SML 20 Pollution Incident Response Management Plan · Report . 1.5 Key Personnel and Responsibilities . ... Truck spills on public roads within or near the site premises which may

Heron Resources Limited Tarago Operations Pty Limited

Woodlawn Mine

SML 20

Pollution Incident Response Management Plan

March 2017

Document Control Details

DOCUMENT DETAILS

Name: Pollution Incident Response Management Plan Author: Robert Byrnes Reference: PIRMP Revision No.: 3 Document Status Operational

REVISION DETAILS

Revision No.

Date Details of Revision Reviewed By

Approved By

1 20/2/15 Draft for Review RB HS 2 19/12/16 Revision 2 RB AL 3 20/3/17 Operational RB AL

CIRCULATION DETAILS

Name Department/Organisation

Heath Sandercock Heron Resources Andrew Lawry Heron Resources Brian Hearne Mine Manager

Tarago Operations Woodlawn Mine - Pollution Incident Response Management Plan Page i

Table of Contents

1. Introduction 1

1.1 Objectives 1 1.2 Document Purpose 1 1.3 Document Definitions 1 1.4 Mandatory Requirements 2 1.5 Key Personnel and Responsibilities 2

2. Legislation 3

2.1 NSW Regulations 3 2.2 Pollution Incidents Causing Material Harm 3

3. Potential Pollution Incidents and Responses 4

3.1 Possible Pollution Incidents at the Woodlawn Mine 4 3.2 Pollution Incident Emergency Response 4 3.3 Emergency Procedure In The Event Of Fire Underground 6

4. Procedures for Calling Emergency Services 8

5. Notification 9

5.1 Internal Notification 9 5.2 Internal Contact List 9 5.3 Notification Details 9 5.4 Pollution Incident Authority Contact List 10 5.5 Resident Contact List 11 5.6 Implementation and Training Requirements 11 5.7 Record Keeping 11

Appendices Appendix A - Notification Logs List of Plans Plan 1 Locality Plan Plan 2 General Arrangement Plan 3 Environmental Monitoring Sites

Tarago Operations Woodlawn Mine - Pollution Incident Response Management Plan Page 1

1. Introduction 1.1 Objectives

This document details Woodlawn Mine’s Pollution Incident Response Management Plan. It provides a management plan designed to outline an appropriate response to a pollution event either on the surface or within the underground workings. This plan ensures compliance with the requirements of NSW’s Protection of the Environment Legislation Amendment Act 2011 (POELA Act) and is a requirement for all licensed mine premises in NSW. This plan forms part of the Environmental Management Strategy at the Woodlawn Mine and the Safety Management Plan prepared under the Mines Health and Safety Act 2002 Part 5, Division l, Subdivision 5, Clause 47.

1.2 Document Purpose The purpose of this Plan is to assure compliance of Woodlawn Mine in terms of management of pollution events and notification requirements in NSW in case of pollution incidents that cause or threaten to cause material harm to people or environment.

1.3 Document Definitions

Term Definition

Act A legal document created from the results of deliberation of a legislative body. In Australia, Acts are passed by State and Commonwealth Parliaments

ARA Appropriate Regulatory Authority. This includes EPA, relevant Local Authority, Fire Brigade, WorkCover and a local Public Health Unit plus any other Public Authority that is a statutory authority for the matter in question, if different from above

Material harm In terms of the POEO Act, material harm caused by a pollution incident relates to "actual or potential harm to the health or safety of people or ecosystems that is not trivial, or loss or property damage exceeding $10,000, either offsite or onsite". The $10,000 threshold includes any investigation costs associated with the pollution incident.

POELA Act Protection of the Environment Legislation Amendment Act 2011, issued by NSW Government to regulate environmental incident reporting and disclosure of environmental monitoring data

PIRMP Pollution Incident Response Management Plan. A detailed emergency response plan that needs to be implemented at all EPA-licensed sites in NSW by 1 September 2012

SOP Standard Operating Procedure. A formal procedure for undertaking complex and recurring tasks where neither physical nor environmental layout will change


1.4 Mandatory Requirements The minimum mandatory requirements for compliance to this Plan are outlined in the table below:

Requirement Examples of Evidence/Verification

The Mine Manager and Environmental Officer for Woodlawn Mine share responsibility to notify immediately the relevant Authorities and community as specified in this document following a serious environmental incident

