Construction Environmental Management Plan

Construction Environmental

Management Plan

Revision

# Date Page

Plan No.

507763-000-0000-4EPA-0008

06 2014-08-07 2 of 35

TABLE OF CONTENTS

DEFINITIONS/GLOSSARY OF TERMS 4

1.0

INTRODUCTION 6

1.1

Purpose ............................................................................................................................... 7

1.2

Scope .................................................................................................................................. 8

2.0

ROLES AND RESPONSIBILITIES 8

2.1

Vale ..................................................................................................................................... 9

2.2

SLI ..................................................................................................................................... 10

2.3

Contractors ........................................................................................................................ 13

3.0

ENVIRONMENTAL POLICY AND PLEDGE 14

3.1

Corporate Environmental Policy ........................................................................................ 14

3.1.1

Project Pledge ................................................................................................................ 15

4.0

REGULATORY AND OTHER REQUIREMENTS 15

5.0

CONSTRUCTION ACTIVITIES, ENVIRONMENTAL ASPECTS AND IMPACTS 16

5.1

Initial identification of Aspects and Impacts ....................................................................... 16

5.2

Environment Focused Management Plans ........................................................................ 16

6.0

ENVIRONMENTAL RISK 20

6.1

Management of Environmental Impacts ............................................................................ 20

6.2

Process Hazard Review .................................................................................................... 21

6.3

Job Environmental Analysis Program ................................................................................ 21

7.0

GOALS, OBJECTIVES AND TARGETS 22

7.1

Key Performance Indicators .............................................................................................. 22

8.0

LEARNING AND COMPETENCE 23

8.1

General Project Orientation ............................................................................................... 23

8.2

Specific Environmental Training ........................................................................................ 23

9.0

SUPERVISION, INSPECTIONS, MONITORING AND REPORTING 27

9.1

Inspection of Other Construction Impacts.......................................................................... 27

9.2

Environmental Monitoring .................................................................................................. 27

10.0

CONTROL OF NON-CONFORMANCE 29

10.1

Audit and Review of Performance ..................................................................................... 30

11.0

COMMUNICATION AND REPORTING 30

11.1

External Communications .................................................................................................. 30

11.2

Internal Communications ................................................................................................... 31

11.2.1

Environmental Topic Communication Highlights ......................................................... 32

11.3

Environmental Reporting ................................................................................................... 32

J:\507763\40-ENG\4E-ENV\PA-Planning\8 Construction EMP\507763-000-0000-4EPA-0008 rev 06.doc


Management Plan

Revision

# Date Page

Plan No.

507763-000-0000-4EPA-0008

06 2014-08-07 3 of 35

11.3.1

Environmental Topic Reporting Highlights .................................................................. 32

12.0

RECORDS, DOCUMENTATION AND DOCUMENT CONTROL 33

13.0

REFERENCES 34

LIST OF TABLES

Table 5-1: Supporting Environmental Management Plan Summaries .............................................17

Table 7-1: Environment Focused Key Performance Indicators .......................................................23

Table 8-1: Environmental Learning Requirements ..........................................................................25

LIST OF FIGURES

Figure 2.1 – Organization Chart: Environmental Management Highlighted

LIST OF APPENDICES

Appendix A Clean AER Project Pledge



Management Plan

Plan No.

507763-000-0000-4EPA-0008

DEFINITIONS/GLOSSARY OF TERMS

Revision

# Date Page

06 2014-08-07 4 of 35

Codes: Rules and standards which have been adopted, by a Government agency or professional regulatory body, as mandatory regulations having the force and effect of law.

Environment*: Surroundings in which an organization operates, including air, water, land, natural resources, flora, fauna, humans, and their interrelation.

Environmental Aspect*: An element of an organization’s activities, products or services which can interact with the environment and can have an impact.

Environmental Audit*: A systematic and independent examination to determine whether environmental activities and related results comply with planned arrangements and whether these arrangements are implemented effectively and are suitable to achieve objectives.

Environmental Impact*: Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization's activities, products or services.

Environmental Incident: An undesired event, condition or behaviour that may or may not result in negative effect on the environment, harm to people, damage to property, or loss to process. Environmental Incidents can be further described as resulting in a negative effect to the environment or harm to people or were considered a near miss. (Source: Vale,

Injury, Incident and Condition Reporting Process Requirements SPI)

Environmental Management*: That aspect of the overall management function that determines and implements the environmental policy.

EMP: Acronym signifying Environmental Management Plan.

Environmental Management System (EMS)*: That part of the overall management system which includes organizational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy.

Environmental Objective*: Overall environmental goal, arising from the environmental policy, that the organization sets itself to achieve, and which is quantified where practicable.

Environmental Policy: Statement by the organization of its intentions and principles in relation to its overall environmental performance which provides a framework for action and for the setting of its environmental objectives and targets.



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 5 of 35

06

06

Job Environmental Analysis: Often called “JEA” or Critical Task Analysis is a component of Job Hazard Analysis (JHA)/ Process Hazard Review (PHR). Negative impacts to the environment should be thought of as an Identified Hazard and assessed for risk and a Control developed to manage the risk to as low as reasonably achievable

(ALARA).

Job Hazard Analysis: A systematic analysis of the steps involved in doing a task, the hazards or loss exposures involved and the controls necessary to prevent loss. It is a pre-requisite to the development of Safe Work Procedures (SWPs).

KPIs: Key Performance Indicators, or specific behaviours expected of managers, i.e. being involved in specific environmental and safety activities and demonstrating safe behaviours to others.

Legal Requirement: A requirement which can be enforced by law.

Non-conformity*: The non-fulfillment of specified requirements. Examples may include:

 injury,

 imminent danger or high potential incident (Vale Class A without injury),

 property damage (including proven ‘upsets’ to Vale water treatment facilities),

 audit finding,

 regulatory inspection order,

 exceedence of legal requirement,

 environmental occurrence, or

 substantiated public or employee complaint.

Other Requirement: Other requirements are: company codes of practice, Industry codes of practice; Agreements with public authorities; non-regulatory guidelines to which the organization subscribes.

Policy: A statement which guides administration, reflects management’s attitudes and commitment to health and safety, and defines the authority and respective relationships required to accomplish the organization’s objectives.

Preventive: Those objectives/measures/indicators/targets etc that focus on “processes” or systems to prevent HSE -related incidents (often termed “pro-active”) such as the development/implementation of management systems (e.g. inspection, communication, incident investigation, training & competency assessment, auditing systems etc).

Procedure: An established and defined method of performing specified work in a step-bystep or sequential manner. There are generally “management procedures” that describe systematic management processes and “work procedures” that describe the various steps required to safely undertake a particular task.


06


Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 6 of 35

Records: Evidence that the task(s) have been performed. Examples include reports, forms, personnel qualification records, equipment qualification records, inspection and test records.

Regulatory Authority: The Federal, Provincial, Territorial, or Municipal agency having the lawful right and power to interpret the law and exercise authority.

Risk: The chance of something happening that will have an impact on objectives. Note: A risk is often specified in terms of an event or circumstance and the consequences that may flow from it.

HSE: Acronym signifying Health, Safety & Environment .

Significant Environmental Aspect: An environmental aspect that has or can have a significant environmental impact. Significance could be tied to:

 Environmental

 Health S afety concerns;

 Regulatory or legal exposure;

 Business or mission concerns;

 Environmental policy commitments; and,

 Community

Significant Risk: Those risks that have been assessed as being “extreme” or “high” using a process which is based on SLI’s Standard Risk ranking matrix.

SNC-Lavalin Inc. (SLI): EPCM Contractor for the Clean AER Project.

Standard: The defined criterion for effective HSE performance or accepted behaviours.

HSE performance standards define who is responsible for performing what work and at what frequency or when.

Work Practice: A set of guidelines for performing a specific work assignment properly

(efficiently – safely – productively).

* Term also included in the Clean AER Project Environmental Instructions Manual (507763-

000-0000-30AG-0004).

1.0 INTRODUCTION

The Construction Environmental Management Plan (CEMP, the Plan) describes the activities and resources that SNC-Lavalin Inc. (SLI) is committed to deploying during the construction of the Clean Atmospheric Emissions Reduction (AER) Project (the Project) so as to minimize negative and maximize positive impacts on the receiving environment.



