Mongbwalu Project Emergency Preparedness and Response Plan
Report Prepared for
Ashanti Goldfields Kilo S.A.R.L.
Report Number 438643/EPRP
August 2011
Report Prepared by
SRK Consulting (South Africa) (Pty) Ltd. in association with SRK Consulting Congo S.P.R.L
SRK Consulting Emergency Preparedness and Response Plan
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Mongbwalu Project Emergency Preparedness and Response Plan
Ashanti Goldfields Kilo S.A.R.L. SRK Consulting (South Africa) (Pty) Ltd. Address
Telephone
SRK House 265 Oxford Road, Illovo, Johannesburg 2196
SRK Consulting CONGO S.P.R.L.
P O Box 55291, Northlands 2116
SRK House 2056, Lukonzolwa, Q/Golf, C/Lubumbashi, Democratic Republic ofCongo
+27 (0) 11 441 1111
+243 (81) 870 1753
Fax
+27 (0) 11 880 8086
+243 (81) 999 9775
Contact name
Briony Liber
Susa Maleba
Email
[email protected]
[email protected]
Website
www.srk.co.za
SRK Project Number 438643/EPRP
August 2011 Author Briony Liber (MPhil (Environmental Management); CEAPSA)
Reviewed by Donald Gibson (MSc (Conservation Biology); Pr.Sci.Nat.)
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Table of Contents
1 Introduction .................................................................................................................. 1 1.1 Purpose of the report ........................................................................................................ 1
2 Background .................................................................................................................. 2 3 Project description ....................................................................................................... 2 4 Overview of legislation, guidelines and policy .......................................................... 3 5 Outline of key risks ...................................................................................................... 6 6 Current risk management approach for emergency preparedness and response planning ........................................................................................................................ 9 7 Emergency preparedness and response action plan.............................................. 11 7.1 Internal emergency preparedness and response planning steps..................................... 11 7.2 External emergency preparedness and response planning steps ................................... 20
8 Conclusion .................................................................................................................. 29 9 References .................................................................................................................. 30 SRK Report Distribution Record .................................................................................... 31
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List of Tables Table 4-1: Summary of legislation, guidelines and policy ................................................................ 4 Table 5-1: Risk assessment for various phases of the mine............................................................ 6 Table 7-1: Internal emergency preparedness and response planning steps .................................. 13 Table 7-2: External emergency preparedness and response planning steps ................................ 21
List of Figures Figure 5-1: Examples of environmental and social risks generated by mine’s internal activities during each phase ......................................................................................................... 7 Figure 5-2: Examples of environmental and social risks generate by external and third parties that may affect AGKs operations .......................................................................................... 8
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August 2011 438643 Mongbwalu Project: Emergency Preparedness and Response Action Plan
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Introduction Ashanti Goldfields Kilo S.A.R.L. (AGK) is undertaking gold exploration in the Ituri District of Orientale Province in north-eastern Democratic Republic of the Congo (DRC). AGK holds mining permits for a 5,487 km2 area (the Kilo Regional Exploration area) within the formerly known Concession 40. Exploration has focussed mainly on the Mongbwalu area and AGK has proceeded to feasibility phase for the proposed Mongbwalu Mine (referred to henceforth as ‘the project’). AGK is a joint venture between AngloGold Ashanti Limited (AGA) and the Office des Mines d’Or de Kilo-Moto (OKIMO). SRK in collaboration with SRK Congo S.P.R.L. was appointed by AGK to conduct an EIS and compile an EMPP for the project. An EIS and EMPP are required for exploitation permit approvals in terms of Article 69 (e) of the Code Minier. The EIS and EMPP involved the assessment of environmental, social and health impacts and the development of management plans for the project. The EIS and EMPP will be submitted to the DRC regulatory authority, the Directorate Responsible for Protection of the Mining Environment (DPEM) for authorisation in support of the existing exploitation permit.
1.1
Purpose of the report Article 94 of the Code Minier or Mining Code, specifies the need for an emergency management plan. In addition AGA has various policies and requirements with respect to emergency management. The purpose of this report is to outline the key actions that will be taken by AGK in developing an emergency preparedness and response plan (EPRP) for the Mongbwalu Mine. The report outlines: •
The governance framework governing the EPRP;
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Identifies potential key risks and emergencies at a high level;
•
Outlines current capacity at AGK to address emergencies; and
•
Lays out a plan for the development of a detailed and operational EPRP.
Background AGK is located in a relatively isolated area as a result of poor road infrastructure and physical remoteness. The availability of emergency services, skills and resources in the towns of Mongbwalu and Bunia are substantially limited. In light of this situation, AGK recognises that it is necessary for the mine to be self sufficient with respect to responding to any emergencies that could potentially occur and further, that the mine has a responsibility to the environment and a duty to the surrounding communities in terms of their safety and ability to prepare for and respond to emergencies that may have an impact on the surrounding communities. AGK also recognises the need to be prepared for emergencies that could arise as a result of third party activities.
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Project description The project is a new underground gold mine with a five year life-of-mine (LOM). The mine will include a temporary contractors camp (providing accommodation during the construction phase), contractors laydown area, plant area, return water dam (RWD), mine development (including blasting activities), security control area, pollution control dam, waste rock dump (WRD), the expansion of the existing Mongbwalu exploration camp (providing accommodation for the mine during the operational phase), pipelines, pump station and tailings storage facility (TSF). The project will involve the underground mining of gold around the old Adidi-Kanga mine near Mongbwalu. The ore will be processed on-site to produce unrefined gold. The mine will be operational 24 hours per day. The ore will be accessed through a portal and decline adit. A metallurgical gold plant is planned for processing mined ore into unrefined gold. The processing plant’s crushing circuit is designed to operate at a maximum of 16 hours/day while the rest of the plant will operate on a 24 hour, 7 day operation. The following processes will be used: crushing, screening and grinding/classification (milling) followed by gravity concentration, intensive leaching, dewatering/thickening, carbon-in-leach (CIL), elution, electro winning and then smelting and detoxification/cyanide destruction. The tailings residue will be pumped to the TSF. Decanted water from the TSF will be pumped to the RWD, from where it will be pumped to the processing plant as required. Waste rock will be stored on a WRD. A pollution control dam and berms will be placed upstream of the WRD for clean and dirty water control. The mine will be supported by a 150 person mine camp (expanded Mongbwalu exploration camp), one helipad for transport of people, gold and essential consumables, internal access and
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haul roads. The mine camp, general plant area, high security plant area, smelt house, mine portal, offices, waste rock area, explosive stores area, TSF and RWD will all be secured by various fencing, surveillance and security arrangements. Access to the Mongbwalu project site is mainly via an 86 km gravel road from Bunia. This road deteriorates during rain events and may become impassable except to light 4-wheel drive vehicles and be intermittently blocked by local vehicles. In dry conditions, the journey takes approximately three hours. Alternatively, a charter plane can be taken from the sealed Bunia airstrip to the 600 m long Mongbwalu gravel airstrip which is located on the edge of the Mongbwalu Town. This flight takes about 10 minutes. Air travel remains the most efficient method of travel into the region. Access to Bunia from outside the DRC is made through the Entebbe airport in Uganda, and the flight takes approximately one hour. The following key transportation considerations are noted with respect to emergency preparedness and response: •
Entebbe, Uganda, will be used as the gateway to Bunia for the transport of people;
•
All reagents, parts and spares will be transported in 20 ft containers for sea and road transport;
•
Doré bars (unrefined bullion) will be transported from the gold plant to Bunia using a helicopter;
•
All explosives and cyanide will be transported by road; and
•
Fuel will be transported to site in tankers with an axle load of not more than 8 t.