Details of notifications summarised in the Incident Report

1.5 Key Personnel and Responsibilities Management responsibility for the Woodlawn Mine will be as follows. Table 1 - Key Mine Personnel

Position Personnel Company Responsibility Contact Details Managing Director Wayne Taylor Heron

Resources Limited

Overall responsibility for the construction and operation of the Woodlawn Project

02 9119 8111

Chief Operating Officer

Andrew Lawry Heron Resources

Responsible for project delivery and operations

02 9119 8111

Manager Mining Engineering

To be appointed Heron Resources Limited

Mine Planning and Design 02 9119 8111

Mine Manager Brian Hearne Heron Resources Limited

Conduct of mining operations

02 9119 8111

Exploration Manager, Chief Geologist

David von Perger

Heron Resources Limited

Resource evaluation 02 9119 8111

Environmental Manager

Robert Byrnes IEC Conduct of environmental management and compliance

02 4878 5502

The personnel will be updated from time to time as changes occur.


2. Legislation 2.1 NSW Regulations

The Protection of the Environment Legislation Amendment Act 2011 (POELA Act) requires:

Immediate notification of an expanded list of relevant statutory authorities in case of a pollution incident.

Establishment of a Pollution Incident Response Management Plan (PIRMP). Making publicly available any Licence related monitoring data. This document addresses the immediate notification requirements for pollution incidents at the Woodlawn Mine.

2.2 Pollution Incidents Causing Material Harm

Any pollution incident that cause or threaten material harm to the environment must be notified by a person to a site specific list of government authorities immediately upon becoming aware of the incident. In case new information comes to hand following the initial notification, this information must also be reported immediately. The failure to do so incurs the maximum penalty to $2,000,000 for a corporation, with $240,000 for each day the offence continues. The definition of “material harm” caused by a pollution incident relates to "actual or potential harm to the health or safety of people or ecosystems that is not trivial, or loss or property damage exceeding $10,000, either offsite or onsite". The $10,000 threshold includes any investigation costs associated with the pollution incident. As such, the incident need not be a significant one as this threshold could be quite easily exceeded within the context of a relatively minor environmental impact if it requires investigation and remediation. This also includes environmental harm caused only on site.


3. Potential Pollution Incidents and Responses 3.1 Possible Pollution Incidents at the Woodlawn Mine The potential, albeit not necessarily likely, pollution incidents at the Woodlawn Mine include:

Fire, explosions and smoke on the surface or within the underground workings. On-site spills or leaks of fuel, oil or hydraulic fluid that cause or threaten

environmental harm, property damage or personal injury.

Bushfire near or around the site which threatens the safety of the workforce or nearby residents.

Truck spills on public roads within or near the site premises which may cause fuel, lubricants or other products to enter the site or threaten to enter water ways.

Pipe burst resulting in contaminated water and/or tailings going off site.

Dam overtopping resulting in contaminated water going off site. This Pollution Incident Response Management Plan covers events and activities which may cause pollution incidents involving material harm. The main areas and issues covered in this plan are: Existing controls to prevent pollution incidents.

Incident response actions to mitigate potential incidents.

Immediate reporting of pollution incidents to relevant statutory authorities.

Maintaining communications with Appropriate Regulatory Authorities during incident response.

Reporting of incidents to stakeholders including local communities.

Site specific roles and responsibilities in incident response and reporting.

3.2 Pollution Incident Emergency Response In the event of a pollution incident the risk of harm to human health will be minimised by engaging an appropriate pollution response as outlined below:

1. Isolate the area: In the event of oil, fuel or hydraulic fluid spill or leak, the area

should be isolated and barricaded if required to reduce the risk of exposure to people. This must occur without exposure to danger.

2. Stop the source: If it safe to do so, stop the process causing the spill/leak or other

environmental incident.

3. Commence early notification: The Mine Manager or Environmental Manager must be notified immediately of the environmental incident. Should the incident


threaten environmental harm, they in turn must immediately proceed with the notification of Authorities as detailed in this Plan. If the environmental incident threatens off site impacts or involves the township of Tarago, the nominated person implements early notification procedures to the relevant Authorities including emergency services and alerts potentially affected residents, with regular updates provided as needed.

