March 24, 2015 Action Plan Status Update : Copper Cliff Smelter Site-Specific Standard Approvals for Sulphur Dioxide, # 503-12-rv0, 504-12-rv0 Context On December 24, 2012 the Ministry of Environment issued Vale Canada Limited two Site-Specific Standard Approvals for sulphur dioxide at its Copper Cliff Smelter. #503-12-rv0 is the 1-hr Site-Specific Standard Approval, #504-12-rv0 addresses the 24-hr standard. Vale submitted an action plan with its application and this became Appendix 1 in the Approvals; it is appended to this report. The reference numbers in the action item updates below are those in Appendix 1. The update of each action item is detailed below:

Action Items 1. In January 2013 Vale’s Ontario Operations announced it will be moving to a single-furnace

operation, which has resulted in a reshaping of the Clean AER Project plan. The single-furnace Clean AER project will deliver significantly improved environmental outcomes. Early calculations estimate an 85% SO2 emissions reduction from current levels. Also expected are significant additional reductions in particulate and metals emissions and concentrations in the community.

In 2014 work was focused on developing the revised Clean AER project execution plans which included scope, schedule, cost, business implications, opportunities and risk. Additionally, execution work unaffected by the move to a single furnace operation has continued. The updated project execution plan was completed in December and is being communicated and reviewed by Vale leadership.

Work scheduled and accomplished in 2014 follows. Progress photographs are included in Appendix 2.

Project Development FEL 3 Quality Engineering:

• Converter blast air blower design • Concentrate receiving / revert facility modifications • Converter scrap handling facility • Cooling Tower rationalization • 1250 ft stack vs 450 ft stack trade off study • Site wide noise study • Vermillion water study

Continued detailed engineering:

• Weak Acid treatment plant scrubber • Furnace ‘M’ floor conveyors

• Converter #10 • Converter hood cooling • Fluid Bed roaster baghouse • Secondary baghouse and fan room • Primary and secondary flues • Converter wet gas cleaning plant • Clarabelle Mill Copper oxidation and separation upgrades • Filter Plant pressure filters

Construction:

• Slag skull area wind fencing • Major Service tie-ins completed • Construction started on the: Mobile equipment shop,

o Material handling building at the Nickel Refinery o Weak acid treatment plant SO2 scrubber

• Converter #10 demolition started

The ramp-up and operation of Converter #8 has proven to be successful. The converter completed the first campaign in April 2014. During the scheduled repair period additional improvements were completed to the primary and secondary hoods to increase SO2 gas capture and decrease dilution. The objectives for Converter #8 were:

• Safe and reliable production • Consistently high blowing rate • Tight fitting hood to enable high strength SO2 to Acid Plant • Improved workroom environment and fewer fugitives from aisle roof monitors

In 2015 the Project team is focusing on detailed engineering and procurement for the critical path items and continued construction activities.

Detailed Engineering and Procurement:

• Converter #5 • West end material handling • Converter scrap handling building • Concentrate receiving and revert building modifications • Wet gas cleaning plant • #1 acid plant modification • MK filtration and load out facility • #2 furnace upgrades • Stack modification • Planned Maintenance Period service tie-ins

Construction:

• Converter #10 demolition and structural steel • Weak acid treatment plant SO2 scrubber completion • Nickel refinery material handling building completion • Fluid bed roaster baghouse completion • Clarabelle Mill oxidation and separation upgrades completion • Filter Plant pressure filter installation completion • Site concrete, foundation and piling work started

2. The sulphur dioxide Emissions Reduction Program (ERP) has been in existence since the

1970’s, originally voluntary, and later mandated through various legal instruments issued by the Ministry; it is currently mandated by the Smelter Environmental Compliance Approval, # 4414-92QPT8. The purpose of the ERP is to limit sulphur dioxide emissions to the atmosphere by curtailing production at the Smelter on days when dispersion conditions are such that unacceptable ground level concentrations of SO2 are anticipated or experienced in the community. Details of ERP, the daily control forecasts, and real-time and historical community SO2 monitoring network data are available on Vale’s website: http://www.vale.com/canada/en/aboutvale/communities/health-safety-environment/our-environment/air-quality/sudbury-air-quality/pages/default.aspx This item is complete and ongoing, as reported March 18, 2013.

3. A second Combined Analysis of Modelling and Monitoring study was conducted to better

correlate measured to modelled sulphur dioxide results in the community. The report was submitted to the Ministry of Environment on June 14, 2012. This item is complete, as reported March 18, 2013.

4. Vale annually reviews its sulphur dioxide Emission Reduction Program (ERP) and looks for

opportunities to enhance the program. As work progresses on the Clean AER project and single furnace operation, and detailed engineering is completed on the scope elements, work to enhance ERP for the few remaining sources of sulphur dioxide will be undertaken. This will occur in stages between 2015 and 2017.

5. A new continuous sulphur dioxide monitor was installed on Union Street in the Little Italy

area of Copper Cliff in consultation with the Ministry of Environment. It was commissioned in November, 2012. Real time data and historical data for the entire Sudbury air quality monitoring network are available on Vale’s website, http://www.vale.com/canada/en/aboutvale/communities/health-safety-environment/our-environment/air-quality/sudbury-air-quality/pages/default.aspx This item is complete, as reported March 18, 2013.

6. Following completion of the Clean AER project, source testing will be performed and a

Combined Analysis of Modelling and Monitoring study will be conducted to verify the emissions reduction accomplishments of the project and the enhancements made to the Emissions Reduction Program. This is planned to occur in 2017 and 2018.

Appendix 2: Progress Photographs

Converter No. 8

Converter No. 10 Demolition, shell and foundation removal

MYN Storage Facility at the CCNR: foundations, structural steel and baghouse

Mobile Equipment Shop, structural steel and building cladding