Internal access roads will comprise the following: •
Service roads in the mine portal and plant area (to be constructed); and
•
The existing Mongbwalu road, which has recently been widened.
The project site is located near Mongbwalu town and in the vicinity of several communities including Pluto Mine, Sayo, Mabalindey, Msisi, Mbalamuno, Nzebi Avenue, Nzebi Village, Gaingo and Kanga Alluvion. The area is located in a known seismic zone.
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Overview policy
of
legislation,
guidelines
and
The requirements for the development and operation of emergency measures are outlined in Article 94 of the Mining Code. These requirements relate largely to occupational health and safety. Given the location of the mine in relation to the surrounding communities and sensitive environments, it is recognised that the contents of an EPRP should extend beyond occupational health and safety to include community health and safety relative to emergencies as well as measures to be taken in the event of accidents and emergencies that affect the biophysical environment. Table 4-1 provides a summary of the legislative requirements, international good practice guidelines and AGA’s policies that are intended to guide the development of an EPRP. Specifically the following are summarised: LIBB
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Legislation o
•
•
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Mining Code, Article 94
Guidelines o
IFC Performance Standards: Performance Standard 3 and Performance Standard 4
o
IFC Environmental Health and Safety Guidelines for Mining
o
UNEP/ICMM Good Practice Guide for Awareness and Preparedness for Emergencies at Local Level (APELL)
International Cyanide Management Code Company policy o
AGA Chemical Management Standard
o
AGA Waste Management Standard
Table 4-1: Summary of legislation, guidelines and policy Guideline/legislation Mining Code
Description Article 94: Emergency Measures The Mining Code requires that the operator describes an emergency plan in case of accidents or natural disasters. The plan should include a description of the intervention programme to manage accidents with a high risk potential particularly landslides in rock and loose soils, major embankment dam break offs and caving-in of bottom workings occurring on the site. The intervention programme against accidents should include in particular: (a) Immediate measures to apply; (b) Measures and methods for marking out the risk zone to be evacuated or barred; (c) Contact details of persons in charge of the mining operation and organisations with which he can enter into contact, particularly the local authorities, local community representative or police force.
IFC Performance Standards
PS3: Pollution Prevention and Abatement In terms of the IFC Performance Standard 3 – Pollution Prevention and Abatement, AGA should: • be in a position to respond to and prevent potential negative consequences of process upset, accidental, and emergency situations in a manner that is appropriate to the mine’s operational risks. • prepare a plan that addresses the training, resources, responsibilities, communication, procedures and other aspects, as required, to effectively respond to emergencies associated with the project’s hazards. PS4: Community Health and Safety In terms of the IFC Performance Standard 4 – Community Health and Safety, AGA should: • evaluate the potential risks and impacts from project activities in all phases of the project, ie design, construction, operation and decommissioning, and inform affected communities of significant potential hazards in a culturally appropriate manner. • give particular attention to potential exposure to natural hazards with respect to infrastructure and equipment safety.
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Guideline/legislation
IFC Environmental Health and Safety Guidelines for Mining
UNEP/ICMM Good Practice Guides
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Description • assist and collaborate with the community and the local government agencies in their preparations to respond effectively to emergency situations, especially when their participation and collaboration is necessary to respond to such emergency situations. As is the case in Mongbwalu, where local government agencies currently have little or no capacity to respond effectively, AGK will be responsible for responding to emergencies associated with the project. • document its emergency preparedness and response activities, resources and responsibilities, and disclose appropriate information to affected communities and relevant government agencies. The IFC EHS Guidelines contain performance levels and measures that are generally considered to be achievable in new facilities through the use of existing technology and at reasonable cost while the application of the guidelines to existing facilities may involve the establishment of site specific targets and timetables for achievement. The UNEP/ICMM Good Practice Guidelines specifically relate to AGK’s ability to prepare for and respond to emergencies that occur as a result of the mine’s activities and have the potential to affect communities living in the vicinity of the mine complex. Processes have been outlined that provide a step-by-step process for preparing, capacitating, communicating with, and involving communities in emergency preparedness and response. These processes are: • Awareness and Preparedness for Emergencies at Local Level (APELL), and • Emergency Planning for the Transport of Dangerous Goods (TransAPELL). While many emergency preparedness and response models exist, the APELL and TransAPELL models have been used as these are accepted industry good practice guides. The APELL process assists in raising community awareness of and capacity to respond to hazardous activities associated with industrial and mining activities in the vicinity through the implementation of a ten-step process. An important precursor to the implementation of APELL, is the preparation of an operational AGK mine-specific EPRP which can then be expanded to incorporate the communities. The TransAPELL process extends beyond the risks associated with the mine footprint, fixed infrastructure and on site operations, and incorporates risks associated with the transportation and distribution of hazardous materials and considers transport routes, communities along those transport routes, facilities within those communities to attend to potential spillages/accidents and the nature of materials being transported
International Cyanide Management Code for the Manufacture, Transport and Use of Cyanide in the Production of Gold (Cyanide Code).