4. Provide a 1st aid response (if required): First aid kits including instruction on use are available at the Contractors Office and designated underground first aid stations. Appropriate PPE is worn by all staff during periods of potential exposure as outlined in relevant MSDS.

5. Identify the release to the greatest extent possible: Do so without being at risk. This includes identifying:

a. the type of material released, e.g. i. Class 2 Gases - compressed, liquefied or dissolved under

pressure. ii. Class 3 Flammable Liquids

iii. Solid material spill

b. The label and Material Safety Data Sheet for the product should give information on safe cleanup.

c. The size of the release and whether the release has stopped; d. Whether chemicals involved may be potentially incompatible; and e. Any unusual features such as foaming, odour, smoke, etc.

6. Determine the level of emergency: review chemical risk assessments, seek

internal advice from area specialists, review MSDSs and seek professional advice from the fire brigade and/or hazardous material specialists.

7. Determine if evacuation is required and consider the impact that wind, rain, local geographical features such as hills and stormwater drainage systems may have in exposing persons at emergency assembly points. The Mine Manager or Construction Contractor Manager is to determine if evacuation of the site is to occur.

8. Stop further release (if not done prior): prevent further release by isolating the source of the release. (Trained personnel only with suitable PPE).

9. Stop the release from spreading (if safe to do so): deploy spill kits to prevent

further contamination dispersal: a. Liquid spills. Use appropriate absorbent/containment materials such as

socks (land) and booms (water), plug drains to prevent contamination of stormwater.

b. Ensure that pollution control ponds remain as nil discharge by checking levels and pumps.

c. Powdered solid spills: cover drains to prevent contamination of stormwater

d. Large spills: Summon specialist spill emergency response contractors (e.g. Transpacific Industrial Solutions, 1800 SPILLS). Although the quantities of materials stored on site are minor, this procedure is relevant


if there is an incident involving a delivery truck. e. Dispose of contaminated spill clean materials and wastes using a

licensed contractor f. If required, remediate the site.

10. Fire on the Surface: Call 000 and report fire.

a. In the event of an equipment fire the operator should activate the fire suppression system on the equipment and disembark carrying any portable fire extinguisher with them. If safe to do so the operator should attempt to extinguish the fire using a portable fire extinguisher. Battery isolator should be turned off if safe to do so.

b. Portable fire extinguishers are located around the site and should be used to extinguish fires if they start within fixed plant. Any energy source should be isolated if safe to do so.

c. Evacuate surface personnel and assemble in the carpark d. Evacuate underground workforce and assemble in the carpark e. Once all personnel are accounted, evacuate the mine site if safe to do so

11. Fire Underground:

a. Call emergency internal number to report incident to the Mine Manager b. Check number of persons on shift c. Check mine monitoring system d. Is the power still on underground e. Is the main fan still running f. Note reports from any witnesses g. Determine level of incident h. Mine Manager to determine evacuation i. Evacuate mine and assemble in Carpark j. Determine contact list and reporting k. Contact Mines Rescue on 4284 4218 l. Contact Mines Inspector on 4222 8333

Further procedures in the event of underground fire is provided below

3.3 Emergency Procedure In The Event Of Fire Underground In the event of an equipment fire the operator should activate the fire suppression system on the equipment and disembark carrying any portable fire extinguisher with them. If safe to do so the operator should attempt to extinguish the fire. Contact and inform the senior mining official of the situation and the status at the mine. Write down any instructions you may be given in response. Summon trained persons around the mine surface to assist. Refer to "Mine Telephone" list and contact personnel in work areas of fire location. Briefly advise them of the situation and instruct them to commence evacuation procedures.

a) Telephone the work area nearest to the fire first. b) Messages to be as short as possible and ensure they are clearly understood.


c) Mark off telephone list as contact is made. d) If you have assistance use additional telephones to speed up this procedure. e) Record name of persons contacted.

Dispatch assistance if required. Assistance may be received from: -

a) Surface personnel b) Work areas unaffected by the fire.

Dispatch equipment if required. This can be done by: -

a) Men carrying the equipment. b) Any available underground vehicle,

Contact Mines Rescue Station and put them on stand-by after briefing them on situation. Arrange an underground transport to be on standby. Keep a log of all vehicle locations, phone calls and instructions. FIRE UNDERGROUND NOTES CHECK LIST

Item Done Time Assistance on the surface. Contact inbye of fire areas Contact officials at the mine. Dispatch assistance Dispatch equipment. Make necessary phone calls. Transport to surface on stand-by. Keep a log.


