300 people inattendance to learn about the Company’s Sudbury Operations and environmental initiatives atDynamic Earth with a variety of interactive exhibits. The Clean AER Project and its Action Plans forits site-specific standard approvals for SO2 and nickel as well as a variety of other environmentalinitiatives at Vale were a key highlight of the event. Visitors also had the opportunity to go on anunderground tour, compliments of Vale.

Invitations to the event were sent to key community stakeholders. The event was also free to thepublic and widely advertised on local radio stations, electronic media and to local schools.

Photos from the September Open House are provided below.

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3 Community Air Quality Monitoring

3.1 Sulphur Dioxide

There are 18 fixed continuous SO2 monitoring stations located in the community, owned by Valeand Sudbury Integrated Nickel Operations, a Glencore Company and operated and maintained byBESTECH Ltd. In addition, the network includes the operation of three meteorological towers andVale’s mobile SO2 monitoring unit. The mobile unit is used to measure ground level concentrationsof SO2 in areas of the community not covered by the 18 fixed stations. A map indicating thelocation of the stations is provided (see figure 1).

In addition to the real-time monitoring data, quarterly and annual reports of SO2 concentrationsmeasured at the fixed stations were compiled and reported by an independent consultant andsubmitted to the MECP. The reports are posted on the Vale website on a quarterly basis.

Results from the monitoring network indicate that annual mean SO2 concentrations in 2018 werelower at all stations than in previous years. The highest annual average in 2018 at any of the Valestations was measured at the Union Street station, at a value of just greater than 0.002 ppm. Thisshows an improvement over levels that were already low in previous years. The Appendixprovides a graph showing the 2018, 2017 and 2016 mean annual SO2 concentrations for all thestations.

On a short-term basis, there were three exceedances of the 1-hour SO2 standard in 2018measured at the SO2 monitoring stations, none of these attributed to Vale operations. The highestmaximum 1-hour SO2 measured in 2018 at any of the Vale stations was measured at the SpruceStreet station, at 0.134 ppm. The Appendix provides a graph showing the 2018, 2017 and 2016maximum 1-hour SO2 concentrations for all the stations.

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Figure 1: Sudbury SO2 Monitoring Network

3.2 Nickel

Vale’s particulate sampling network operates on concurrent 3-day or 6-day sampling schedules,with 9 stations operating monitors that collect particulate matter on filters over a 24-hour period.The filters were sent to an independent lab/consultant for gravimetric and metals analyses andreporting in 2018.

Quarterly reports are posted on the Vale website as they become available (several months lagtime required for filter and data analysis). A map showing the location of the monitoring stations isprovided below. The map shows 9 stations, including the newest station at Fielding Road,installed in the summer of 2017.

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Figure 2: Vale’s particulate sampling network

In 2018, the following nickel standards were in effect:

· 24-hr Upper Risk Threshold (URT) of 2 µg/m3 nickel· Annual average standard of 0.04 µg/m3 for Power Street and Fielding Road· Annual average standard of 1.0 µg/m3 for the remaining monitoring stations to reflect the

site-specific standard in effect until December 2021

In addition, there is a 24-hour standard for Total Suspended Particulate of 120 µg/m3

There were four nickel exceedances measured in 2018, two of the 24-hr URT and two of theannual standard. The 24-hour total suspended particulate (TSP) standard was also exceeded onone day (on the same day as one of the nickel incidents). Details and discussion about theseevents along with graphs showing all the measured values are provided in the Appendix.

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4 Emissions Reduction Program Update

Vale’s Emissions Reduction Program (ERP) is a significant contributor to the company’s positiveSO2 emissions performance. This program limits SO2 emissions to the atmosphere by curtailingproduction at the Smelter when dispersion conditions are such that unacceptable ground levelconcentrations of SO2 are anticipated or experienced in the communities located around theSmelter property. ERP operators monitor Smelter operating conditions 24 hours per day, 7 days aweek and control production accordingly.

