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Sustainability Accounting Standards board (sasb) DISCLOSURES

SASB Sector / SICS

Extractives & Minerals Processing / Iron & Steel Producers — Industry Standard Version 2018-10

Reporting Period

Fiscal Year 2021 (September 1, 2020 through August 31, 2021)

Metric Category Unit of Measure Code Response/Comment
Activity Metrics
Production Activities
Metric: Raw steel production, percentage from: (1) basic oxygen furnace
processes
Category: Quantitative Unit of Measure: Metric tons
(t), Percentage (%)
Code: EM-IS-000.A Response/Comment: Not applicable. We do not produce steel via basic oxygen furnace (BOF) processes. All steel we produce is via electric arc furnace (EAF) processes. From a GHG emissions standpoint, EAF steelmaking results in far lower GHG emissions than BOF steelmaking. Comparable CO2e emissions factors per metric ton of steel produced are: 1.83 for global steel production, 1.59 for U.S. integrated steel production, 0.65 for all U.S. steel production, 0.21 for U.S. EAF steel production. Our emissions factor is approximately 0.17.
Metric: Raw steel production, percentage from: (2) electric arc furnace processes Category: Quantitative Unit of Measure: Metric tons
(t), Percentage (%)
Code: EM-IS-000.A Response/Comment: 417,000
100%
Melt shop production: Our melt shop includes an EAF, a ladle refining furnace with enhanced steel chemistry refining capabilities, and a five-strand continuous billet caster, permitting the mill to produce special alloy grades of steel not currently produced by other mills on the West Coast of the U.S. The melt shop produced approximately 460 thousand short tons of steel in the form of billets during fiscal 2021. The substantial majority of these billets are reheated in a natural gas-fueled furnace and are then hot-rolled through the rolling mill to produce finished steel products. The rolling mill has an effective annual production capacity under current conditions of approximately 580 thousand short tons of finished steel products.

The primary feedstock (over 90% by weight) for the manufacture of our finished steel products is ferrous recycled scrap metal. Our steel mill obtains substantially all of its scrap metal raw material requirements from our integrated metals recycling and joint venture operations.

In fiscal 2021, we sold 488 thousand short tons of finished steel products, i.e., rebar and wire rod, as well as over 4 million metric tons of ferrous scrap metal (including intercompany sales to our steel mill) for use in EAF steelmaking in the U.S. and around the world.

To learn more please review our 2021 Sustainability Report.
Metric: Total iron ore production Category: Quantitative Unit of Measure: Metric tons (t) Code: EM-IS-000.B Response/Comment: Not applicable. We do not consume or sell iron ore in the production of our steel products. Rather, the recycling of 1 metric ton of ferrous scrap for use in EAF steelmaking is estimated to conserve 2,425 pounds of iron ore. Therefore, by extension, our operations supported the conservation of more than 10.8 billion pounds of iron ore in fiscal 2021. Additionally, we produce three valuable coproducts: millscale, baghouse dust, and slag. Millscale functions as a metallurgical input to steelmaking, supporting the avoidance of iron ore production and the conservation of raw iron ore, while baghouse dust avoids zinc production and slag avoids cement and gravel production.
Metric: Total coking coal production Category: Quantitative Unit of Measure: Metric tons (t) Code: EM-IS-000.C Response/Comment: Not applicable. We do not consume or sell coking coal in the production of our steel products. Rather, the recycling of 1 metric ton of ferrous scrap for use in EAF steelmaking is estimated to conserve 1,389 pounds of coal. Therefore, by extension, our operations supported the conservation of more than 6.2 billion pounds of coal in fiscal 2021.
Accounting Metrics
Greenhouse Gas Emissions
Metric: Gross global Scope 1 emissions, percentage covered under emissions-limiting regulations Category: Quantitative Unit of Measure: Metric tons (t) CO2-e, Percentage (%) Code: EM-IS-110a.1 Response/Comment: 145,534
0%
Currently, 0% of our gross global Scope 1 emissions are covered under emissions-limiting regulations. We are required to annually report GHG emissions from our steel mill to the State of Oregon Department of Environmental Quality (ODEQ) and the U.S. Environmental Protection Agency (EPA). In March of 2020, the Governor of Oregon issued an executive order directing state agencies to take certain actions to reduce and regulate GHG emissions, including the development of a "cap and reduce" program that would cover large stationary sources. In Oregon our steel manufacturing and metal shredding operations may be subject to emissions-limiting regulations in the near term that may impact approximately 53% of our Scope 1 emissions.
Metric: Discussion of long-term and short-term strategy or plan to manage Scope 1 emissions, emissions reduction targets, and an analysis of performance against those targets Category: Discussion and Analysis Unit of Measure: n/a Code: EM-IS-110a.2 Response/Comment: Our sustainability goals are aligned with our long-term business success with targets for fiscal 2030 to 2050 in the (a) long-term and fiscal 2022 to 2025 in the (b) short-to-medium term, set to a base year of fiscal 2019. We have set a fiscal 2025 goal to achieve net zero from all operations with an interim target to reduce Scope 1 GHG emissions from our recycling operations by 25% by end of fiscal 2025. Mechanisms for achieving our goal and meeting our targets may include (1) capital investments in emissions control and air pollutant elimination technologies on our metal shredding operations, (2) capital investments to achieve greater fuel-economy by retrofit and/or replacement of on-road transport vehicles and off-road equipment, (3) capital investments to electrify equipment that is currently fuel-consuming, (4) sourcing a greater proportion of fuels with suitable low-carbon fuel alternatives (i.e., renewable natural gas, renewable diesel, biodiesel and ethanol fuel blends), (5) capital investments in other energy efficiency technologies for water and space heating applications that reduce our consumption of natural gas, and (6) the purchase and retirement of "high-quality" carbon offsets. Limiting factors to achieving these goals may include (i) a shortfall in or inability to make adequate capital investments, (ii) a shortfall in the emission reduction performance of control technologies acquired and deployed, (iii) an inability to acquire and deploy adequate emission reduction controls and energy efficiency technologies, (iv) an inability to source suitable low-carbon fuel alternatives, and (v) an inability to source "high-quality" carbon credits. In fiscal 2021, we achieved an 8% reduction in Scope 1 emissions from all operations compared to our base year. We have obtained external assurance, by S&P Global Market Intelligence in accordance with AA1000AS Type 2 moderate-level assurance, for 100% site coverage and sources of Scope 1 emissions.