4. Procedures for Calling Emergency Services Dial 000 Ask for Ambulance/ Fire Brigade/Police. Be prepared to state: Woodlawn Mine calling Collector Road Tarago Nature of Emergency: Fire Serious Injury — number of injured and nature of injury Entrapment — number of personnel Mine Telephone Number: 02 9119 8111 Give your name Directions to the mine: Approaching from Bungendore: Turn left on Collector Road. Mine Entrance is 5.3 km but before the Veolia Bioreactor entrance. Approaching from Tarago: Proceed past the Crisps Creek Intermodal rail facility Turn right on Collector Road Mine Entrance is 5.3 km but before the Veolia Bioreactor entrance. GPS Coordinates 350 03’ 36.33” S 1490 35’ 02.20” E Ask for estimated time of arrival at the mine and log same: ETA………………..


5. Notification 5.1 Internal Notification Any pollution incident satisfying the material harm threshold must be immediately reported to relevant statutory authorities by either the Mine Manager or the Mine Environmental officer.

In cases where “material harm” level cannot be immediately assessed or insufficient information comes to hand on the severity of the incident, the general advice is to err on the site of caution and notify the Relevant Authorities with a qualification that the situation could not yet be fully assessed.

Although the listed personnel are authorised to contact the relevant agencies, as always, it is every employee’s responsibility to immediately call 000 in the event of emergency particularly if there is injury or rescue is required.

5.2 Internal Contact List

Position Name Phone Heron Resources Limited Sydney Office 02 9119 8111

Managing Director Wayne Taylor 02 9119 8111

COO Andrew Lawry 0411 873 356

Mine Manager Brian Hearne 0409 680 084

Environmental Manager Robert Byrnes 0417437120

OH&S Representative Alexandra Bonner 0422 169 365

Veolia Reception Bioreactor 02 4844 6262

Veolia Facility Manager Henry Gundry 02 4844 6351

Veolia Operations Manager David Figueiredo 02 4844 6352

5.3 Notification Details The Mine Manager or Environmental Manager is authorised to enact the necessary notification and must be done immediately upon becoming aware of the pollution incident. The initial notification should include as much of the following information (if known) as possible:

- location and time of the pollution incident

- type of the incident (spill, fire, unlicensed harmful discharge, etc) - assessed level of incident gravity and extent


- whether the Emergency Services have been required to attend.

All notifications must be documented in the Notification Log (form attached) with the details of time of notifications and the persons who took to the call.

5.4 Pollution Incident Authority Contact List The following contact list includes compulsory notification and a supplementary list which require notification depending on the nature of the incident.

Government Authority - Compulsory Notifications

Emergency notification phone number

EPA – Environment Line 131 555

NSW Police and Ambulance 000

NSW Fire and Rescue 1300 729 579

Goulburn Mulwaree Council 4823 4444

Palerang Shire Council 1300 735 025

Emergency Services 132500

WorkCover 131050 Company ABN asked: 62 008 528 523

Public Health Unit (Sydney South West) – Camperdown Office

BH: 9515 9420 AH: 9515 6111 Ask for Public Health Officer on call

Government Authority – If Relevant Emergency notification phone number

Mines Rescue 4286 5499

Sydney Catchment Authority 1800 061069

Roads and Maritime Services (road spills) 132 701

NSW Office of Water 8838 7885

Bush Fire Control Officer 1800 049933

Poisons Information Centre 131 126

Goulburn Hospital 4827 3111

Goulburn Police 4824 0799

Tarago Police 02 4849 4411 (not 24 hrs)

Endeavour Energy (power line emergencies) 131 003


5.5 Resident Contact List In case of pollution incidents that may potentially pose a threat to health or safety of the neighbours the nearby residents need to be urgently notified. As it is likely that not all residents can be contacted by phone, it will be the responsibility of the Mine Manager or Environmental Officer to make arrangements for available employees to door knock around the village of Tarago.

The Environmental Officer will undertake the early warning of the neighbourhood in the first instance by phone. The current contact list for neighbours is provided below. The initial notification should be brief and contain only a description of the environmental threat together with instructions what to do. For example:

Due to a fire on site or bushfire nearby, we are experiencing elevated dust emissions from the site. Please keep your doors and windows closed until further notice.