AGA Chemical Management Standard, Revision 2, 23 June 2009
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The APELL and TransAPELL steps are described however it is recognized that many other models exist and may be equally appropriate. AGA is a signatory to the Cyanide Code. As a signatory to the Cyanide Code, AGA and its operations are compelled to protect communities and the environment through the development of emergency response strategies and capabilities. The specific standards of practice are as follows: 7.1 Prepare detailed emergency response plans for potential cyanide releases. 7.2 Involve site personnel and stakeholders in the planning process. 7.3 Designate appropriate personnel and commit necessary equipment and resources for emergency response. 7.4 Develop procedures for internal and external emergency notification and reporting. 7.5 Incorporate into response plans monitoring elements and remediation measures that account for the additional hazards of using cyanide treatment chemicals. 7.6 Periodically evaluate response procedures and capabilities and revise them as needed. The AGA Chemical Management Standard states the following with respect to emergency preparedness and planning: 5.7 Emergency Preparedness and Response
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AGA Waste Management Standard, Revision 2, 23 June 2009
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Description 5.7.1 Emergency preparedness and response plans shall be maintained current to ensure that appropriate responses can be taken following incidents involving environmentally hazardous chemicals (EHCs) that can threaten the safety of people and the environment. Where appropriate, for example with transportation incidents, these plans should be coordinated with local and regional emergency response agencies. 5.7.2 Training and communication of procedures governing the management of EHCs and emergency response plans should be done in simple language that is easily understood by relevant staff. 5.7.3 Sites must ensure that the necessary emergency response equipment and response team skills are maintained. The AGA Waste Management Standard states the following with respect to emergency preparedness and planning: 5.6 Emergency Preparedness and Response Sites must include appropriate responses to hazardous waste incidents in their emergency preparedness and response planning.
Outline of key risks The risks associated with the AGK mine will vary in significance over the duration of the construction, operation and closure phases of the mine. While AGK is in process with various risk assessments, it is recognised that typically most risk assessments tend to focus on the current phase of activity and the immediate footprint area of risk, or risk activity, and often exclude an assessment of all project phases and risks relating to broader issues such as community safety, transportation routes, communities along those routes, and environmental receptors located ‘offsite’. Table 5-1 illustrates this point with a summary of the typical phases and issues that should be considered in a risk assessment, while Figure 5-1 and Figure 5-2 provide an indication of the typical risks that could result in emergencies at AGK as a result of AGKs operations and as a result of external and third party factors. Table 5-1: Risk assessment for various phases of the mine Construction phase • • • •
• •
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Construction footprint (can be larger than the eventual mine footprint) Construction camps On and off-site environmental receptors Transport routes and modes of transport for construction materials and workers (may be different to operations phase transport routes) Communities Resettlement host communities
Operations phase
Closure phase
•
Mine footprint
• •
Mine footprint Residual activities
• •
Mine camps On and off-site environmental receptors Downstream receptors Transport routes and modes of transport
• •
Employee accommodation On and off-site environmental receptors Downstream receptors Transport routes and modes of transport
Communities
•
• •
•
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Communities
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Figure 5-1: Examples of environmental and social risks generated by mine’s internal activities during each phase
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Figure 5-2: Examples of environmental and social risks generate by external and third parties that may affect AGKs operations
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Current risk management approach for emergency preparedness and response planning While conventional EPRPs focus on the management of environmental and social risks associated with the operation of a mine and in many cases natural events/hazards as well, the operating context of AGK requires that the impact of external security risks on the mine’s personnel and their families, is also managed. Emergency preparedness and response to operational risks and hazards associated with AGKs operations, and the broader environment, should thus be addressed from four perspectives, these being: •
Security;
•
Occupational health and safety;
•
Environment; and
•
Community.
Typically AGA projects’ EPRP’s are aligned with the UNEP Awareness and Preparedness for Emergencies at Local Level (APELL) process. Several documents have been developed at corporate and operations levels to provide guidance to corporate crisis management and major incidents, and at a company level to provide guidance to the security and occupational health and safety elements of the exploration phase. The focus of these documents is on security, occupational health and safety and productivity and includes the following: •
AGK Camp Induction Sheet (Exploration phase);
•
Induction for expatriates arriving in the DRC (Exploration phase);
•
Occupational Health and Safety Plan (Exploration phase);
•
Emergency Evacuation Plan (All phases); and
•
Hazard and Operability Study for Mongbwalu Project – Metallurgical Plant (Operations phase).
At present there is very limited attention to emergency preparedness and response planning with respect to environment and community, as can be expected at this stage of the project. AGK does not currently have an emergency preparedness and response policy, however in terms of AGK’s safety and health principles AGK is committed to preventing injuries or illnesses among their employees, customers and the wider community arising from work performed on site. The following Safety and Health aspirations have been established for the project: •
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No harm to people;
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Zero medical incidents;
•
All injuries to be reported and investigated timeously;
•
All near misses to be reported and investigated; and
•
Lessons from incidents to be shared as soon as possible.
AGK however recognises the need to develop an overall EPRP that coordinates and guides actions that are taken with respect to emergencies that may result in environmental and social risks to employees, communities and the environment. At present AGK has the following capacity with respect to emergency preparedness and response: •
Security o
•
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AGK has a Risks and Security Manager that is responsible for the security of its personnel, the families of expatriate personnel, contractors and consultants. The security division focuses on keeping the mine’s exploration camps secure. This staff complement will be escalated to secure the total mine site at construction and operations phases. The security division undertakes regular security risk evaluation. The risk assessment is based on intelligence gathered from local, regional, national and international sources as well as input from risk management organisations. An emergency evacuation plan has been documented by AGA and outlines the procedures to be taken in the event of any emergencies requiring evacuation from Mongbwalu. Roles and responsibilities, chain of command and communication protocols are outlined in the plan. The details of the plan are confidential.
Occupational health and safety o
AGK’s approach to, competence and organisational capacity with respect to occupational health and safety are more fully described in the Occupational Health and Safety Plan, however an overview is provided here to provide context from en emergency preparedness and response respective.
o
At present the OHS Plan is tailored to the needs of an exploration camp and will need to be expanded to address the needs of the construction, operation and closure phases of the project.
o
Key principles of the plan relate to hazard studies prior to engaging in any activities, appropriate expertise and training for specialised activities, and appropriate inductions.
o
Currently AGK has a small on-site clinic with one expatriate nurse that can attend to basic medical conditions. For any more serious medical conditions or emergences local employees are transported to one of the 17 local clinics in the area or to the
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Mongbwalu Hospital or Bunia. Expatriates are evacuated out of the country to an appropriate international hospital in their country of origin. •
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Environment and community o
AGK has an environmental manager on site. In addition AGK has a community affairs manager and community liaison officer that are responsible for developing and maintaining relationships with the surrounding communities as well as providing relevant project information to the communities.
o
It is expected that during construction and operations, each operational area will be responsible for its own environmental management and will be able to request technical input and advice from the environmental division, with this division being capacitated primarily to perform support functions with respect to establishing environmental management systems, and performing monitoring and auditing functions.
