Follow-up to the order issued in 2024 by the Ministry of the Environment, Climate Change, Wildlife, and Parks

The outcomes of the equipment audit reflect the ongoing efforts we have been making at the Port since 2013:

• Our overall performance was rated 4.45 out of 5 and described by the auditor as achieving a high level of operational performance that meets technical best practice and exceeds current industry standards. This outcome results from significant investments over the last few years.

• That said, we know that community perceptions and expectations go beyond performance audits, which is why we are continuing our work in the field.

• In terms of best practice in the maritime sector, our average score of 4.35 out of 5 puts us well above the usual average of 2 to 3 for similar operations elsewhere.

Our identified strengths:

• Effective control of fugitive dust emissions;

• Proper loading and unloading procedures;

• Rigorously maintained cleaning and surveillance equipment.

Areas for improvement were also highlighted:

• Modernizing the terminology of certain procedures;

• Exploring solutions to limit handling during cleaning in the closed warehouse, in order to minimize the risk of emissions;

• Studying the possibilities and means of reintroducing products recovered during cleaning into the main handling flow.

In the interests of continuous improvement, the elements audited will now be incorporated into our ISO 14001 audits.

As a reminder, we have been ISO 14001 certified since 2015. This internationally recognized standard provides a rigorous and verifiable framework for environmental management, including annual surveillance audits and a recertification audit every three years.

In practical terms, this means that:

• Our actions to prevent and reduce emissions will not only be monitored: they will also be verified by external auditors.

• Each recommendation contained in the external audit report and the pre-feasibility study will be incorporated into our continuous improvement program.

• These actions will become an integral part of our formal environmental management cycle.

We assessed several concepts in response to the MELCCFP’s request to limit emissions during the loading of nickel matte.

Of these options, the concept of a removable hard cover seemed to best meet the objective of capturing dust while being technically feasible on paper.

• This solution may be technically feasible on paper, but it is now proving unrealistic in the operational context of the Port of Quebec.

• The modules required would be enormous (three modules measuring 7.6 m wide x 25 m long and weighing 19 tonnes per module), implying major logistical and storage constraints on site. We also anticipate safety issues for our workers when handling these modules.

Although closing the holds is not a viable option in our current context, we are actively exploring other solutions to reduce dust emissions during loading. For example, a new project will be implemented this summer at the Sudbury smelter to capture fine dust at its origin, before it is shipped to the Port of Quebec. In practical terms, this initiative will improve the retention of the lightest particles (fine matte) at source, by redirecting them to a specialized collection system. This is another step in our commitment to proactively reducing the environmental impact of our activities.

We mandated AtkisRéalis to conduct a pre-feasibility study to assess the possibility of enclosing the nickel concentrate unloading process using a cover adapted to the configuration of the MV Arvik I vessel and our operational constraints.

The objective of the study was to analyze solutions for covering the ship's holds, in addition to the fogging and radar systems already in place.

Three types of hold covers were examined:

1. Static cover: not selected due to its impact on the unloading process, its low efficiency, and the significant dust removal requirements.

2. Tarp cover: not selected due to its vulnerability to weather conditions, its effect on the operation of the unloader, and the lack of a proven design on the market.

3. Dynamic cover: option selected for the pre-feasibility study, offering a more flexible and adjustable solution, adapted to the unloading arm and allowing for a smoother process.

The study showed that there is no technology or solution available on the market to cover the holds during transshipment operations on the MV Arvik I.

In addition, the study highlighted significant constraints and risks associated with the system studied (dynamic cover), including the risk of not achieving improved dust emission control compared to the water atomization system currently in place.

We are continuing to explore possible areas for improvement in order to further minimize dust emissions during the unloading of nickel concentrate. To this end, the addition of real-time monitors, installed in 2025, will allow us to continuously adjust our operations.

It should be noted that the measures implemented in recent years, in particular our fogging and radar systems, have already led to a marked improvement in our environmental performance at the Port of Québec.

We have installed monitors that measure nickel in fine particles (PM10) in the ambient air in real time. This measurement is a key driver for optimizing and calibrating our activities on an ongoing basis, based on data collected in real time on our emissions.