Report for Ontario Regulation 455/09: Toxics Reduction Act€¦ · TRA ANNUAL REPORT (2016 Reporting Year) This Toxics Reduction Act (TRA) Annual Report has been prepared in accordance

June 1, 2017

Report for Ontario Regulation 455/09: Toxics Reduction Act

The Province of Ontario developed a Toxics Reduction Strategy that included the

introduction of the Toxics Reduction Act, 2009 to reduce toxic substances created or

used in manufacturing processes and to better inform Ontarians about toxic chemicals in

the air, water, land and consumer products. The promotion of positive health and

environmental outcomes is a basic expectation of a responsible, democratically elected

government and a healthy economy provides the resources to support such positive

outcomes.

Ontario is blessed with a geology that provides a huge mineral abundance. The mining

and refining of these riches has brought Ontarians wealth and supported us for

generations. The goods produced from our minerals provide the essentials we rely on in

food, medicine, energy, construction, transportation and communication, among our

other daily needs. In addition, mining provides the building blocks we require to meet

the growing global demand for greener products and services.

The concept of sustainability has been incorporated into mining practices at Sudbury

Integrated Nickel Operations. The ore that is mined contains a large number of

elements, some of which have been classified under the Toxics Reduction Act. While

there is no opportunity to reduce the levels of these naturally occurring substances, nor

should there be a desire to eliminate highly useful and recyclable metals from our

economy, there are opportunities for leadership on improving health outcomes for

Ontarians when it comes to chemical exposures.

Sudbury Integrated Nickel Operations (Smelter and Onaping Area Mines/Mill) is

committed to continual improvement of our environmental performance through

conformance to our certified Environmental Management Systems. This commits us to

managing our emissions and adoption of feasible, safe and green technologies to achieve

excellence in environmental performance. In our ongoing efforts to implement this

strategy the Sudbury Smelter and Onaping Area Mines/Mill sites have completed

Annual Reports for applicable substances under the Toxics Reduction Act and we will

continue to assess opportunities for further improvement of our emissions through

completion and adoption of the required plans.

Summaries of the Annual Reports are available at:

www.sudburyino.ca

TRAANNUALREPORT(2016ReportingYear)This Toxics Reduction Act (TRA) Annual Report has been prepared in accordance with, and satisfies the

requirements of Section 10 of the TRA and Section 27 of Ontario Regulation (O.Reg.) 455/09 for all TRA

toxic substances for which Toxic Substance Reduction Plans have been prepared to date.

BasicFacilityInformation

Mandatory Basic Facility Information Item Details

Substance Name and Chemical Abstracts Service (CAS) Registry Number, if any

This Report on Toxic Substance Reduction Plans applies to the Toxic Substance Reduction Plans for the following prescribed Toxic Substances: Arsenic, Cadmium, Chromium, Cobalt, Copper, Lead, Manganese, Nickel, Selenium, Zinc, Total Reduced Sulphur, Particulate Matter, PM-10, PM-2.5, Ammonia (total), Nitrate Ion, Cyanides (Ionic) (Per O.Reg.455/09; “no single CAS numbers apply to these substances”), Vanadium (CAS number 7440-62-2), Sulphuric Acid (CAS number 7664-93-9), Nitrogen Oxides (CAS Number 11104‐93‐1), Carbon Monoxide (CAS Number 630‐08‐0), Carbon Disulphide (CAS Number 75-15-10), I-Butyl Alcohol (CAS Number 78-83-1), Solvent Naphtha Medium Aliphatic (CAS Number 64742-88-7)

National Pollutant Release Inventory (NPRI) and O.Reg.127/01 Identification Numbers

NPRI ID: 1233 O.Reg.127/01 ID: N/A

The legal and trade names of the owner and the operator of the facility, the street address of the facility and the mailing address of the facility, if different

Sudbury Integrated Nickel Operations (Sudbury INO)

Onaping Mines Mill

Strathcona Services Building,

85 Regional Road, Onaping, ON P0M 2R0

The number of full time employee equivalents at the facility

860

North American Industry Classification System (NAICS) codes and the six‐digit NAICS Canada code

21 - Mining & Oil & Gas Extraction 2122 - Metal Ore Mining 212232 – Nickel-Copper Ore Mining

Public contact

Joe Fyfe Superintendent – Environment and SD Management Systems Onaping Mines/Mill Operations Strathcona Services Building, 85 Regional Road, Onaping, ON P0M 2R0

The spatial coordinates of the facility expressed in Universal Transverse Mercator (UTM) within a North American Datum 83 (NAD83) datum

UTM Zone 17 473367 E 5168770 N

Parent Company Information

Glencore Canada Corporation 100 King Street West, 1 First Canadian Place, Suite 6900 Toronto, Ontario M5X 1E3

ListofAllSubstancesforwhichToxicSubstanceReductionPlansHaveBeenPreparedattheFacilityThe Facility has prepared Toxic Substance Reduction Plans for the following prescribed Toxic Substances:

Arsenic*

Cadmium*

Chromium*

Cobalt*

Copper*

Lead*

Manganese*

Nickel*

Selenium*

Zinc*

Vanadium (CAS number 7440‐62‐2)

Sulphuric Acid (CAS number 7664‐93‐9)

Particulate Matter*

PM‐10*

PM‐2.5*

Ammonia (total)*

Nitrate Ion*

Nitrogen Oxides (CAS Number 11104‐93‐1)

Carbon Monoxide (CAS Number 630‐08‐0)

Carbon Disulphide (CAS Number 75‐15‐10)

Total Reduced Sulphur*

I‐Butyl Alcohol (CAS Number 78‐83‐1)

Solvent Naphtha Medium Aliphatic (CAS Number 64742‐88‐7)

Cyanides (Ionic)

*Per O.Reg. 455/09, “no single CAS numbers apply to these substances”

ToxicSubstanceAccountingInformationRefer to Appendix A: TRA Toxic Substance Quantification and Accounting Summary for the information

required under s.12(1) of O.Reg.455/09. Note that the following substances did not meet their

reporting thresholds for 2016, and therefore no reporting information is required:

Arsenic

Cyanides (Ionic)

Nitrate Ion

ComparisonofToxicSubstanceAccountingtothePreviousCalendarYearRefer to Appendix B: Comparison of Toxic Substance Quantification and Accounting to the Previous

Calendar Year for the information required by s.26(2) of O.Reg.455/09.

ChangesinQuantificationMethodsThere were no changes made to any quantification methods since the preparation of the Toxic

Substance accounting information for the previous calendar year and therefore no changes outlined in

the above comparison occurred due to changes in quantification methods.

ObjectivesofToxicSubstanceReductionPlansRefer to Appendix C: Plan Summaries which contains objectives of the respective Toxic Substance

Reduction Plans covered by this Report, as required by s.26(2)3 of O.Reg. 455/09.

ToxicSubstanceReductionOptionsIdentifiedinToxicSubstanceReductionPlansAs outlined in the Plan Summaries attached in Appendix C, no toxic substance reduction options were

identified in any of the respective Plans and therefore the information required by s.26(2)4, s.26(2)5 and

s.26(2)6 is not applicable for this Report.

AmendmentstoToxicSubstanceReductionPlansNo Amendments have been made to any Toxic Substance Reduction Plans.

CertificationStatementAs of June 1, 2017, I certify that I have read the 2016 TRA Annual Report for the substances listed below

and am familiar with its content and to my knowledge the information contained in the Report is

factually accurate and the Report complies with the Toxics Reduction Act, 2009 and Ontario Regulation

455/09 (General) made under the Act.