An accidental discharge occurred from the site. There maybe emergency vehicles using the Collector Road.

Due to a diesel spillage onto a street from the site, a cleanup operation is being organised. Please be watchful for road closures in relation to this operation.

Follow up information on the resolution of emergency situation would be timely conducted also on the phone. If required, further information would be disseminated by means of leaflets in a letterbox drop.

5.6 Implementation and Training Requirements The mine’s Environmental Officer is responsible for dissemination and training of the requirements of this Plan to all site staff and contractors.

Any changes to the document are to be communicated to personnel in a timely manner. Audits and checks will verify that the implementation and compliance to this Plan are monitored.

5.7 Record Keeping An accurate record of immediate notifications is to be kept in all cases. A Notification Log format as attached is preferable. Other proforma record cards are attached.

All training and induction records are to be kept at the mine by the Training Manager and entered into the training register. Records of any toolbox talks are to be maintained by the relevant supervisor using the toolbox talk meeting minutes’ proforma. Record of incident review and corrective action is to be generated and retained to provide evidence of complying with this Plan.


Appendix A - Attachments


Pollution Incident Immediate Notification Log

Person undertaking notification (Name/Function):

Date and time when first become aware of the incident:

Incident type:

Comments:

Initial immediate notification log

Appropriate Regulatory Authority

Time of call

Respondent’s name/function

Approximate call duration

Comments

EPA

Public Health Unit

NSW Fire Brigade

Police/Ambulance 000

Emergency Services

Mines Rescue

Sydney Catchment Authority (WaterNSW)

Goulburn Mulwaree Council

WorkCover

Other:

Other:

Summary of initial communication:


Person undertaking notification (Name/Function):

Date and time when additional information become available:

Comments:

Immediate notification of further pertinent information (if applicable)

Appropriate Regulatory Authority

Time of call

Respondent’s name/function

Approximate call duration

Comments

EPA

Public Health Unit

Emergency 000

Local Council

Tarago Township

Other:

Other:

Summary of additional communication


Log sheet Date:……………………………..

Item Time


Emergency Call Receiver Card

INFORMATION REQUIRED FOR AN ACCIDENT/EMERGENCY SITUATION

Name of person reporting emergency

Telephone number from where the person is calling

Location of accident or emergency

Type of accident or emergency

Name and number of injured

Type of injuries

Assistance required

Make sure someone stays at the phone, if this is not possible arrange a method for further contact

Log time of call and information received, commence a diary of events

STAY CALM. THINK BEFORE YOU ACT, REPEAT THE MESSAGE TO THE CALLER TO ENSURE YOU HAVE THE CORRECT INFORMATION

Notes:………………………………………………………………………………………… …………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………

Heron Resources

Location: Woodlawn Mine Communications Officer

On becoming aware of an emergency the Communications Officer will take the following actions

Ascertain the nature and location of the incident Identify problems/ solutions to effective communications Notify the appropriate personnel Transmit and record instructions between Chief Warden and others Request outside emergency assistance if instructed by Chief Warden Notify any other parties i.e. neighbours etc

______________________________________________________________________________________ NATURE OF EMERGENCY? ……………………………………………………………………………….. ARE THERE PERSONS INJURED?------------------------------------------------------------------------------------ LOCATION? ……….……………………………………….. Date ……/……/……. Time ……………….

Communications Officer Name ……………………………………………….. Supervisor Name ………………………………………………..

Alarm sounded Yes / No Time ……………… Supervisor Notified Area Supervisor Name ………………………………………… Other Name ………………………………………….

Evacuation Status Prepare for evac Yes / No Time ……………… Evacuate Yes/No Time……………….Evacuation areas ……………………...

Communication Method Radio Runner(s) Phone Mobile/Landline Ph No……………………………..

Action Taken None Fire Suppression Extinguisher Fire Hose Other …………………………………………………………..