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 7 of 35

Vale Canada Limited (Vale) is the Owner of the Project and SNC-Lavalin Inc (SLI) is the

Engineering Procurement and Construction Management (EPCM) Contractor and as such, acts as an agent for Vale.

The CEMP was prepared at the initiation of detailed engineering and prior to the commencement of construction and demolition. This revision of the CEMP reflects current construction practices.

The majority of the Project scope of work is occurring at the Vale Canada Ltd. (Vale) Copper

Cliff Smelter Complex in Sudbury, Ontario. Some work is planned at the Nickel Refinery and the Clarabelle Mill. The purpose of the Project is to reduce emissions of sulphur dioxide, metals and particulate to air.

Construction activities commenced at site in the first quarter of 2012. Certain detailed engineering has continued in 2014 as well as limited construction in areas such as the MYN storage facility, the mobile equipment maintenance facility, and Converter 10 demolition.

The new Surface Facilities Upgrade scope at Clarabelle Mill, the Filter Plant, MK Filtration and other areas are presently in detailed engineering. By August 2014 the Project

Execution Plan Update will be complete which will define the future project cost and scope of facilities. Execution of the remaining scope will follow in 2015, 2016 and 2017.

06

The CEMP is designed to meet requirements pursuant to the applicable laws and regulations of, as well as to meet the objectives of the SLI Environmental Policy and the

Vale Safety, Health, and Environmental Policy (North Atlantic Base Metals).

The Plan provides a framework for managing environmental incidents related to the Project.

The CEMP also provides a structured framework for the proactive identification and elimination, or acceptable management, of environmental issues that may be associated with the execution of the Project work scope.

The CEMP is in conformance with the requirements of the SLI Global Environmental

Management System (GEMS).

1.1 Purpose

The overall purpose of this CEMP is to provide management framework required for the planning and implementation of construction activities and related demolition. It has been developed in accordance with legal requirements, best management practices, SLI policy

, and the environmental risks and commitments identified.

The CEMP describes the mitigation measures or corrective actions to be taken to ensure works are being carried out in accordance with the environmental requirements, together with the checking, monitoring and audit processes that would be followed to ensure that those measures are successfully implemented.



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 8 of 35

In particular the Plan:

 Documents the strategy, intent, processes, commitment, requirements and systems for managing the environment that SLI use’s, as Vale’s agent to execute the Project;

 Reduces the risk of adverse impact of construction activities on the physical environment and minimize disturbance to resident neighbours;

 Assures legal compliance;

 Provides systematic control of environmental aspects;

 Describes environmental management related roles and responsibilities of personnel; and,

 States objectives and targets for issues important to the environmental performance of the project.

06

1.2 Scope

The CEMP applies at the Project construction site and it is implemented by SLI from the home office and from the construction site. The CEMP includes applicable and necessary information to carry out construction activities in such a way that environmental impacts are avoided, minimized or mitigated.

Several related environmental management documents developed for Project 507763 are described throughout this document and are referenced by name. SLI document numbering is provided in the Reference listing.

The CEMP requirements apply to all project management personnel and all construction personnel involved in the Project. The Project Execution Plan (507763-000-0000-30PL-

0001) requires the development of the CEMP. The CEMP works in conjunction with other management processes and the Health and Safety Plan (507763-000-0000-68AG-0001).

In support of the CEMP, specific operational instructions in the Environmental Instructions

Manual (507763-000-0000-30AG-0004) have been developed and issued to ensure that all negative environmental impacts are appropriately controlled to levels as low as reasonably achievable (ALARA). The instructions for environmental control define minimum requirements to properly mitigate or eliminate environmental aspects that have the potential to result in significant environmental impacts or incidents.

The scope of this CEMP is not applicable to the on-going Vale operations at the Smelter and

Refinery Complexes, the Clarabelle Mill and to other adjacent Vale operations (Mines etc.).

2.0 ROLES AND RESPONSIBILITIES

The lines of responsibility for environmental management during the Project are shown below in Figure 2.1. The following paragraphs identify roles and responsibilities specific to environmental management of construction activities during the Project.



Management Plan

Revision

# Date Page

Plan No.

507763-000-0000-4EPA-0008

06 2014-08-07

Figure 2.1 – Organization Chart: Environmental Management Highlighted

9 of 35

Project

Sponsor

Vale

Project Director

SNC Lavalin Inc.

Project Director

Project

Sponsor

Specialist

Support

Environmental &

Permitting Manager

Manager

,Health, Safety, Environment

(HSE)

Environmental Coordinator

TORONTO HOME OFFICE

Senior Construction

Manager (CM)

HSE Support

Environmental EIT

Area CMs

Superintendents & Inspectors

Project

Team

SUDBURY FIELD OFFICE

Central Environmental

Group

Contractor Environmental

Representative

An overall organization chart for the Project is presented in Appendix C of the Project

Instruction Manual (507763-000-0000-30AG-0001).

2.1 Vale

Project Director The Vale Project Director acts on behalf of the Project Sponsor and is ultimately accountable for HSE performance on the Project.

HSE Manager Vale’s HSE Manager reports to the Project Director and is responsible for monitoring the performance of the Project against legal requirements and the agreed environmental standards. Environmental duties of the HSE Manager include:

 Review the CEMP and specialist procedures and identify any areas for improvement;

 Review method statements for environmental aspects and advise of any suggested improvements prior to work starting;

 Oversee construction activities to ensure that identified and appropriate control measures are effective and in compliance with the CEMP; and,

 Forward Vale specific requirements to the SLI Environment & Permitting Manager.



Management Plan

Revision

# Date Page

Plan No.

507763-000-0000-4EPA-0008

06 2014-08-07 10 of 35

Environmental Engineer in Training This role reports to the HSE Manager and is responsible for monitoring the day-to-day activities on-site to ensure that they are conducted in an environmentally compliant manner, and in accordance with the CEMP. The role also oversees environmental monitoring and mitigation programs, ensuring compliance with permitting conditions, and environmental status reports and site inspections.

Project Team Responsibilities of the Vale Project Team include the following where requested by the HSE Manager:

 Approve any modifications or changes made to the CEMP that may be recommended;

 Review and comment on reports provided by SLI;

 Review permit applications related to the Project;

 Coordinate and supply Vale information required to accompany permit application.

 Inspect and audit Project activities as required;

 Audit the CEMP;

 External communication relative to regulatory issues is the responsibility of Vale

Corporate Affairs with support from SLI, as requested;

 Encourage efficient use of resources through the 3R’s (Reduce, Reuse, Recycle); and,

 Provide technical support for field identification of equipment, content and piping etc.

Central Environmental Group Responsibilities of the Group include the following:

 Review and comment on reports/documents provided by SLI;

 Review and submit permit applications (where required) related to the Project;

 Coordinate and supply Vale information required to accompany permit application.

 Encourage efficient use of resources through the 3R’s;

 Provision of training information and training material, where requested;

 Provide “train the trainer” exercise for waste, fugitive dust management, and spill prevention/contingency plans; and,

 Provide advice to SLI, where requested, on environmental practices considered as best practices by Vale.

2.2 SLI

Project Director SLI’s Project Director, as Vale’s agent, is responsible to deliver a suitable, adequate and effective HSE program and meet the performance standards of the EPCM contract. The Project Director has the full responsibility to ensure:

 Project compliance with SLI’s environmental policy through leadership, commitment and accountability;

 That at each phase of project execution preventive actions are incorporated so that appropriate EMPs can be implemented prior to the start of construction;

 Appropriate resources, equipment and required materials are made available and any necessary environmental controls or mitigation measures are implemented; and,


06


Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 11 of 35

 Attest compliance with the requirements of the environmental policy for activities in the Project.

