VALE # DATED. Name: Phil Langlois Position: Lead Electrical Engineer REVISIONS. App Thom. App PC. App Sud HL 2015/01/30

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1 Department 2015/01/0 Page 1 of 12 Training Code (N/A): Document Owner: Name: Phil Langlois Position: Lead Engineer REVISIONS Rev Description Rev n by Sud PC Thom VB LH Clyd Act Issue Date YYYY/MM/DD SPI-ENG-0004 reformatted to Maintenance Standard document. Minor edits made and added Personal Lightning Detectors. PL 2014/09/16 HL 2015/01/0 N/A N/A N/A N/A N/A N/A 2015/01/0 2A SPI-ENG /12/18 201/12/18 201/12/18 Sud = Sudbury, Ontario, PC = Port Colborne, Thom = Thompson, Manitoba, VB = Voisey s Bay, LH = Long Harbour, Act = Acton, England, Clyd = Clydach, Wales, N/A = Not licable

2 Department 2015/01/0 Page 2 of 12 Table of Contents 1.0 PURPOSE APPLICATION EXCEPTIONS....0 REFERENCE DOCUMENTATION COMMITMENTS DEFINITIONS CONTEXT DETECTION METHODS RISK ASSESSMENT PRIORITY TO PERFORMING WORK STORM WARNINGS DURING WORK PERIODS STEPS TO TAKE DURING STORMS AND LIGHTNING STRIKES AFTER THE STORM WARNING APPENDICES... 8

3 Department 2015/01/0 Page of PURPOSE This precautionary guideline identifies the risks associated with working during storms or occurrences of lightning, and to outline means by which risks can be reduced to ALARA. 2.0 APPLICATION In order to reduce the risk of harm to personnel, to optimize available resources and lower the associated costs, supervision and workers will be able to assess the risk when lightning is present or where there is a potential for lightning during storms, and take appropriate precautions. 2.1 EXCEPTIONS This guideline applies only to Vale Sudbury area sites..0 REFERENCE DOCUMENTATION The following documents were used in the development of this document or are related to it. They shall be used in their most recent revision. Construction Safety Association of Manitoba Education Program - #24, Lightning Safety Vale SPI-P5516/PWR#4, Power Department s Lightning Storm Warning Procedure Environment Canada Website 4.0 COMMITMENTS The guideline is committed to comply with: The Vale Safe Production model Occupational Health and Safety Act

4 Department 2015/01/0 Page 4 of DEFINITIONS ALARA: As Low As Reasonably Achievable Elevated Risk: For the purpose of this document, elevated risk refers to risk associated with lightning and storms. ERP: Emission Reduction Program (SO2 specific) Lightning: Lightning is a massive electrical discharge from cloud-to-cloud, or cloud-to-air, associated with thunderstorms. PSP: Protection Services Personnel SSL: Shaft Services Leader Storm: For the purpose of this document, a storm is any inclement weather producing lightning or thunder. Thunder: Thunder is sound generated by the intense and sudden heating of air by lightning. 6.0 CONTEXT On average, 9-10 people are killed and people are injured each year by lightning in Canada despite our relatively short lightning season. In the United States, these statistics are 100 and 1,000. Lightning can strike from as far away as 16 kilometers (10 miles) from the storm cloud. The electrical current generated from lightning can be thousands of amperes at very high voltage levels, resulting in the generation of rapid heating, thereby creating shock, burn, sound and panic hazards. Due to a lack of clear and specific instructions, responses to lightning storms have been variable. This may have put personnel or equipment at risk, or caused miscommunications resulting in manpower inefficiencies or process delays.

5 Department 2015/01/0 Page 5 of DETECTION METHODS Vale Sudbury Operations has the following informal storm / lightning strike detection methods: Power department utility men at generating plants Power department field personnel #1 Substation Systems Operator ( , 24-hr coverage) #1 First Aid Attendant ( ) PSP s at each site Smelter ERP Operator ( , from 6 am to 6 pm) Weather web sites ( Vale Sudbury Operations recommends the following personal lightning detector when the risk assessment justifies it: Personal lightning detectors work by detecting the EMF pulse emitted by a lightning strike up to 40 miles (65km) away. Most lightning detectors provide approximate ranges, and not exact distances of lightning strikes. For example the StrikeAlert model provides the following ranges (in miles): miles miles 6-12 miles 0-6 miles According to the National Lighting Protection Institute, precautions should be taken when lightning is observed within 10 miles which corresponds to the 6-12 miles range on the StrikeAlert lightning detector. When lightning is detected within the 6-12 miles range, work should be suspended for 0 minutes past the last detected strike in that range.

6 Department 2015/01/0 Page 6 of 12 It should be noted that EMF interference can be present due to electronic devices or other environmental interference near the lightning detector. Some lightning detectors will warn that they are in the presence of interference (for example the green LED on the Strike Alert lightning detector will blink to indicate interference). Interference can produce false results; as a result lightning detectors should be used with other methods described in Section RISK ASSESSMENT PRIORITY TO PERFORMING WORK Despite the relative unpredictability of lightning strikes, the following precautionary steps are recommended to prepare for the occurrence of a storm or lightning strike: Supervisors, Vale Representatives for contracted work and workers are to assess the risks associated with the possibility of storms and lightning strikes at the start of the shift and before beginning work. If potential lightning hazards are identified, appropriate risk mitigation measures are to be documented and reviewed with the affected work group(s). Lightning hazards are to be identified during Process Hazard Reviews (PHR s). Provide the area Control Room or Supervisors (via the work permit system or SLAM sheets) with a list of jobs which are at an elevated risk from storms / lightning strikes due to their outdoor location or other issues. For work where the risk of lightning strikes has been assessed as High or Extreme, such as maintenance on the 1,250-foot Superstack, a Vale approved detection monitor will be used. There are several methods for reducing the risk of a lightning strike. Before starting work, a risk assessment should be conducted to determine is if some of all of these methods are applicable. Ultimately no single method is a perfect predictor of lightning activity. Where possible, multiple methods should be combined to create the best overall picture of lightning risk.