Outside Assistance Required Time requested by Chief ……………………….. Agency(s) contacted

Fire Brigade Time contacted …………… Name……………………. Ambulance Time contacted …………… Name……………………. Police Time contacted …………… Name……………………. SES Time contacted …………… Name……………………. SES Time contacted ……………

Heron Resources

Page 2 of 2

Neighbours contacted Person Time

Other ………………………………………………………………………… Other …………………………………………………………………………

Management Contacted Who ………………………………………………… Time ……………………… ………………………………………………… …………………….. ………………………………………………… …………………….. ………………………………………………… …………………….. Message Log From To Details of Message Time …..………………………………………………………………………………………………………….. ……………………………………………………………………………………………………………………………..…………………………………………………………………………………………………..………………………………………………………………………………………………………………………..……………………………………………………………………………………………………………. …..………………………………………………………………………………………………………….. ……………………………………………………………………………………………………………………………..…………………………………………………………………………………………………..…

Stand Down Stand down by Supervisor Time …………….. All Parties Notified of stand down Time of completion …………………..

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Infigen Woodlawn Wind Farm turbines

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Veolia operational site (The Veolia Site)

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Local Government Boundary

November 2015

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Topographic map source : Lake Bathurst 8827-4-N

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Woodlawn

FIGURE 1Woodlawn Site - Locality Plan

MINE VOID

Collector - Tarago Road

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Proposed Tailings Storage Facility (TSF4)

Proposed Site Entry

Proposed Ventilation

Shafts

Proposed Box Cut and Mine Entry

TSF4

Proposed Mine Office and Car Park

Proposed Processing Plant

Proposed Haul Road

Proposed ROM Pad

Proposed Waste Rock Emplacement Area

Proposed Box Cut and Mine Entry

FIGURE 2 Woodlawn Site - Mine and ContextN

Datum GDA MGA Zone 55

Infigen Woodlawn Wind Farm EPL20436

DRAWN: Dean Oliver 17-03-2017

APPROVED: Robert Byrnes 17-03-2017

6 115 000 N

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737 500 E

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732 500E732 500 E

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March 2017


Veolia Environmental ServicesEPL11436

Tarago Operations EPL20821

Veolia MBT FacilitySite Boundary

EPL 20476

Veolia MBT Plant EPL 20476

Stg 1

Stg 2

Tailings Storage Facility

(TSF4)

Site Entry

Ventilation Shafts

Paste Plant Mine Office

and Car Park

Processing Plant

Haul Road

ROM Pad

Waste Rock Emplacement

Box Cut and

Mine Entry

Proposed Heron Resources infrastructure

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Attachment 1 Woodlawn Site EPL - Monitoring Sites

Drawing No: TOP - G - 001

Attachment 1 Woodlawn Site EPL - Monitoring Sites

Drawing No: TOP - G - 001

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R E H A B I L I T A T E D W A S T E R O C K

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Veolia Office

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"Cowley Hills"

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DP754919

DP954149

DP357155

DP523960

DP754894

DP754919

DP126600

DP754919DP754919

68

17

12

35

90

21

13

74

75

16

69

179

173

20

13

4

3

2

29

23

1

1

259

57

9687

1

1

1

1

74DP754919 Cadastral boundary and DP/lot numberCadastral boundary

Lot 4

Lot 3

Lot 1

Lot 2

Pt Lot 1

N

Datum : GDA MGA Zone 55

N

MB13

MB6

105

MB4

DG22

DG24

115

DG28

MB13

MW6RWM6

WM5

MW8DWM202, 203

SPRING2

MB3

MB10

MB2

MB8

109

MB5

WM201MB1

P100

WM4

WM1

P38A

P45

P44

MB13WM3

P58

P59

MW8SMW6RWM6

MB7

WM5

ED3B

MB15100

MB14

WM5

MB15

WM300GMBH1

GMBH4

LGF

LGEEP

Met Station

WM200

GEB

GMBH2

MB12

ED2

DG33

MB17MB16

MB11

TSF4

Tarago Operations

Veolia Environmental Services

Shared site

MONITORING SITES

779

790780790

770

780

780

785

775

780

760750

770

800

820

840

850

860

850

840830820

810

800800

810 820

830

800

790780

810

820 830

840

860

800

770

780

765

760

765

765

770

715

810

820

785

785780

785

820

790

800

810

840830

830

820

810 80

0

840

850

770780

770

780

785785

790

795

800

810820

820

830

810

Documents

SML 20 Pollution Incident Response Management Plan · Report . 1.5 Key Personnel and Responsibilities . ... Truck spills on public roads within or near the site premises which may