On January 1, 2017, the SO2 air quality standard limit that applied at the monitoring (and mobile)stations dropped from 0.340 ppm to 0.250 ppm. Vale’s Smelter Operations team respondedaccordingly and amended the ERP program that included longer periods of cutbacks and moresevere cutbacks to production in order to remain in compliance. With the expiry of the SulphurDioxide Site Specific Standard Approval (1-hr and 24-hr) on June 30th, 2018, the ERP programwas once again amended to allow for the implementation of cutbacks to ensure compliance tomodelled SO2 emissions.

5 Environmental Community Concerns

The Smelter Environmental Compliance Approval and Nickel Site-Specific Standard Approvalsrequire Vale to make a telephone number available to the public to register environmentalcomplaints and requires all complaints be documented and followed up. Vale has had a process inplace to address community concerns for many years. For the Smelter, there is a telephonenumber, 705-682-8283, that is answered by a Smelter employee 24 hours per day, 7 days perweek. Vale also has a general community concerns line at 705-222-VALE that is also answered 24hours per day, 7 days a week by an answering service; Vale employees respond to the concernsreceived on this line within 48 hours.

The Smelter Environmental Concerns Summaries for 2016, 2017 and 2018 are presented in thefollowing graph. There was a total of 76 community concerns logged in 2018, compared to 78 in2017 and 171 in 2016. The figure below depicts the number of complaints received per annum,categorized by type.

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Figure 3: Vale Smelter Environmental Concerns Summary for 2016 to 2018

It is important to note that the decreasing trend in the number of complaints received continued in2018, with lower totals in multiple categories. There was however a slight increase in the numberof complaints received related to “SO2 fugitive emission”, “Fallout” and “Unknown” categories. The“unknown” category refers to complaints where after investigation, Vale was unable to identify thesource of concern.

The number of “Fluid Bed Dryer Odour” calls were slightly lower than in previous years. TheAction Plan which was developed and shared with the MECP in December of 2017, in an effort tocurb the number of calls, was implemented throughout 2018. In early 2019, the plan was furtherrefined with changes implemented. The Plan involves dedicated community odour patrols onnights when easterly winds are predicted (were not dedicated previously) with cut-back of feeddrying rates when any odour is detected as well as precautionary cutbacks of feed drying ratesunder specific wind directions.

When community concern calls are received, they are routed to the appropriate department andthe caller is contacted directly by a subject matter expert from Vale.. A complaint log form is filledout that records the date, time, name, address and phone number of the person, along with thewind direction at the time of the incident (available from Vale’s meteorological records). Specificdetails about the complaint are also logged in the form. Within one week of receiving thecomplaint, the following information is entered into the log:

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· Actions taken to investigate the cause of the complaint and result· Recommendations for remedial measures· Managerial/operational changes to avoid recurrence· Feedback given to the caller

The Smelter Environmental Compliance Approval (ECA) requires Vale to keep the complaintrecords on file for seven years, and to submit quarterly reports to the MECP summarizing theinformation about the complaints, including follow-up details. This information was submitted tothe MECP in Q1 (April 2018), Q2 (July 2018), Q3 (October 2018) and Q4 (February 2019).

Feedback on community concerns is also actively sought and logged at Vale’s annual OpenHouse and through its annual Report to the Community. The company invites the public to expresstheir concerns through a variety of methods (phone lines, email, feedback forms and in person).

6 Action Plan Updates

As part of its submission for site-specific standards for nickel and SO2, Vale submitted ActionPlans to the MECP to reduce its overall emissions and ground level concentrations in thecommunity. These Action Plans became conditions and were appended to the site-specificstandard approvals. Vale prepares a report to update the status of its Action Plans semi-annually,in March and September. The updates are posted on Vale’s website at:

http://www.vale.com/canada/EN/aboutvale/communities/sudbury/sudbury-environment/environmental-reporting-sudbury/air-quality-monitoring-results/Pages/default.aspx

Some main points are as follows:

SO2:· The site-specific standards (SSS) for SO2 expired on June 30, 2018. To comply with the

Ontario standards, both at the monitors and in the dispersion modeling, the EmissionReduction Program (ERP) was modified based on a comprehensive modelling study.

