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Page 1: HPCL-Mittal Pipelines Limited - Indian Coast Guard€¦ · HPCL-Mittal Pipeline Ltd. Oil Spill Contingency Plan(OSCP) 9213-081-HSE-006-00002 Revision 03 Issue Date 14-JUL-2016 Next
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Format No. 9111-000-PCT-007-00006 Rev-00

HPCL-Mittal Pipelines Limited Mundra – Bathinda Pipeline Oil Spill Contingency Plan (OSCP)

9213-081-HSE-006-00002

03 14-JUL-2016 IFI Issued for Implementation Ashok Tiwary (Dy. M-Pipelines) Partha Chakraborty (DGM – Pipelines) Pawan Agrawal (GM - Pipelines)

REV DATE STATUS REVISION LIST PREPARED CHECKED APPROVED This document is confidential. Neither the whole nor any part of this document may be disclosed to any third party without the prior written consent of HPCL-MITTAL ENERGY LTD. The copyright of this document is vested in HPCL-MITTAL ENERGY LTD. All rights reserved. Neither the whole nor any part of this document may be reproduced, stored in any retrieval system or transmitted in any form or by any means (electronic, mechanical, reprographic, recording or otherwise) without the prior written consent of the copyright owner.

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REV DATE REV DETAILS 00 15-DEC-2012 First Issue for implement

01 31-DEC-2014 Overall plan revised in line with NOSDCP requirement

02 31-DEC-2015 Overall plan revised in line with NOSDCP requirement

03 14-JUL-2016 Overall plan revised in line with NOSDCP requirement

Note:

The Owner of this document is department Marine at Mundra. Please contact GM-PL for any clarifications, updates or revisions.

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TABLE OF CONTENTS

CONTENT PAGE NO.

STRATEGY

1. 1.0 Introduction 7

1.1 Authorities and Responsibilities 9 1.2 Coordinating Committee 10 1.3 Statutory Requirements 11 1.4 Mutual Aid Agreements 11 1.5 Geographical Limits of Plan 11 1.6 Interface with ROSDCP and NOSDCP 12

2. Risk Assessment 13

2.1 Identification of activities and risks 13 2.2 Types of oil likely to be spilled 14 2.3 Probable Fate of Spilled oil 15 2.4 Development of Oil spill Scenarios Including Worst Case Discharge 16 2.5 Shoreline Sensitivity Mapping 21 2.6 Shoreline Resources, Priorities for Protection 22 2.7 Special Local Considerations 22

3. Response Strategy 23

3.1 Philosophy and Objectives 23 3.2 Limiting and Adverse Conditions 23 3.3 Oil Spill Response in Offshore Zones 24 3.4 Oil Spill Response IN Coastal Zones 24 3.5 Shoreline Oil Spill Response 25 3.6 Storage and Disposal of Oil and Oily Waste 25

4. Equipment 26

4.1 Marine Oil Spill Response Equipment 26 4.2 Inspection, Maintenance and Training 26 4.3 Shoreline Equipment, Supply and Service 27

5. Management, Manpower and Training 28

5.1 Crisis Manager and Financial Authorities 28 5.2 Incident Organisation Chart 29

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5.3 Manpower Availability (On site, on call) 32 5.4 Availability of Additional Manpower 33 5.5 Advisors & Experts- Spill response, Wild Life & Marine Environment 33 5.6 Training / Safety schedules and Drill / Exercise Programme 34

6. Communications 38

6.1 Incident Control Room and Facilities 38 6.2 Field Communications Equipment 39 6.3 Reports, Manuals, Maps, Charts and Incident Logs 39

ACTION AND OPERATIONS

7. Initial Procedures 41

7.1 Notification of Oil Spill to Concerned Authorities 41 7.2 Preliminary Estimate of Response Tier 41 7.3 Notifying key team members and authorities 41 7.4 Manning Control Room 41 7.5 Collecting information (oil type, sea /wind Weather forecast, aerial 41

Surveillance, beach reports) 7.6 Estimating fate of oil slick (24, 48 & 72 hours) 42 7.7 Identifying resources immediately on risk, informing parties 42

8. Operations Planning 44

8.1 Assembling Full Response Team 44 8.2 Identifying immediate response priorities 45 8.3 Mobilising immediate response 45 8.4 Media Briefing 45 8.5 Planning medium term operations (24, 48 and 72 hour) 45 8.6 Deciding to escalate response to higher tier 47 8.7 Mobilising or placing on standby resources required 47 8.8 Establishing field command post and communications 48

9. Control of Operations 49

9.1 Establishing a management team with experts and advisors 49 9.2 Upgrading information (Sea / Wind /Weather Forecasts, Aerial 49

Surveillance, Beach Reports) 9.3 Reviewing and Planning Operations 49 9.4 Obtaining Additional Equipments, Supplies and Manpower 50 9.5 Preparing daily incident log and management report 50 9.6 Preparing operations accounting and financial report 51 9.7 Preparing releases for public and press conferences 51 9.8 Briefing local and government officials 51

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10. Termination of Operations 52

10.1 Deciding Final and Optimal Levels of shoreline Clean-up 52 10.2 Standing down Equipment, Cleaning Maintaining & Replacing 52 10.3 Preparing Final Detailed Report 52 10.4 Reviewing Plan and Procedures from Lessons Learnt 52

DATA DIRECTORY - APPENDICES

Appendix-01 Area of Operation – SPM and Adani Port lay out 55 Appendix-02 Emergency response Organisation 56 Appendix-03 Weather Condition 57 Appendix-04 Statutory requirements- Relevant agreements 60 Appendix-05 Sensitive Area Map 64 Appendix-06 Shore Clean-up Techniques Exposed Tidal Flats 66 Appendix-07 Oil Spill Response Decision Making Tree 67 Appendix-08 CPCB Approved Oil Recyclers 69 Appendix-09 List of OSR offshore equipment 73 Appendix-10 Information System Flow Chart 74 Appendix-11 Manpower Details for OSR Team 75 Appendix-12 Training and Competency 76 Appendix-13 HSE Policy of HMPL 77 Appendix-14 Emergency Contact Numbers 78 Appendix-15 Oil Spill Report Form 81 Appendix-16 POLREP 82 Appendix-17 Daily Incident Log 83 Appendix-18 Personal Log Form 85 Appendix-19 Tiered Response Concept 86 Appendix-20 Communication Channels 87 Appendix-21 Initial Press Statement Form-Pollution Incident 88 Appendix-22 NOSDCP Circular No. 03/2013 (Certificate of Endorsement) 89 Appendix-23 NOSDCP Circular No. 02/2015 (Guidelines for Net 90

Environmental Benefit Analysis) Appendix-24 Mutual Agreement between HMPL & Adani Port 97 Appendix-25 Contingency Planning Compliance Checklist (Appendix E5) 99 Appendix-26 Abbreviation 103

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STRATEGY

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1. INTRODUCTION

ABOUT HPCL-MITTAL PIPELINES LIMITED

HPCL-Mittal Pipelines Limited (HMPL) is a subsidiary of HPCL-Mittal Energy Limited (HMEL), a joint Venture company of Hindustan Petroleum Corporation Limited (a Government of India, Public Sector Enterprise) and Mittal Energy Investments Pvt Ltd., (a 100% subsidiary of Mittal Investments S.a.r.l, Luxembourg).

HMPL management implements the receipt, storage and cross country transportationfacilities of crude oil at an approximate cost of Rs. 3183 crores (as on 2011).

Crude Oil Terminal (COT) at Mundra is bound by the following coordinates:

A. 22o 47’ 34.50” N, 69o 41’ 31.57” E, B. 22o 47’ 56.18” N, 69o 41’ 32.19” E, C. 22o 47’ 33.38” N, 69o 42’ 16.18” E, D. 22o 47’ 54.82” N, 69o 42’ 26.70” E.