Arsenic*

Cadmium*

Chromium*

Cobalt*

Copper*

Lead*

APPENDIX A: TRA TOXIC SUBSTANCE QUANTIFICATION AND ACCOUNTING SUMMARY

TRA Toxic Substance Quantification and Accounting Summary

Unit Use Creation Contained in Product

Cadmium N/A-3 kg >1 to 10 0 to 1 >1,000 to 10,000Chromium N/A-4 tonnes >100 to 1,000 0 to 1 >10 to 100Cobalt N/A-5 kg >100,000 to 1,000,000 0 to 1 >100,000 to 1,000,000Copper N/A-6 tonnes >10,000 to 100,000 0 to 1 >10,000 to 100,000Lead N/A-8 kg >100,000 to 1,000,000 0 to 1 >100,000 to 1,000,000Manganese N/A-9 tonnes >1,000 to 10,000 0 to 1 >1,000 to 10,000Nickel N/A-10 tonnes >10,000 to 100,000 0 to 1 >10,000 to 100,000Selenium N/A-12 kg >10,000 to 100,000 0 to 1 >10,000 to 100,000Vanadium 7440-62-2 tonnes >100 to 1,000 0 to 1 >100 to 1,000Zinc N/A-14 tonnes >100 to 1,000 0 to 1 >100 to 1,000Sulphuric Acid 7664-93-9 tonnes >1,000 to 10,000 0 to 1 0 to 1Ammonia N/A tonnes 0 to 1 >10 to 100 0 to 1Carbon Disulphide 75-15-0 tonnes 0 to 1 >10 to 100 0 to 1I-Butyl Alcohol 78-83-1 tonnes 0 to 1 >10 to 100 0 to 1Total Reduced Sulphur N/A- 300 tonnes 0 to 1 >10 to 100 0 to 1Nitrogen Oxides 11104-93-1 tonnes 0 to 1 >100 to 1,000 0 to 1Carbon Monoxide 630-08-0 tonnes 0 to 1 >10 to 100 0 to 1PM N/A - M08 tonnes 0 to 1 >10 to 100 0 to 1PM-10 N/A - M09 tonnes 0 to 1 >10 to 100 0 to 1PM-2.5 N/A - M10 tonnes 0 to 1 >10 to 100 0 to 1Solvent Naphtha Medium Aliphatic 64742-88-7 tonnes >1 to 10 0 to 1 0 to 1

Toxic Substance CAS No.*Public Reportable Values (Report to Public)

* Substances with CAS Numbers starting with "N/A" do not have CAS Numbers in NPRI or TRA guidance. The CAS Numbers assigned those substances are arbitrary CAS

APPENDIX B: COMPARISON OF TOXIC SUBSTANCE QUANTIFICATION AND ACCOUNTING TO

THE PREVIOUS CALENDAR YEAR

TRA Reporting Comparison

Used

Substances CAS No. Reporting Units % Change Comment if Change +/- 10%

Arsenic N/A-2 kg — —Cadmium N/A-3 kg -99% Fewer ore types milled in 2016Chromium N/A-4 tonnes -62% Fewer ore types milled in 2016Cobalt N/A-5 kg -25% Fewer ore types milled in 2016Copper N/A-6 tonnes -1% —Lead N/A-8 kg -9% —Manganese N/A-9 tonnes -9% —Nickel N/A-10 tonnes -1% —Selenium N/A-12 kg -7% —Vanadium 7440-62-2 tonnes -12% Fewer ore types milled in 2016Zinc N/A-14 tonnes -6% —Sulphuric Acid 7664-93-9 tonnes 27% More sulphuric acid used in 2016Ammonia N/A tonnes — —Nitrate Ion N/A-11 tonnes — —Carbon Disulphide 75-15-0 tonnes — —Cyanides N/A-7 tonnes — —I-Butyl Alcohol 78-83-1 tonnes — —Total Reduced Sulphur N/A- 300 tonnes — —Nitrogen Oxides 11104-93-1 tonnes — —Carbon Monoxide 630-08-0 tonnes — —PM N/A - M08 tonnes — —PM-10 N/A - M09 tonnes — —PM-2.5 N/A - M10 tonnes — —Solvent Naphtha Medium Aliphatic 64742-88-7 tonnes -3% —

Created


Arsenic N/A-2 kg — —Cadmium N/A-3 kg — —Chromium N/A-4 tonnes — —Cobalt N/A-5 kg — —Copper N/A-6 tonnes — —Lead N/A-8 kg — —Manganese N/A-9 tonnes — —Nickel N/A-10 tonnes — —Selenium N/A-12 kg — —Vanadium 7440-62-2 tonnes — —Zinc N/A-14 tonnes — —Sulphuric Acid 7664-93-9 tonnes — —Ammonia N/A tonnes -25% Decreased creation of Ammonia in the Mining StageNitrate Ion N/A-11 tonnes — —Carbon Disulphide 75-15-0 tonnes -23% Decreased Xanthate usageCyanides N/A-7 tonnes — —I-Butyl Alcohol 78-83-1 tonnes -23% Decreased Xanthate usageTotal Reduced Sulphur N/A- 300 tonnes -23% Decreased Xanthate usageNitrogen Oxides 11104-93-1 tonnes -6% —Carbon Monoxide 630-08-0 tonnes -1% —PM N/A - M08 tonnes -8% —PM-10 N/A - M09 tonnes -9% —PM-2.5 N/A - M10 tonnes -9% —Solvent Naphtha Medium Aliphatic 64742-88-7 tonnes — —

Contained in Product


Arsenic N/A-2 kg — —Cadmium N/A-3 kg 2% —Chromium N/A-4 tonnes -5% —Cobalt N/A-5 kg -4% —Copper N/A-6 tonnes 5% —Lead N/A-8 kg -3% —Manganese N/A-9 tonnes -5% —Nickel N/A-10 tonnes -4% —Selenium N/A-12 kg 2% —Vanadium 7440-62-2 tonnes -6% —Zinc N/A-14 tonnes -1% —Sulphuric Acid 7664-93-9 tonnes — —Ammonia N/A tonnes — —Nitrate Ion N/A-11 tonnes — —Carbon Disulphide 75-15-0 tonnes — —Cyanides N/A-7 tonnes — —I-Butyl Alcohol 78-83-1 tonnes — —Total Reduced Sulphur N/A- 300 tonnes — —Nitrogen Oxides 11104-93-1 tonnes — —Carbon Monoxide 630-08-0 tonnes — —PM N/A - M08 tonnes — —PM-10 N/A - M09 tonnes — —PM-2.5 N/A - M10 tonnes — —Solvent Naphtha Medium Aliphatic 64742-88-7 tonnes — —Notes:"BT" below the reporting threshold

APPENDIX C: PLAN SUMMARIES

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TOXIC SUBSTANCE REDUCTION PLAN SUMMARY This Toxic Substance Reduction Plan Summary has been prepared in accordance with Section 8(2) of the

Toxics Reduction Act and satisfies the minimum Plan Summary content requirements stipulated in

Section 24 of Ontario Regulation (O.Reg.) 455/09.

