2010
AMBATOVY SUSTAINABILITY REPORT
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C1. Environmental Performance
Ambatovy’s Air Quality and Noise Management Plan was
developed to ensure that systems in place achieve the
required objectives through data collection and analysis.
Key components of the Air Quality and Noise Management
Plan include:
3
The collection of meteorological data in the area to
help understand dispersion characteristics at any
given time.
3
Regular monitoring to ensure that construction and
operational activities do not have a negative effect on
air quality and noise levels for employees and local
communities.
3
The verification of air quality and noise emissions from
mobile and fixed equipment against baseline levels
and standards.
3
Correct maintenance of all equipment and machinery.
Environmental Incidents
Ambatovy operates an Incident Reporting System (integrated
with the Health and Safety and Security Departments), which
encompasses losses of containment and loss of biodiversity.
All spills are tracked and documented as part of the internal
compliance reporting process.
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The majority have been
small fuel spills. Spills are categorized into three levels as
shown in the table below. Figure 1 gives a breakdown of our
environmental incidents in 2010, by level.
Figure 1: Environmental Incidents by Level
Environmental Incidents in 2010
n
Level 1
n
Level 2
n
Level 3
The main concern at the mine site is the risk of fuel and oil
spills from storage tanks, generators and vehicles, or from
the ore screening machinery. Ambatovy has a comprehensive
Emergency Response Plan for a pipeline spill or breach. A
pipeline breach is considered an extremely unlikely event.
Furthermore, in the event of a leak, the slurry in the pipeline
is a benign mixture of earth and water that does not pose a
serious contamination risk.
The plant site is the most complex of the Project’s
components and therefore a wide range of possible spills
could occur. The full range of possible spills has been
identified and their respective risks have been assessed
to ensure that we understand and have controls in place
to address them. In some instances we have conducted
detailed risk assessments to identify potential severity and
controls. The emergency response team has prepared itself to
respond to a large variety of potential issues that may arise;
this effort includes “dry runs” to practice the implementation
on response to incidents.
Off-site spills have also been taken into consideration. Main
spill risks are fuel leaks from vehicles such as cars, trucks,
trains, ships and airplanes. Each has its own protocol for
dealing with leaks or spills and the risk is no more significant
than any other operation using such vehicles. There were no
spills from the port-to-plant infrastructure or railway in 2010.
There is an extensive safety plan and vigilant monitoring
due to the proximity of this transportation infrastructure to
residential areas. Possible risks include:
3
The pipeline that carries ammonia from the port to the
plant and storage tanks located off-site.
3
Spills of bulk material upon loading and transport.
3
Spills from the rail line, which carries non-toxic
products, primarily limestone and coal, and is
separated by a fence from the densely populated
areas of Toamasina through which it passes.
Hazardous Waste
Ambatovy is required to have systems to stabilize, dispose,
treat or destroy all waste, by-products and output materials
created by its operations.
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Incidents shown here are based on construction-phase parameters and construction contractor reports. During 2010, an integrated incident reporting mechanism was
created that will monitor all environmental spills and incidents – both construction and operations related. As we transition from construction to operations, and for the
2011 report, we will use this latter incident level structure.
Level Classification Concern
Clean-up
Volume
1
Minor
No risk of contamination of sensitive areas
Clean-up using kit on site
Volume is < 25 litres
2
Significant
No risk of contamination of sensitive areas Clean-up using kit on site
Volume is
or specialized external resources (excavation,
between 25-100 litres
pumping, etc.); spill inside site limits
3
Major
Contamination of sensitive areas
Clean-up using specialized external resources; Volume is > 100 litres
decontamination required
2 4
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