Offshore/Onshore Pipeline connecting SPM to COT approx. 16 km ( 10.089 km offshore &6.285 km onshore ) with Landfall Point at approximate coordinates of 22° 45' 07.098" N & 69° 40' 54.726" E and terminating within COT boundary at approximate coordinates 22° 47' 45.451" N 69° 41' 32.670" E.

Mundra – Bathinda Pipeline and associated/allied facilities (MBPL) are running along the length of about 1012 km

Crude Oil Terminal (COT) has 14 tanks, having total capacity of 840000 m3 and is connected to SPM with underground and subsea pipeline having diameter of 48 inches.

Very large Crude Carriers (VLCCs) with capacity of as high as 320,000 DWT and as small as 60,000 DWT capacity are berthed at Single Point Mooring (SPM) and crude is pumped by tanker’s pumping facilities through SPM to COT through pipelines. The flow rate is maintained between 6300 to 9550 m3/hr to storage tanks at Crude Oil Terminal (COT).

HMEL SPM Terminal

Position 220 40.88’ N, 0690 37.48’ E Light Colour White Max. DWT 320000 TonsMin. DWT 80000 Tons Max. Draft 23 Mtr.

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Min Draft As required by MARPOL Max. LOA 345 Mtr. Min. LOA 185 Mtr. Beam 60.1 Mtr. General Compliance of vessels = As per OCIMF Bow Mooring 02 nos. Chain stoppers (tongue type/hinge bar type only), Arrangements capable of accepting 76mm chain and with SWL 200 MT

(valid certificate to be provided) Bollard Strength at stern 54 MT Manifold Crane SWL 15 Tons Cargo Manifold Size 16”X2 Nos. Max. Flow Rate 9772 m3 per hour Max. Pressure at Manifold 10 Kg/cm2

TANKER OPERATION

The Pilots of Mundra Port bring the tanker near SPM, and the tanker mooring with SPM is carried out by fastening the mooring ropes with the tanker. There are two strings of floating hoses of 24’’ diameter at the Buoy end, subsequently stepwise reducing to 16” diameter at tanker end. These are lifted by the tanker’s crane and connected to tanker manifold. In absence of tankers, these floating hoses remain floating in the sea. At the end of the strings, butterfly valves are used to blind the line to avoid spillage of oil trapped in the pipeline, when not in operation. Once the floating hose strings are connected to the tanker, the system is ready for discharge of cargo through SPM system.

Before commencement of discharge of the tankers, ullaging of the tanker is done as per standard procedure. Meanwhile shore tanks at COT are aligned by opening tank valves for receipt of cargo in the tanks. The inlet and outlet valves of the shore tanks are motor operated and can be closed within five minutes in case of any emergency or after the discharge of the tanker is over. Mundra Port is providing the tug for pullback operation to avoid tankers overriding the buoy, hoses etc. to prevent damage to the buoy, pipeline and consequent oil pollution. Further during the operation of the tanker, there is a constant watch on the SPM system and the connected hoses for any leakage or burst, and the operating parameters are kept well within the designed limits besides observing all safety aspects concerning tanker, buoy and its accessories.

The work of connecting, disconnecting hoses and repair of lines has been outsourced to an external expert agency. During discharge operations technical personnel from following agencies are always available:

i) Mundra Port

ii) HPCL-Mittal Pipelines Limited

iii) Operation & Maintenance Contractor

iv) Crude Oil Tanker

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Isolating valves have been provided for isolation of the floating hose strings and under buoy hose strings. They are used in any emergency arising out of failure of hose or burst of hose during operation to prevent oil loss, pollution and to sustain operation through the other strings. Thus by meticulously following the international marine standards of operations and maintenance the entire tanker discharge operation is kept totally oil spill free.The entire off-shore facilities are subjected to stringent inspection checks as per Oil Companies International Marine Forum (OCIMF) guidelines and rigorous preventive and scheduled maintenance for the upkeep of the facilities/equipment in order to avoid any unforeseen instances of hose burst, leaks or any other such eventualities which may result in either small or large scale oil spills in the ocean.

Taking into account the intrinsic importance of the offshore operations HMPL has commissioned services of M/s National Institute of Oceanography (NIO), Goa for carrying out Risk Assessment & Oil Spill Contingency Plan. While charting the Disaster Management Plan, the findings and recommendations of NIO have been given due consideration.

1.1 AUTHORITIES AND RESPONSIBILITIES

The Management Committee of HPCL- Mittal Pipelines Limited (HMPL) has allocated following authorisation and responsibilities: a. The duties of Incident Controller (IC) will be carried out by the General Manager

Pipelines. He will co-ordinate all the activities offshore and onshore as well. He would also coordinate and supervise the response activities along with the Emergency Control Team (ECT), which will co-ordinate all response activities.

b. HMPL OSR Team is designated as On Scene Commander (OSC). The OSC is responsible for coordinating the on-site tactical response to an oil spill emergency.

c. ECT will be located atHMPL Crude Oil Terminal Conference Room and will co-ordinate the strategic response and mobilization of equipment, materials, services and technical support as required to support the offshore resources and will manage follow up actions.

d. The Emergency Response Team (ERT’s) will report to OSC for all response related activities from the time the response has started & response has been closed down.

e. Immediate response to an oil spill is carried out by the Offshore Emergency Response Team which is nearest to the location of the spill.

Emergency Response Teams (ERTs)

In the event of a significant offshore oil spill, there will be requirement for continuous monitoring for working out strategies involving recovery and control. When the spills threaten to reach shore or sensitive recovery sites, the situation will call for diversion and recovery and in worst cases, will require clean-up actions as well. The teams to perform these tasks are:

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Offshore Response Team comprise of :

a. On Scene Commander ( OSC ) b. Offshore Emergency Response Teamc. Master of Vessel and its crew.

Onshore Response Team comprises of:

a. On Scene Commander (OSC) b. On shore Emergency Response Team c. Sufficient numbers of workers. d. Security Personnel

Both the onshore and offshore teams, under the guidance and supervision of OSC, will operate the equipment & devices on board OSR vessels. Additional support vessels with trained manpower will also be available for helping in deployment of OSR equipments. These personnel will be deployed for handling oil spill scenarios both, offshore as well as Onshore/Beach Cleaning operations onshore, passing and receiving of lines for deployment of Booms, Anchoring and deployment of shore sealing Booms, Recovery &Disposal of oil etc.

All the OSR Equipment for offshore response are to be placed on tug and for tackling shore cleanup activities, will be stored at OSR storeroom at HMPL Crude Oil Terminal premises.

1.2 COORDINATING COMMITEE

All the senior officers of different departments form the coordination committee the committee is headed by GM Pipelines and operation the members are from those departments, which have direct bearing on oil spill response operations. The committee members are:

(i) General Manager Pipelines (ii) Dy. General Manager Pipelines (iii) Manager Operations (iv) DM &Asst. Manager Marine (v) Safety Officer(HSE) (vi) Manager Maintenance& Manager SCADA (vii) Dy. Manager Finance (viii) Dy. Manager Administration (ix) Security Officer

Generally all above will meet periodically for training, exercises or any other policy discussion / decisions for normal activities. These members coordinate with outside agencies for general OSR activities during normal times, and at the time of Oil Spill Emergencies form the Emergency Control Team.

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The details about the committee, is covered in chapter 5.

1.3 STATUTORY REQUIREMENTS

As per Navigational Safety Ports Committee (NSPC), and NSB Report 2013, all ports and as per MoP&NG, all petroleum companies are required to be ready for any oil spill response eventualities in their area of operation.

This is also further clarified in National Oil Spill Disaster Contingency Plan (NOS DCP) 2014 of the Indian Coast Guard, August 2014. Details of international and national regulations are placed at Appendix – 4.