Environmental & Permitting Manager SLI’s Environmental & Permitting Manager reports to the Engineering Manager and the Project Director and is responsible for coordinating and managing all the environmental activities during construction with support from an

Environmental Coordinator (or equivalent) at the field office. The Environmental &

Permitting Manager responsibilities are:

 Provide advice, strategies and problem solving to project personnel on all environmental issues to achieve the Project’s goal and objectives;

 Promote a culture wherein environment is a value that will never be compromised;

 Together with the Project Director and Construction Manager, develop and implement Policies, EMPs and Standards which are aligned with the Project’s Pledge and comply with the CEMP;

 Provide assistance in obtaining the necessary permits for the Project;

 Define local statutory and regulatory requirements and communicate throughout the

Project;

 Identify environmental competence requirements for all staff working on the Project and ensure delivery of environmental training to personnel within the Project Team;

 Gather/assemble information from SLI, Contractors and Vale to support environmental and building permit applications;

 Track all aspects of permitting including maintaining the Commitment and Permitting

Registers;

 Act as a main point of contact between Vale on environmental issues, and provide support to Vale in their communications with the regulatory authorities;

 In conjunction with the Construction Manager and the Environmental Coordinator, perform overall monitoring of the program for environmental works, and arrange to provide status reports as necessary;

 Provide advice and liaise with the construction team to ensure that environmental risks are identified and appropriate controls are developed and included within method statements and risks assessments;

 Liaise with Vale’s HSE Manager and the team to ensure coordination of

 environmental mitigation and monitoring procedures;

Liaise Corporate Affairs, Vale Canada as required;

 Manage the environmental monitoring program and review the routine reports;

 Audit the performance of the Project’s HSE initiatives;

 Implement and manage environmental audits for SLI and all contractors;

 Identify those environmental regulations, standards, practices and guidelines that are applicable to the Project and to its environmental aspects and to identify any applicable regulatory changes as they occur;

 Indentify changes in the scope of work or facilities (engineering and construction) that might affect the applicability of environmental regulations or influence environmental aspects and local policy; and,


06

06


Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 12 of 35

 Develop, document, and implement on-going environmental regulatory compliance verification process and communicate the results of these verification practices to the

Project.

Environmental Coordinator This position reports to the Construction Manager on a day to day basis (or where required) as well as the Environmental & Permitting Manager at the

Home Office as required. (If a full-time position is not required due to project scope the responsibilities of the role may be delegated to other project personnel by the SLI HSE

Manager.) The role has the noted responsibilities.

 Review and approve Contractor environmental documentation prior to work starting;

 Monitor construction activities and performance to ensure that identified and appropriate environmental management practices are being effective and monitor compliance with the Plan;

 Assist in the development and delivery of environmental training for site personnel and subcontractors;

 Develop content for environmental section of the Project site orientation;

 Lead the investigation and related activities in the event of an environmental occurrence / incident;

 Complete the communication process for all field environmental inquiries and liaise with the Manager , Corporate Affairs, Vale Canada as required;

 Provide advice and liaise with the construction team to ensure that environmental risks are identified and appropriate controls are developed and included within method statements and risks assessments (Example: Designated Substances &

Hazardous Materials Survey, JEA, PHR) ;

 Liaise with Vale’s HSE Manager and the team to ensure coordination of environmental mitigation and monitoring procedures as required;

 Update method statements for environmental aspects where required;

 Monitor and administer all waste management activities (characterization, handling and disposal of hazardous and non-hazardous wastes and excess materials) as described in the Waste Management Plan;

 Implement SLI’s on-site responsibilities as described in the EMPs;

 Conduct weekly monitoring of environmental parameters, including waste, water, noise, vibration and dust;

 Completion of routine forms and reports;

 Participation in regular coordination meetings;

 Completes tasks which are relative to site environmental inspection and management as well as maintaining documentation;

 Routine auditing of Contractor activities; and,

 Provide input and support to the EPM as requested.

Senior Construction Manager SLI’s Senior Construction Manager is accountable to the

Project Director. He actively manages all HSE activities, continually monitors the Project

HSE performance, measures the results against Project objectives and targets and takes appropriate corrective and preventive action to ensure continual improvement. The Senior

Construction Manager can delegate day-to-day responsibility for environmental



Management Plan

Revision

# Date Page

Plan No.

507763-000-0000-4EPA-0008

06 2014-08-07 13 of 35 management on site to the appropriate Manager or equivalent. The Senior Construction

Manager is responsible for:

 Environmental management within the battery limits;

 Ensuring all personnel on-site adhere to the CEMP and associated EMPs;

 Regular project review meetings address environmental issues;

 Appropriate and prompt actions taken to correct any non-compliance to the CEMP and associated EMP’s; and,

 Remaining aware of legal and other requirements and for arranging to complete any tasks as identified by the EPM.

Area Construction Manager The SLI Area Construction Manager is accountable to the

Senior Construction Manager and is responsible for:

 Ensuring that the environmental considerations are implemented by the Contractors during construction;

 Implementing the environmental management systems; and,

 Monitoring compliance to the established management systems.

2.3 Contractors

06

Contractor Environmental Representative The Contractor shall retain the services of a

“qualified” environmental contractor/consultant, possessing a high level of knowledge and experience related to environmental management and construction/operations of major industrial sites, as their Environmental Representative.

The Contractor’s Environmental

Representative shall be approved by SLI’s Senior Construction Manager. The Contractor shall designate personnel (which may be the Health and Safety representative) within their site team, who shall be responsible for receiving environmental related concerns and shall communicate these to his/her supervisor, Environmental contractor/consultant (as required) and to SLI’s Environmental Coordinator (or delegate). Spills will require forthwith communication. The Representative’s supervisor will be accountable to report such concerns following the proper communication chain, until the appropriate notifications are made by Vale, if required.

The Representative shall be able to issue a “stop work order” if unknown or unanticipated environmental risks or work conditions evolve that may impact the environment or necessitate greater precautions than those provided for. The Representative shall also supervise the installation of control measures and any remedial actions that may result from their activities.

The Contractor’s Environmental Representative is responsible for the day-to-day environmental management which includes:

 Familiarity with and implementation of the Project Environmental Management Plans;

 Compliance with all permits/approvals and reporting;

 Routine interaction with construction crews to ensure all construction activities are in compliance with requirements of the EMPs;



Management Plan

Revision

# Date Page

Plan No.

507763-000-0000-4EPA-0008

06 2014-08-07 14 of 35

 Routine monitoring to identify activities which are not in compliance with the EMPs, and propose corrective actions;

 Implementation of corrective actions;

 Attendance at all environmental meetings/Project meetings (as required);

 Assistance to the SLI Environmental Coordinator in completing environmental incident/non-compliance reports, if required; and,

 Participation in post-construction monitoring and inspection and project closing.

3.0 ENVIRONMENTAL POLICY AND PLEDGE

06

SLI developed and maintains an Environmental Policy. The Policy states our commitment to the responsible management of the natural environment. Our commitment is based on the principles of controlling risks, associated with all environmental issues. The President and the Chief Executive Officer of SLI are jointly responsible for implementing and monitoring this policy. All employees and outside consultants/contractors working for SLI must share this commitment.

The objectives in implementing the environmental policy are:

 Prevent environmental aspects from resulting in environmental impacts;

 Protect the health and safety of the general public;

 Comply with standards, regulations, know-how and good practices, as well as with implementation of appropriate technologies; and,

 Implement means of supervising and monitoring environmental hazards, along with means of preventing or resolving incidents that could pose hazards to health or the environment.

The current Vale Health Safety and Environmental Policy for Ontario Operations commits to sustainable development (meeting the needs of the present without compromising the ability of future generations to meet their own needs) and Vale believes in zero harm to their people, workplaces, communities in which they operate and to the natural environment.

For all operations, Vale has issued related policies including the Sustainable Development

Policy, the Health and Safety Policy and the Human Rights Policy.

The underlying principles necessary to deliver on the commitments set out in Vale’s policy, relevant to this Project are:

 Safety, Health, and Environmental excellence are exemplified by the visible action of leadership;

 Working in a manner that is safe, healthy, and environmentally sound is an accountability for everyone;

 People involvement is essential;



All operating exposures can be safeguarded to ALARA;


06

06


Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 15 of 35

 All injuries, occupational illness, and environmental impacts related to our activities, products and services are preventable;



Prevention of occupational illness, personal injuries, process upset and environmental impacts is good business; and,

 Respect for the communities, cultures and customs where we operate is the foundation for productive relationships and social responsibility.

The SLI and Vale policies can be accessed through the links below:

Vale Ontario Operations http://www.airquality-sudbury-vale.com/index.asp

SLI http://www.snclavalin.com/about_policy_environment.php?lang=en

A Project Pledge has been developed and endorsed by Senior Management from Vale and

SLI. The pledge succinctly combines the key elements of the noted HSE Policies from each organization. The pledge document is provided in Appendix A.