To learn more please review our 2021 Sustainability Report.
Air Emissions
Metric: (1) CO Category: Quantitative Unit of Measure: Metric tons
(t)
Code: EM-IS-120a.1 Response/Comment: 274 We report on distinct air emissions associated with the consumption of fuels by our on-road transport vehicles and off-road equipment only. The emittance of some of these pollutants (i.e., VOCs) from other sources, such as production processes or the consumption of natural gas, may be reported on within our gross global Scope 1 emissions in terms of metric tons of CO2-e.
Metric: (2) NOx (excluding N2O)
Category: Quantitative
Unit of Measure: Metric tons
(t)
Code: EM-IS-120a.1
Response/Comment: 1,264
We report on distinct air emissions associated with the consumption of fuels by our on-road transport vehicles and off-road equipment only. The emittance of some of these pollutants (i.e., VOCs) from other sources, such as production processes or the consumption of natural gas, may be reported on within our gross global Scope 1 emissions in terms of metric tons of CO2-e.
Metric: (3) SOx
Category: Quantitative
Unit of Measure: Metric tons
(t)
Code: EM-IS-120a.1
Response/Comment: 83
We report on distinct air emissions associated with the consumption of fuels by our on-road transport vehicles and off-road equipment only. The emittance of some of these pollutants (i.e., VOCs) from other sources, such as production processes or the consumption of natural gas, may be reported on within our gross global Scope 1 emissions in terms of metric tons of CO2-e.
Metric: (4) PM10
Category: Quantitative
Unit of Measure: Metric tons
(t)
Code: EM-IS-120a.1
Response/Comment: 89
We report on distinct air emissions associated with the consumption of fuels by our on-road transport vehicles and off-road equipment only. The emittance of some of these pollutants (i.e., VOCs) from other sources, such as production processes or the consumption of natural gas, may be reported on within our gross global Scope 1 emissions in terms of metric tons of CO2-e.
Metric: (5) MnO
Category: Quantitative
Unit of Measure: Metric tons
(t)
Code: EM-IS-120a.1
Response/Comment: n/a
We report on distinct air emissions associated with the consumption of fuels by our on-road transport vehicles and off-road equipment only. The emittance of some of these pollutants (i.e., VOCs) from other sources, such as production processes or the consumption of natural gas, may be reported on within our gross global Scope 1 emissions in terms of metric tons of CO2-e.
Metric: (6) Pb
Category: Quantitative
Unit of Measure: Metric tons
(t)
Code: EM-IS-120a.1
Response/Comment: n/a
We report on distinct air emissions associated with the consumption of fuels by our on-road transport vehicles and off-road equipment only. The emittance of some of these pollutants (i.e., VOCs) from other sources, such as production processes or the consumption of natural gas, may be reported on within our gross global Scope 1 emissions in terms of metric tons of CO2-e.
Metric: (7) VOCs
Category: Quantitative
Unit of Measure: Metric tons
(t)
Code: EM-IS-120a.1
Response/Comment: 110
We report on distinct air emissions associated with the consumption of fuels by our on-road transport vehicles and off-road equipment only. The emittance of some of these pollutants (i.e., VOCs) from other sources, such as production processes or the consumption of natural gas, may be reported on within our gross global Scope 1 emissions in terms of metric tons of CO2-e.
Metric: (8) PAHs
Category: Quantitative
Unit of Measure: Metric tons
(t)
Code: EM-IS-120a.1
Response/Comment: <1
We report on distinct air emissions associated with the consumption of fuels by our on-road transport vehicles and off-road equipment only. The emittance of some of these pollutants (i.e., VOCs) from other sources, such as production processes or the consumption of natural gas, may be reported on within our gross global Scope 1 emissions in terms of metric tons of CO2-e.
Energy Management
Metric: (1) Total energy consumed Category: Quantitative Unit of Measure: Gigajoules (GJ), Percentage (%) Code: EM-IS-130a.1 Response/Comment: 2,918,073 In fiscal 2021, we experienced an 7% decrease in total energy consumed compared to our base year. Sources of energy consumed by our operations include grid electricity, natural gas, and other fuels (listed below). In the medium-term, we anticipate our energy consumption to increase, from both renewable and non-renewable sources. We have obtained external assurance, by S&P Global Market Intelligence in accordance with AA1000AS Type 2 moderate-level assurance, for 100% site coverage and sources of energy consumed.