This oil spill contingency plan is for Tier I spillage in line with Govt. Norm. (Appendix 19)

1.4 MUTUAL AID AGREEMENTS

HPCL-Mittal Pipelines Limited, Mundra has Mutual Aid Agreements with Adani Port & SEZ for Offshore Operation. MoU between HMPL & Adani Port is reflected in Appendix-24. Adani Port & SEZ PR Equipment list are attached S No Details of Equipment Quantity 01 Canadyne Fence Boom Canadyne Boom Reel Model

7296/8496,Canadyne Power Pack DH 10Y-1,Single control, for driving Boom Reel) Towing bridles and Tow Lines)

255 Mtr

02 Lamore side Collector system(Side collector LSC-3 C/2300 (01C02-P5336)oil Transfer pump GT A-50 (03B03-P643),Oil Transfer Hose set for GTA 50 H(03B03-P1264) JIB manual LJM 640 (02C02-P1248)side sweep and Jib fitting Bar (02B03-P1488) control stand, 02 valve (03A01-P1692)

02 Set

03 Lamor Minimax 12 (skimmer) with Portable Pump 02 Set 04 Boat sparay 50DF-TS (Portable Dispersant spray system,

Set of 2xAFEDO 30 Even Drop, out Nozzle Assemblies, Flow control, Module and all necessary Hoses, and fitting)

01 Set

05 OSD 10000 Ltrs 06 Floating Tank (25 M3) 01 No 07 1000 I portable Dispersant Storage tank 01 No 08 Tugs 14 Nos 09 Boats, Tug Khusboo or equivalent Boat Anjali or equivalent 2 Nos.

1.5 GEOGRAPHICAL LIMITS OF PLAN

This SPM is located off Mundra Port at coordinates 22° 40' 53.596" N, 69° 37' 28.267" E in Gulf of Kutch, India, About 10.089 km from Adani Port and 16 km from Crude Oil

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Terminal. The operating port (Adani Port) is located on North-East coast of India in Gulf of Kutch, about 60 Km south-west of Kandla Port. This Port is the largest private Port of India. The jurisdiction of Adani Port falls under the Gujarat Maritime Board, which in turn comes under Director of Ports (minor ports), Gujarat Government. Liquid cargo is unloaded through pipelines running along the jetty.

a) Dynamic physical process with high tidal amplitude, strong current &good

circulation.

b) Healthy water quality with good DO, low nutrients and normal PHc.

c) Sediment quality is comparable and does not indicate any enrichment.

d) Moderate phytopigments (av1.5 mg/m3)andphytopopulation.

e) Mangroves represented by Avicenniamarina but absent at SPM site.

f) Good secondary (zooplankton) production.

g) Low sub-tidal and high intertidal macrobenthic standing stock.

h) No large commercial fishing operation at SPM site.

i) Does not sustain reef building corals.

j) No endangered species.

The COT is well connected to State Highways; there is no hindrance in movement of cargo to any part of the country by road. However the crude oil is transported to refinery through underground pipeline.The nearest major port is Kandla.

1.6 INTERFACE WITH ROSDCP AND NOSDCP

This plan should be used in conjunction with the following documents:

i) HMPL’s, Emergency Response Plan ii) National and Regional Oil Spill Disaster Contingency Plans of the Coast Guard.

DOCUMENT HOLDERS

The Oil Spill Contingency Plan forms an integral part of the HPCL- Mittal Pipelines Limited, Mundra. It is a Controlled Document to which only authorised amendments/ revisions are to be made.

All changes, amendments and revisions etc. has to be carried out in line with the Company’s Document Control Procedures.

S.N. Document Holders Copy No.

1. General Manager Pipelines 1 2. Dy. General Manager Pipelines 2 3 Manager Operation 3 4 Manager Maintenance& Manager SCADA 4 5. Dy Manager Marine 5 6. Safety Officer(HSE) 6

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7 Security Officer/HL Officer 7 8 HMPL OSR Team (OSC) 8 Spare 9-10

As per the provisions of NOSDCP, this OSCP will be vetted by Indian Coast Guard before distribution.

2. RISK ASSESSMENT

The quantity of spills is difficult to estimate since they occur accidentally at the SPM/Oil terminals. The normal loading/unloading operations of crude oil / petroleum products at SPM’s are designed and constructed to be leak proof for achieving zero spill situations.

2.1 Identification of activities and Risks

The various situations related to Single Point Mooring (SPM) off Mundra that may lead to the oil spill are given below:

Hose failure at SPM during unloading of crude oil Leakage from the sub-sea pipeline running from SPM to LFP Collision/grounding of the tanker in the vicinity of SPM Leakage from the pipeline on the land connecting to COT Drifting and breaking away of the tankers from the SPM and anchorages Damage to the tanker due to high tidal waves, earthquakes, tsunami etc.

2.1.1 EXPECTED SPILL QUANTITIES

2.1.2 Oil spill may vary from a small quantity from accidental spill from tankers to several thousands of tonnes of oil during other unexpected situations. However, it is required to have a fair understanding of the risks and probability of spills arising out of its operations and their consequences due to movement and landing along the coast.

2.1.3 The exact quantity from the above incidents is difficult to predict due to the variations in operating conditions and the length of risk exposure. The maximum risks associated with the events have been considered while devising the oil spill contingency plan. The worst spill scenario shall be the spillage occurring at the water surface.

The following scenarios are taken into account considering the above spill risks and the guidelines for development of oil spill contingency plan.

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(A) Operational Leakages

Spill at SPM: (158 t of crude oil at the pumping rate of 9772 m3/hr of crude oil for 1 minute)

In the present study, 158 t of crude oil at the pumping rate of 9772 m3/hr has been considered for assessing the higher risk.

Probability of loading arm failure during operations is very low and in case of any break down or failure; it can be controlled well within 1 minute. The Marine Breakaway coupling which is fitted in both loading arms (floating hose string) will get activated in less than one minute time and will be stopped crude oil spill from loading arms. Accordingly, the quantity of crude oil spill have been estimated to be 158 t, considering the response time as 1 minute.

Leakage from sub-sea pipeline running from SPM to LFP : (79 t of crude oil at the pumping rate of 9772 m3/hr for 30 seconds)

Failure during operations is very low and in case of any leakage in the sub-sea pipeline can be controlled well within 30 seconds. Accordingly, the quantities of crude oil have been estimated to be 79 t, considering the response time as 30 seconds.

Spill due to Collision/Grounding

Spill at SPM : (1000 t of crude oil)

In the present study, the amount of spill likely to occur due to collision/grounding is roughly taken as 1000 t based on assumption of partial damage to the oil compartment of the tanker. However, with the concept of double hull tanker, the entire cargo compartments are protected by another hull. Thus, cargo spillage due to collision/grounding is remote.

Leakage from Pipeline Corridor on the Land - LFP to COT

(79 t of crude oil at the pumping rate of 9772 m3/hr for 30 Second)

Failure during operations is very low and in case of any leakage in the pipeline corridor can be controlled well within 30 seconds.

Other mentioned risks such as drifting and breaking away of the tankers from the SPM and anchorages, High tidal waves, Earthquakes, Tsunami, are very rare incidents (as observed from the data base). However, the amount of oil spill likely to cause from these incidents is also assumed to be as 1000 tonnes similar to that of collision/grounding.

2.2 TYPES OF OIL LIKELY TO BE SPILLED

The types of oil carried by the vessels and likely to be spilled are:

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Chances of other oil being spilled are also not ruled out, because the finished product includes the commercial derivatives of hydrocarbons and edible oil as well.

2.3 Probable Fate of Spilled Oil and Effects

The spilled Crude oil undergo a number of physical and chemical changes (weathering). The major weathering processes are spreading, evaporation, dispersion, emulsification, dissolution, oxidation, sedimentation and biodegradation. The last three processes are long-term processes, which determine the ultimate fate of the Crude oil. The remaining processes are the most important during early stages of the spill, especially in coastal and inshore areas.