The Pledge provides a framework for setting and reviewing environmental objectives and targets relative to the Project. (Refer to section 7.0 on goals, objectives and targets.) The

Pledge will be made available to the public, if requested, and communicated to all employees on the Project. Periodic review of the Pledge will be conducted and changed if it is no longer relevant. Pledge changes will be communicated by Senior Project

Management, if deemed appropriate.

4.0 REGULATORY AND OTHER REQUIREMENTS

The Project specific regulatory and other requirements are detailed in the Clean AER Project

Permitting Plan (507763-000-0000-4EPA-0007). The purpose of the Permitting Plan is to provide guidance on the permitting requirements of the Project, including identification of responsibilities for obtaining permits and ensuring that permits are obtained in a timely manner.

In general, the SLI Environmental & Permitting Manager is responsible for identifying regulatory requirements (including permitting) and for consolidating information for permit applications. Vale is responsible for reviewing and submitting permit applications to the regulatory agency.

Additionally, in each individual supporting Environmental Management Plan (further discussed in section 5.0), the regulatory and other requirements are noted therein.

Project changes that may impact regulatory requirements are primarily managed through regular review of the Change Notice Register and weekly Project Review meetings.

External communication relative to regulatory agencies is discussed in section 11.



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 16 of 35

The Environmental Instruction Legal and Other Requirements (507763-000-0000-30AG-

0010) outlines the activities for identifying and evaluating compliance to applicable environmental legal and other requirements. The instruction discusses verification of compliance with environmental regulations as well as identification of legal and other requirements. Verification of compliance is the responsibility of the Environmental &

Permitting Manager and Senior Project Management. The means of verifying on-going compliance is through the use of Environmental Inspection results as well as through the audit process, discussed in section 10.

The Clean AER Project External Commitments Register (507763-000-0000-30AL-4E01) and

Permits / Approval Register (507763-000-0000-30AL-4E02) are maintained throughout the duration of the Project. Document maintenance of the Register(s) is the overall responsibility of the Environment & Permitting Manager.

5.0 CONSTRUCTION ACTIVITIES, ENVIRONMENTAL ASPECTS AND IMPACTS

5.1 Initial identification of Aspects and Impacts

The Environmental Instruction Environmental Aspects and Change Management (507763-

000-0000-30AG-0011) describes the process for identifying and assessing environmental aspects, determining those aspects which can have a significant impact on the environment and the process of maintaining the aspects up-to-date for the Project.

Since this Project is within an existing century old industrial property, it is not expected to have any significant direct effect on the natural ecological and biological systems (native soil, flora and fauna, cultural heritage) or on archaeological features.

The Project environmental aspects are documented in the Clean AER Project Environmental

Aspect Log (form).

Changes to the Project are evaluated for either the addition of new environmental aspects or changes to existing aspects. New aspects may be identified through routine operations, the site audit process, the assessment of new works, legislative developments or be reported by the public or Project personnel. If possible, the aspect will be evaluated prior to it being introduced to the site. The Project Change Register is regularly reviewed for this purpose.

5.2 Environment Focused Management Plans

Analysis of the potential effects on the physical, natural, and socio-economic environments, led to the development of several Environmental Management Plans (EMPs) to prevent, minimize and/or mitigate the significant environmental aspects and associated effects. The strategic details on how these will be controlled across the Project have been provided in the individual EMPs relative to the topics of Demolition, Waste Management, Water and

Wastewater (including erosion and sediment control), Air Quality and Dust, Noise and

Vibration, and Spill Prevention and Response. These Plans support the CEMP for the successful management of the construction project and are summarized in Table 5-1.



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 17 of 35

The requirements of these Plans apply to all the Project site personnel including Vale employees, SLI as well as Contractors to the Project where appropriate.

Project personnel shall use the control measures specified in these documents as guidance while completing risk assessments and will incorporate appropriate mechanisms for implementation on-site. All Plans have been developed inclusive of occupational health and safety considerations for workers involved in the various demolition and construction activities and the risks associated with the removal, movement, or disposal of waste and other materials.

Environmental strategies may also be developed as required throughout the Project. These will also guide environmental management of potential impacts on-site.

Vale’s environmental procedures and site environmental standards have been reviewed and those applicable have been incorporated in the individual EMPs.

Table 5-1: Supporting Environmental Management Plan Summaries

Name and

Document

Reference

Purpose

Environmental

Management

Plan for

Demolition

507763-000-

0000-4EPA-

0001

Addresses the activities related to demolition of buildings, structures and equipment which may have a significant impact upon the environment.

Objectives

 Make application for and receive regulatory approval as per the Project schedule;

 Conduct surveys to determine locations of designated substances, hazardous materials and building components and determine appropriate methods of decontamination and abatement;

 If required in contracts, clean building structures as far as reasonably possible prior to commencement of dismantlement and demolition activities.

The technologies selected will depend on the extent and nature of contamination in the building;

 Schedule demolition activities in order to ensure that buildings are demolished in a manner that preserves their stability during the process;

 Test collected process materials (solid, oxidized feed) for acceptability for reprocessing through Vale;

 Maximize recycling opportunities and minimize disposal of wastes;

 Apply emission controls during these activities to minimize the release of dust and contaminants to the surrounding environment; and,

 Coordinate demolition activities with on-going production activities.



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 18 of 35

Name and

Document

Reference

Purpose

Waste

Management

Plan

507763-000-

0000-4EPA-

0002

Provides guidance on the handling, processing and disposal of waste, including hazardous waste and excess materials, generated during construction activities of the

Project.

Air Quality and

Dust

Management

Plan

507763-000-

0000-4EPA-

0003

Establishes a framework to control and monitor construction processes that may impact local air quality in association with the Project.

Noise and

Vibration

Management

Plan

507763-000-

0000-4EPA-

0004

Provides guidance on the requirements for noise and vibration minimization during the demolition and construction phases of the

Project.

Objectives

 Where required, making application and/or submitting required documentation for regulatory approvals and notifications, and receiving approvals as per the project schedule;

 Performance of waste audits, preparation of waste reduction work plans

(WRWPs), and development of source separation programs in accordance with applicable regulations;

 Implementing WRWPs and source separation programs in order to minimize the waste generated though reuse and recycling, where practical;

 Managing hazardous/subject wastes in accordance with regulatory requirements and in such a way as to protect personnel and the public from unnecessary exposure;

 Defining waste handling and disposal requirements and managing these activities during the project;

 Providing training to personnel on waste management and disposal, including safety issues related to Vale’s landfill, and requirements for manifests and record keeping for designated staff; and,

 Coordinating project waste management activities with on-going waste management activities and integrating where possible.

 Periodically review and update the AQDMP throughout the life of the Project;

 Application of best management practices for fugitive dust generating construction activities;

 Maintain concentrations of particulate matter (PM) in air emissions within the applicable standards;

 Maintain concentrations of particulate matter (PM) in ambient air outside the

Project development area within the applicable standards;

 Maintain concentrations of trace metals, particularly Ni, in ambient air outside the Project development area within the applicable standards;

 Maintain communication with the Vale environmental department, and,

 Minimize the generation of dust emissions from within the Project development area.

 Periodically review and update the NVMP throughout the life of the Project;

 Application of best management practices for the minimization of noise and vibration which may have an impact on community residences, during demolition and construction activities on the Project;

 Minimize disturbances at off-site, community residences from a noise and vibration perspective (Ensure that horns and other signaling devices

(reversing beepers) fitted to construction vehicles to provide a danger warning, are least intrusive to the residences and community off site);

 Prevent modifications that could potentially increase the noise emitted from exhaust systems of equipment utilized on site;

 Ensure adjustment of construction activities work hours to meet regulatory requirements to suit the activity; and,

 Integrating communication of noisy construction activities that may impact the local community with on-going Vale communication processes.



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 19 of 35

Name and

Document

Reference

Purpose

Spill

Prevention and Response

Plan

507763-000-

0000-4EPA-

0005

Provides guidance on the required actions relative to the prevention of spills and response to spills of potentially hazardous materials that may occur during construction activities.