Basic Facility Information



This Plan Summary applies to the Toxic Substance Reduction Plans for the following prescribed Toxic Substances: Arsenic, Cadmium, Chromium, Cobalt, Copper, Lead, Manganese, Nickel, Selenium, Zinc (Per

O.Reg.455/09; “no single CAS numbers apply to these substances”) and Vanadium (CAS number 7440-62-2)


NPRI ID: 1233

O.Reg.127/01 ID: N/A


Xstrata Nickel

Onaping Mines/Mill Operations




379

North American Industry Classification System (NAICS) codes and the six-digit NAICS Canada code

21 - Mining & Oil & Gas Extraction

2122 - Metal Ore Mining

212232 – Nickel-Copper Ore Mining

Public contact

Joe Fyfe

Superintendent – Environment and SD Management Systems





UTM Zone 17

473367 E 5168770 N


Xstrata Canada Corporation 100 King Street West, 1 First Canadian Place, Suite 6900 Toronto, Otario M5X 1E3

List of All Substances for which Toxic Substance Reduction Plans Have Been

Prepared at the Facility The Facility has prepared Toxic Substance Reduction Plans for the following prescribed Toxic Substances:

Arsenic*

Cadmium*

Chromium*

Cobalt*

Copper*

2 of 4

Lead*

Manganese*

Nickel*

Selenium*

Zinc*

Vanadium (CAS number 7440-62-2)

Sulphuric Acid (CAS number 7664-93-9)


Statement of Intent As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility’s intent to reduce

the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this

statement.

A statement of the Facility’s intent to reduce its “use” of the Toxic Substance has not been included as a

part of this Plan. The Toxic Substance is never created within the Facility’s process and therefore no

statement with respect to intent to reduce creation of the Toxic Substance is required.

The Facility is captured by the requirements of the TRA pertaining to the Toxic Substance since the

Facility meets the TRA’s definition of target facilities “with North American Industry Classification

System (NAICS) codes commencing with the digits 212 (mining – except oil and gas – that processes

minerals, but only if the mineral processing at the facility involves the use of chemicals to separate,

refine, smelt or concentrate metallic or non-metallic minerals from an ore)” and also triggered the Toxic

Substance’s TRA reporting threshold, which was adopted by the TRA from National Pollutant Release

Inventory (NPRI).

Per guidance pertaining to the Toxic Substance, reporting is triggered if the Toxic Substance was

“manufactured, processed, or otherwise used” (MPO) in the previous calendar year in an amount that is

greater than a specified quantity. In the Facility’s case, and following Ontario Ministry of the

Environment (MOE) guidance, processing of feedstocks in which the Toxic Substance is present due to

natural deposition in previously mined and/or processed materials, meets the definition of MPO,

despite the fact that the Toxic Substance travels through the Facility’s concentration process without

undergoing any significant chemical change.

Although the Toxic Substance is present in the feedstocks at relatively low concentrations, the Toxic

Substance’s “use”-based reporting threshold was exceeded due to the large quantity of feedstock that is

processed at the Facility on an annual basis.

As a result, and in accordance with the TRA, this specified quantity has been reported to the MOE as a

“use” of the Toxic Substance as a part of a mandatory Toxic Substance quantification, accounting and

reporting exercise.

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This document satisfies the additional TRA requirement of Toxic Substance Reduction Plan preparation,

which requires the Facility to systematically examine opportunities to reduce its “use” of the Toxic

Substance. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan

which are all requirements; the implementation toxic substance reduction options identified in the Plan

(if any) is not a requirement of the TRA or O.Reg.455/09.

The Facility understands the benefits to reducing the use and creation of toxic substances, informing

Ontarians about toxic substances in their community and helping Ontario position itself to compete in

an increasingly green global economy. However, due to the fact that the only Facility activity which the

TRA has defined as a “use” of the Toxic Substance is the processing of ore in which the Toxic Substance

occurs naturally, there are no opportunities to reduce the “use” of the Toxic Substance aside from

reducing the Facility’s production.

As a part of fulfilling its requirements under the TRA and O.Reg.455/09, the Facility has prepared a total

of eleven Toxic Substance Reduction Plans and Plan Summaries for naturally occurring elements which

are prescribed toxic substances and whose “use” cannot be reduced based on the factors presented

above.

The MOE has stated that the TRA is not intended to focus on “end of pipe” emissions as they don’t

necessarily have any bearing on the amount of a substance that is “used” or “created,” however the

Facility would like to take this opportunity to inform the reader of the fact that the Facility currently

complies with all environmental regulations that control the release and disposal of the Toxic Substance;

meeting or exceeding the strict release limits imposed by these regulations for the Toxic Substance.

Objectives of the Toxic Substance Reduction Plan The Objectives of the Plan are as follows:

provide support for the Facility’s position with respect to the Statement of Intent by providing an

explanation of how the TRA’s definition of the word “use”, as applied to the Toxic Substance,

renders it impossible to reduce the “use” of the Toxic Substance without reducing Facility

production;

provide the reader with an understanding of the nature of the Facility activity which the TRA has

defined as a “use” of the Toxic Substance; and

document how the Facility has fulfilled the applicable requirements under the TRA and O. Reg.

455/09 with respect to the Toxic Substance.

Description of Why the Toxic Substance Is Used or Created As stated elsewhere in this Plan, the Facility activity that the MOE has defined for the purpose of the

TRA as a “use” of the Toxic Substance is the handling and processing of previously mined and/or

processed materials in which the Toxic Substance is present due to natural deposition. Since the Toxic

Substance occurs naturally in mined materials, and the Facility is a mining and mineral processing

4 of 4

facility, it is impossible to reduce this “use” of the Toxic Substance without reducing the Facility’s

production. The Toxic Substance simply travels through the Facility process along with all other non-

desired materials without undergoing any significant chemical change. It is impossible for the Toxic

Substance to be created within the Facility process, since the Toxic Substance is reportable under the

TRA and O.Reg.455/09 as an elemental mass contribution to the material in which it may be a

component.

Rationale for Not Implementing Toxic Substance Reduction Options As required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an

explanation of why no toxic substance reduction options will be implemented.

Facility personnel have considered each of the seven categories for toxic substance reduction options,

and, in light of the information provided in the Statement of Intent section of this Plan, the Facility feels

that no toxic substance reduction options can be identified in any of the seven toxic substance reduction

categories.

Therefore the rationale for not implementing toxic substance reduction options is that no toxic

substance reduction options could be identified.

Statement that the Plan Summary Accurately Reflects the Current Version of

the Plan As required by s.24(1)8 of O.Reg.455/09 this Plan Summary accurately reflects the current version of the

Plan.

Planner License Number As required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic

Substance Reduction Planner responsible for providing Planner Recommendations on and certification

of this Plan is as follows:

Russell Polack

Air Quality Specialist

Golder Associates Ltd.

Toxic Substance Reduction Planner License Number TSRP0002

Copies of the Certification Certification statements are provided in the following page.

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Sulphuric Acid (CAS No. 7664-93-9)


NPRI ID: 1233



Xstrata Nickel





454





Public contact

Joe Fyfe






UTM Zone 17

473367 E 5168770 N


Xstrata Canada Corporation 100 King Street West, 1 First Canadian Place, Suite 6900 Toronto, Otario M5X 1E3



Arsenic*

Cadmium*

Chromium*

Cobalt*

Copper*

2 of 3

Lead*

Manganese*

Nickel*

Selenium*

Zinc*

Vanadium [CAS number 7440-62-2]

Sulphuric Acid [CAS number 7664-93-9]




statement, as well as objectives of the Plan.

A statement of the Facility’s intent to reduce use of the Toxic Substance has not been included as a part

of this Plan. The Toxic Substance is never created within the Facility’s process and therefore no

statement with respect to intent to reduce creation of the Toxic Substance is required.

The Facility is of the opinion that it has previously optimized its use of the Toxic Substance to greatest

extent that can reasonably be expected. It should be noted that existing processes and systems in place

at the Facility are capable of meeting or exceeding exposure and release limits imposed by applicable

occupational and environmental regulations.

Substitution of the Toxic Substance is possible but potential substitutes are also prescribed Toxic

Substances under the TRA, and therefore there would be no net benefit to making such a substitution.

Reduction of use of the Toxic Substance would result in decreased recovery of metals, with significant

economic impact and increase of the sites discharges.