S No. Types of Oil

1. Arabian Medium

2. Arabian Heavy

3. Arabian Light

4. Arabian Ex-light

5. Khafji

6. Kuwait Export

7. Basrah Light

8. UMM SHAIF

9. Forozan Blend

10. MASILA

11. Gharib Blend

12. Castilla

13. New Lokele Crude14. Ebok

15. Ratawi16. Eocene17. Sirri18. Nawroz19. Oman export blend20. Qtar Marine21. Enfield22. Pazflor23. Usan24. Upper Zakum25. Jubrate26. Vasconia27. Maya28. Heavy Fuel Used by Vessel

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2.3.1 Evaporation

The rate and extent of evaporation depends primarily on the volatility of the oil. In general terms, the oil components with a boiling point below 200o C evaporate within 5 to 6 hr under tropical conditions. Spills of refined products such as HSD, kerosene and gasoline evaporate much faster than Crude Oil and Fuel Oil. Analysis suggests that nearly 40% volume of oil will be evaporated during its movement in post monsoon period.

2.3.2 Emulsification

Several oils have tendency to absorb water to form water-in-oil emulsions thereby increasing the volume of the emulsified mass by a factor of 3 to 4. Oils with asphaltene contents greater than 0.5% and higher percentage of Wax tend to form stable emulsions often referred to as ‘Chocolate mousse’ while those with less asphaltene disperse faster. The rate at which an oil is emulsified is largely a function of sea state though viscous oils absorb water slowly. In turbulent sea conditions, low viscosity oils can incorporate as high as 80% water by volume within 2 to 3 hr.

2.3.3 Dissolution

The heavy components of crude oil are virtually insoluble in seawater while lighter compounds, particularly aromatic hydrocarbons like benzene and toluene are slightly soluble. Hence levels of dissolved petroleum hydrocarbons rarely exceed 1 ppm following a spill. Evidently, dissolution does not make a significant contribution to the removal of oil from the sea surface.

2.4 Development of Oil Spill Scenarios Including Worst Case Discharge Spill Scenario

2.4.1 Hose Rupture

Great care has been taken in the Design to provide double carcass hose so that any rupture will not result inOil Spill. Other precautions as per OCIMF Guidelines are taken in the Design.

In the Event of Oil spillage during discharging of crude oil from Tanker to COT will be limited to less than 16 tonnes due to hose failure. The spilled quantity has been worked out considering the period of 9 seconds require for actuation of Marine Breakway couplings. The past failure data show that 91% spillage occur during loading and discharging operations.

2.4.2 Submarine Pipeline Failure

As the submarine pipeline system is a feeding lifeline for the Refinery, a number of Design Provisions have been provided to safeguard the Pipeline and Prevent failures. These include Provision of Extra Corrosion Allowance in the Wall Thickness, effective

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Cathodic Protection, Protective external Coating, Concrete weight Coating and burying the pipeline below the Sea bed.

The probability of failure of pipeline is the order of 3 x 10¯4 km¯1 year ¯1 as per literature data used in Risk Analysis Studies. The length of submarine pipeline is 7.7 km. The total probability of occurrence of pipeline failure will be 2.31 x 10¯3 (7.7 x 3.0 x 10¯4) year ¯1.The chances of occurrence of pipeline failure will be ½.31 x 10¯3 i.e. once in 432 years. The frequency of submarine pipeline failure is Negligible.

2.4.3 Ship – Ship Collision and Ship Grounding

Ship-Ship collision is totally avoided by providing separate SPM anchorage and piloting the vessel to the Buoy with the Help of escort tug. Ship grounding is taken care in locating the SPM swinging circle in water depth in excess of 32 Meters and with a safe navigational approach to the SPM.

In case of an Oil Spill the oil will be recovered by activating the “Oil Spill Contingency Plan”.

As explained earlier that maximum spillages occur during loading/ and discharging operations. It has been estimated that about 91 % spillage takes place during these operations. Balance 9% spillage take place during ship – ship collision, ship grounding and ship berthing contact. In case of SBM, the ship berthing contact is ruled out. In order to study quantitatively, the Port of London Authority probability data of ship- ship collision and ship grounding (all type of tanker including VLCC)has been analyzed. As per these data, following are probabilities of various events:

a) Ship – ship collision probability = 0.50 x 10¯4 per transit b) Ship grounding probability per transit = 0.3 x 10¯4

c) Probability of spillage during collision = 2 x 10¯2

d) Probability of spillage during ship grounding = 2 x 10¯2

e) As a normal practice, these probability data are used in Risk Analysis Studies. f) Total probability of spillage due to ship collision per transit = 1.0 x 1.0-6

g) Total probability of spillage due to ship grounding = 0.6 x 10¯6 per transit

Assuming a VLCC size of 320,000 DWT calling at SBM, the number of VLCCs for 9.0 Million Tons/ Annum crude handling works out to be 36 in a year. Hence, probability of spillage due to ship collision will be 3.6 x 10¯5 per year. In other words, there are chances of oil spillage due to ship collision once in 27000 (1/3.6 x 10¯5) years. The chances of oil spillage due to ship grounding will be once in 46000 years. Hence, chances of large spills are ruled out.

From the failure frequency estimation for different failure scenarios explained above, the most likely failure case will be hose rupture. The detailed Disaster Management Plan has been prepared for this scenario.

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2.4.4 Disaster Management Plan (DMP) For Hose Rupture

2.4.5 The chronological activities shall be:

The unloading operation shall be stopped immediately.

The personnel at SBM will notify time, position, source and cause of spill to control room of MPSEZL and COT.

The roles and responsibilities of the controller, who will be Incharge of SBM and COT will be as follows:

To assist the ‘On Scene Commander’ designated Coast Guard and his team to reach the spill site.

To assess the scale of spillage and inform all statutory authorities namely Gujarat Pollution Control Board (GPCB), Gujarat Maritime Board (GMB), Gujarat Adani Port Limited, Collector, Kutch District, Coast Guard, District Health Superintendent, Superintendent of Police, Kutch District, Regional Transport Officer, Local Customs, etc.

To mobilize oil spill combating equipment to the site of spillage. Since the location of SBM is about 7.5 km from shore, therefore, coast guard has

to recover oil as per National Oil Spill Disaster Contingency Plan and HMPL will provide all manpower assistance and equipments.

The recovered oil in the oil recovery barge will be sent to oil reception facility. The details of Oil Spill Contingency Plan are covered in reply of query (xiv).

2.4.6 Facilities:

The following equipment will be available with HMPL/MPSEZL for tackling Oil Spills:

Mechanical oil skimmer Boom around SBM during discharging Chemical dispersant with spray system Oil recovery barge Salvage pump to transfer recovered oil from barge to COT tanks

2.4.7 In addition to the above equipment, OSR equipment are also available in Kandla Port at the disposal of Coast Guard.

2.4.8 The following marine fleet will be available with HMPL for operation and maintenance of SPM Terminal through O&M Contract which can also be utilised to recover spilled oil Tug / Supply Boat / Line Boat Maintenance Vessel with ‘A’ Frame.

