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MAINTENANCE STANDARD PROCEDURE Ontario Operations TITLE Department Energized Work Procedure VALE # MPROC-50007 DATED 2018-05-04 PAGE Page 1 of 17 REV. 4 Table of Contents 1.0 PURPOSE... 2 2.0 APPLICATION... 2 2.1 EXCEPTIONS... 2 3.0 REFERENCE DOCUMENTATION... 3 4.0 COMMITMENTS... 4 5.0 DEFINITIONS... 4 6.0 THE NEED FOR ELECTRICALLY SAFE WORKING CONDITIONS... 5 7.0 REASONS FOR PERMITTING ENERGIZED ELECTRICAL WORK CSA Z462-15, 4.3.2.2)... 5 8.0 PERMIT REQUIREMENT (CSA Z462-15, 4.3.2.3.1)... 7 9.0 ENERGIZED ELECTRICAL WORK PERMITS (CSA Z462-15, 4.3.2.3.2)... 7 10.0 EXEMPTIONS TO WORK PERMITS (CSA Z462-15, 4.3.2.3.3)... 8 11.0 APPENDICES... 9 Appendix A: National Fire Protection Association Approach boundaries... 10 Appendix B: Vale - Energized Work Permit Form... 11 Appendix C: Sample Completed Energized Work Permit... 12 Appendix D: Sample Generic Energized Work Permit... 14 Appendix E: Revision Notes and Approvals... 16 Page 1 of 17

Department MPROC-50007 Energized Work Procedure Rev.4 1.0 PURPOSE Since 2009, Vale has been working towards compliance with CSA Z462 (Workplace electrical safety). One of the requirements of this effort is to greatly reduce energized electrical work when feasible; however, when this effort cannot be realized, the issuance of Energized Work Permits (permits) needs to be instituted. These permits are risk assessments which complement Vale s general safety management systems such as HomeSafe (Ontario) and SafeProduction (Manitoba) using SLAM or a JHA to drive hazards down to manage risk. Overall as a business, energized electrical work should be avoided whenever possible. This procedure provides clarity on energized electrical work and provides both generic and task-specific work permit templates for performing energized work. 2.0 APPLICATION It is the Vale electrical plant authority s responsibility to make this procedure known at site and to assist in its implementation. (Equal Code EL305) It is a requirement to have an electrical authority review the permit before it is signed off by management. This procedure, applies at any Vale locations indicated with approval on the cover page, with the following exceptions: 2.1 EXCEPTIONS This procedure excludes the Power Department performing utility work that follows IHSA (EUSA) rules. This procedure excludes the following Vale jurisdictions which have their own procedure: Thompson, Manitoba - SPI 32-4 Energized Work Port Colborne Refinery, Ontario - SPI PCR 6-0 Energized Work Page 2 of 17

3.0 REFERENCE DOCUMENTATION Department MPROC-50007 Energized Work Procedure Rev.4 The following documents were used in the development of this document. They shall be used in their most recent revision. CSA Z462-15 Workplace electrical safety CSA Z463-13 Guideline on maintenance of electrical systems O.Reg#854 Mines and Mining Plants (Ontario) each province has its own regulation CSA C22.1-15 Canadian Code, Part I CSA M421-11 Use of electricity in mines O.Reg#213 Construction Projects (Ontario) each province has its own regulation ZES Zero Energy State Program Locking & Tagging Variance EMOC#7977 (Ontario only) Page 3 of 17

4.0 COMMITMENTS Department MPROC-50007 Energized Work Procedure Rev.4 This procedure is committed to align with the following: Vale s general safety management systems such as HomeSafe (Ontario) and SafeProduction (Manitoba) The energized work portion of CSA Z462, Workplace electrical safety 5.0 DEFINITIONS Boundary, Limited Approach: an approach limit at a distance from an exposed energized electrical conductor or circuit part within which a shock hazard exists. Boundary, Restricted Approach: an approach limit at a distance from an exposed energized electrical conductor or circuit part within which there is an increased likelihood of electric shock, due to electrical arc over combined with inadvertent movement, for personnel working in close proximity to the energized electrical conductor or circuit part. ly-safe working condition: A state in which an electrical conductor or circuit part has been disconnected from energized parts, locked out in accordance with established standards, tested to ensure the absence of voltage, and grounded (if grounding is determined to be necessary). Energized: ly connected to or having a source of voltage FAQs: Frequently Asked Questions JHA: Joint Hazard Assessment PPE: Personal Protective Equipment SLAM: Stop, Look, Assess and Manage. Page 4 of 17