· As Converters 6 and 11 were still connected to the Super Stack, the operation ofConverters 6 and 11 were curtailed according to the dispersion modelling study as well asmeteorological conditions. By the end of 2018, both converters were shut down.

· Once Converters 8 and 10 were connected to the Wet Gas Cleaning Plant, such that SO2

emissions are now converted to saleable sulphuric acid, their operation no longer requiredcurtailment, aside from the timing of the nitrogen blow phase

· Once the Converter 8 and 10 secondary offgas were tied into the Copper Stack, restrictionson the timing of the nitrogen blow phase were initiated due to complaints from thecommunity regarding short term SO2 impact as well as concerns from workers on the new450’ stacks. The restrictions required the first portion of the nitrogen blow to be directed tothe Converter Wet Gas Cleaning Plant under specific meteorological conditions

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Nickel:· Fugitive Dust management practices at the Smelter continued as per requirements set out

in the Fugitive Dust Management Practices manual (updated annually and submitted toMECP every spring).

· Changes in Vale’s flowsheet and economic conditions in 2017 necessitated thecancellation of the construction of 2 new material handling buildings on the Smelterproperty. These had been in the original AER scope. A number of alternativeconfigurations are being considered by Vale management, including moving the handlingactivities to a different location. Multiple dispersion model runs have been undertaken, toensure that alternatives meet the MECP air quality standards. Monthly updates to theMECP are provided.

Clean AERThe Clean AER Project is now complete. 2018 saw the completion of the following:

· Tie-in of the furnace uptake fugitive vents to the overall furnace fugitive collection system.This redirected the furnace uptake fugitive emissions from a side wall vent to the CopperStack instead of out a side wall vent.

· Commissioning and ramp-up of the Converter Wet Gas Cleaning Plant. High strength SO2

off-gas from the oxygen blowing phase of Converters 8 and 10 were redirected from theSuper Stack to the Converter Wet Gas Cleaning Plant.

· Commissioning and ramp-up of the Secondary Off-gas System. This duct system combinedthe furnace fugitive stream (including the furnace uptake fugitives described above) with thesecondary off-gases collected over Converters 8 and 10 as well as the off-gases collectedover the Converter Slag Cleaner, and directed the combined stream through a SecondaryBaghouse and out the Copper Stack.

· Lift tube conveyors were installed on M-Floor

Operational modifications and improvements will continue into 2019, particularly on the SecondaryBaghouse which experienced process difficulties upon startup.

Construction of the new 450ft stacks for the Surface Facilities Upgrade Project continued through2018. The concrete shells are complete and work on the liners will be the focus in 2019. Tie-insto the new stacks are scheduled for 2020.

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Figure 4: New Converter

Figure 5: New Wet Gas Cleaning Plant (right); Smelter & Superstack (left)

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Figure 6: Secondary Baghouse and Fan Building, Construction Complete

7 Contact Info

For more information or to discuss this report, contact Lisa Lanteigne, Manager – Environment,Ontario Operations, Vale Canada Limited at: [email protected] 705-682-8172, or GaryRemington, Superintendent – Environment, Ontario Operations, Vale Canada Limited at:[email protected] or 705-682-6866.

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8 APPENDIX

8.1 SO2 Measurements

Summary graphs of the SO2 measurements taken at the 18 stations in 2018 are provided in thisAppendix. Very low SO2 concentrations were measured at all stations for most of the year; allstations were calculated to have annual arithmetic mean concentrations that were less than0.002ppm SO2 in 2018, except for Union station which was just above 0.002ppm SO2

(presented in Figure 7).