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Development of Oil Spill Scenarios Including Worst Case Discharge

Pre monsoon

During this period, crude oil of approximately 35% spilled at SBM and pipeline corridor will be move towards north-eastern direction and reaching Mundra coast within 30 hours. The spills at pipeline corridor will be partially landing northern coast of Gulf of Kutch at Mundra within 35 hr. The details of volume of spill are furnished in Table 4.1 - 4.3

Monsoon

Oil slicks of approximately 40% spilled at SPM moves parallel and closed to eastern coast of Gulf and may reach Mundra coast after 28 hr. The spills at pipeline will be landing northern coast of Gulf of Kutch at Mundra within 30 hr. The details of volume of spill reaching the coast/open boundary and time taken are furnished in Table 4.1 - 4.3

Post-monsoon

During this period spilled oil at SPM will move N-NE direction towards Kandla coast reaches within 35 hrs and spills at product jetty would reaches the coast of Mundra within 35 hr. During the movement of oil slick nearly 40% of oil volume will be evaporated and rest will be on the coast after 14 hr of spill. The details of volume of spill movement and weathering processes are furnished in Table 4.1 - 3.3

The likely areas affected by the oil spill during various seasons are given below:

Table 4.1 (a): Percentage of spill quantity (tonnes) reaching the coast/open boundaries

Spill volume Pre monsoon (April)

Monsoon(July)

Post monsoon (Oct)

158 t Crude oil at SPM 56 53 53 Crude oil spill of 79 T along the pipeline corridor

60 56 56

1000t Crude oil at SPM 62 64 64

Table 4.1 (b): Extent of oiling on coast/open boundary, metres

Spill volume Pre monsoon (April)

Monsoon(July)

Post monsoon (Oct)

158 t Crude oil at SPM 1200 1400 1400 Crude oil spill of 79 T along the pipeline corridor

1000 1200 1200

1000 T Crude oil at SPM 2400 2800 2800

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Table 4.2 Spill Analysis

Pre monsoon(April)-During Spring Tide

Spill Location Spill quantity (t)

Losses (t)

Time taken to reach port /open boundaries (hours)

Amount of oil on surface (tones)

Remarks

SPM 158t Crude oil 90 20 68 Reaching Mundra coast

Pipe line leakage 79 t Crude oil 46 20 33 Reaching Mundra coast

Collision/Grounding 1000 t Crude oil

450 20 550 Reaching Luni in northern side of Gulf

Monsoon(Jul)-During Spring Tide

Spill Location Spill quantity (t)

Losses (t)

Time taken to reach port /open boundaries (hours)

Amount of oil on surface (tones)

Remarks

SPM 158t Crude oil 105 35 53 Reaching Luni in northern side of Gulf

Pipe line leakage 79t Crude oil 45 35 34 Reaching Luni in northern side of Gulf

Collision/Grounding 1000 t Crude oil

530 35 470 Reaching Luni in northern side of Gulf

Post Monsoon(Oct)-During Spring Tide

Spill Location Spill quantity (t)

Losses (t)

Time taken to reach port /open boundaries (hours)

Amount of oil on surface (tones)

Remarks

SPM 158t Crude oil

105 35 53 Crossing eastern open boundary

Pipe line leakage 79t Crude oil 45 35 34 Crossing eastern open boundary

Collision/Grounding 1000 t Crude oil

530 35 470 Crossing eastern open boundary

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Table 4.3 Spill landing Position and locations

Pre-Monsoon(April)

Spill Location Tide condition

Time taken to reach coast/port boundary(hrs)

Landing Position (Lat. & Long.) and Location

158t Crude oil at SPM Spring 25 Reaching Mundra coast in northern side of Gulf

9500 m3/h for 30 sec., Crude oil along pipe line

Spring 25 Reaching Mundra coast in northern side of Gulf

1000t Crude oil at SPM

Spring 25 Reaching Mundra coast in northern side of Gulf

Monsoon(July)

Spill Location Tide condition

Time taken to reach coast/port boundary(hrs)

Landing Position (Lat. & Long.) and Location

158t Crude oil at SPM

Spring 30 Reaching Luni area, in northern side of Gulf

9772 m3/h for 30 sec., Crude oil at along pipeline

Spring 30 ,,

1000t Crude oil at SPM

Spring 30 ,,

Post-Monsoon(Oct)

Spill Location Tide condition

Time taken to reach coast/port boundary(hrs)

Landing Position (Lat. & Long.) and Location

158t Crude oil at SPM Spring 35 Crossing eastern open boundary

9772 m3/h for 30 sec., Crude oil along pipe line

Spring 35 ,,

1000t Crude oil at SPM

Spring 35 Crossing eastern open boundary

2.5 SHORELINE SENSITIVITY MAPPING

The Mundra shore line has been surveyed extensively, by water craft and road as well. The mangroves are on the North East side of the Adani Port. Severe damage to ecology will be caused from oil spill in side this port.The spill is likely to move up and down with the tidal current and likely to hit the north east coast of Mundra at Luni during high tide level. But during low tide or ebbing, the spill is likely to go into the channel due to storage ebb current, and not likely to hit the coast but remain into channel due to tidal activities.

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Priority for protection of shoreline zone areas is to protect those areas which have great economic, environmental and social importance. Following areas figure in this list as per their importance:

1. Luni Beach 2. Mangroves area (Mundra Port) 3. Tata Power Plant 4. Adani Power Plant 5. Adani& Mundra Port Harbour

2.6 SHORELINE RESOURCES, PRIORITIES FOR PROTECTION

1. Luni Beach: Mundra coast has the characteristics of very high currents, wind and tide level as well. Thus in case of any oil spill, the spill is likely to spread rapidly and move along in the direction of the prevailing current. However the spill is likely to move up and down with the tidal current and likely to hit the northern coast of Mundra at Luni during high tide level. But during low tide or ebbing, the spill is likely to go into the channel due to storage ebb current, and not likely to hit the coast but remain into channel due to tidal activities.

2. Mundra Port Mangroves Area:- If the oil spill is likely to be very close to the Mundra port and some reaction time of about 2-4 hrs is available then in that case a barrier of boom can be to as to direct the oil shock to Luni so that the sensitive vegetation of maneuver can be saved and shore clean up can be undertaken at Luni mash land area . contablished by anchoring the boom at suitable place with the help of small country boats.

Now if the slick has already entered the geek leading to Mundra bunder, then in that case since the bunder is a tidal port and some water is always available. In that case feasibility can be studied if skimmer can be deployed and oil can be recovered from shallow and deep waters, as or else use of OSD can be applied by back pack spray system to neutrilise to spill. The use of sorbent resorted pads can also be initiated if the situation feasible permits.

2.7 SPECIAL LOCAL CONSIDERATIONS

Local considerations have their own importance and need to be addressed logically and thoughtfully. Luni village is situated near the Luni Beach which is high Importance in social life and economically for fishing. These areas need to be kept in mind while planning spill response operations.

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3. RESPONSE STRATEGY

The main strategy of the port is of containment and recovery, reason being is that the areas all around, and inside the port are considered highly sensitive. Therefore no chances can be taken in allowing oil spill to hit the shores.

It has been observed from the current and wind pattern that the spill at SPM is likely to hit Luni Beach The time taken for the spill to hit the shores Luni Beach will be 30-35 Hrs.

The strategy is also governed by the international consensus of not using Oil Spill Dispersant (OSD) in less than 20 meters depth of water that is slowly gaining momentum in India also. Also directives of Indian Coast Guard on use of OSD are quiet relevant.

3.1 PHILOSOPHY AND OBJECTIVES

For different oil spill scenarios different strategies have been developed, keeping in view the following factors:

a. Most probable discharge scenarios. b. Oil spill trajectory and possible fate of oil spilled.c. Time window available since the spill and likely time of it hitting the coastline. d. Nature of shoreline and priority for protection.

IMMEDIATE RESPONSE PLAN

These will be same for anchorage for waiting ships and spills alongside berth. Strategy during First 4 Hours: The following options are considered:

1. Containment of spilled oil and prevention from further spreading. 2. Recovery of spilled oil3. Booming of the sensitive areas, which are to be protected on assigned priority.

LONG TERM RESPONSE PLAN

Oil Spill Response equipments are required to be stored on tug boat, and the boom will be deployed to contain and prevent spread of spill. This is to be done by containment or deflecting spills towards the eastern side at the area being reclaimed for port, designated as collection points on the shoreline where it will cause less harm to the environment.

3.2 LIMITING AND ADVERSE CONDITIONS

It is to be well understood that any response is likely to be less effective in bad sea conditions, low visibility and during dark hour operations.