Water and

Wastewater

Management

Plan

507763-000-

0000-4EPA-

0006

Establishes a framework to control and monitor demolition and construction processes that may impact local surface and ground water quality in association with the Project. The plan also incorporates control measures to retain sediment generated onsite to minimize impacts to the environment.

Objectives

 Identification of potential spill scenarios associated with construction activities at the Project;

 Identification of required preventative measures to minimize the potential for spills;

 Identification of predetermined course of actions (contingency plans) for responses to spills of potentially hazardous materials;

 Provision of instructions for spill scenarios resulting in emergency situations

(environmental incidents) including incident reporting requirements under

Vale’s existing SAF 079 Incident Reporting system;

 Provision of spill notification and reporting requirements to coordinate with

Vale’s existing Environmental Occurrences Reporting System and meet regulatory and legal requirements;

 Provide support to Vale’s existing Spill Prevention and Contingency Plans

(SPCPs) for operations at facilities affected by the Project such that the existing SPCPs continue to comply with regulatory requirements;

 Outlining training requirements for contractors related to spill prevention and response; and,

 Identification of spill response equipment that will be provided and maintained by Contractors to respond to potential spills associated with their work.

 Application of best management practices for ensuring minimal impacts to water quality during all phases of demolition and construction;

 Ensuring that all water takings are in accordance with regulatory requirements and Vale’s procedures;

 Providing practical and cost-effective solutions for erosion and sediment control, and ensuring that excessive erosion does not occur on disturbed areas during construction requiring the implementation of unscheduled mitigation measures; and

 Coordinating water and wastewater management activities with Vale’s environmental personnel.

 Preventing an upset of Vale’s wastewater treatment plants.


06


Management Plan

Plan No.

507763-000-0000-4EPA-0008

6.0 ENVIRONMENTAL RISK

Revision

# Date Page

06 2014-08-07 20 of 35

06

The Clean AER Project Risk Management Plan (507763-000-0000-30VA-0001) defines the policy, objectives and the approach and scope of risk management for the

Project. Environmental and other risks are required to be effectively assessed and managed at every stage of the Project through various risk management practices that incorporate the concept of Hierarchy of Control (HoC).

The concept of HoC is to emphasize on the following: Eliminate, Substitute,

Engineering Controls, Administrative Controls and PPE.

6.1 Management of Environmental Impacts

Major construction activities undertaken on the site are subjected to the established risk assessment process, established by the SLI Risk Manager and the Vale HSE Manager.

Environmental Instruction Environmental Aspects and Change Management (507763-000-

0000-30AG-0011) describes how environment is considered within the risk management program.

During the project planning phase, the Clean AER Project team has identified environmental aspects and assessed the risks posed to the environment as a result of constructing on a Brownfield site. The result of this process was the

Environmental Aspects Log, which includes those aspects that the team could not control by either elimination or substitution, and will therefore require engineering and/or administrative controls to be developed, as the project advances.

The following critical and significant environmental aspects are identified for the project and documented in the Environmental Aspects Log:

Critical

 Environmental Occurrences/Emergencies (natural disasters, city-wide leaks);

 Point Source Air Emissions (exhaust from equipment start-up/commissioning);

 Waste Discharge to Sewer;

 Discharge;

 Waste Generation – Subject Waste;

 Waste Generation – Recyclables;

 Waste Generation – Solid Non-Hazardous Waste;

 Waste Generation – Excavated/Excess Materials;

 Impact.

Significant

 Energy/Fuel

 Water


06

06


Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 21 of 35

 Air Emissions – Point and Mobile Sources (exhaust from fuel combustion associated with HVAC from Contractor Infrastructure, trucks and mobile equipment, stand-by generators, large industrial heaters, personal vehicles, buses);

 Emissions from Stockpiles, roads;

 Air Emissions - Noise and Vibration, and

 Environmental Occurrences/Emergencies (other).

The specification titled Environmental Specification for Construction (507763-000-0000-

4EEG-0001) applies to all Contractors carrying out works at the Project site. This specification describes the minimum environmental requirements that Contractors will abide by during the delivery of site works. All Contractors’ personnel are required to comply with the requirements outlined in this document. This document is not intended to be a comprehensive manual of procedures for all applicable environmental control measures that may apply to the Project.

6.2 Process Hazard Review

Prior to mobilization, all Contractors are required to participate in a Process Hazard Review

(PHR). PHR is conducted by using one or more standard risk assessment tools to address process hazards, environmental aspects (issues), previous incidents, engineering and administrative controls and consequences and their failures. A PHR team shall include

Contractor’s Construction Manager, Contractor Safety Supervisor, specialists executing the job, Vale and SLI’s HSE Manager, SLI Environmental Coordinator and the Senior

Construction Manager (or designate). The Construction PHR Procedure (507763-000-0000-

61PA-0010) details the program.

Each Contractor’s PHR shall include a monitoring and a review plan. The PHR team will identify environmental aspects and manage risk using elimination and/or substitution, where possible. Otherwise, they will examine a way to engineer a solution in their project planning. Where engineering controls are not possible, they shall develop/implement procedures to be followed to mitigate the risk, usually including the use of PPE and/or environmental protection equipment. The Contractor supervisor shall communicate job specific PHR information to all contractor personnel and contractor personnel must sign off on the understanding of the risks, preventive measures and controls related to the job.

6.3 Job Environmental Analysis Program

The Job Environmental Analysis (JEA) Program was developed to assist in ensuring all work activities are conducted in accordance with Vale’s environmental (physical and social) commitments. This program shall be implemented every time the Contractor embarks on a new activity or works in a new area and also where, PHRs are unable to identify and manage the risk associated with a specific task(s).

The Contractor and its Environmental

Representative shall participate in the JEA program.


06

06


Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 22 of 35

The Contractor shall be responsible for the following aspects of the JEA program:

 Completion of a JEA form by the Contractor prior to the initiation of new work activities in new areas;



Identify and assess environmental risks associated with specific task(s), and consider ways to eliminate or substitute the aspect, or implement an engineered solution to control the aspect. Otherwise, examine whether or not a procedure exists that need to be followed or if one should be created. Lastly, also identify any PPE and/or environmental protection equipment that will be required;

 Participation in an iterative consultation process with the SLI’s Environmental

Representative to ensure all parties are in agreement regarding protection procedures that are to be implemented;

 Ensuring that employees understand the protection procedures required and that they are implemented according to the plan described in the JEA form;

 Participation in a “close out” of the JEA once the work is finished; and

 Making good any deficiencies identified through the JEA close-out to the satisfaction of SLI’s Environmental Representative.

7.0 GOALS, OBJECTIVES AND TARGETS

The Project’s primary goal is to ensure that Project personnel eliminate injuries, occupational diseases and environment and community incidents, by providing a place of work where risk is managed to ALARA such that the workplace is safe with minimal risk to health for themselves and the public.

The overall objective of the CEMP is to comply with the Global norms of EMS, and to meet legal and other (SLI/Vale) requirements and standards.

At the outset of the Project Senior Management established a series of KPI’s with associated targets. At the time of establishing the targets, consideration was given to the economic, social and environmental aspects, as well as policy, regulatory and other requirements, technological options, financial, operational and business requirements, views of interested parties and senior management direction. The KPI’s relative to environment are documented in Table 7-1. The established values have been deployed and communicated through the Project and are tied into performance.

Tracking of the data to inform the noted KPI’s are the responsibility of the SLI Health and

Safety Manager. Values are reviewed at the weekly Construction Meeting.



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 23 of 35

Table 7-1: Environment Focused Key Performance Indicators

KPI

Environmental

Occurrences

% Completion of

Corrective Actions by due date

Target zero Cat. 3 & 4 and

≤ 4 Cat. 2

≥ 91%

Supporting Metrics

 Category 1-4 Env Occurrences.

 Corrective Action Registry.

 Incident



 Public orders.

 Audit

Weekly

Inspections

≥ 100%

8.0 LEARNING AND COMPETENCE

 Weekly Inspection documented.

All personnel are to be appropriately trained and competent to carry out work. Training will be relevant to the individual’s duties. At the end of training the competency of individuals shall be validated (exam, or assessment) by the trainer. Training records will be maintained and retained on-site. Refer to Table 8-1 providing a summary of Environmental Learning

Requirements.