Objectives of the Toxic Substance Reduction Plan The objectives of this Plan are as follows:

provide the reader with information on measures currently in place at the Facility which influence

the way in which the Toxic Substance is used at the Facility;

provide support for the Facility’s position with respect to the Statement of Intent of this Plan; and

document how, by preparing this Plan, the Facility has fulfilled the applicable requirements under

the TRA and O.Reg.455/09 with respect to the Toxic Substance.

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Description of Why the Toxic Substance Is Used or Created Sulphuric acid is used at the Facility in the Milling Stage for pH adjustment to optimize concentrating

conditions. Acidified process water is transferred to the Tailings Management Process where all

Sulphuric Acid entering the process is destroyed by neutralization. This use of the Toxic Substance

allows for the optimization of the separation process and is a common practice within the industry. The

Toxic Substance is never created at the Facility.



Facility personnel have carefully examined each of the seven categories for toxic substance reduction

options, and, in light of the information provided in the Statement of Intent section of this Plan, the

Facility feels that no toxic substance reduction options can be identified in any of the seven toxic

substance reduction categories at this time.





Plan.

Planner License Number As required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic



Russell Polack




Copies of the Certification Certification statements are provided in the following pages.

1 of 6

TOXICSUBSTANCEREDUCTIONPLANSUMMARYThis Toxic Substance Reduction Plan Summary has been prepared in accordance with Section 8(2) of the






This Plan Summary applies to the Toxic Substance Reduction Plans for the following prescribed Toxic Substances:

Particulate Matter, PM10, PM2.5 (Per O.Reg. 455/09; “no single CAS numbers apply to these substances”)


NPRI ID: 1233



Sudbury Integrated Nickel Operations (Sudbury INO)

Onaping Mines Mill




550


21 ‐ Mining & Oil & Gas Extraction

2122 ‐ Metal Ore Mining

212232 – Nickel‐Copper Ore Mining

Public contact

Joe Fyfe


Sudbury Integrated Nickel Operations




UTM Zone 17

473367 E 5168770 N



2 of 6


Arsenic*

Cadmium*

Chromium*

Cobalt*

Copper*

Lead*

Manganese*

Nickel*

Selenium*

Zinc*

Vanadium [CAS number 7440‐62‐2]

Sulphuric Acid [CAS number 7664‐93‐9]

Particulate Matter*

PM10*

PM2.5*

Nitrogen Oxides [CAS number 11104‐93‐1]

Carbon Monoxide [CAS number 630‐08‐0]

Ammonia (Total)*

Nitrate Ion*


I‐Butyl Alcohol [CAS number 78‐83‐1]

Carbon Disulphide [CAS number 75‐15‐10]

*Per O.Reg.455/09, “no single CAS numbers apply to these substances”

3 of 6

StatementofIntentAs required by s.4(1) of the TRA, a Plan must include either a statement of the Facility’s intent to reduce the use

and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement.

A statement of the Facility’s intent to reduce its “creation” of the Toxic Substance has not been included as a part

of this Plan. The Toxic Substance cannot be “used” in the Facility process and therefore no statement with respect

to intent to reduce use of the Toxic Substance is required.

The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to two activities at the Facility

which are interpreted as “creations” of the Toxic Substance under the TRA framework. The first activity that has

been classified as a “creation” of the Toxic Substance for the purpose of the required TRA Quantification,

Accounting and Reporting exercise for the Toxic Substances is the generation by physical means of suspended

particulate matter in various size fractions commonly referred to as dust; which is subsequently released either as

stack or fugitive emissions.

The second activity that has been classified as a “creation” of the Toxic Substance is the generation of suspended

particulate matter as a by‐product of combustion of fuels in stationary equipment.

The Ontario Ministry of the Environment (MOE) has stated that the TRA is not intended to focus on “end of pipe”

emissions as they don’t necessarily have any bearing on the amount of a substance that is “used” or “created,”

however in this case, “end of pipe” emissions of suspended particulate matter is the determining factor of the

Facility’s TRA reporting status with respect to the Toxic Substance.

Despite the Facility’s reporting status with respect to the Toxic Substance, the Facility feels that it has previously

optimized its control of the “creation” and subsequent release of the Toxic Substance to the greatest extent that

can reasonably be expected. This opinion is supported by the following two aspects:

Compliance with Regulatory Requirements

It is well documented that release of suspended particulate matter is an inherent by‐product of mining and

mineral processing and that the activities leading to the release of suspended particulate matter are essential to

the process of mining and mineral processing. In recognition of this, the MOE has imposed various regulatory

requirements related to the release of suspended particulate matter, which include:

Ontario Regulation 419/05, under which a Facility must demonstrate compliance with substance‐specific

ground‐level concentration limits of emitted substances, including suspended particulate matter in all forms

that are reportable under the NPRI and TRA reporting programs.

The requirement for any Facility that may discharge any contaminant to the atmosphere to apply for and

obtain an Environmental Compliance Approval (ECA) for air which approves the facility’s emissions and

provides performance limits, documentation requirements and reporting requirements which a Facility must

meet in order to maintain compliance with the ECA on an ongoing basis.

The requirement for qualifying a facility to prepare and implement a “Fugitive Dust Best Management

Practices Plan.” This document outlines controls in place with respect to minimizing suspended particulate

matter releases in the form fugitive dust at the facility, along with the decision making process that was used

to identify fugitive dust emission sources and to develop appropriate best management practices for each

type of source. A qualifying facility’s Fugitive Dust Best Management Practices Plan must be approved by the

MOE as a part of the ECA implementation process.

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The requirement to prepare and implement an Operations and Maintenance Manual which outlines

operating procedures and maintenance programs for processes with what the MOE refers to as “Significant

Environmental Impacts.” This document assists Facility personnel in operating the Facility in a manner that

minimizes the potential for environmental impacts and is also a part of the ECA implementation process.

Sudbury INO currently meets and/or exceeds all of the above regulatory requirements which are designed to

control the release of the Toxic Substance and minimize potential off‐site impacts resulting from the release of the

Toxic Substance.

Measures Currently in Place to Minimize Releases of Suspended Particulate Matter

As a result of satisfying all of the above noted regulatory requirements in addition to voluntary actions with

respect to suspended particulate matter releases, Sudbury INO actively implements a variety of controls to

minimize suspended particulate matter releases from different parts of its process components. These controls

include, but are not limited to, the following:

Implementation of the controls outlined in the Facility’s Fugitive Dust Best Management Practices Plan,

which was developed in consultation with the MOE; such as:

Regular road watering, sweeping of Facility paved roadways and dust suppressant application to Facility

unpaved roadways. Annual Dust sampling on Facility roadways is conducted to confirm the effectiveness

of these controls.

Strategic placement of stockpiles with respect to windbreaks (buildings, hills, trees etc…) for material

that is susceptible to wind erosion.

Installation of wind screens in the vicinity of certain material handling operations where existing wind

breaks may not be available.

Optimization of material stockpile size, location and drop heights.

Reactive measures including curtailing operations in the event of visual disturbance of dust that may

occur despite the above controls.

Operation of eleven baghouses and/or dust collectors serving various process components to minimize

suspended particulate matter. This equipment is actively maintained as outlined in the Facility’s Operations

and Maintenance Manual, which was developed in consultation with the MOE.

Measures in place to minimize fuel consumption, including but not limited to:

Fuel‐burning heating equipment is inspected and serviced at the frequencies described in the Operations

and Maintenance Manuals. Efficient operation of this equipment minimizes fuel consumption and

generation of particulate matter.

The mine air heaters at Fraser Mine were replaced in 2013 and the replacements meet, or exceed, the

requirements of ANSI Z83.4/CAN‐CSA 3.7 “Non‐recirculating direct gas‐fired industrial air heaters” in

terms of fuel efficiency and emissions.