Weather, sea conditions and time factor play a significant role in oil spill response operations.

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3.3 OIL SPILL RESPONSE IN OFFSHORE ZONES

Any oil spill occurrence at SPM is within Port Limit, considering severe cyclones which develop in SW monsoon as well as NE monsoon conditions. Such situations do demand strategies to be adopted for responding to Oil Spills at the SPM area. These strategies are as follows:

(i) Monitor and Evaluate (ii) Recovery, Storage and Disposal (iii) Dispersant Spraying (iv) Protection of Sensitive Areas

(i) Monitor and Evaluate- On reporting of oil spill, it is be monitored continuously by vessels deployed in that area. The Emergency Response Team will close up in Emergency Control Room (ECR) and will start plotting the position and tracking the oil slick every 15 -30 minutes or as required. Thereafter the Emergency Control Team (ECT), on the basis of data received from various sources, would evaluate the size of oil spill. ECT would also predict the fate and track of spilled oil based on weather conditions and strategy to be initiated.

(ii) Recovery, Storage and Disposal - The spill occurring through the Crude oil discharge vessel or SPM Pipeline involved in the accident is most likely to move towards north easterly side towards the shore due to wind direction and prevailing currents. In such conditions it will be quiet difficult to recover the Spilled Oil by normal methods.

(iii) Dispersant Spraying - In case the weather conditions are bad, and deployment of OSR equipment is not possible/ practical, the ECT may take decision for OSD spraying, with due permission from CG authorities or seek help of Coast Guard helicopter.

(iv) Protection of Sensitive Areas - If the danger of oil spill approaching towards the coastline in that case the protection of sensitive areas i.e., mangroves, Luni Beach and adani port harbour channel; has to be done by diversion / protection booming with the help of booms and shore sealing booms.

3.4 OIL SPILL RESPONSE IN COASTAL ZONES

In view of crude oil offloading at SPM, the environmental damage is expected to be quiet high. Therefore notwithstanding the risks from the movement of above type of vessels, there will be a need to immediate response to the spill, so that the spill or residue after evaporation does not reach the sensitive areas. Effective protection and diversionary booming are to be carried out for protecting the sensitive areas.

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3.5 SHORELINE OIL SPILL REPONSE

Collection of oil and oily soil has to be done manually for the oil spill hitting the shores, in the temporary storage tanks and the disposal will be as per IMO and State Pollution Control Board guidelines in force through registered oil recyclers of the state.

The OSR team is to prepare itself well in advance during mock drills, for shore cleanup activities. In this process the Shore Cleanup, equipments are to be checked for operational availability and then arranged and kept ready for deployment at short notice. So that OSR Team spends very little time in transportation and subsequent deployment. The potential impact areas being predominantly mangroves of Mundra Port area, Luni Beach, Power Plants and Salt Pans, Tuna Port lying with mud flats with upcoming vegetation and fishing stakes will be a cumbersome operation due to nature of the topography.

3.6 STORAGE AND DISPOSAL OF OIL AND OILY WASTE

The recovered oil and oily water mixture will be collected in the tanks of the vessel. If this is not practical then in that case, floating tanks are to be used for storage and transportation of the recovered oil. If the spill recovery point is close to the shore, then in that case the same is to be stored in open storage tanks / drums and subsequently pumped to the Lorries for disposal. A list of oil recyclers is placed as APPENDIX-08

A range of options for shoreline cleanup and waste disposal methods as per IMO guidelines are given below: Option for Separation and Disposal of Oil & Debris

Type of Material Separation Methods Disposal methods

LIQUIDSNon-emulsified oils

Gravity separation of free water Use of recovered oil as fuel or refinery feedstock.

Emulsified Emulsion broken to release water by: heat treatment emulsion-breaking chemicals mixing with sand

Use of recovered oil as fuel or refinery feedstock. Return of separated sand to source.

SOLIDS Oil mixed with sand

Collection of liquid oil leaching from sand during temporary storage. Extraction of oil from sand by washing with water or solvent. Removal of solid oils by sieving.

Use of recovered liquid oil as fuel or refinery feedstock. Direct disposal Stabilization with inorganic material. Degradation through land farming or composting Burning.

Oil mixed with cobbles, pebbles or shingle.

Collection of liquid oil leaching from sand during temporary storage. Extraction of oil from beach material by washing with water or solvent.

Direct disposal Burning

Oil mixed with wood, plastics, seaweed and sorbents.

Collection of liquid from debris during temporary storage. Flushing of oil form debris with water.

Direct disposal BurningDegradation through land farming or composting for oil mixed with seaweed or natural sorbents.

Tar balls Separation from sand by sieving. Direct disposal Burning

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4. EQUIPMENT

4.1 MARINE OIL SPILL RESPONSE EQUIPMENT & CONSUMABLES

The inventory of oil spill response equipment expected to be maintained by each risk category of ports as stipulated by Coast Guard Authorities, also finds mention in National Shipping Boards Report 2013, is appended in the table below.

SNo.

Equipment Qty Manpower Response Time by standby Vessel

01 Boom 1000 Mtr IMO Level II – 02 IMO Level I – 06 Other - 10

30 minutes for pipeline leakage

02 Skimmer (20 TPH) 04 No. 60 minutes for other oil spill incidents

03 OSD Applicator 02 No. 04 OSD 5000 Ltr 05 Flex Barge (10 Tons) 02 No. 06 Sorbent Boom Pack 200 Mtr 07 Sorbent Pads 1000 No. 08 Current Buster Boom

at Ports where Tidal current is > 4 Kn

02 No.

09 Work Boat 01 No. 10 MSV/OSV/Tug 01 no.

4.2 INSPECTION, MAINTENANCE AND TESTING

All the sea going OSR Equipment need to be maintained and preserved in highest state of operational readiness. To achieve this, a planned maintenance, inspection and testing program is initiated by.OSC, which will ensure that all oil spill response equipment under him, onshore as well as offshore, placed at pollution control stores, and Tug Boats, are inspected periodically and maintained as per their PMS (Preventive Maintenance Schedule) system. A record of inspection, maintenance, tests, exercises and training etc. is to be maintained at all times.

Similarly the OSC is to ensure that, OSR Team ensure the availability of operational readiness of spill response equipment and dispersant capability heldonboard vessel and HMPL COT. This can be ensured by regular testing and periodical drills conducted by the IC / OSC.

It is to be ensured that all personnel assigned with the task of operation of these equipments are adequately trained by a competent training institute. The competency of the responders can be maintained by holding regular exercises with other organisations. Hands on training to the responders are to be imparted by practically deploying the equipment and checking their effectiveness at sea / sheltered waters.

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4.3.0 SHORELINE CLEANUP EQUIPMENT, SUPPLIES AND SERVICES

4.3.1 LIST OF SHORELINE CLEANUP EQUIPMENT

Sl. No. Items Quantity

1 Brush Skimmer 10 TPH 1 2 HDPE Hoses 3” dia. with cam lock coupling 120 Mt 3 HDPE Hoses 2.5” dia. with cam lock coupling 75 Mt 4 Air Compressor 1 5 Air Hose braided 150 Mt 6 Air Hose braided 30 Mt 7 Back pack OSD Spraying System 2 8 Diaphragm Pumps – Wilden M8 (30 tph) with Air & HDPE

Hoses 2

9 Hydro Pneumatic Power Pack with Accessories 1 10 On shore Storage Tank – 9 T with Frames 2 11 Tractor with Trailer 1 12 Mobile Crane – Hydra 1 13 Mahindra Bolero Camper 1 14 Electrical Generator Set – 5 KV 1 15 Petroleum Remediation Powder (PRP) – Further

replenishment will be done by HMPL as per actual usage 200 Kg

16 Cleaning Material like rag etc. 200 Kg 17 Bio versal 100 Lt

4.3.2 SUPPLIES AND SERVICES

In order to carryout immediate spill response for the protection of sensitive areas, Luni beach, Power Plants, fishing harbor, mangroves, Salt Pans etc., the spill response equipment need to be stored at a suitable place inside HMPL premises. As it is observed that sensitive area Luni beach from north east from HMPL COT reached by road and response equipment can be transferred and transported for deployment easily within an hour.The OSC is to check, if the affected area is approachable faster and safer from seawards or landwards.