The Emission Reduction Program (ERP) operators reduce Smelter operations when theypredict adverse air dispersion conditions that have the potential to cause an exceedance of theSO2 standards in the community. The decrease of the 1-hr SO2 (monitored) standard from0.340 ppm to 0.250 ppm on 1 January 2017 resulted in more frequent cut-back hours in 2017and 2018 than in 2016.

In 2018, sulphur dioxide gases from Converter #10 (beginning in April) and Converter #8(beginning in in May) were permanently redirected from the Super Stack to be treated in thenew Converter Wet Gas Cleaning Plant and the Acid Plant, off-gas from Converters 6 & 11 stillexhausted to the Super Stack (with ERP control) until the end of 2018 Additionally, the SO2 SiteSpecific Standard Approval (1-hr and 24-hr) expired on June 30, 2018 resulted in furtheramendments to the ERP program to ensure compliance to these legislative changes. Thesechanges were only applicable to Converters 6 and 11 as all the SO2 emissions from Converters8 and 10 are now captured. All of these factors contributed to lower measured SO2 emissionsattributed to Vale’s operations at monitoring stations during 2018.

The maximum 1-hour values for each station (presented in Figure 8) also exhibit a downwardtrend, with significantly lower maximum 1-hr SO2 concentrations than in previous years for moststations. Three 1-hour exceedances were measured in 2018, but none of these are attributed toVale’s operations.

The graphs on the following page provide a summary of the 2016, 2017 and 2018 hourly (clock)maximum and mean SO2 values.

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Figure 7: SO2 Annual Mean Concentrations: All Stations

Note: There were three exceedances of the 1-hour SO2 standard in 2018 measured at the SO2 monitoring stations,none of these attributed to Vale operations.Figure 8: SO2 Maximum 1-hour and Annual Mean Concentrations

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8.2 Nickel/ TSP Measurements

Nickel Exceedances

There were two exceedances of the nickel Upper Risk Threshold (URT) of 2 µg/m3 occurring onApril 14th at the Venice St. monitoring station (5.99 µg/m3) and at the Copper Cliff Creekmonitoring station (4.04 µg/m3). There were severe wind conditions on April 14th with gustsreaching above 50 km/hr at times. There were several sources of dust including materialhandling areas, roads, and the general property. Conditions were dry and full dust controlmeasures had not been started yet due to freezing temperatures.

There were two exceedances of the nickel annual standard of 0.04 µg/m3 at the Power Stmonitor (0.065 µg/m3) and Fielding Road monitor (0.046 µg/m3).

Total Suspended Particulate Exceedances

On February 22nd there was an exceedance of the 24-hour Total Suspended Particulate (TSP)limit of 120 µg/m3 at the Dynamic Earth monitoring station (180 µg/m3). Winds on that day werelight but blowing primarily from the Smelter property. The investigation concluded that thecause was from a combination of road dust at the Smelter and from municipal roads.

All of these events have been scrutinized and analyzed with management at the Smelter, withthe aim of preventing future occurrences from these sources. The aforementioned SmelterMaterial Handling project will provide better controls and increase the buffer between thematerial handling sources and the community, thereby decreasing the potential for futureexceedances.

Nickel monitoring data for 2016, 2017 and 2018 for the 9 air quality monitoring stations arepresented in the two graphs that follow. The most recent and historical detailed monitoringresults for these and other metals measured at these stations are posted on the Vale website.

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Figure 9: 24-hour Measured Nickel in TSP – all stations 2016 to 2018

Note: The Power Street and Fielding Road stations are not included in the nickel Site-specific Standard (SSS) for theCopper Cliff Smelter and as such fall under the Ontario annual standard limit of 0.04µg/m3.Figure 10: Annual averaged Nickel concentrations – all stations 2016 to 2018

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2018 Environment Management System Community Engagement … · 2019-05-31 · Page 4 of 20 Vale 2018 Environment Management System & Community Engagement Report (March 30, 2019) 2.1