The diesel engines in mining equipment are also regularly inspected and serviced including tailpipe

emissions monitoring.

5 of 6

ObjectivesoftheToxicSubstanceReductionPlanThe objectives of this Plan are as follows:

Provide the reader with information on measures currently in place at the Facility which control the

“creation” and subsequent release of the Toxic Substance;

Provide support for the Facility’s position with respect to the Statement of Intent of this Plan; and

Document how the Facility has fulfilled the applicable requirements under the TRA and O. Reg. 455/09

with respect to the Toxic Substance.

DescriptionofWhytheToxicSubstanceIsUsedorCreatedThe Toxic Substance has triggered reporting under the TRA and O. Reg. 455/09 due to two activities at the Facility

which are defined as “creations” of the Toxic Substance under the TRA framework. The first activity that has been

classified as a “creation” of the Toxic Substance is the generation by physical means of suspended particulate

matter in various size fractions as dust; which is subsequently released either as stack or fugitive emissions. The

second activity that has been classified as a “creation” of the Toxic Substance is the generation of particulate

matter as a by‐product of combustion of fuels in stationary equipment. The Toxic Substance cannot be used in the

Facility process.

For the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance,

the calculated “release” values have been assumed to be equal to the amount “created” for each emission source,

despite the fact that some of these releases are controlled releases. S.12(6) of O. Reg. 455/09 provides

considerations for determining the “Best Available Methods” for tracking and quantifying the Toxic Substance.

MOE guidance pertaining to this section of O. Reg. 455/09 states that the importance of selecting Best Available

Methods is to provide the best decision making information when determining which toxics reduction options, if

any, are worthwhile to implement. It should be noted that, given the Facility’s decision to not include in this Plan a

statement of its intent to reduce the “creation” of the Toxic Substance (as supported by the information provided

in the Statement of Intent section of the Plan), no decisions will be made with respect to toxics reduction based on

the calculated “creation” values for the Toxic Substance. Taking this into consideration, the Facility used

judgement based on relevance and effort required to obtain information and feels that it has gone to reasonable

efforts in identifying and applying the Best Available Methods for quantifications in this case.

RationaleforNotImplementingToxicSubstanceReductionOptionsAs required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an


Facility personnel have considered each of the seven categories for toxic substance reduction options, and, in light

of the information provided in the Statement of Intent section of this Plan, the Facility feels that no toxic substance

reduction options can be identified in any of the seven toxic substance reduction categories.

Therefore the rationale for not implementing toxic substance reduction options is that no toxic substance

reduction options could be identified.

6 of 6

StatementthatthePlanSummaryAccuratelyReflectstheCurrentVersionofthePlanAs required by s.24(1)8 of O.Reg.455/09 this Plan Summary accurately reflects the current version of the Plan.

PlannerLicenseNumberAs required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic



Russell Polack




CopiesoftheCertificationCertification statements are provided in the following pages.

1 of 4

TOXIC SUBSTANCE REDUCTION PLAN SUMMARY This Toxic Substance Reduction Plan Summary has been prepared in accordance with Section 8(2) of the Toxics Reduction Act and satisfies the minimum Plan Summary content requirements stipulated in Section 24 of Ontario Regulation (O.Reg.) 455/09.

Basic Facility Information Mandatory Basic Facility Information Item Details


This Plan Summary applies to the Toxic Substance Reduction Plans for the following prescribed Toxic Substances: Carbon Disulphide (CAS Number 75-15-10); Total Reduced Sulphur (No CAS Number); I-Butyl Alcohol (CAS Number 78-83-1)




Sudbury Integrated Nickel Operations Onaping Mines Mill Strathcona Services Building, 85 Regional Road, Onaping, ON P0M 2R0

The number of full time employee equivalents at the facility 550



Public contact

Joe Fyfe Superintendent – Environment and SD Management Systems Sudbury Integrated Nickel Operations Strathcona Services Building, 85 Regional Road, Onaping, ON P0M 2R0


UTM Zone 17 473367 E 5168770 N



2 of 4

List of All Substances for which Toxic Substance Reduction Plans Have Been Prepared at the Facility The Facility has prepared Toxic Substance Reduction Plans for the following prescribed Toxic Substances:

Arsenic*

Cadmium*

Chromium*

Cobalt*

Copper*

Lead*

Manganese*

Nickel*

Selenium*

Zinc*



Particulate Matter*

PM10*

PM2.5*

Nitrogen Oxides [CAS number 11104-93-1]

Carbon Monoxide [CAS number 630-08-0]

Ammonia (Total)*

Nitrate Ion*


I-Butyl Alcohol [CAS number 78-83-1]

Carbon Disulphide [CAS number 75-15-10]


3 of 4

Statement of Intent As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility’s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement.

A statement of the Facility’s intent to reduce the “creation” of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is not used within the Facility’s process and therefore no statement with respect to intent to reduce creation of the Toxic Substance is required.

The activity that has been classified as a “creation” of the toxic substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance is the generation of the Toxic Substance as a result of chemical decomposition, or breakdown, of xanthate which is the vital reagent in the Facility’s flotation process. The breakdown of xanthate as it passes through the process is unavoidable and therefore the “creation” of the Toxic Substances cannot be avoided as long as xanthate is being used in the process.

Substitution of the xanthate product whose breakdown results in the “creation” of the Toxic Substances is possible but potential substitutes have been considered and it has been determined that the currently used xanthate product provides the best recovery of metals and therefore it is the most suitable reagent to use in the process. Reduction of use of the xanthate product that results in the “creation” of the Toxic Substances would result in decreased recovery of metals, which would have a significant negative economic impact.

The Facility is of the opinion that it has previously optimized its use of the xanthate product to greatest extent that can reasonably be expected. Furthermore, the use of the xanthate product is directly linked to the Facility’s production and therefore, given the previously optimized use of the xanthate product, this use cannot be reduced without negatively impacting Facility production.

It should be noted that existing processes and systems in place at the Facility are capable of meeting or exceeding exposure and release limits imposed by applicable occupational and environmental regulations pertaining to the Toxic Substance.

Objectives of the Toxic Substance Reduction Plan The Objectives of this Plan are as follows:

• provide support for the Facility’s position with respect to the Statement of Intent of this Plan; and

• document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance.

Description of Why the Toxic Substance Is Used or Created The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to its generation as result of chemical decomposition, or breakdown, of xanthate which is the vital reagent in the Facility’s

4 of 4

flotation process. Per TRA guidance, this generation is treated as a “creation” of the Toxic Substances in the TRA exercise. Xanthate acts as a collector which selectively adheres to the surface of a desired mineral and is subsequently floated to the surface of the flotation cell through agitation and aeration before being skimmed from the surface of the flotation cell along with the desirable mineral which constitutes flotation concentrate, the ultimate product of the process. Some xanthate inevitably breaks down as it travels through the Facility, and it is this breakdown process which is responsible for the “creation” of the Toxic Substance.

Rationale for Not Implementing Toxic Substance Reduction Options As required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an explanation of why no toxic substance reduction options will be implemented.

Facility personnel have considered each of the seven categories for toxic substance reduction options, and, in light of the information provided in the Statement of Intent section of this Plan, the Facility feels that no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories.

Therefore the rationale for not implementing toxic substance reduction options is that no toxic substance reduction options could be identified.

Statement that the Plan Summary Accurately Reflects the Current Version of the Plan As required by s.24(1)8 of O.Reg.455/09 this Plan Summary accurately reflects the current version of the Plan.