Department MPROC-50007 Energized Work Procedure Rev.4 6.0 THE NEED FOR ELECTRICALLY SAFE WORKING CONDITIONS Applicable codes, standards and regulations recognize that there are occasions when energized work is warranted providing that the proper methods are followed and the proper tools and protective equipment are used. Ontario Regulation 213, Construction projects (sections 181 to 195), more specifically section 190 stipulates that written measures and procedures are established to ensure that workers are adequately protected from electrical shock and burn; power supply to the electrical equipment, installation or conductor shall be disconnected, locked out of service and tagged before the work begins, and kept disconnected, locked out of service and tagged while the work continues hazardous stored electrical energy shall be adequately discharged or contained before the work beings and shall be kept discharged or contained while the work continues. Ontario Regulation 854, Mines and Mining Plants (sections 155 to 180), stipulates in section 159 that work shall not be performed on live equipment except where CSA-Z462-15 Workplace electrical safety, stipulates in section 4.3.2.1 that Energized electrical conductors or circuit parts shall be put into an electrically safe work condition before a worker works within the limited approach boundary CSA-Z463-13 Guideline on maintenance of electrical systems, covers safe working conditions in section 6.7. CSA C22.1-15, Canadian Code, Part I, stipulates in section 2-304(1) No repairs or alterations shall be carried out on any live equipment except where complete disconnection of the equipment is not feasible. CSA-M421-11, Use of electricity in mines, section 4.2.5 makes stipulations on energized work as well. Vale Golden Rules, HomeSafe or SafeProduction Program (as is applicable at site) 7.0 REASONS FOR PERMITTING ENERGIZED ELECTRICAL WORK CSA Z462-15, 4.3.2.2) Energized work may be performed when the employer can demonstrate the following: de-energizing introduces additional hazards or increased risk; the task to be performed is infeasible in a de-energized state because of equipment design or operational limitations; Page 5 of 17

Department MPROC-50007 Energized Work Procedure Rev.4 energized electrical conductors and circuit parts that operate at less than 50V shall not be required to be de-energized when the capacity of the source and any overcurrent protection between the energy source and the worker are considered and it is determined that there will be no increased exposure to electrical burns or to explosion due to electric arcs. Examples (not a complete list) of additional hazards or increased risk are as follows: Interruption of life support equipment Deactivation of emergency alarm systems (such as Chlorine, SO2, Fire, etc.); Shutdown of hazardous location ventilation equipment; Specific Vale examples from FAQs: o Adding or removing an MCC bucket within a critically important MCC connected to backup power feeding loads such as large motor lubrication systems, instrument air, furnace cooling pumps, fire protection pumps, etc.; and o Interruption of UPS fed panels (or lighting/distribution panels) feeding PLCs, DCS systems and instrumentation which would blind operators Examples (not a complete list) of infeasibility include the following: Performance of diagnostics and testing (e.g. start-up and troubleshooting) of electric circuits that can only be performed with the circuit energized; Work on circuits that form an integral part of a continuous process that would otherwise need to be completely shut down to permit work on one circuit or piece of equipment Specific Vale examples from FAQs: o Working on UPS batteries; o Working on substation/switch-room switchgear station batteries; o Smelter converter aisle emergency roll-out batteries; o Serving or removing cables within a marshaling cabinet, field junction box, PLC panel, operator console, UPS fed distribution panel, lighting/distribution panels feeding process PLCs and/or instruments controlling critical processes, etc. having voltages of 240 V or less and fed from transformers of 112.5kva or less Page 6 of 17

Department MPROC-50007 Energized Work Procedure Rev.4 Inconveniences and cost increases are not deemed as acceptable reasons to perform energized electrical work and place personnel at risk. 8.0 PERMIT REQUIREMENT (CSA Z462-15, 4.3.2.3.1) When energized work is permitted in accordance with section #7, an energized electrical work permit shall be required under the following conditions: a) when work is performed within the restricted approach boundary; or b) when the worker interacts with the equipment when conductors or circuit parts are not exposed but an increased likelihood of injury from an exposure to an arc flash hazard exists. 9.0 ENERGIZED ELECTRICAL WORK PERMITS (CSA Z462-15, 4.3.2.3.2) Permits should include concise information that ensures all parties understand the risks and controls involved in the task. Permits must have all signatures ranging from the requester of the work, up to the highest position at the site. This ensures that energized work is discouraged and that line management has every opportunity to seek, or offer, alternatives. Only truly justifiable work should attain approval. Refer to Appendix B and C for the Vale Energized Work Permit Form and example. In order to maintain the practical aspect of CSA-Z462, it is recommended that each site develop generic work permits which would pre-approve electrically energized work that could occur on a daily basis at each facility. Refer to Appendix D for an example taken from the Copper Cliff Smelter Complex. Here are examples of site generic work permits from FAQs: Serving, removing and terminating cables and wires into PLC marshaling cabinets; and Serving, removing and terminating cables and wires into UPS distribution panels Serving, removing and terminating cables and wires into lighting/distribution panels feeding process PLCs and/or instruments controlling critical processes Page 7 of 17