Environmental Instruction Environmental Training and Competency (507763-000-0000-

30AG-0012) describes the process for identifying and tracking the completion of environmental training requirements for Contractors and SLI employees working on the

Project. Training is required to confirm that person(s) performing tasks have the knowledge and skills to perform their jobs in an environmentally responsible manner.

8.1 General Project Orientation

The raising of environmental awareness is a very important element in the appreciation and implementation of the CEMP. All Project personnel (including Contractors) are required to attend a compulsory site induction/orientation that includes an environmental component prior to commencement of work on-site. This is done to ensure all personnel involved in the

Project are aware of the requirements of the CEMP and to ensure the implementation of environmental management measures on the Project. The Environmental & Permitting

Manager (or designate) is responsible for providing content and associated testing materials. Review and updating content will be as required.

Non-project Vale staff that enter construction areas should attend project and/or appropriate local site orientations as prescribed in the HSE Plan (507763-000-0000-68AG-0001).

8.2 Specific Environmental Training

A project specific training plan that identifies the competency and training requirements for all personnel allocated with environmental responsibilities has been presented in the Table



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 24 of 35

8-1. Training for all personnel identified shall be completed before commencement of the associated construction activities.

The objective of the training is to raise awareness and ensure all personnel understand the importance of:

 Potential effects and consequences of their work activities on the environment;

 Potential environmental benefits of improved environmental performance; and,

 Roles and responsibilities of each Project personnel in achieving environmental performance.

The Environmental Coordinator (or equivalent) shall provide specific environmental sensitivity training to the Contractor whose activities present a high risk of causing environmental concerns as identified through the PHR and JEA processes. Attendance and participation at the environmental sensitivity training is mandatory for the identified

Contractor prior to conducting any work activities at the Project site. The Vale Central

Environmental Group may also conduct a “train the trainer exercise” if required. The

Contractor will be required to provide evidence of training completed for personnel involved in specific activities including: hazardous materials, wastes, asbestos removal, transportation of dangerous goods.


Name

Clean AER Project Site

Orientation:

General Environmental

Awareness Module

Specific Environmental

Orientation:

Waste Management

Specific Environmental

Orientation:

Dust Control

Environmental Training:

Waste Manifesting


Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 25 of 35

Table 8-1: Environmental Learning Requirements

Topics

 Vale and SLI Environmental Policies and Pledge

 Accountabilities

 Reporting and investigation of environmental incidents

 Prohibitions (outside waste, disposal down drains, speaking to media)

 General disposal of construction and demolition wastes and source separation

 Dust

 Inspections and audits

 Waste types and source separation (recyclable materials)

 Waste handling, good housekeeping

 Waste segregation and accumulation points

 Materials intended for on-site disposal

 Materials intended for off-site disposal

 Rationale (metal content, protect community, occupational exposure)

 Obligation to apply dust controls for all outdoor activities

 Obligation to suspend poorly controlled activities during windy periods

Required

Attendees

All Personnel

Working on

Project

(Excludes

Visitors)

 Provincial requirements for Generators

 Internal Vale Manifest

 Waste identification and classification

 Paperwork

Delivery By

SLI

SLI

Construction

Area

Management

Contractors down to frontline supervision

SLI

(Environmental

Coordinator)

SLI

Construction

Area

Management

Contractors down to frontline supervision

Designated

*

Contractors or

SLI employees at each jobsite.

SLI

(Environmental

Coordinator)

SLI

(Environmental

Coordinator)

Or

Contractor



Management Plan

Revision

# Date Page

Plan No.

507763-000-0000-4EPA-0008

06 2014-08-07 26 of 35

Name


Noise and Vibration

Control


Spill Prevention and

Response

Topics

 Rationale (protect community)

 Obligation to noise and vibration controls for all outdoor activities

 Advance Notification and Communication of Noisy Activities

 Regulatory

 Provincial requirements for Generators

 Operation and maintenance of clean-up equipment

 Proper handling and storage of all materials brought on site or used by contractors (including handling of hazardous wastes)

 Use of Material Safety Data Sheets (MSDS) and the Workplace

Hazardous Materials Information System (WHMIS)

 Types of potential spills and releases

 Spill measures

 Spill control and clean-up procedures for spills

 Information on location of emergency response equipment and specifically spill response equipment

 Proper use of spill kits

 Notification

 Transportation of Dangerous Goods (TDG)

Required

Attendees

Designated

Designated

*

Contractors

(including Front

Line

Supervision)

*

Contractors

(including Front

Line

Supervision)

Delivery By

SLI

(Environmental

Coordinator)

Designated

Contractors


Asbestos,

Transportation of

Dangerous Goods,

WHMIS (Hazardous

Materials)

 Provision of evidence of noted training to employees performing the work.

 Specific to materials brought on site or used by contractors or the nature of the work.

Designated

Contractors

* Designated

Contractors

* Contractors that have completed a Job Environmental Analysis (or at SLI’s discretion) indicating there are significant issues associated with the work.



Management Plan

Revision

# Date Page

Plan No.

507763-000-0000-4EPA-0008

06

9.0 SUPERVISION, INSPECTIONS, MONITORING AND REPORTING

2014-08-07 27 of 35

All construction activities including those carried out by Contractors and Suppliers shall be supervised, or regularly checked through the completion of site inspections by the

Environmental Coordinator, to ensure that the CEMP is being implemented. The frequency and extent of this supervision will vary according to the competence of the workforce and the risks or potential effects to the environment. Inspection, Monitoring and Reporting records may include completed forms or notes. Records are further discussed in section 12.

9.1 Inspection of Other Construction Impacts

The Construction Area Managers and/or the Environmental Coordinator shall carry out daily inspections of their respective construction areas, to verify that housekeeping or supporting controls are being implemented effectively. These inspections would consider the site environmental standards as the minimum standards that should be achieved, with necessary actions to be recorded and raised at weekly progress meetings.

Environmental Instruction titled Environmental Inspections (507763-000-0000-30AG-0009) outlines the procedures for Environmental Inspections on the Project. It includes information on planning, types of inspections, classification of findings including non-conformities, as well as communication of findings.

The requirements noted in the Environmental Specification titled Environmental

Specification for Construction shall form the basis for inspections of construction impacts.

Deliverables of the project shall be inspected by the Environmental Coordinator or the Area

Managers to certify the conformity with environmental requirements. The inspections are to confirm construction works are progressing in accordance with agreed methods, agreed protection or mitigation measures are in place and works have been completed in accordance with design and commitments made during permitting. Vale environmental personnel may attend the inspections. For any non-conformance identified, Vale shall agree to the proposed correction action or make recommendations for additional corrective action.

Refer to section 10 for information pertaining to the control of non-conformance.

SLI is responsible for developing and implementing monitoring procedures before construction begins. Monitoring activities of the physical environment related to project construction will be performed according to the EMPs prepared for the project. A register of all required construction environmental monitoring will be maintained by the Environmental /

Permitting Coordinator. Table 9-1 summarizes monitoring activities.



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 28 of 35

Table 9-1: Summary of Environmental Monitoring Requirements

06

Topic

Demolition

Waste

Air

Monitoring Requirement

 Focus on releases of dust (asbestos in air and airborne particulates) that may impact air quality. Monitoring of the performance of the required mitigation measures through-out the implementation of the demolition activities for the purpose of immediately identifying any negative effects.

 Where materials are removed, specific testing for asbestos will take place. Specifically, any Type 3 asbestos abatement undertaken will be subject to verification air sampling and clearance air testing to ensure that no residual hazards remain after the work is completed. Where clearance air testing is required, it shall be done using the phase contrast microscopy method or using the transmission electron microscope method. SLI will provide the resources to complete this work.

 Adherence to overall and material specific waste diversion targets.

 Periodic monitoring and regular site inspections of the waste segregation bins to ensure that source separation is being implemented by all Contractors on the site.

 Tracking measured demolished material records to ensure that the source separated materials and wastes that are collected are removed.

 Use of MOE waste manifest forms to track all loads of waste transported off site and Vale’s internal manifest to track all waste materials transferred to the on-site waste disposal facility.

 With regard to off-site transfers of waste or recyclable materials where manifests are not required, weigh tickets will be used to track quantities that provide a description of the waste and its weight.