Planner License Number As required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic Substance Reduction Planner responsible for providing Planner Recommendations on and certification of this Plan is as follows:

Russell Polack Air Quality Specialist Golder Associates Ltd. Toxic Substance Reduction Planner License Number TSRP0002


1 of 4

TOXIC SUBSTANCE REDUCTION PLAN SUMMARY This Toxic Substance Reduction Plan Summary has been prepared in accordance with Section 8(2) of the Toxics Reduction Act and satisfies the minimum Plan Summary content requirements stipulated in Section 24 of Ontario Regulation (O.Reg.) 455/09.

Basic Facility Information Mandatory Basic Facility Information Item Details


This Plan Summary applies to the Toxic Substance Reduction Plans for the following prescribed Toxic Substances: Ammonia (Total); Nitrate Ion (Per O.Reg.455/09, “no single CAS numbers apply to these substances”)




Sudbury Integrated Nickel Operations Onaping Mines Mill Strathcona Services Building, 85 Regional Road, Onaping, ON P0M 2R0




Public contact

Joe Fyfe Superintendent – Environment and SD Management Systems Sudbury Integrated Nickel Operations Strathcona Services Building, 85 Regional Road, Onaping, ON P0M 2R0


UTM Zone 17 473367 E 5168770 N



2 of 4

List of All Substances for which Toxic Substance Reduction Plans Have Been Prepared at the Facility The Facility has prepared Toxic Substance Reduction Plans for the following prescribed Toxic Substances:

Arsenic*

Cadmium*

Chromium*

Cobalt*

Copper*

Lead*

Manganese*

Nickel*

Selenium*

Zinc*



Particulate Matter*

PM10*

PM2.5*



Ammonia (Total)*

Nitrate Ion*





3 of 4

Statement of Intent As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility’s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement.

A statement of the Facility’s intent to reduce the “creation” of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is not used within the Facility’s process and therefore no statement with respect to intent to reduce creation of the Toxic Substance is required.

The activity that has been classified as a “creation” of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substances is the generation of the Toxic Substance as a dissolved residue in effluent which is a by-product of explosives detonation within the underground mining operations at the Facility.

The Facility is of the opinion that it has previously optimized its use of explosives to greatest extent that can reasonably be expected. Furthermore, the use of explosives is directly linked to the Facility’s production and therefore, given the previously optimized use of explosives, the use of explosives cannot be reduced without negatively impacting Facility production. Sudbury INO actively implements a variety of controls to optimize the use of explosives. For example, the Morgan expansion of Fraser Mine is designed to use blasthole stoping, a mining and blasting method that minimizes the use of explosives relative to the amount of ore removed. Fraser Morgan is also using gassed emulsion explosives, rather than ammonium nitrate: fuel oil (ANFO), which allows the adjustment of explosive density (minimizing the amount of explosive used per blast) and which also reduces the production of combustion gases.

Furthermore, it should be noted that existing processes and systems in place at the Facility are capable of meeting or exceeding exposure and release limits imposed by applicable occupational and environmental regulations.


• provide the reader with information on measures currently in place at the Facility which control the “creation” and subsequent release of the Toxic Substance;

• provide support for the Facility’s position with respect to the Statement of Intent of this Plan; and

• document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance.

Description of Why the Toxic Substance Is Used or Created The activity that has been classified as a “creation ” of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance is the generation of the Toxic Substance as a dissolved residue in effluent which results from explosives detonation within the underground mining operations. The Toxic Substance is never used in the Facility process.

For the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance, the calculated “release” values have been assumed to be equal to the amount “created,” despite the fact that these releases are controlled releases. S.12(6) of O.Reg.455/09 provides considerations for determining the “Best

4 of 4

Available Methods” for tracking and quantifying the Toxic Substance. MOE guidance pertaining to this section of O.Reg.455/09 states that the importance of selecting Best Available Methods is to provide the best decision making information when determining which toxics reduction options, if any, are worthwhile to implement. It should be noted that, given the Facility’s decision to not include in this Plan a statement of its intent to reduce the “creation” of the Toxic Substance (as supported by the information provided in the Statement of Intent section of the Plan), no decisions will be made with respect to toxics reduction based on the calculated “creation” values for the Toxic Substance. Taking this into consideration, the Facility used judgement based on relevance and effort required to obtain information and feels that it has gone to reasonable efforts in identifying and applying the Best Available Methods for quantifications in this case.

Rationale for Not Implementing Toxic Substance Reduction Options As required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an explanation of why no toxic substance reduction options will be implemented.

Facility personnel have considered each of the seven categories for toxic substance reduction options, and, in light of the information provided in the Statement of Intent section of this Plan, the Facility feels that no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories.


Statement that the Plan Summary Accurately Reflects the Current Version of the Plan As required by s.24(1)8 of O.Reg.455/09 this Plan Summary accurately reflects the current version of the Plan.

Planner License Number As required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic Substance Reduction Planner responsible for providing Planner Recommendations on and certification of this Plan is as follows:



1 of 5

TOXICSUBSTANCEREDUCTIONPLANSUMMARYThis Toxic Substance Reduction Plan Summary has been prepared in accordance with Section 8(2) of the






This Plan Summary applies to the Toxic Substance Reduction Plans for the following prescribed Toxic Substances:

Nitrogen Oxides (CAS Number 11104‐93‐1);

Carbon Monoxide (CAS Number 630‐08‐0)


NPRI ID: 1233




Onaping Mines Mill




550


21 ‐ Mining & Oil & Gas Extraction

2122 ‐ Metal Ore Mining

212232 – Nickel‐Copper Ore Mining

Public contact

Joe Fyfe






UTM Zone 17

473367 E 5168770 N


Glencore Canada Corporation

100 King Street West, 1 First Canadian Place, Suite 6900

Toronto, Ontario

M5X 1E3

2 of 5


Arsenic*

Cadmium*

Chromium*

Cobalt*

Copper*

Lead*

Manganese*

Nickel*

Selenium*

Zinc*

Vanadium [CAS number 7440‐62‐2]

Sulphuric Acid [CAS number 7664‐93‐9]

Particulate Matter*

PM10*

PM2.5*

Nitrogen Oxides [CAS number 11104‐93‐1]

Carbon Monoxide [CAS number 630‐08‐0]

Ammonia (Total)*

Nitrate Ion*


I‐Butyl Alcohol [CAS number 78‐83‐1]

Carbon Disulphide [CAS number 75‐15‐10]


3 of 5

StatementofIntentAs required by s.4(1) of the TRA, a Plan must include either a statement of the Facility’s intent to reduce the use

and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement.

A statement of the Facility’s intent to reduce its “creation” of the Toxic Substance has not been included as a part

of this Plan. The Toxic Substance cannot be “used” in the Facility process and therefore no statement with respect

to intent to reduce use of the Toxic Substance is required.

The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to its generation as a by‐product

of combustion of fuels in stationary equipment or detonation of explosives, both of which are classified as a

“creation” of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting

exercise for the Toxic Substance.

The Ontario Ministry of the Environment (MOE) has stated that the TRA is not intended to focus on “end of pipe”

emissions as they don’t necessarily have any bearing on the amount of a substance that is “used” or “created,”

however in this case, “end of pipe” emission of the Toxic Substance are the determining factor of the Facility’s TRA

reporting status with respect to the Toxic Substance.

Despite the Facility’s reporting status with respect to the Toxic Substance, the Facility feels that it has previously

optimized its control of the “creation” and subsequent release of the Toxic Substance to the greatest extent that

can reasonably be expected. This opinion is supported by the following two aspects:

Compliance with Regulatory Requirements

It is well documented that the release of combustion products such as the Toxic Substance is an inherent by‐

product of mining and mineral processing and that the activities leading to the release of combustion products are

essential to the process of mining and mineral processing. In recognition of this, the MOE has imposed various

regulatory requirements related to the release of combustion products, which include:

Ontario Regulation 419/05, under which a Facility must demonstrate compliance with substance‐specific

ground‐level concentration limits of emitted substances, including combustion products in all forms that are

reportable under the NPRI and TRA reporting programs.