Emergency action plan
preparedness
and
response
Environmental and social emergency planning and response requires the involvement of local communities, authorities and other external stakeholders in the EPRP. It is recognised that at present there are very limited resources and capacity within the local communities, as well as at a local authority level in the Greater Mongbwalu area. As a result the prime objective of this report is to outline the steps that AGK will need to take in order to develop adequate capacity and ability to respond to any emergencies that it may face as a result of its own activities or external factors that result in emergencies that affect the mine and/or communities surrounding the mine. Once AGK has developed a sufficient understanding of it owns internal capacity, resources, competencies, risks and requirements in terms of EPRP, the company will proceed with the external process which incorporates the community and communications elements of the Plan. Some of these steps can be undertaken in parallel with the internal steps however it would be ideal that AGK has its own EPRP in order to begin with. The external steps focus on providing information to external stakeholders on the potential hazards and measures taken to reduce risks associated with living in close proximity to a mine, review and update the EPR for the local area, increase the mine’s involvement in community awareness and EPR planning, integration of the mine and community plans and involvement of communities in developing, testing and implementing the plans. The external steps have been based on the ten-step APELL process outlined as follows:
7.1
Internal emergency preparedness and response planning steps Prior to commencing with steps that incorporate external stakeholders into the EPRP or any form of joint planning with stakeholders external to AGK, it is necessary that AGK has a firm understanding of its own requirements, resources, capacity and competencies with respect to Emergency Preparedness and Response. While AGK already has taken some steps to prepare for
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emergencies, the following steps are outlined for the sake of comprehensiveness and context. These steps include:
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•
Identification of an EPR Champion;
•
Identification of internal and external stakeholders and the roles they can/should be responsible for;
•
Identification of capacity and resources within AGK for EPR;
•
Internal workshops with AGK operational and service department directors to internalise EPR requirements;
•
Risk assessment for all operational areas (internal risks) and all third party activities that could result in risks to AGK (external risks);
•
Preparation of procedures and registers for management of chemicals, including hazardous chemicals, and hazardous materials; and
•
Procedures for monitoring and evaluation.
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Table 7-1: Internal emergency preparedness and response planning steps Issue
Action
Responsibility
Identify a champion for EPRP
It is necessary that at a strategic level an EPRP champion be identified to provide guidance, structure and ownership to the process of developing an EPRP. It is suggested that the owner of the EPRP should be the Engineering Manager. The General manager will however have overall responsibility for emergency preparedness and response at AGK.
Engineering Manager
Progress indicators Champion identified and job descriptions amended to reflect this
Timing December 2011
Resources / Budget Included in operational budgets
The overall EPRP champion will be capacitated in, trained and sensitive to the requirements of EPR. Operationally however it will also be relevant that in any emergency situation that effective leadership is available to take charge of a situation. It is necessary that in any situation, leadership should have the confidence, capacity, availability and the articulated responsibility to direct the situation. In certain situations it may be appropriate that the direction of the situation be the responsibility of a line function manager, however where any situation exceeds the boundaries of one operational area it is necessary that the leadership be elevated to a higher level.
Engineering Manager
Engineering Manager has complete authority to control the situation in the event of a security emergency. The allocation of responsibility for the coordination of an emergency will be allocated by functional discipline according to the incident typology. Job descriptions and KRAs will be updated as relevant to ensure that the necessary operational directors have the relevant EPR responsibilities incorporated into their functions. In addition to having an overall EPR Champion, it is noted that within AGK a culture of awareness, accountability and responsibility should ideally be developed with the objective being that all personnel are capacitated with the knowledge and responsibility to prevent potential accidents and emergencies, stop these from escalating and have sufficient knowledge on what to do if they are first on the scene and thereafter how to escalate responsibility up the chain of command. Develop a Mongbwalu EPR policy statement and corporate directives.
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AGA has several policies and plans which relate to chemical management, waste management and occupational health and safety and emergency evacuation. Additional policies need to be developed with regards to security, emergency preparedness and community health to support the EPRP development.
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Chain of command identified
Job descriptions amended
Engineering Manager
December 2011
December 2011
Included in operational budgets
Included in operational budgets
Training plan
December 2011
Included in operational budgets
Corporate directives and policies
December 2011
Included in operational budget
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Issue Identify internal stakeholders
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Action
Responsibility
It should be noted that with respect to ‘communicating’ it will be necessary at minimum, in the event of an environmental emergency, to notify the authorities when an emergency occurs and advise on steps being taken to address the situation with respect to clean up, monitoring, and recording of results. With multiple stakeholders involved in EPR, it will be necessary for AGK to ensure that all personnel that will have responsibilities in EPR share a common understanding and approach to EPR. o
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Timing
Resources / Budget
While it is necessary to have a clear leader in any situation it is also appropriate that there will be many parties within AGK that have an interest in or are affected by an emergency situation and as a result there are a number of roles and functions that need to be resourced to adequately address any emergency. A stakeholder analysis should be undertaken to identify a listing of stakeholders within AGA and AGK that will have a responsibility in terms of: o Preventing o Controlling o Communicating (internally and externally) o Responding o Assisting o Reporting o Monitoring
Internalize EPRP requirements
Progress indicators
Engineering Manager will convene an internal workshop(s) with all operational and service area directors to: o Sensitize personnel to the requirements and importance of an EPRP o Sensitize and educate personnel on the requirements of EPR models o Facilitate a preliminary risk evaluation in terms of EPR for each operational and service area. o Discuss various emergency scenarios
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Engineering Manager
Engineering Manager, plus all operational and service area managers, and selected personnel as identified in internal stakeholder analysis
Analysis of stakeholders and allocation of responsibilities
December 2011
Included in operational budgets
December 2011
Included in operational budgets
Minutes of workshops and attendance registers
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Issue Risk assessment
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Action
Responsibility
In order to prepare effectively to respond to emergencies it is necessary that AGA/AGK are sufficiently aware of the possible emergencies that could arise as a result of operational activities and how these emergencies could manifest themselves and take measures to prevent these from occurring. Some risk assessment work has already been undertaken and further risk assessments are planned with the objective of defining risk and identifying key risks (environmental, social, community, supply chain etc), what measures will be put in place to manage these risks, with a risk register as an output of the process.