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5. MANAGEMENT

5.1 CRISIS MANAGER AND FINANCIAL AUTHORITIES

If the situation demands for mobilisation of Offshore Emergency Response Team (ERT) by OSC/IC, the following action is required to be undertaken by the team members.

a. Get ready to prepare the equipment for operation

b. Offshore ERT to get transferred to the vessel by boat or as required.

c. Ensure VHF/ Cell Phone communication is checked and established with

ECR.

d. While the vessel proceeds to the oil spill area, get ready to deploy the

equipment

e. Co-ordinate with Master of the vessel to line up storage tank(s) for

receiving recovered oil

f. Carry out operations under instructions from OSC.

g. Co-ordinate with other response teams if mobilised.

h. Stand down operations when advised by OSC.

In the initial stages of a spill emanating from an offshore accident / incident, these functions will be carried out by ships/ vessel’s personnel. Thereafter on arrival of OSC, they will assess the situation, plan the strategy for deployment of OSR equipment and offshore Emergency Response Team to the available vessel and commence the emergency response operations. The Backup Emergency Response Team will be kept ready at the shore. Subsequently, more resources will be mobilised through the ECR, if required.

Both the offshore and onshore ERT’s will be required to assemble at the ECR, immediately on sounding of response activation alarm. In the event of the spill moving towards the shore, onshore Oil Spill Response Team will also be pressed into service.

The Emergency Control Room will function from the HMPL COT Conference Hall and all the Emergency Control Team members will be deliberating and taking all the decisions from this place The ECR will be activated immediately on sounding of an oil spill alert. This room will have all the facilities to monitor the spill and equipments for decimating the required information to the OSC and his team. The complete Oil Spill Response Operation will be conducted and directed from this room. The financial authority’s representative is also the member of the crisis management team. The composition of Crisis Managers and Financial Authorities team has been described in chapter 5.2.1

The roles of IC, OSC & (ECT) members have been discussed in succeeding paragraphs.

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5.2 INCIDENT ORGANISATION CHART

The Incident organisation chart / Information System Flow Chart is placed at APPENDIX-10 & 11

5.2.1 EMERGENCY CONTROL TEAM (ECT)

The ECT members will be operating from ECR which will be activated in the Conference Room of HMPL COT(Control Building). This is designed so as to monitor spill response effectively, decimation of information and decisions immediately to avoid any time loss and appreciate the spill situation from time to time. It comprises of:

(i) General Manager Pipelines (ii) Dy. General Manager Pipelines (iii) Manager Operations (iv) Dy. &Asst. Manager Marine (v) Safety Officer (HSE) (vi) Manager Maintenance/Manager SCADA (vii) Dy. Manager Finance (viii) Dy. Manager Administration (ix) Security Officer

The duties and responsibilities of individual members including OSC are given below:

ROLES AND RESPONSIBILITIES

INCIDENT CONTROLLER (IC)

General Manager Pipelines- The General Manager Pipelines of the HMPL COT has been designated as Incident Controller (IC).

He is the person who has been assigned all the responsibilities for all the actions during any incident / accident of oil spill.

The IC will assign the roles and responsibilities as per procedures to the ECT members and monitor whole offshore as well onshore activities/operation from ECR.

In the event of an oil spill he will immediately

a. Assume over all in charge of situation b. Proceed to ECR c. Evaluate the severity of situation d. Inform Management / Director e. Assign the roles and responsibilities as per procedures to the ECT members

OPERATION IN CHARGE

Dy. General Manager Pipelines- The Dy. General Manager Pipelines of the HMPL COT has been designated as whole operation in charge. He is the person who has

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been executed all the responsibilities for all the actions during any incident / accident of oil spill. Also operation in charge will be nodal point in between IC & OSC.

The operation in charge is responsible for the all the clean-up activities associated with oil spills arising at the spill site at sea as well as on the shores. He will plan and formulate appropriate strategy for effectively dealing with spill response operations in consultation with OSC. He is also responsible for all operational, logistics and support services to the OSC and his team.

In the event of an oil spill he will immediately

a. Assume over all operation in charge of situation b. Evaluate the severity of situation at site c. Ensure other protocol and regulatory requirements are taken care ofd. Arrange funds mobilisation as situation warrants, by informing Accounts Dept. with

help of IC. e. Recommend mobilisation of resources from external agencies such as Indian

Coast Guard, Mundra, Adani Port, Kandla Port etc, as required. Initiate Mutual Aid assistance with concurrence of IC.

f. Recommend mobilisation of resources and trained manpower from private Oil Spill Response Agencies (OSRA) in this field as stipulated in NSB Report of Aug 2013, if situation demands and if available in the area with concurrence of IC.

ON SCENE COMMANDER (OSC) – Dy. Manager (Marine)

The immediate duties of the OSC on receiving the information about oil spill will be to establish the following information:

a. Time spill occurred, b. Position and shape of the slick, c. Visual appearance and apparent thickness of the oil, d. Percentage cover of the various thickness of oil, e. Speed and direction of the slick, f. sensitive areas/vessels etc in its path, g. Local weather conditions and sea state.h. Investigate the source of leak / spillage i. Contact the Vessel / Helicopter and request monitoring of the spill. j. Report to Incident Controller (IC) and draw a strategy to deal with the Emergency. k. Forward Oil Spill Report Form ASAP but within 30 minutes.

Duties during Operations

During course of ongoing Oil Spill Response operations, the OSC has to ensure that has to provide all operational, logistical support to his men in consultation with IC. He is also to ensure that all the men and machinery are suitably turned around, men are adhering to all safety regulations. During ongoing operations the OSC is to pass on all the

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information to the ECR every day. Any assistance required from outside agencies are also be informed to the ECR within reasonable time.

In the event of Standing Down:

The OSC after the winding up action, is to forward a detailed report on the performance of men, machinery, lessons learnt, incidents / accident occurred during operations with his recommendations. 5.2.1.1 Manager Operations

The Manager Operations will responsible for stop pumping at COT, Valve isolation and co-ordination with marine & refinery.

In the event of an oil spill he will immediately

a. Isolate the station. b. Stop pumping and isolate the shore tanks. c. Contact and arrange with all required contractors and local vendors who are

associated with station. d. Oil accounting and oil loss assessment.

5.2.1.2 Dy. Manager Marine

The moment ECR is closed up the AM Marine, after briefing by IC, will in consultation with inform all the government agencies as required including Coast Guard. The Director / CEO, partners and other civil authorities having a bearing on company by the oil spill, will also be informed by him.

Marine man himself would assume the responsibility of plotting of spill position and guide the IC of predicted path of the oil spill. In addition to this, he will establish communication with the masters of the vessel and OSC. He will keep the OSC up dated of all the weather parameters. Being a mariner, he will also advise IC in all the marine related matters from time to time. He will keep a sharp lookout of all the incidents happening and log them suitably for debrief / hot washand in the event of Standing Down, take stock of the situation for reports, equipments and men.

Incase the quantum of spill is high and beyond capacity, he will advise IC to request seeking assistance from other ports / companies or Coast Guard as per NOSDCP for their help. While this process is on, he will assess the extent of loss and initiate insurance formalities in consent with accounts head.

After the operations are considered over, the AM operations will monitor all the movements and inform all the concerned agencies / offices, of the situation. He would also collect all the reports and log sheets for debrief.

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5.2.1.3 Media Coordinator - IC or nominated by IC

The IC or nominated by IC will assume the duties of Media Coordinator as per policy of HMPL when spill emergency alarm is sounded.

