2011
AMBATOVY SUSTAINABILITY REPORT
28
Environmental Performance
Environmental Spills and Incidents
Ambatovy operates an integrated reporting system for all
environmental, health & safety or security incidents. Spills and
incidents are tracked and documented as part of the internal
compliance reporting process.
In 2011 we had a limited number of significant spills: two
fuel spills, which were 500 litres and 600 litres respectively,
and two instances of external complaints related to dust and
spillage during the limestone and sulphur unloading and
transfer from the port to plant. Normally areas of containment
prevent spills from having any major impact, however when
spills go outside of the containment area, we have clean-up
procedures to neutralize the impact, such as that of the fuel
spills. We made specific improvements and adjustments
to the port and Madarail equipment to prevent spillage in
following shipments.
The reporting system ensures that appropriate measures are
taken in response to a range of environmental incidents, not
just spills. For example, in 2011, clearing rates briefly exceeded
the usual operational maximum of 10 ha/month. This resulted
in lemurs and other fauna being marooned in a patch of forest
and requiring rescue. As a result, our Environment and Mine
Operations teams worked together to develop an improved Job
Environmental Analysis and a standard operational procedure.
This now delineates clearing paths and imposes stricter
procedures for the speed, direction and process of clearing.
The improved procedure ensures fauna search and salvage
work is completed before the area is cleared. No repeat
incidents were observed for the rest of the year, indicating that
this new cooperative procedure had resulted in more effective
management of the mine footprint.
Materials
Primary Materials Input
In addition to approximately six million tonnes of ore that will
be mined annually, the operation of the process plant requires
four key raw input commodities. In 2011, we used modest
quantities of the following for commissioning and start-up of
our plant site:
Major Commodity Consumptions
Commodity
AMOUNT (tonnes)
Coal
118,184
Sulphur
6,409
Limestone
9,218
Ammonia
N/A
Since we were not in production in 2011, no ammonia was
consumed for processing. Quantities used of all commodities
will be significantly higher once in production. Processing
will also use smaller quantities of materials, such as sodium
hydroxide, alum and polymers. The process does not make
use of any recycled materials.
Level CRITERIA
1
3
An unpermitted release into the environment that does not meet the threshold for levels 2-5.
2
3
An unpermitted release to the environment equal to or in excess of regulatory threshold.
3
A permitted emission that exceeds the emission criteria.
3
Direct physical activity causing biodiversity loss.
3
In the absence of a regulatory threshold, a spill volume threshold of 25 kg for toxic substances; 500 kg for all other substances except air,
uncontaminated water, CO
2
, methane, ethane, hydrogen, nitrogen, and other inerts.
3
3
A release of materials that poses a threat to the environment or the health and safety of the public.
3
A release that results in an external complaint.
4
3
A release that results in the evacuation or shut-down of non-company-owned facilities; restricts the use of public roads or highways or
navigational and recreational use of a water-ways; or adversely affects a drinking water source.
5
3
A release of material that causes persistent, severe off-site environmental damage extending over a large area.
3
Ecological disaster.
* A release can be a solution, particulates, noise or induced fog.
Environmental Incident Criteria