Each operational area and service area manager with support from Engineering Manager, Environmental manager, OHS manager, Community manager, AGA Senior Vice president for DRC Business unit managers
AGK business units will be required to add the lower order risks, from the abovementioned risk workshop, to their respective risk registers and as part of this process each business unit will be required to facilitate their own individual risk assessments to prepare or update their existing risk registers. •
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Each operational area and service area at AGK will prepare/update a risk assessment of all possible emergencies and evaluate according to: o What could go wrong o Likelihood o Frequency o Previous similar emergencies o Design measures that are in place to prevent or reduce such emergencies o Standard Operating Procedures in place to handle an event o Training of personnel/skills to handle an event o Evaluation of possible receptors o No of community/households that could be affected o Environmentally sensitive receptors o Possibility of simultaneous events o Complications as a result of local conditions (eg impassable roads)
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Progress indicators Record of risk assessment workshops and risk registers
Timing December 2011
December 2011
Resources / Budget Budget to be reviewed based on risk workshops
Included in operational budgets
Business unit level risk registers and assessment
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Issue
Action o o o •
• Corporate Directives and Standard Operating Procedures to address risks
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Responsibility
Progress indicators
Timing
Resources / Budget
Financial implications - what will it cost if it goes wrong Capacity of other stakeholders to assist in responding to an emergency Mechanisms for communicating beyond the boundaries of the mine
The risk assessments will be reviewed at minimum by the following: o Engineering manager o Security manager o Environmental manager o Health and Safety manager o Community Manager
Engineering Manager
Record of review and updates
Annually
Included in operating budgets
December 2012
Included in operational budgets
December 2012 and then Ongoing
Included in operational budgets
AGA and AGK management will review and update the risk assessments at least once a year as well as when there are material changes to the project description.
The following Corporate Directives and Standard Operating Procedures (SOPs) should be prepared: • Directive on Emergency Preparedness and Response • Major Incident Response Plan • Emergency and Fire Plan • Emergency Medical Management Plan. • Risk assessment SOP • Simulations of emergencies for testing and training SOP • Shutdown of operations in emergencies SOP • Hazardous chemical storage, handling and transport SOP • Spill response SOP
Business unit managers with support from Environment Division and Health and Safety Division
•
Engineering Manager
AGA and AGK will collate and review all Standard Operating Procedures that relate to EPR with the objective of confirming their appropriateness in light of the risk assessment above. All SOPs will be reviewed by at minimum the EPR Champion, the operational director for each operational area, as well as representatives from the environmental and safety departments.
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Evidence of SOPs
Records of review of SOPs
August 2011
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Issue
Action
Responsibility
AGK will ensure that for any risks identified above, that do not have associated SOPs, new SOPS will be prepared by the relevant operational manager and reviewed at minimum by the Engineering Manager, and representatives from the environmental and safety departments.
Business unit managers with support from Engineering Manager, and Environmental and Safety Divisions Training division with input from OHS and Environmental Divisions
•
Identify EPR resources and capacity
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Training requirements will be evaluated and appropriate training of all relevant personnel will be provided.
Progress indicators Evidence of new SOPS where relevant
Timing December 2012
Resources / Budget Included in operational budgets
Training plan
December 2012
Budget to be determined by Training Division
Effective response to any emergency situation requires that the necessary equipment, resources and capacity are available at AGA and AGK. Specifically it should be noted that if AGK is to expand its EPRP to incorporate the APELL requirements, dedicated personnel (at least for an initial period) will be required for the purposes of facilitating the external communications, capacity building and training of communities, external stakeholders and individuals who are to play a role in the EPRP. •
AGK will assess current staffing capacity and job functions with a view to identifying where competencies and skills are available and currently underutilized, and/or identifying where additional capacity is required to address responsibilities that currently cannot be addressed due to lack of capacity.
HR with input from Environmental, Security and Safety
Job analysis
December 2012
Budget to be determined by HR
•
AGK will prepare an inventory of the following: o Equipment required and available for EPR, its location and state of repair o Vehicles and other transport facilities available for EPR and whether these are dedicated or not o Communications equipment such as cell phones, loudhailers, notice boards, sirens, etc o Personnel trained in first aid, fire fighting, hazardous chemical clean up and their location/availability on site
Manager: Safety, Manager: Security, Manager HR, Manager: Training
Inventory of EPR equipment and training
December 2012
Included in operational budgets
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Issue
Action • •
Prepare a chemicals and hazardous materials register
Responsibility
AGK will identify what EPR equipment and resources are not available on site and have not yet been budgeted for. AGK will prepare a cost motivation for items that are still required
Identification and risk assessment of hazardous materials that are used on site.
Manager: Safety, Manager: Security, Manager HR, Manager: Training Manager Environment with input from business unit managers
•
AGK will prepare a centralised register of hazardous materials used on site in consultation with all operational areas. The register will include: o Where materials are used o How the materials are stored o Quantities in use o How materials are disposed of o How materials are handled o How materials are transported o The area of influence associated with potential spillages of specific hazmats.
•
AGK will obtain and file material safety data sheets (MSDS), in at least English, French and Swahili, for all chemicals and hazardous materials and will ensure that all personnel that handle chemicals and hazmats, have been trained in the correct handling, transport, use and disposal thereof A summary of MSDSs, will be prepared for each hazardous material and provided to personnel as part of training materials Appropriate signage will be prepared and erected ensuring that relevant international conventions are adhered to with respect to symbols, size, visibility and recognition.
Manager: Environment with support from Training Division
AGK will confirm that all hazmat transporters are aware of and trained in their responsibilities with respect to hazmat transport, and that at minimum the following are in place: o Tremcards (Transport emergency cards) are prepared for each cargo, in
Manager; Supply Chain with support from Training
• •
•
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Progress indicators Gap analysis Budget motivation
Timing December 2012
Resources / Budget Include in capex budget for 2009
December 2012
Included in operational budgets
December 2012
Included in operational budget
Ongoing with each contract
Included in operational budgets
Hazardous materials register
File of MSDSs
MSDSs Signage
Tremcards and training records
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Issue
Action
•
•
Monitoring and measurement programme
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Responsibility
the language that is understood by at least the driver, the destination country and the recipient of the cargo, o Drivers are well trained and equipped for a hazmat spillage, transport, handling and transfer AGK will review and update the hazmat register at least bi-annually
A fully equipped Spill Response Intervention Mobile Unit will be available at AGK at all times with suitably trained personnel to make use of the equipment.