To learn more please review our 2021 Sustainability Report.
Metric: (2) Percentage grid electricity
Category: Quantitative
Unit of Measure: Gigajoules (GJ), Percentage (%)
Code: EM-IS-130a.1
Response/Comment: 46%
In fiscal 2021, we experienced an 7% decrease in total energy consumed compared to our base year. Sources of energy consumed by our operations include grid electricity, natural gas, and other fuels (listed below). In the medium-term, we anticipate our energy consumption to increase, from both renewable and non-renewable sources. We have obtained external assurance, by S&P Global Market Intelligence in accordance with AA1000AS Type 2 moderate-level assurance, for 100% site coverage and sources of energy consumed.

To learn more please review our 2021 Sustainability Report.
Metric: (3) Percentage renewable (including carbon-free): (i) total energy, (ii) grid electricity use, (iii) fossil fuel consumption
Category: Quantitative
Unit of Measure: Gigajoules (GJ), Percentage (%)
Code: EM-IS-130a.1
Response/Comment: 46%
100%
<1%
In fiscal 2021, we experienced an 7% decrease in total energy consumed compared to our base year. Sources of energy consumed by our operations include grid electricity, natural gas, and other fuels (listed below). In the medium-term, we anticipate our energy consumption to increase, from both renewable and non-renewable sources. We have obtained external assurance, by S&P Global Market Intelligence in accordance with AA1000AS Type 2 moderate-level assurance, for 100% site coverage and sources of energy consumed.

To learn more please review our 2021 Sustainability Report.
Metric: (1) Total fuel consumed Category: Quantitative Unit of Measure: Gigajoules (GJ), Percentage (%) Code: EM-IS-130a.2 Response/Comment: 1,580,675 In fiscal 2021, we experienced a 7% decrease in total fuel consumed compared our base year. Sources of fuel consumed by our operations include natural gas, diesel, biodiesel blends, gasoline, ethanol blends, fuel oil, kerosene, propane, propylene, ametalene, and acetylene. We have obtained external assurance, by S&P Global Market Intelligence in accordance with AA1000AS Type 2 moderate-level assurance, for 100% site coverage and sources of fuel consumed.