The requirement for any Facility that may discharge any contaminant to the atmosphere to apply for and

obtain an Environmental Compliance Approval (ECA) for air which approves the facility’s emissions and

provides performance limits, documentation requirements and reporting requirements which a Facility must

meet in order to maintain compliance with the ECA on an ongoing basis.

Sudbury INO currently meets and/or exceeds all of the above regulatory requirements which are designed to

control the release of the Toxic Substance and minimize potential off‐site impacts resulting from the release of the

Toxic Substance.

Measures Currently in Place to Minimize Releases of Combustion Products

As a result of satisfying all of the above noted regulatory requirements in addition to voluntary actions with

respect to combustion product releases, Sudbury INO actively implements a variety of controls to minimize

combustion product releases from different parts of its process components. These controls include, but are not

limited to, the following:

4 of 5

Measures in place to minimize fuel consumption, including but not limited to:

Fuel‐burning heating equipment is inspected and serviced at the frequencies described in the Operations

and Maintenance Manuals. Efficient operation of this equipment minimizes fuel consumption and

generation of particulate matter.

The mine air heaters at Fraser Mine were replaced in 2013 and the replacements meet, or exceed, the

requirements of ANSI Z83.4/CAN‐CSA 3.7 “Non‐recirculating direct gas‐fired industrial air heaters” in

terms of fuel efficiency and emissions.

The diesel engines in mining equipment are also regularly inspected and serviced including tailpipe

emissions monitoring.

Measures in place to optimize explosives usage, including but not limited to:

Blasting is a process designed to optimize, among other objectives, the minimal use of explosives. Each

production or development blast is planned and performed in a manner that minimizes or eliminates

worker exposure to combustion products.

The Morgan expansion of Fraser Mine is designed to use blasthole stoping, a mining and blasting method

that minimizes the use of explosives relative to the amount of ore removed. Fraser Morgan is also using

gassed emulsion explosives, rather than ammonium nitrate: fuel oil (ANFO), which allows the adjustment

of explosive density (minimizing the amount of explosive used per blast) and which also reduces the

production of combustion gases.


provide the reader with information on measures currently in place at the Facility which control the

“creation” and subsequent release of the Toxic Substance;


document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with

respect to the Toxic Substance.

DescriptionofWhytheToxicSubstanceIsUsedorCreatedThe activity that has been classified as a “creation” of the Toxic Substance for the purpose of the

required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance is the

generation of the Toxic Substance as a by‐product of combustion of fuels in stationary equipment and

detonation of explosives. The Toxic Substance cannot be used in the Facility process.

RationaleforNotImplementingToxicSubstanceReductionOptionsAs required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an


5 of 5




categories.



StatementthatthePlanSummaryAccuratelyReflectstheCurrentVersionofthePlanAs required by s.24(1)8 of O.Reg.455/09 this Plan Summary accurately reflects the current version of the

Plan.

PlannerLicenseNumberAs required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic



Russell Polack





1 of 5





Mandatory Basic Facility Information Item

Details


Propane (CAS No. 74-98-6)

NPRI and O.Reg.127/01 Identification Numbers NPRI ID: 1233



Sudbury INO





454

NAICS codes and the six-digit NAICS Canada code




Public contact

Joe Fyfe





Technical contact and person who is responsible for coordinating plan preparation

John Petherick

Occupational Hygiene & Environment Specialist




The person who prepared the plan

Russell Polack

Toxic Substance Reduction Planner

Golder Associates Ltd. – 1010 Lorne Street, Sudbury, ON

P3C 4R9

(705) 524-6861

Highest Ranking employee at the facility who has management responsibilities relating to the facility and who is responsible for making certification

Rob Roeterink

Strathcona Mill Manager





UTM Zone 17

473367 E 5168770 N




Toronto, Otario

M5X 1E3

2 of 5



Propane [CAS number 74-98-6]

Solvent Naphtha Medium Aliphatic [CAS number 64742-88-7]

Arsenic*

Cadmium*

Chromium*

Cobalt*

Copper*

Lead*

Manganese*

Nickel*

Selenium*

Zinc*



Particulate Matter*

PM10*

PM2.5*



Ammonia (Total)*

Nitrate Ion*





3 of 5



statement.

A statement of the Facility’s intent to reduce its “creation” or “use” of the Toxic Substance has not been

included as a part of this Plan.

The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to two activities at

the Facility, one of which is defined as a “use” under the TRA Framework and another which is

interpreted as a “creation” of the Toxic Substance under the TRA framework.

The activity that has been classified as a “use” of the Toxic Substance for the purpose of the required

TRA Quantification, Accounting and Reporting exercise for the Toxic Substance is the use of spray paint

cans which contain the Toxic Substance. The Facility is of the opinion that it has previously optimized its

use of products containing the Toxic Substance to greatest extent that can reasonably be expected and

therefore a statement of the Facility’s intent to reduce use of the Toxic Substance has not been included

as a part of this Plan.

The activity that has been classified as a “creation” of the Toxic Substance for the purpose of the

required TRA Quantification, Accounting and Reporting exercise for the Toxic Substances is the

generation and subsequent release of the Toxic Substance as a by-product of natural gas combustion. It

should be noted that the quantity “created” by this means contributed less than 10% of the total TRA-

reportable use/creation quantity for the 2013 baseline reporting year.

The Facility is of the opinion that it has previously optimized its control of the “creation” and subsequent

release of the Toxic Substance to the greatest extent that can reasonably be expected, and therefore a

statement of the Facility’s intent to reduce “creation” of the Toxic Substances has not been included as a

part of this Plan. As a result of satisfying various regulatory requirements in addition to voluntary

actions with respect to combustion product releases, Sudbury INO actively implements a variety of

controls to minimize combustion product releases from different parts of its process components.

Relevant measures in place which minimize natural gas combustion which can lead to the “creation” and

subsequent release of the Toxic Substance include, but are not limited to, the following:

Natural gas burning heating equipment is inspected and serviced at the frequencies described

in the Operations and Maintenance Manuals. Efficient operation of this equipment minimizes

natural gas consumption and generation of the Toxic Substance.

The mine air heaters at the Fraser Mine complex at the Facility were replaced in 2013 and the

replacements meet, or exceed, the requirements of ANSI Z83.4/CAN-CSA 3.7 “Non-recirculating direct

gas-fired industrial air heaters” in terms of fuel efficiency and emissions.

Finally, it is Sudbury INOs feeling that the exceedance of the NPRI and TRA reporting threshold that was

observed for the Toxic Substance in the 2013 reporting year (which resulted in the requirement to

prepare this Toxic Substance Reduction Plan) is likely a one-time occurrence, and that the Facility is not

likely to trigger reporting for this substance in subsequent reporting years.

4 of 5


provide the reader with information on measures currently in place at the Facility which influence

the way in which the Toxic Substance is used or created at the Facility;




Description of Why the Toxic Substance Is Used or Created The activity that has been classified as a “use” of the Toxic Substance for the purpose of the required


cans which contain the Toxic Substance. The activity that has been classified as a “creation” of the Toxic

Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the

Toxic Substances is the generation and subsequent release of the Toxic Substance as a by-product of

natural gas combustion.






categories.





Plan.