In order to support the commitment of preventative action it is necessary to establish a programme of monitoring and measuring certain parameters to ensure that AGK is timeously aware of conditions that could give rise to an emergency. • AGK will establish a monitoring and measurement programme that outlines the parameters that will be monitored, the frequency of monitoring and the dissemination and actions to be taken relative to the results of monitoring and measurements. • At minimum the monitoring and measurement programme will cover the following parameters: o Levels of liquid in tanks; o Levels of liquid in ponds; o Reagent storage and concentrate ponds; o Weather such as heavy rain events which may influence spillages from ponds; o Pressure gauges and redundant gauges; o Other.
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Progress indicators
Timing
Resources / Budget
and Environmental Divisions Manager: Environment with support from operational departments Manager: Safety
Record of updates
Annually
Included in operational budgets
Evidence of equipment Training records
Ongoing
Engineering Manager with input from Business Unit managers and Environmental Division
Monitoring and measure programme Monitoring records
December 2012
Included in capital and operational budgets Included in operational budgets
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External emergency preparedness and response planning steps Once AGK has developed a sufficient understanding of it owns internal capacity, resources, competencies, risks and requirements in terms of EPR, the company will proceed with the external process which incorporates the community and communications elements of the Plan. Some of these steps can be undertaken in parallel with the internal steps however it would be ideal that AGK has its own EPRP in order to begin with. The external steps focus on providing information to external stakeholders on the potential hazards and measures taken to reduce risks associated with living in close proximity to a mine, review and update the EPR for the local area, increase the mine’s involvement in community awareness and EPR planning, integration of the mine and community plans and involvement of communities in developing, testing and implementing the plans. The external steps have been based on the ten-step APELL process outlined as follows:
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Step 1: Identify the emergency response participants and establish their roles and responsibilities, resources and concerns;
•
Step 2: Evaluate the risks and hazards that may result in emergency situations for the community and define options for risk reduction;
•
Step 3: Have participants review their own emergency plans for adequacy relative to a coordinated response, including the adequacy of communication plans;
•
Step 4: Identify the required response tasks not covered by the existing plans;
•
Step 5: Match these tasks to the resources available from the identified participants;
•
Step 6: Make the changes required to improve existing plans, integrate them into an overall emergency response and communication plan and gain agreement;
•
Step 7: Commit the integrated plan to writing and obtain approval from local governments;
•
Step 8: Communicate the integrated plan to participating groups and ensure that all emergency responders are trained;
•
Step 9: Establish procedures for periodic testing, review and updating of the plan; and
•
Step 10: Communicate the integrated plan to the general community.
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Table 7-2: External emergency preparedness and response planning steps Issue Step 1: Identify the emergency response participants and establish their roles and responsibilities, resources and concerns
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Action
Responsibility
Progress indicators
Timing
Resources / Budget
On the basis of work undertaken by AGK, and SRK with respect to the ESIA, it is already understood that AGK is vulnerable to emergencies in light of the lack of capacity and resources available within the local authorities and communities. AGK will make efforts to establish relationships with the authorities and various other stakeholders with respect to security issues and similar efforts are required for the purposes of the EPRP to ensure that, where possible, the mine’s capacity can be supplemented and in turn, supplement efforts within the area. •
AGK will prepare a checklist of all stakeholders external to the mine that could have a role to play in an emergency. This checklist should be prepared proactively and then reviewed and updated as appropriate in the event of each emergency: o Other mines or industries o Authorities o Service providers o Extension of capacity/relief capacity o Emergency transport facilities o Surrounding communities o Key community representatives in each community
•
AGK will facilitate the establishment of a Local Emergency Planning Coordinating Group (LEPCG). o It is suggested that this LEPCG be piggybacked on an existing communications forum (eg Mongbwalu Forum) at least initially, to make most efficient use of existing structures and relationships. o This committee should have a pivotal role in developing a communityfocused EPRP and should have representation from all parties that in some way have a responsibility for minimising and responding to the effects of emergencies. Participants in the LEPCG should include: AGK Local government Surrounding communities Neighbouring mines NGOs eg PISIPI
EPRP_Final_Aug2011.docx
Engineering Manager with input from Security and manager, Health and Safety manager, Environmental Manager and Community Manager and other Business Units as appropriate Engineering Manager
Checklist of stakeholders and their roles Records of review after each event
December 2011
Included in operational budgets
Minutes of meetings
December 2012
Included in operational budgets
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Issue
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Action
Responsibility
It is recognized that capacity at the local government and community level will be limited and it may be necessary to conduct some initial capacity building exercise with these parties separately in order to develop skills and improve the ability for input to the LEPCG prior to these stakeholders being included in the LEPCG. o AGK’s community relations/liaison officers will assist in communicating the purpose of the Committee to community representatives and provide some initial awareness raising prior to the first committee meeting. This step aims to develop a comprehensive list of risks and hazards and evaluate the impact on the communities. While this step will have already been undertaken from the perspective of AGK as part of the internal risk assessment, this step also provides an opportunity to develop awareness within the communities regarding the potential hazards. It further offers an opportunity to update the risk assessment and broaden AGK’s understanding of community perceptions associated with these risks. •
•
Step 3: Have participants review their own emergency plans for adequacy relative to a coordinated response, including the adequacy of communication plans
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Timing
Resources / Budget
Response teams (eg ISOS)
•
Step 2: Evaluate the risks and hazards that may result in emergency situations for the community and define options for risk reduction
Progress indicators
The risk evaluation (and preventative measures) prepared by AGK will be presented to the LEPCG for discussion. It will be necessary to document perceptions of risk as articulated by community representatives, local authorities and other stakeholders. Given the history of the area with respect to conflict and the current presence of artisinal miners, third party risks will also be evaluated and incorporated into an updated risk assessment.