7 Department 2015/01/0 Page 7 of STORM WARNINGS DURING WORK PERIODS If the workers see lightning or hear thunder prior to a storm warning call, they are to stop all work at elevated risk and communicate the event to their supervisor. Supervisors will take all necessary precautions to protect the workers under their supervision, including notifying the #1 First Aid PSP as needed. If a storm warning is issued, the Power Department Systems Operator will call the PSP at #1 First Aid as per SPI-P5516 / PWR#4. The PSP will in turn contact all locations as per the Storm Warning Notification Protocol see endix C. The #1 First Aid PSP will also issue a storm warning on all radio channels, to all PSPs and all Smelter radios STEPS TO TAKE DURING STORMS AND LIGHTNING STRIKES If a storm warning has been issued or if lightning is detected, precautionary steps should be implemented: Those notified via the #1 First Aid Storm Warning Notification Protocol (endix C) are to communicate the hazard to all work groups identified as being at elevated risk. Suspend all outdoor work that poses an elevated risk due to lightning strikes, and proceed to a safe area. Examples include working at a heights (ladders, roofs, scaffolding, etc.) or working in open areas or near open water. Suspend all confined space work that poses an elevated risk due to lightning strikes unless appropriate precautions have been taken. Note: the risks associated with confined space work can be due to loss of power for ventilation or lighting within the confined space, or due to process upsets caused by power outages that can create an atmospheric hazard within the confined space. Provide a backup power supply as needed, and assess the risks associated with process upsets. For high-risk outdoor machinery work (cranes, man lifts, boom trucks, etc.), place the machinery in a safe mode and proceed indoors. When storms occur in areas where no safe shelter is available, avoid tall structures such as trees, hills and towers. Immediately move to lower ground and present as small a target as possible. Keep well clear of all water bodies. If possible stay inside a rubber-tired enclosed vehicle until the storm has passed.

8 Department 2015/01/0 Page 8 of AFTER THE STORM WARNING Normal activities may resume after the All Clear has been declared through the #1 First Aid PSP, or where the Supervisor has determined that an elevated risk of lightning strike is no longer present APPENDICES endix A: Estimating the Distance between You and the Lightning endix B: Maintenance Activities Which Should be Postponed or Re-Assessed During Elevated Risks of Storms/Lightning Strikes endix C: #1 First Aid Storm Warning Notification Protocol endix D: Revisions and rovals

9 Department 2015/01/0 Page 9 of 12 APPENDIX A Estimating the Distance Between You and the Lighting How to Calculate the Distance of a Lightning Storm Step 1 Step 2 Step Lightning is visible Count the number of seconds until thunder is heard Divide the number of seconds by 5 to get the approximate distance in miles Example: If thunder is heard 20 seconds after a lightning flash, the storm is approximately 4 miles (6.44 km) away. Quick Reference Lightning Strike Distance Calculations Duration between lightning and thunder Distance 5 seconds 1 mile (1.6 km) 0 seconds 6 miles (9.66 km) 50 seconds 10 miles (16 km)

10 Department 2015/01/0 Page 10 of 12 endix B Maintenance Activities Which Should be Postponed or Re-Assessed During Elevated Risks of Storms/Lightning Strikes Rationale UPS Maintenance Back-up Generator Testing Confined Space Entry Outdoor Crane Hoisting Activities Working at Heights (Outdoors) Power Department Outdoor Activities In maintenance mode, the critical loads do not have back-up power which would de-energize the critical loads. Most generator design and installations will not supply power to the emergency buses while in maintenance mode or cogeneration mode. Confined Space Entry work should be re-assessed and additional mitigation put in place as required. Power failures due to lightning strikes can interrupt lighting and other necessary services (such as ventilation) not powered by local generation. Nearby process upsets caused by outages need to be considered as well. Lifting operations must be stopped and booms retracted to avoid attracting lightning. Elevated structures or man-lifts must be avoided since they pose a greater threat to lightning strikes. As per Power Dept. standards. All Mines - Hoisting - Handling of explosives outdoors - Sandfill / Backfill operations Reduce hoisting speeds to mitigate sudden stop impacts. Take precautions to reduce risks of handling explosives. Perform a site specific assessment related to plugging of lines due to power failures. CCNR Breathing Air Usage 1,250-foot Stack Work Suspend work that requires Breathing Air from the central compressed air system. Suspend work during High or Extreme risk periods. Assess risk for other periods, and monitor the lightning detector.

11 Department 2015/01/0 Page 11 of 12 endix C Storm Warning Notification Protocol (Refer to the latest version of this protocol)

12 Department 2015/01/0 Page 12 of 12 endix D Revision Notes and rovals Rev Revision Notes Last Revised by: Phil Langlois, Lead Engineer SPI-ENG A dated 12/18/201 reformatted to Maintenance Standard document:. Minor edits made and added Personal Lightning Detectors.

LIGHTNING SAFETY #24 CONSTRUCTION SAFETY EDUCATION PROGRAM

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