Department MPROC-50007 Energized Work Procedure Rev.4 10.0 EXEMPTIONS TO WORK PERMITS (CSA Z462-15, 4.3.2.3.3) An energized electrical work permit shall not be required if a qualified person is provided with and uses appropriate safe work practices and PPE under any of the following conditions: a) testing, troubleshooting, and voltage measuring; b) thermography, ultrasonic and visual inspections if the restricted approach boundary is not crossed; c) access and egress to an area with energized electrical equipment if no electrical work is performed and the restricted approach boundary is not crossed; and d) general housekeeping and miscellaneous non-electrical tasks if the restricted approach boundary is not crossed. Page 8 of 17

11.0 APPENDICES Department MPROC-50007 Energized Work Procedure Rev.4 Appendix A: National Fire Protection Association - Approach boundaries to energized electrical conductors or circuit parts for shock protection for AC or DC systems (distance from energized electrical conductors or circuit part to worker) * Appendix B: Vale - Energized Work Permit - Form Appendix C: Sample Completed Energized Work Permit Appendix D: Sample Generic Energized Work Permit Appendix E: Revision Notes and Approvals Page 9 of 17

Department MPROC-50007 Energized Work Procedure Rev.4 Appendix A: National Fire Protection Association Approach boundaries to energized electrical conductors or circuit parts for shock protection for AC or DC systems (distance from energized electrical conductors or circuit part to worker) Table 1A Approach boundaries to energized electrical conductors or circuit parts for shock protection for AC systems (distance from energized electrical conductors or circuit part to worker) Nominal System Voltage Range, Phaseto-Phase Limited Approach Boundary Exposed Movable Conductor Exposed Fixed Circuit Part Restricted Approach Boundary (includes inadvertent movement adder) Less than 50 V Not specified Not specified Not specified 50 V 150 V * 3.0 m (10 ft. 0 in) 1.0 m (3 ft. 6 in) Avoid contact 151 V 750 V 3.0 m (10 ft. 0 in) 1.0 m (3 ft. 6 in) 0.3 m (1 ft. 0 in) 751 15 kv 3.0 m (10 ft. 0 in) 1.5 m (5 ft. 0 in) 0.7 m (2 ft. 2 in) 15.1 36 kv 3.0 m (10 ft. 0 in) 1.8 m (6 ft. 0 in) 0.8 m (2 ft. 7 in) 36.1 46 kv 3.0 m (10 ft. 0 in) 2.5 m (8 ft. 0 in) 0.8 m (2 ft. 9 in) 46.1 72.5 kv 3.0 m (10 ft. 0 in) 2.5 m (8 ft. 0 in) 1.0 m (3 ft. 3 in) For single phase systems above 250V, select the range that is equal to the system s maximum phase-toground voltage times 1.732. A condition in which the distance between the conductor and a person is not under the control of the person. The term is normally applied to overhead line conductors supported by poles. * This includes circuits where the exposure does not exceed 120V Table 1B: Approach boundaries to energized electrical conductors or circuit parts for shock protection for DC systems (distance from energized electrical conductors or circuit part to worker) Nominal System Voltage Range, Phaseto-Phase Limited Approach Boundary Exposed Movable Conductor Exposed Fixed Circuit Part Restricted Approach Boundary (includes inadvertent movement adder) Less than 100 V Not specified Not specified Not specified 100 V 300 V 3.0 m (10 ft. 0 in) 1.0 m (3 ft. 6 in) Avoid contact 301 V 1 kv 3.0 m (10 ft. 0 in) 1.0 m (3 ft. 6 in) 0.3 m (1 ft. 0 in) 1.1 kv 5 kv 3.0 m (10 ft. 0 in) 1.5 m (5 ft. 0 in) 0.4 m (1 ft. 5 in) A condition in which the distance between the conductor and a person is not under the control of the person. The term is normally applied to overhead line conductors supported by poles. Page 10 of 17

Appendix B: Vale - Energized Work Permit Form Department MPROC-50007 Energized Work Procedure Rev.4 Page 11 of 17

Department MPROC-50007 Energized Work Procedure Rev.4 Page 12 of 17

Department MPROC-50007 Energized Work Procedure Rev.4 Appendix C: Sample Completed Energized Work Permit Page 12 of 17

Department MPROC-50007 Energized Work Procedure Rev.4 Jason Chalut Gord Legault Janet James Page 13 of 17

Appendix D: Sample Generic Energized Work Permit Department MPROC-50007 Energized Work Procedure Rev.4 Page 14 of 17

Department MPROC-50007 Energized Work Procedure Rev.4 Page 15 of 17

Appendix E: Revision Notes and Approvals Department MPROC-50007 Energized Work Procedure Rev.4 Revision notes describe what was changed, and if applicable, why it was changed, and the plan to implement the change, including whether changes are retroactive. The revision notes are a summary of the changes and may not necessarily be a complete list. A risk code is entered each revision and if applicable, the revision notes will describe how risk was addressed for the revision Page 16 of 17