CLOs
Engineering manager, Manager:Security, Manager: Community, Manager Environment with support from CLOs
Records of capacity building meetings / training materials
December 2012
Record of risk assessment Comments registers
December 2012
Budget to be provided 2011/2012 operational budget
Outline EPRP plan
December 2012
Budget to be provided in 2011/2012 operational budget
Budget to be provided in 2011/2012 opex
While it is a requirement of APELL to have participants review their own emergency plans for adequacy and relevance it is understood that there is currently no capacity within the local authority and community levels to respond to emergencies at all and no emergency plans are expected to be in place. •
The focus of this step will thus be to expand AGK’s EPRP to include an outline plan which covers the preparedness and response of all the stakeholders involved in any emergency. This plan will be written so that it forms a standalone section which can be distributed to the communities and other external stakeholders. At minimum this plan will include the following: o Communication procedures between AGK and the affected
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General Manager with input from Manager: Security, Manager: Community,
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Action
Responsibility
communities and other stakeholders Notification of authorities Criteria for triggering the plan Methods of alerting the public and co-ordinating evacuation using sirens or other warnings, with rehearsed warnings and evacuation procedures o Identification of meeting points and alternative routes o Alarm and emergency signals o Communications equipment that can reach all participants, such as loudhailers, mobile phones, pagers, or short wave radio o Flow diagramme, in a layman format, outlining steps to take in each type of emergency o Cleary defined roles for participants in different areas of response, such as fire-fighting, community protection etc; as well as a list of responsible parties and contact details o Specialised hazard monitoring and training, such as for dealing with chemical fumes or water pollution; o Adequate emergency equipment for spill containment or collection, such as booms and absorbent materials; o Media contacts and a media relations strategy, including relevant descriptive material of the operation o Clear reporting procedures o Alternative drinking water supplies in cases where usual supplies are contaminated; o Rapid test kits for chemical spills; o Readily available information on dealing with chemical hazards; and o Evacuation procedures and local authority roles o Compensation schemes for injury on duty. Once the plan has been drawn up in outline, and any other plans evaluated, the gaps can be identified and responsibilities assigned. This will involve identifying any missing or weak elements or tasks not being covered by any group. The significance of these weaknesses will be discussed in the context of a coordinated response. However, it should be noted that as local facilities and capabilities are currently relatively weak, it will become the responsibility of AGA/AGK to provide the necessary resources to respond to emergencies e.g. fighting certain types of fire or providing sufficient equipment to deal with certain types of casualties that may arise from an accident. o o o
Step 4: Identify the required response tasks not covered by the existing plans
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Progress indicators
Timing
Resources / Budget
Manager Environment
Engineering manager with input from Manager: Security, Manager; Community, Manager Environment
Gap analysis Responsibilities analysis
December 2012
Budget to be provided in 2011/2012 operational budget
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Issue Step 5: Match these tasks to the resources available from the identified participants
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Action
Responsibility
Timing
Resources / Budget
Local capacity is currently very limited and AGK will take responsibility for providing all the necessary equipment and training for any emergencies that relate to its operations or affect its personnel and/or communities associated with the mine. o
AGK will develop a plan for building local capacity including possible options such as: o Training volunteer emergency helpers such as fire fighters and traffic control officers to supplement dedicated skills in these areas. These volunteers may be drawn from the workforce. o Providing first aid training to staff and selected community representatives. o Evacuation training o Clean up training
In the event of an emergency that impacts on several sites at once, it may be necessary to supply sufficient slack capacity and equipment to ensure that no single area is without rapid access to equipment in an emergency. While much of this equipment will hopefully remain redundant, it is appropriate to take a precautionary approach rather than assume it will be possible to share equipment especially basic emergency equipment. o AGK will identify what basic emergency resources are required in each of the communities to deal with emergencies that could affect the communities as a result of AGK operations. These resources could include: o Firefighting equipment o Transport o Cell phones and other communication devices o Masks o Loudhailers and sirens o Flares o Spare water o Basic first aid equipment o Basic clean up equipment o AGK will ensure that this equipment is checked, maintained and if necessary replaced to ensure that all equipment is in working order.
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EPRP_Final_Aug2011.docx
Manager: HR/Training with support from Safety and Environment Divisions
Capacity building and training plan Training records
December 2012
Budget to be included in 2011/2012 operational budgets
Manager; Community
Records of equipment needs analysis Procurement records
December 2011
Included in operational budgets
Safety Manager
Maintenance records
Ongoing
Included in operational budgets
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Issue
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Action
Responsibility
It is considered necessary to ensure that, over a period of time, the capacity of the local authority is built to an extent where emergency services can be provided/supplemented effectively by the local authority and/or professional service providers. o AGK will consider what steps are appropriate to provide support to this process and coordinate with its neighbouring mines to provide appropriate support. o A timeline and target deadline for the provision of this support and handover of responsibilities will be discussed and agreed with the participating local authority bearing in mind that it may be necessary for this to be a long term process and commitment from AGK. Step 6: Make the changes required to improve existing plans, integrate them into an overall emergency response and communication plan and gain agreement
Analysis of support requirements Programme for handover
Timing
Resources / Budget
December 2012
Budget to be provided in 2011/2012 operational budget
Ongoing 2012
Included in operational budgets
The objective of this step is to ensure coordination between the individual EPRPs for the participating stakeholders with respect to coordination of resources and equipment, manpower, capacity and skills. It is expected that the existing mines will have their own plans which can be coordinated and cross referenced and that, basic EPRPs for each community and for the Greater Mongbwalu area will be developed initially at a basic level and will be strengthened iteratively as skills and capacity within the communities and local authority increase over time. o
o
Step 7: Commit the integrated plan to writing (and obtain approval from local governments)
Manager:Security, Manager: Community, Manager: Environment, Manager: Training
Progress indicators
AGK will provide assistance and skills to facilitate the preparation of an overall EPRP for the Greater Mongbwalu area that cross references to the individual EPRPs and will encourage the other mines to assist in a similar manner. This plan will be communicated to all members of the LEPCG and may require some iterative dialogue and amendments to approach agreement.
Engineering manager with support from Manager:Security, Manager: Community, Manager: Environment, Manager: Training
Overall EPRP
Records of communication
The APELL process requires that the EPRP be approved by local government, the communities and other stakeholders. A further objective is to transfer “ownership of the plan” to these parties so that they buy-in and take responsibility for the implementation of the plan. It is unrealistic however to expect that agreement and consensus will take place in the short term given the existing lack of capacity and skills and the objective of this step is thus amended to achieve a level of communication that is sufficient to ensure
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Action
Responsibility
Progress indicators
Timing
Resources / Budget
that the relevant stakeholders are aware of the plan and have had a level of input into the plan. •
•
The overall EPRP will be written up by a small team drawn from the LEPCG. The plan will as far as possible be prepared in the format of a series of flow charts, table and diagrammes which will be made available in both soft copy as well as in a series of posters which can be made available in various public places. AGK will communicate the final EPRP and seek support and comments from: o AGK stakeholders (key personnel, AGA) o OKIMO o PISIDIPI o The DPEM o The mayor of Mongbwalu
EPRP Engineering Manager with support from Manager:Security, Manager: Community, Manager: Environment, Manager: Training
AGK will establish a programme for communication and comment from other stakeholders over a period of time that fits with the programme for capacity building of stakeholders. This process should in no way compromise AGK’s PreAPELL steps or the ability to respond to emergencies according AGK’s EPRP. It will be necessary to communicate the EPRP to all participating groups and specifically to those who will have responsibilities in terms of the EPRP. In addition to communicating the plan, it will be necessary to train participants and emergency responders with respect to their individual responsibilities. •
•
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AGK will prepare a series of easy to understand poster presentations supplemented with simple scenarios and role playing to demonstrate the way in which the EPRP will work. The role playing will be used both as a communication tool as well as a training and testing tool. Other communication mechanisms could include toolbox talks and industrial theatre. A communication and training programme will be established outlining who needs to attend the sessions, a schedule of sessions, time commitments, and resources required. This training programme will recognize the need for refresher training as well as induction training in addition to specialized training for specific roleplayers in the EPRP. The training programme will also extend to include personnel, contractors, suppliers and other parties that may have an influence on successful implementation of the EPRP.