To learn more please review our 2021 Sustainability Report.
Metric: (2) Percentage coal
Category: Quantitative
Unit of Measure: Gigajoules (GJ), Percentage (%)
Code: EM-IS-130a.2
Response/Comment: 0%
Not applicable. We do not consume coal as a source of fuel. Rather, the recycling of 1 metric ton of ferrous scrap for use in EAF steelmaking is estimated to conserve 1,389 pounds of coal. Therefore, by extension, our operations supported the conservation of more than 6.2 billion pounds of coal in fiscal 2021.
Metric: (3) Percentage natural gas
Category: Quantitative
Unit of Measure: Gigajoules (GJ), Percentage (%)
Code: EM-IS-130a.2
Response/Comment: 56%
In fiscal 2021, we experienced an 8% decrease in total natural gas consumption compared to our base year. Our primary use of natural gas is in the reheat furnaces and melt shop of our steel manufacturing operations, where precasted billets are reheated and then processed through our rolling mill to produce our finished steel products — rebar and wire rod. Our secondary use of natural gas consumption is in regenerative thermal oxidizers of our metal shredding operations where captured VOC air emissions are treated to reduce GHG emissions from our shredding production processes. In fiscal 2021, our steel manufacturing operations were briefly shuttered. This one-off event is the primary reason for decreased natural gas consumption. In the medium-term we anticipate our natural gas consumption to increase.
Metric: (4) Percentage renewable
Category: Quantitative
Unit of Measure: Gigajoules (GJ), Percentage (%)
Code: EM-IS-130a.2
Response/Comment: <1%
We consume a small amount of biodiesel-blended and ethanol-blended fuel in our on-road transport vehicles and off-road equipment. In the medium-term, we anticipate our renewable fuel consumption to increase.
Water Management
Metric: (1) Total fresh water withdrawn Category: Quantitative Unit of Measure: Thousand cubic meters (m3), Percentage (%) Code: EM-IS-140a.1 Response/Comment: 1,236 In fiscal 2021, we experienced a 5% increase in total fresh water withdrawn compared to our base year. Our steel mill is the primary user of water, representing 57% of total fresh water withdrawal and maintaining a water recycling rate of approximately 96% in fiscal 2021. Our metal shredding operations are also significant users of water, representing 31% of total fresh water withdrawal in fiscal 2021. We have obtained external assurance, by S&P Global Market Intelligence in accordance with AA1000AS Type 2 moderate-level assurance, for 100% site coverage and sources of fresh water withdrawn.

To learn more please review our 2021 Sustainability Report.
Metric: (2) Percentage recycled
Category: Quantitative
Unit of Measure: Thousand cubic meters (m3), Percentage (%)
Code: EM-IS-140a.1
Response/Comment: 96%
Our steel mill is the primary user of water, representing 57% of total fresh water withdrawal and maintaining a water recycling rate of approximately 96% in fiscal 2021. Our metal shredding operations are also significant users of water, representing 31% of total fresh water withdrawal in fiscal 2021. Water recycling rates and capabilities for our metal shredding operations are influenced by various factors, such as (i) weather-related events (i.e., floods, hurricanes, storms, wildfires, heat waves, and droughts), (ii) regulatory compliance requirements regarding control and treatment of wastewater and stormwater, and (iii) existing infrastructure, conveyance and storage equipment, and control technologies for practicable collection and reuse of water.
Metric: (3) Percentage in regions with high or extremely high baseline water stress
Category: Quantitative
Unit of Measure: Thousand cubic meters (m3), Percentage (%)
Code: EM-IS-140a.1
Response/Comment: 2%
The percentage of total fresh water resources indirectly withdrawn from areas characterized to have high or extremely high baseline water stress remains unchanged at approximately 2%. Our operations source water from (1) third-party purchased municipal water sources and (2) onsite well extracted renewable groundwater sources. Approximately 20% of our sites purchase water from municipalities that operate in geographic areas characterized to have high or extremely high baseline water stress. At this time, water availability directly linked to the respective geographic locations of our operations is not believed to be of significant concern as water is not a direct, raw material input of our products, and our water uses in operations are limited in scope to predominately cooling in steelmaking and metal shredding production processes, emergency response fire suppression, emissions control, dust suppression, and to lesser extent, landscaping irrigation, human sanitation and consumption.
Waste Management
Metric: Amount of waste generated Category: Quantitative Unit of Measure: Metric tons
(t), Percentage (%)
Code: EM-IS-150a.1 Response/Comment: 704,637 In fiscal 2021, we experienced a decrease in total waste generated compared to our base year as a result of (i) greater stakeholder engagement with our providers of waste services and (ii) greater employee training on proper waste classification, handling, storage, and management. We have obtained external assurance, by S&P Global Market Intelligence in accordance with AA1000AS Type 2 moderate-level assurance, for 100% site coverage and sources of waste generated.