 Review Vale Ambient Air Quality Monitoring Program

(AAQMP) data. Identified issues discussed to investigate the potential for the Project related causes and appropriate corrective actions will be taken if needed.

 Discussion with appropriate Vale staff will be undertaken to investigate any potential issue which could be linked to construction activities to ensure the adequacy of the Air Quality and Dust

Management Plan

(AQDMP). Potential issues and corrective actions will be discussed with Vale site personnel, to ensure the integrity of the AQDMP.

 Contractor log sheets will be reviewed to ensure the adequacy of the program. Implemented controls will also be monitored. Issues identified will be investigated as needed and discussed with Vale to ensure compliance requirements are met.

 Results of the ongoing atmospheric dispersion modeling program

(as part of the Emission Reduction Program (ERP) for current operations) may be requested and used to provide input for ongoing adherence to the requirements of the AQDMP.

 Ongoing monitoring of upcoming weather patterns to assist in


Topic

Water & Wastewater


Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 29 of 35

Monitoring Requirement predicting potential weather events that could affect construction events, such as stop work due to gusty winds. Vales’ existing weather monitoring resources will be accessed along with other sources such as those from Environment Canada.

 Air monitoring results will be reported as required by Regulation by

Vale.

 Periodic monitoring and regular site inspections will be conducted to ensure that Contractors are operating in accordance with the requirements of the Water and Wastewater Environmental

Management Plan, conditions of any issued Permits to Take Water, and Regulations.

 Vale may also choose to undertake periodic inspections to satisfy their own environmental auditing requirements.

The SLI Senior Construction Manager (or his delegate) shall lead a detailed inspection of all activities identified as non-conforming and produce a report containing an explanation of the reason for non-conformance, the root cause(s), the proposed corrective actions, identification of accountable persons, and verification that the corrective actions have been implemented. Non-conformities include:

 Non-conforming audit findings;

 Environmental occurrences or incidents;

 Exceedance of a legal requirement;

 Non-compliance with the permit condition;

 Government inspection findings; and,

 Substantiated public or employee complaints.

The non-conformance report will be provided to both the SLI and Vale Project Directors. A register of non-conformities shall be maintained by SLI, as a separate database on the SLI project network. SLI HSEC staff shall also measure and report on the percentage of corrective actions completed as a lagging indicator.

Where required, implementation or modification controls necessary to avoid repetition of the nonconformance (preventive action) shall be completed which may include modification in procedures, as necessary, resulting from corrective action.

In the instance of any identified issue of non-conformity with the Plan or the regulations, the following information shall be provided:

 The date, time and reason for the non-conformity;

 The cause, nature and extent of the non-conformity and potential or known environmental consequences;



Management Plan

Revision

# Date Page

Plan No.

507763-000-0000-4EPA-0008

06 2014-08-07 30 of 35

 Corrective action taken or planned to mitigate any adverse environmental consequences if appropriate; and,

 Corrective actions taken or planned to prevent a recurrence of the non-conformity, if appropriate, including a timeline for implementation and person(s) accountable for execution.

10.1 Audit and Review of Performance

It is the responsibility of Senior Project Management to conduct regular Project audits to ensure compliance to program standards, permit requirements, Vale and SLI standards and legislation.

The Environmental Instruction Legal and Other Requirements (507763-000-0000-30AG-

0010) outlines the process for Environmental Management Plan Auditing.

Environmental Management Plans shall be audited on an annual basis. This includes field verification in conjunction with a desktop review to identify any gaps in the implementation of the plans and to certify that the activities are deployed in agreement with the environmental requirements.

11.0 COMMUNICATION AND REPORTING

The Environmental Instruction Environmental Communications (507763-000-0000-30AG-

0008) outlines the process for communications of an environmental nature with interested or concerned parties external to the Project and with all employees on the Project. Internal and external communication requirements are highlighted below.

06

11.1 External Communications

Vale will communicate directly with the public and is directly responsible for communication with the Public. Media inquiries are to be immediately forwarded to Vale Corporate Affairs.

Regulatory personnel are to be directed to the Vale Clean AER Project HSE Manager.

All queries received from external parties (public) are to be immediately referred to the Vale

Community Concerns Line (705-222-8253) or the Emission Reduction Program (ERP) (705-

682-8283) for inquiries on environmental issues including complaints.

With respect to planned noisy activities, Vale Corporate Affairs will inform the community (in advance of planned work) through established communication channels.

Any community complaint, received by Vale and forwarded to SLI, that may be attributed to the Project will be investigated as a priority.

All persons working on the project are responsible for notifying all emergency situations including spills forthwith to their Supervisor or Management after becoming aware of the spill occurring and safely carrying out any immediate response required (e.g. stopping spill source), as per the Incident Reporting and Investigation Procedure (507763-000-0000-

68AG-0034).

The Supervisor is to notify Vale Environment On-Call immediately.



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 31 of 35

External reporting of spills, where required, will be conducted by Vale. In the event that a spill is externally reportable, a member of Vale’s Environmental Department (daytime) or the

Environmental On-Call (off-hours) will contact the MOE Spills Action Centre and Municipality of Sudbury.

All communications with regulatory bodies are the responsibility of Vale except where specifically sanctioned by Senior Project Management at Vale. For example, Building

Permit Department Inspectors may directly communicate with select SLI personnel.

11.2 Internal Communications

Management will maintain regular communication meetings between the various levels and functions of the Project dealing with its pledge, aspects and environmental management program. Venues for these communication meetings may include:

 Risk Management Meetings (Construction PHRs);

 Daily Toolbox Meetings; and,

 Weekly Team Meetings.

Internal communication of environmental topics with the home office is required for areas such as environmental performance reporting and objective and targets. Methods of communication may include meetings, status reports, audits, corrective actions from audits and other means. On-site environmental communications will be coordinated through the

Environmental Coordinator.

Other methods of communication to ensure personnel are kept current on any environmental information will include bulletin boards placed in common or high traffic areas as well as regular toolbox meetings and monthly reports.

Communication methods may include conference calls, letters and memos, electronic mail and face-to-face.

Upon initiation of select work activities at the project site environmental tool box meetings will be held either daily or weekly. The frequency of the meetings will be determined based on the type of work activity, environmental conditions or sensitivities. An environmental tool box meeting will be held at a minimum: at the start of any work activity and at the completion of that specific work activity.

The purpose of the tool box meetings will be to address any environmental issues that may arise from work activities and to identify any mitigation measures that may be required on an ongoing basis. During these meetings the PHR may be reviewed and any changes addressed.

All Contractors are required to discuss environmental topics on at least one occasion during the week to foster environmental awareness. For Contractors completing demolition activities, daily meetings discussing environmental topics are required.


06


Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 32 of 35

Records of minutes and attendance are to be submitted or otherwise made available to the

Environmental Coordinator.

11.2.1 Environmental Topic Communication Highlights

Air Quality: The Project Team will assist Vale Environmental in any investigations concerning air quality. In the event of an exceedance of dust recorded by Vale’s monitoring network, Vale may request information regarding construction and demolition activities taking place at the approximate time of the exceedance.

Noise and Vibration: Communications of issues relative to noise and vibration will be addressed at the regular meetings, and will be coordinated through the SLI Environmental

Coordinator and the Senior Construction Manager.

SLI shall inform Vale Project staff who will communicate general information about the project to Vale Corporate Affairs. SLI will be responsible for communicating the schedule of specific events such as planned blasting and piling activities including duration in advance of the work. One week or more in advance is preferred. Vale Corporate Affairs will inform the community. The Vale Clean AER Project Operations Representative is responsible for arranging relative internal (Vale) communications with Vale Corporate Affairs (for example, traffic pattern changes).

The Vale Emission Reduction Program (ERP) group shall provide wind and weather advisories to the SLI Environmental Representative who shall instruct the Contractor to supplement the Contractors program for noise and vibration control or defer activities.

Environmental Emergencies / Spills: Persons working on the Project are responsible for notifying all emergency situations including spills forthwith to their supervisor or management after becoming aware of the spill occurring and safely carrying out any immediate response required (e.g. stopping spill source). The AER On-Call and the Vale

Environmental On-Call must also be notified forthwith .

SLI’s Senior Construction Manager (or designate) will assess the environmental performance based upon the information received from his staff, Contractors and their own evaluation of the construction works. Reporting will take place on a weekly basis or more often if needed.