EPRP_Final_Aug2011.docx
Included in operational budgets
December 2012
Budget to be provided in 2011/2012 operational budget
Comments register
Communication plan and records of communications
•
Step 8: Communicate the integrated plan to participating groups and ensure that all emergency responders are trained
December 2012
Manager: Training
Training and communication plan Training records Posters and other training tools
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Issue
Action • •
Step 9: Establish procedures for periodic testing, review and updating of the plan
Responsibility
AGKs training department will devise the training materials and criteria for completion of training. A programme for refresher training will also be prepared by the AGK training department.
It is the objective of any EPRP to be prepared for, and in so doing prevent emergencies from occurring. However for this to happen effectively it is necessary that AGK: • test the plan and responsible parties abilities to implement the plan and effect any other actions that are required to maintain commitments to prevention and preparedness, • review the plan for relevance, • update the plan to ensure it is current, • debriefing and updating the plan in light of experience from previous emergencies. •
•
• Step 10: Communicate the integrated plan to the general community
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AGK will establish a programme for periodically testing the plan to ensure that skills and training remains current. At minimum AGK will test the plan at least biannually and in some cases limited scenarios and role playing as training exercises may be required on a more frequent basis to keep skills refreshed and current, AGK will commit to reviewing the EPRP at least annually and/or when there are changes to the project, the project environment and/or the socio-economic context within which the mine operates to ensure that the EPRP remains relevant in terms of the operational risks and scale of the project. AGK will in relation to the above, update the plan to reflect changes as and when these occur.
Progress indicators
Timing
Resources / Budget
Refresher training plan Training records
Engineering Manager with support from Manager:Security, Manager: Community, Manager: Environment, Manager: Training
Records of testing, role playing and scenario planning
December 2012
Annually
Budget to be included in operational budgets from 2012 onwards
Records of review Ongoing Records of updates and changes
The APELL process was specifically developed to increase awareness and preparedness for emergencies at a local level and focuses heavily on communicating and empowering communities to prepare for and respond to emergencies that may affect them. For any EPRP to be effective it is necessary that all stakeholders are well trained in and understand the plan so that they can respond confidently and timeously. The objective of this final step is to communicate the EPRP to the general community, ie members of villages surrounding the mine as well as members of
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Action
Responsibility
villages and towns located along any transport routes that AGK and/or its suppliers may use. The communication strategy needs to recognize various communication needs and various audiences within these communities and structure the communication methods accordingly. •
•
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AGK will develop a communication strategy for the communication of the EPRP to the general public. This communication strategy will: o Outline the methods of communication o The target audiences including children, women and the elderly o A schedule for communication that recognizes availability of community members o Refresher communications recognizing that community members may need to be reminded of the EPRP and its importance on the assumption that emergencies will be few and far between. AGK will ensure that its communication methods are appropriate to the target audiences and that a mix of methods is used to convey the messages associated with the EPRP including: o posters, o pictorial/cartoon, o community/industrial theatre o storytelling, o signage and symbols
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Manager: Community
Manager: Training and Manager: Community
Progress indicators
Timing
Resources / Budget
Communication strategy Records of communications
December 2012
Budget to be provided in operational budget from 2012
Records of communication tools Attendance registers
December 2012 and ongoing
Included in budget from 2012 onwards
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Conclusion The Mongbwalu mine project is located in an area that is isolated in terms of accessibility, levels of infrastructure and social services. The area has been historically characterised by violence and tension and as a result is now experiencing severe levels of poverty. The key stakeholders in the area lack the capacity to prepare for or respond to emergencies of any nature. AGK has taken some steps to prepare itself for emergencies of an occupational health or security nature for its exploration phase activities; however limited steps have yet been taken to prepare for emergencies that could pose a risk to the biophysical and social environment. This plan lays out the steps that AGK will take in order to position itself for emergency situations that result either form AGK’s operational activities or third party activities that pose a threat to AGK and its employees. The process that is outlined in this document is based on the APELL process which is an internationally upheld good practice guideline for preparing for and responding to emergencies that could affect both the mine’s activities as well as the communities in the vicinity of the mine.
Prepared by
Briony Liber Principal Environmental Scientist
Reviewed by
Donald Gibson Project Reviewer
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References •
Anglo Gold Ashanti, 23 June 2009. Chemical Management Standard.
•
Anglo Gold Ashanti, 23 June 2009. Waste Management Standard
•
AGK Camp Induction Sheet (Exploration phase) (Undated)
•
AGK Induction for expatriates arriving in the DRC (Exploration phase) (Undated)
•
AGK Occupational Health and Safety Plan (Exploration phase) (Undated)
•
AGK Emergency Evacuation Plan (All phases), 2010
•
EPS, September 2010. Hazard and Operability Study for Mongbwalu Project – Metallurgical Plant (Operations phase)
•
IFC Performance Standards: PS 3 and PS 4
•
IFC Environmental Health and Safety Guidelines for Mining
•
UNEP/ICMM Good Practice Guide for Awareness and Preparedness for Emergencies at Local Level (APELL)
•
International Cyanide Management Institute, October 2009. International Cyanide Management Code.
•
Mining code.
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SRK Report Distribution Record Complete this form and include it as the final page for each copy of the report produced.
Report No.
414878/ EPRP
Copy No.
Name/Title
Company
Copy
Date
Charlene Wrigley
AGA
1
August 2011
SRK Library
SRK
2
August 2011
Authorised by
Approval Signature:
This report is protected by copyright vested in SRK Consulting (South Africa) (Pty) Ltd. It may not be reproduced or transmitted in any form or by any means whatsoever to any person without the written permission of the copyright holder, SRK.
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