5 of 5

Planner License Number As required by s.18(2) of O.Reg.455/09, the Licensed Toxic Substance Reduction Planner responsible for

providing Planner Recommendations on and certification of this Plan is as follows:

Russell Polack





1 of 4





Mandatory Basic Facility Information Item

Details


Solvent Naphtha Medium Aliphatic (CAS No. 64742-88-7)

NPRI and O.Reg.127/01 Identification Numbers NPRI ID: 1233



Sudbury INO





454

NAICS codes and the six-digit NAICS Canada code




Public contact

Joe Fyfe





Technical contact and person who is responsible for coordinating plan preparation

John Petherick

Occupational Hygiene & Environment Specialist




The person who prepared the plan

Russell Polack

Toxic Substance Reduction Planner

Golder Associates Ltd. – 1010 Lorne Street, Sudbury, ON

P3C 4R9

(705) 524-6861

Highest Ranking employee at the facility who has management responsibilities relating to the facility and who is responsible for making certification

Rob Roeterink

Strathcona Mill Manager





UTM Zone 17

473367 E 5168770 N




Toronto, Otario

M5X 1E3

2 of 4





Arsenic*

Cadmium*

Chromium*

Cobalt*

Copper*

Lead*

Manganese*

Nickel*

Selenium*

Zinc*



Particulate Matter*

PM10*

PM2.5*



Ammonia (Total)*

Nitrate Ion*





3 of 4



statement.

A statement of the Facility’s intent to reduce its “creation” or “use” of the Toxic Substance has not been

included as a part of this Plan.

The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to one activity at the

Facility which is defined as a “use” under the TRA Framework. The activity that is defined as a “use” of

the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting

exercise for the Toxic Substance is the use of spray paint cans which contain the Toxic Substance. The

Facility is of the opinion that it has previously optimized its use of products containing the Toxic

Substance to greatest extent that can reasonably be expected and therefore a statement of the Facility’s

intent to reduce use of the Toxic Substance has not been included as a part of this Plan. The Toxic

Substance is never created in the Facility process and therefore no statement with respect to reduction

in creation is required.





Description of Why the Toxic Substance Is Used or Created The activity that has been classified as a “use” of the Toxic Substance for the purpose of the required


cans which contain the Toxic Substance.






categories.

4 of 4





Plan.

Planner License Number As required by s.18(2) of O.Reg.455/09, the Licensed Toxic Substance Reduction Planner responsible for

providing Planner Recommendations on and certification of this Plan is as follows:

Russell Polack





1 of 3

TOXICSUBSTANCEREDUCTIONPLANSUMMARYThis Toxic Substance Reduction Plan Summary has been prepared in accordance with Section 8(2) of the Toxics Reduction Act and satisfies the minimum Plan Summary content requirements stipulated in Section 24 of Ontario Regulation (O.Reg.) 455/09.




Cyanides (Ionic) (Per O.Reg.455/09; “no single CAS number applies to this substance”)

NPRI and O.Reg.127/01 Identification Numbers NPRI ID: 1233 O.Reg.127/01 ID: N/A


Sudbury INO Onaping Mines/Mill Operations Strathcona Services Building, 85 Regional Road, Onaping, ON P0M 2R0




Public contact

Joe Fyfe Superintendent – Environment and SD Management Systems Onaping Mines/Mill Operations Strathcona Services Building, 85 Regional Road, Onaping, ON P0M 2R0


UTM Zone 17 473367 E 5168770 N


Cyanides (Ionic)*



Arsenic*

Cadmium*

Chromium*

Cobalt*

Copper*

Lead*

2 of 3

Manganese*

Nickel*

Selenium*

Zinc*



Particulate Matter*

PM10*

PM2.5*



Ammonia (Total)*

Nitrate Ion*





StatementofIntentAs required by s.4(1) of the TRA, a plan must include either a statement of the facility’s intent to reduce the use and/or creation of the Toxic Substance at the facility, or the reasons for not including this statement, as well as objectives of the plan.

A statement of the Facility’s intent to reduce use of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is never created within the Facility’s process and therefore no statement with respect to the intent to reduce creation of the Toxic Substance is required.

The Facility is of the opinion that it has previously optimized its use of the Toxic Substance to greatest extent that can reasonably be expected. It should be noted that existing processes and systems in place at the Facility are capable of meeting or exceeding exposure and release limits imposed by applicable occupational and environmental regulations.



3 of 3

document how, by preparing this Plan, the Facility has fulfilled the applicable requirements under the

TRA and O.Reg.455/09 with respect to the Toxic Substance.

DescriptionofWhytheToxicSubstanceIsUsedorCreatedThe Toxic Substance is a component of sodium cyanide which is used for separation of nickel and copper in the Facility’s ore milling process. Currently no other reagent is known to be as effective as sodium cyanide for this application, and therefore this substance is widely used in ore processing operations the world over. The Toxic Substance is never created at the Facility.

RationaleforNotImplementingToxicSubstanceReductionOptionsAs required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an explanation of why no toxic substance reduction options will be implemented.

Facility personnel have carefully examined each of the seven categories for toxic substance reduction options, and, in light of the information provided in the Statement of Intent section of this Plan, the Facility feels that no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories at this time.


StatementthatthePlanSummaryAccuratelyReflectstheCurrentVersionofthePlanAs required by s.24(1)8 of O. Reg. 455/09 this Plan Summary accurately reflects the current version of the Plan.

PlannerLicenseNumberAs required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the licensed Toxic Substance Reduction Planner responsible for providing planner recommendations on and certification of this plan is as follows:



Golder Associates Ltd.Golder Associates Ltd.

33 Mackenzie Street, Suite 100, Sudbury, Ontario, Canada P3C 4Y1 Tel: +1 (705) 524 6861 Fax: +1 (705) 524 1984 www.golder.com

Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

Dear Mr. Petherick:

Golder Associates Ltd. (Golder) was retained by Sudbury Integrated Nickel Operations (Subury INO) Onaping

Mines Mill (the Facility) to provide various services pertaining to Toxic Substance Reduction Plan (the Plan)

preparation for Toxics Reduction Act (TRA) substance referred to as “Cyanides (Ionic)”, including Toxic

Substance Reduction Planner (Planner) certification.

The following Planner Certification Statement which is made under s.19.1(4) of Ontario Regulation

(O.Reg.) 455/09 (as amended by s.11 of O.Reg.214/11) satisfies the Planner Certification requirements for the

Plan for the substance Cyanides (Ionic). Furthermore, the following Certification Statement is limited to the

version of the Plan which is dated as indicated in below the Certification Statement:

As of September 7, 2016, I, Russell Polack certify that I am familiar with the processes at the Sudbury Integrated Nickel Operations Onaping Mines Mill facility that use or create the toxic substance referred to below, that I agree with the estimates referred to in subparagraphs 7 iii, iv and v of subsection 4 (1) of the Toxics Reduction Act, 2009 that are set out in the toxic substance reduction plan referred to below for the toxic substance and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act.

• Cyanides (Ionic) (September 7, 2016)

_________________________ _________________________

Russell Polack Date Toxic Substance Reduction Planner License No. TSRP0002

RLP/NJC/ms

September 7, 2016 Project No. 1547358

John Petherick Sudbury Integrated Nickel Operations

LICENSED TOXIC SUBSTANCE REDUCTION PLANNER CERTIFICATION STATEMENT FOR THE TOXIC SUBSTANCE REDUCTION PLAN FOR THE TRA SUBSTANCE CYANIDES (IONIC) SUDBURY INTEGRATED NICKEL OPERATIONS ONAPING MINES MILL

November 9, 2016

Documents

Report for Ontario Regulation 455/09: Toxics Reduction Act€¦ · TRA ANNUAL REPORT (2016 Reporting Year) This Toxics Reduction Act (TRA) Annual Report has been prepared in accordance