ENVIRONMENT

Management of the Physical Environment

The objective of Ambatovy’s Physical Environmental Management Program is the protection of the land, air, and water from mining related impacts. This aspect of the environmental program was defined during the design and planning stages of the project. Background environmental conditions are identified and key parameters are tracked during the Operations phase as indicators of performance. The management programs are documented in a series of Environmental Management Plans for the Plant Site and associated facilities, the Pipeline, and the Mine Site. Routine environmental monitoring can detect slight changes in air, water, ground water quality, and indicator species so that, if required, process adjustments can be made to ensure the protection of the environment

Water Management Program

Water is managed using different techniques that tend to vary somewhat depending on the project component.

Mine Site – Sediment control is the primary water treatment objective. The removal of vegetation allows soil particles to be suspended in rainwater runoff. To minimize the concentration of suspended solids in water affected by the Mine, a number of actions are taken:

1) Areas without vegetation are minimized by progressively reclaiming any disturbance as soon as mining activities are complete;

2) Water from undisturbed areas is diverted to prevent it from flowing onto disturbed areas;

3) Settlement ponds are constructed to enable sediment to be removed from water before it enters the natural environment;

4) Drainage ditches collect and control impacted water, directing it to settlement ponds.

Another significant water treatment activity that takes place at the Mine Site is the treatment of domestic waste water and drinking water.

Pipeline – As with the Mine Site, the suspension of soil particles in runoff water is the primary water quality issue. However, the characteristics of the pipeline disturbance result in more restricted sediment control options. Treatment options are limited, focusing on sediment control prevention through:

1) Re-profiling pipeline disturbance to disperse water and minimize runoff water velocity;

2) Rapid and effective revegetation to minimize areas of bare soil that are exposed to rainfall;

3) Diversion of clean water away from the pipeline right of way;

4) Directing water on the right of way to areas with low erosion potential.

Plant Site – The focus for the Plant Site is the treatment of process waste water to meet national and international standards for discharge. This includes treatment to remove suspended solids, to stabilize and precipitate metals, and to control pH. All process water, including storm water falling within a process area, is collected and treated through the neutralization process used to treat the ore residue following the extraction of nickel and cobalt. Storm water from other areas of the Plant Site is directed to retention ponds where samples are taken and analyzed to ensure good water quality prior to discharge to the surrounding area.

The Tailings Management Facility receives all of the treated process waste water and treated tailings, or ore residue, following nickel and cobalt extraction. The Tailings is a large containment facility that receives all of the treated slurry allowing the material to settle and consolidate. The supernatant, which contains mineral salts, is released to the ocean through a diffusor system to ensure full compatibility with the ocean environment. The consolidated material is non-toxic and at the end of the project life, the surface of the Tailings will be revegetated with plants compatible with the surrounding vegetation. During Operations, surface and groundwater is protected through monitoring wells and a network of groundwater interception wells designed to pump seepage back into the Tailings facility.

In addition to the treatment of process and runoff water, the Plant Site also treats domestic waste water using a variety of treatment systems located both at the Plant Site and within residential areas.

Waste Management Program

Ambatovy’s Waste Management Plan is implemented to ensure the responsible handling, re-use, recycling, treatment, and disposal of all waste materials generated by the Project. A wide variety of waste material is generated including; food, domestic waste, wood, cardboard, paper, plastic, scrap metal, tires, contaminated soil, used oil and lubricants, domestic sludge, stabilized process waste, used chemicals, contaminated containers, and power plant ash. For all of these materials, recycling and reuse is the preferred method of treatment and handling. A variety of treatment processes are applied for material that cannot be recycled or reused; these include: land farming, neutralization, stabilization, incineration, biological treatment, composting, distillation, and secure landfill.

Air Management Program

The Air Management Program is designed to monitor known sources of key emission parameters, such as particulates, sulfur dioxide, oxides of nitrogen, hydrogen sulfide, and ammonia. At the Mine, the key parameter monitored is dust, or particulate matter, due to the continuous handling and transportation of large volumes of ore. Similarly, at the Port, dust can result from the unloading of the bulk commodities such as limestone, sulfur, and coal. At the Plant Site the conveying and stockpiling of these bulk materials can be a source of particulate matter. Dust suppression for these sources is achieved through water spraying or mist systems.

Other particulates can result from fleet vehicle combustion, diesel generators, and the coal-fired power plant. The selection, design, and maintenance of combustion equipment minimize particulate emissions and the application of precipitators in the power plant controls particulate emissions. The processes at the Plant Site used to extract and refine nickel and cobalt from the laterite is complex and can also be an emission source of low levels of sulfur dioxide: oxides of nitrogen, hydrogen sulfide, and ammonia. The design of the facilities has been assessed through an Environmental Impact Assessment process to ensure compliance with international air quality standards. Ambatovy’s greenhouse gas emissions have been minimized, in part through the transportation of the ore from the Mine Site to the Plant Site via the slurry pipeline where gravity provides much of the energy requirements. Using a fleet of modern mining equipment further reduces potential greenhouse gases.

The design and operation of the processing facility maximizes energy utilization through the efficient use of high, medium, and low-pressure steam systems. In addition, the Biodiversity Offsets Program, put in place to ensure that no net loss of biodiversity occurs as a result of the Project, provides an offset for a portion of greenhouse gas emissions.

To ensure that air emissions remain within the permitted limits, an air-monitoring network has been put in place, utilizing continuous analytical monitoring and periodic passive sampling.Real time Plant Site meteorology and air quality data is available by computer link at all times.

Noise Management Program

At the Mine Site, noise is generated by the Ore Preparation Plant (OPP), mining equipment, and intermittent blasting. Computer modeling of expected noise sources and receptors, done as part of the environmental assessment, indicated that noise levels would remain within World Bank criteria. Noise monitoring is conducted to confirm that noise levels are acceptable and within these limits. In addition, a program to monitor lemur response to blasting has found that behavior patterns show no indication of being affected by blasting activities.

At the Plant Site, boilers, fans, compressors and other motors can generate noise. At the Port, loading and unloading activities also contribute to noise levels. Computer modeling of expected noise sources and receptors, done as part of the environmental assessment, indicated that these noise levels would also remain within World Bank criteria. Routine noise monitoring is carried out to confirm that the actual plant operations are consistent with the predictive model and that noise levels are within the limits permitted.

Land Management Program

Although many precautions are taken, occasionally accidental spills of harmful materials can occur. When they do occur it is important to ensure that impacts are minimized and contaminated material is disposed of safely. Disposal methods are selected based on volume, contaminant, and the degree of contamination. Spills of acidic material are neutralized using lime. A variety of mitigation options exist for soil contaminated by hydrocarbons. These range from incineration to land farming.