SLI will use the identified key performance indicators to assess performance and these will be reported in the Weekly Meeting. The project Monthly Report will include a section for

Environment.

11.3.1 Environmental Topic Reporting Highlights

Spill Reporting: For all spill incidents, the Contractor shall complete a paper incident report for submission to the SLI Environmental Representative, including a description of the spill incident, the root cause, any corrective and site remediation/restoration measures



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 33 of 35 implemented and the efficacy of their implementation. SLI personnel shall enter the incident in Vale’s SAF079 incident reporting system. Upon request SLI shall provide necessary information to Vale Environmental so that they may fulfill any internal reporting requirements, including those in their corporate instruction (Instruction for the Classification and Communication of Environmental Occurences).

Formal Project reporting from SLI to Vale shall include the following information as per the noted frequency:

 Significant issues and means to mitigate;

 Details of any spill;

 Progression of environmental deliverables; and,

 Status of environmental KPI’s.

Demolition:

SLI will be responsible for reporting the results of the asbestos monitoring program and auditing of dust control measures to ensure that the results meet the requirements of the applicable regulations.

Waste: Quarterly reports will be prepared by SLI compiling waste management data.

Detailed information from the monthly summaries will be compared to the waste reduction work plan and source separation program requirements prepared by SLI. A summary report will be prepared by SLI on an annual basis using the compiled monthly data summaries.

SLI will undertake periodic audits of waste Contractors, demolition Contractors, the worksite accumulation areas and waste receiving facilities to verify that facilities are operating accordance with regulations and that waste manifest information is correct. Vale may also choose to undertake periodic audits of waste management activities and reporting to satisfy their own environmental auditing requirements.

Any issues of non-conformity will be included in the monthly reports.

12.0 RECORDS, DOCUMENTATION AND DOCUMENT CONTROL

The Project Instruction Manual include the procedures for Document Control to ensure that all project documents sent to site or produced on site are correctly registered, copied, distributed, filed and easily retrieved. Records of documents, evaluations, reports, field data, and other information will be archived and revised according to the environmental need.

The Environmental Coordinator will be responsible for the Project’s environmental documentation.

Project records shall include the following:

 Information on compliance with applicable legislation and other requirements as specified by Vale;

 Details of non-conformities, and corrective and preventive actions;

 All incidents and spills to the environment;



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 34 of 35

 Composition of products used on-site (chemical composition and properties; health and safety data);

 Evidence to support achievement of objectives/targets;

 Training/learning

 Permits, licences, authorizations or other forms required by governing legislation;

 Records of field instrumentation inspection and calibration (if required);

 Data pertaining to operational controls (maintenance, design, etc); and,

 Public

The effective control of the noted records, which includes identification, collection, indexing, filing, storage, maintenance, retrieval and retention, is an essential component to the management process.

The two (2) major types of controlled Environmental documents identified include:

 Non-changeable records (i.e., record of contact - complaints, training, incidents, inspections, monitoring results, etc.); and

 Environmental Management Plan documents (changeable).

Non-changeable records will be established and maintained, as necessary, to demonstrate conformity to the requirements of the CEMP and its accomplishments. Records will be and will remain legible, identifiable and traceable. SLI is responsible for establishing, implementing, and maintaining a procedure for the storage, retrieval, retention and disposal of records in accordance with Company policies.

The CEMP and its Environmental Management Plans will undergo revisions as the Project develops to reflect a change in Project layout and activities. These revisions will occur through updates or modifications to the Plans identified in this document through a controlled procedure developed to ensure all changes are thoroughly documented and approved, the current document is updated, and distributed to all previous document holders as a new revision.

13.0 REFERENCES

Air Quality and Dust Management Plan , SNC-Lavalin Inc., Document No. 507763-000-0000-

4EPA-0003.

Clean AER Project Permitting Plan , SNC-Lavalin Inc., Document No. 507763-000-0000-

4EPA-0007.

Clean AER Project HSE Plan , SNC-Lavalin Inc., Document No. 507763-000-0000-68AG-

0001.

Clean AER Project Risk Management Plan SNC-Lavalin Inc. Document No. 507763-000-

0000-30VA-0001.



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 35 of 35

Construction PHR Procedure, SNC-Lavalin Inc. Document No. 507763-000-0000-61PA-

0010.

Environmental Instructions Manual , SNC-Lavalin Inc., Document No. 507763-000-0000-

30AG-0004.

Environmental Instruction Legal and Other Requirements , SNC-Lavalin Inc., Document No.

507763-000-0000-30AG-0010.

Environmental Instruction Environmental Inspections , SNC-Lavalin Inc., Document No.

507763-000-0000-30AG-0009.

Environmental Instruction Environmental Communications , SNC-Lavalin Inc., Document No.

507763-000-0000-30AG-0008.

Environmental Instruction Environmental Training and Competency, SNC-Lavalin Inc.,

Document No. 507763-000-0000-30AG-0012.

Environmental Instruction Environmental Aspects & Change Management , SNC-Lavalin

Inc., Document No. 507763-000-0000-30AG-0011.

Environmental Management Plan for Demolition , SNC-Lavalin Inc., Document No. 507763-

000-0000-4EPA-0001.

Global Environmental Management System , SNC-Lavalin Inc. Document No. 6901-EN-REV.

00.

Noise and Vibration Management Plan , SNC-Lavalin Inc., Document No. 507763-000-0000-

4EPA-0004.

Project Instruction Manual , SNC-Lavalin Inc., Document No. 507763-000-0000-30AG-0001.

Spill Prevention and Response Plan , SNC-Lavalin Inc., Document No. 507763-000-0000-

4EPA-0005.

Standard Specification Environmental Specification for Construction . SNC-Lavalin Inc.,

Document No. 507763-000-0000-4EEG-0001.

Waste Management Plan , SNC-Lavalin Inc., Document No. 507763-000-00000-4EPA-0002.

Water and Wastewater Management Plan , SNC-Lavalin Inc., Document No. 507763-000-

00000-4EPA-0006.

END OF DOCUMENT



Management Plan

Plan No.

507763-000-0000-4EPA-0008

Revision

# Date Page

06 2014-08-07 Appendix

Appendix A

Clean AER Project Pledge


One vision.

One goal.

Zero Harm.

The Clean AER Project Team as well as

Sudbury operations, have no higher priority than SafeProduction.

• Plan all work using risk management tools

• Accept Boundaries – follow all legislated requirements, training and procedures and work within our capabilities

• Care for one another – work as a Team

• Lead by example – walk the talk

We believe

that

Zero Harm

in areas of safety, health and environmental issues is achievable on the Clean AER Project.

All employees will work together to achieve this goal without compromise.

Dave Stefanuto, P.Eng.

Project Director

Clean AER Project – Vale

Hank Froese

Project Director

Clean AER Project – SNC Lavalin

John Anderson

Construction Manager

Clean AER Project – Vale

Nick Mills

Sr. Construction Manager

Clean AER Project – SNC Lavalin

Construction Environmental Management Plan

Appendix A

Clean AER Project Pledge

One vision.

One goal.

Zero Harm.

The Clean AER Project Team as well as

Sudbury operations, have no higher priority than SafeProduction.

• Plan all work using risk management tools

• Accept Boundaries – follow all legislated requirements, training and procedures and work within our capabilities

• Care for one another – work as a Team

• Lead by example – walk the talk

We believe

that

Zero Harm

in areas of safety, health and environmental issues is achievable on the Clean AER Project.

All employees will work together to achieve this goal without compromise.

Related documents

Products

Support

Construction Environmental Management Plan

Appendix A

Clean AER Project Pledge

One vision.

One goal.

Zero Harm.

The Clean AER Project Team as well as

Sudbury operations, have no higher priority than SafeProduction.

• Plan all work using risk management tools

• Accept Boundaries – follow all legislated requirements, training and procedures and work within our capabilities

• Care for one another – work as a Team

• Lead by example – walk the talk

We believe

that

Zero Harm

in areas of safety, health and environmental issues is achievable on the Clean AER Project.

All employees will work together to achieve this goal without compromise.

Related documents

Add this document to collection(s)

Add this document to saved

Suggest us how to improve StudyLib