To learn more please review our 2021 Sustainability Report.
Metric: Percentage hazardous
Category: Quantitative
Unit of Measure: Metric tons
(t), Percentage (%)
Code: EM-IS-150a.1
Response/Comment: <1%
In fiscal 2021, we experienced a decrease in total waste generated compared to our base year as a result of (i) greater stakeholder engagement with our providers of waste services and (ii) greater employee training on proper waste classification, handling, storage, and management. We have obtained external assurance, by S&P Global Market Intelligence in accordance with AA1000AS Type 2 moderate-level assurance, for 100% site coverage and sources of waste generated.

To learn more please review our 2021 Sustainability Report.
Metric: Percentage recycled
Category: Quantitative
Unit of Measure: Metric tons
(t), Percentage (%)
Code: EM-IS-150a.1
Response/Comment: 90%
In fiscal 2021, we experienced a decrease in total waste generated compared to our base year as a result of (i) greater stakeholder engagement with our providers of waste services and (ii) greater employee training on proper waste classification, handling, storage, and management. We have obtained external assurance, by S&P Global Market Intelligence in accordance with AA1000AS Type 2 moderate-level assurance, for 100% site coverage and sources of waste generated.

To learn more please review our 2021 Sustainability Report.
Workforce Health & Safety
Metric: (1) Total recordable incident rate (TRIR) for full-time employees Category: Quantitative Unit of Measure: Rate Code: EM-IS-320a.1 Response/Comment: 1.71 In fiscal 2021, our TRIR fell 39% and our NMFR fell 81% against our base year. Our fatality rate remains 0%.

To learn more please review our 2021 Sustainability Report.
Metric: (2) Fatality rate for full-time employees
Category: Quantitative
Unit of Measure: Rate
Code: EM-IS-320a.1
Response/Comment: 0
In fiscal 2021, our TRIR fell 39% and our NMFR fell 81% against our base year. Our fatality rate remains 0%.

To learn more please review our 2021 Sustainability Report.
Metric: (3) Near miss frequency rate (NMFR) for full-time employees
Category: Quantitative
Unit of Measure: Rate
Code: EM-IS-320a.1
Response/Comment: 15.27
In fiscal 2021, our TRIR fell 39% and our NMFR fell 81% against our base year. Our fatality rate remains 0%.

To learn more please review our 2021 Sustainability Report.
Metric: (1) TRIR for contract employees
Category: Quantitative
Unit of Measure: Rate
Code: EM-IS-320a.1
Response/Comment: Not applicable. We do not report on rates exclusive to “contract employees.”
Metric: (2) Fatality rate for contract employees Category: Quantitative
Unit of Measure: Rate
Code: EM-IS-320a.1
Response/Comment: Not applicable. We do not report on rates exclusive to “contract employees.”
Metric: (3) NMFR for contract employees Category: Quantitative
Unit of Measure: Rate
Code: EM-IS-320a.1
Response/Comment: Not applicable. We do not report on rates exclusive to “contract employees.”
Supply Chain Management
Metric: Discussion of the process for managing iron ore and/or coking coal sourcing risks arising from environmental and social issues Category: Discussion and Analysis Unit of Measure: n/a Code: EM-IS-430a.1 Response/Comment: Not applicable. A process for managing iron ore and/or coking coal sourcing risks is not necessary because we do not consume iron ore or coking coal. Rather, the recycling of 1 metric ton of ferrous scrap for use in EAF steelmaking is estimated to conserve 2,425 pounds of iron ore and 1,389 pounds of coal. Therefore, by extension our operations supported the conservation of more than 10.8 billion pounds of iron ore and 6.2 billion pounds of coal in fiscal 2021. Additionally, we produce three valuable coproducts: millscale, baghouse dust, and slag. Millscale functions as a metallurgical input to steelmaking, supporting the avoidance of iron ore production and conservation of raw iron ore, while baghouse dust avoids zinc production, and slag avoids cement and gravel production.

In regards to any existing or projected risks or constraints in obtaining other raw materials, we believe we operate the only mini-mill in the Western U.S. that obtains the majority of its scrap metal feedstock from an integrated metals recycling operation. Our metals recycling operations provide our steel mill with a mix of recycled metal grades, which allows the mill to achieve optimum efficiency in its melting operations. Although the synergies from our integrated operations allow us to be our own source for some raw materials, particularly with respect to scrap metal for our steel manufacturing operations, we rely on third-party suppliers for other input needs, including inputs to steel production such as graphite electrodes, alloys, and other required consumables.