5.2.1.4 Safety Officer (HSE)

All the HSE related jobs are to be looked by the AM HSE along with timely advices on HSE matters to IC and OSC. He will submit reports on HSE matters to all the relevant Govt. and statutory authorities including State PCBs also.

5.2.1.5 Manager Maintenance &Manager SCADA

Manager Maintenance: All the maintenance related jobs are to be looked by the Manager Maintenance along with timely advices on maintenance matters to IC and OSC. He will be prepared reports on maintenance matters to submission the same later to the management.

Manager SCADA: All the telecom and instrumentation related jobs are to be looked by the Manager SCADA along with timely advices on T&I matters to IC and OSC. He will be prepared reports on telecom and instrumentation matters to submission the same later to the management.

5.2.1.6 Dy. Manager – Finance

The Asst. Manager Finance will be monitoring & maintaining accounts of all expenses incurred on Oil Spill Response activities and providing all details to Legal department for raising of compensation, claims/prosecutions etc.

5.2.1.7 Dy. Manager Administration

In the event of Oil Spill Alarm raised, he will close up in ECR and assume his designated task. He will assist IC in mobilizing Boats, Helicopter, Manpower, vehicles and arrange all the boarding and lodging requirements. He will also assist IC in procurement of OSR equipments / consumables from the local market or from friendly organizations. The manager administration has also to endorse urgent nature of requirements of OSR equipments and other consumables procured, so that payments for them are ensured in time. The timely return of OSR equipments to their owners after due maintenance, also falls in the line of duty of Manager Administration.

5.2.1.8 Security Officer

The Security Officer’s duty includes providing safety and security of all the men and machinery during ongoing OSR operations as well as during rest and off periods also from outside elements. He would deploy his manpower in such a fashion that at any given point of time if OSC / IC require extra hands, he should be able to spare hands as

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required by the situation. The security officer must ensure that all the OSR operations are conducted free from all the hindrances from public. He is to liaise with local police authorities to provide safety cover to responders and other field staff from outside elements.

5.3 MANPOWER AVAILABILITY (ON - SITE, ON - CALL)

The HMPL’s COT Policy on Oil Spill Response has been quiet liberal and no constraint is visualised, therefore following system will prevail:

(i) Marine department will maintain the OSR equipments under guidance of OSC. (ii) HSE Department in consultation with Marine department will look after the training

and exercise part. (iii) Administration department will provide assistance of additional watercrafts, vehicles,

mobile cranes, forklifts etc. for movement of men and material to ensure continuous and uninterrupted OSR operations.

The manpower needed for OSR Teams are placed at APPENDIX-.11

5.4 AVAILABILITY OF ADDITIONAL MANOWER

Any requirement of additional manpower will be met by Administration Department. Manager Administration, AM -HSE and Security Officer in consultation with Dy General Manager Pipelines will maintain the list of trained manpower available with various departments. A list of qualified and semi-skilled casual workers, who can be utilised ashore for shore cleanup or any other specific operation, is also to be maintained by HSE department. This can be done before hand and checked during mock drills etc with the help of Safety & Security Department. This process will ensure easy availability of a dependable additional work force apart from the designated workforce. This will also augment the work force in case we get OSR equipments from outside without manpower.

5.5 ADVISORS AND EXPERTS – SPILL RESPONSE, WILDLIFE AND MARINE ENVIRONMENT

The advisors and consultants locally available are NGO’s, fishermen, senior citizens for valuable advice if required, and shall be nominated by the HMPL.

In addition, the following shall be very useful and may be utilised for seeking advice on local issues information on various matters and conditions

Advice as felt necessary will also be sought from the nearest Indian Coast Guard Station at Mundra or COMDIS - 1 at Porbander or COMCG (NW) at Gandhinagar. Adani Port authorities may also assist for consult & mobilise responses, if required when requested.

In addition the following can also be contacted for any assistance and advice. (a) NEERI

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National Environmental Research Institute, Nehru Marg, 440 020 Ph. 0712-2249885-88, Fax- 0712- 2249900

(b) NIO – Goa Dona Paula- Goa, 403004, Epbx 0832-2450450, Fax – 0832-245060

(c) Viraj CSE D-440, Vashi Plaza, 2nd Floor, Sector 17, Vashi, Navi Mumbai 400 703 022-27657811, 40135610, Mob. 9867456877

5.6 TRAINING / SAFETY SCHEDULES AND DRILL / EXERCISE PROGRAMME

Personnel of various departments and hired expert OSR Team of HMPL nominated as Oil Spill Responders for oil spill response and emergency management duties shall undergo training appropriate to their role/responsibility i.e IMO Level I & II respectively.

Dy, General Manager Pipelines, AM HSE and Manager Administration will ensure that every person, who has been assigned role or responsibility in emergency response or management, undergoes OSR IMO Level I & II training as specified in National Shipping Board 2013 Report and also as detailed in the oil spill training matrix. The training of onshore personnel will be co-ordinated by AM HSE. The schedule of Training and competency is placed at APPENDIX-12

The OSC will ensure that all Emergency Response Team personnel, who are required to operate OSR equipment, undergo training for effective deployment of equipment and associated devices. No of trained personal with IMO level list are attached

S No NAME DESIGNATION CONTACT No.

IMO OPRC LEVEL 1/ 2

01 Mr.Vinod Shrivastava Sr. Manger (Tech)

9099904047 IMO Level I & II

02 Mr. Ravinder Kumar Sr. PTM IMO Level I & II03 Mr. Ajay koul Sr. PTM IMO Level I & II04 Mr. JS Yadav Sr. PTM IMO Level I & II05 Mr. Ravindra Yadav PTM IMO Level – I 06 Mr. Shashi Kumar PTM IMO Level – I 07 Mr. Yogesh Padave PTM IMO Level – I 08 Mr. Ujesh Singh PTM IMO Level – I 09 Mr. Bhavesh Rabari PTM IMO Level – I 10 Mr. Devender Singh PTM IMO Level – I 11 Mr. Sandeep Kumar PTM IMO Level – I 12 Mr. Subhash Chand PTM IMO Level – I

Oil Spill Response Drills and Exercises

Periodical drills, exercises, and testing of men, machinery and contents of OSCP will ensure that skills and awareness of HMPL’s ERT are always available in a state of operational readiness. Half yearly exercises are recommended for testing OSCP and to

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have optimal utilisation of equipment and to minimise wear and tear in each exercise. Testing and exercises also provide management an opportunity to assess men and equipment, measure their performance, obtain feedback from participants, update and correct the OSCP, and give inputs to the company’s management to improve commitment on oil spill prevention and response.

Regular time bound exercise and drills involve any or a combination of the following:

(a) OSCP orientation in all the participants. (b) Table top scenarios for the Management team (IC, OSC & ERT leader) (c) Table top scenarios for the Emergency Control Team (ECT) (d) Notification and callout procedures for ECT and Responders (e) Equipment, Personnel mobilisation and deployment – for ECT,OSC Responders (f) Joint exercises with other agencies.- for all (g) Full scale incident management exercises.- for all.

It is to be ensured that after every exercise there shall be a debriefing to identify weaknesses in the OSCP, Equipment and to undertake appropriate remedial action wherever required. Dy. General Manager Pipelines will ensure that amendments required to be reflected in OSCP are suitably and timely incorporated into this plan.

SAFETY

According to Occupational Safety and Health Act, the employers are required to provide a safe and healthy atmosphere and workplace free of recognized hazards and follow OSHA standards. In this regard, they are also required to arrange for necessary training, provide appropriate protective equipment. It is very important that, workers also must adhere to the employer’s safety and health rules stipulated to comply with OSHA standards. They must use and wear or use all required gear and equipment as stipulated by the said Act. It is also very important and healthy sign that workers are encouraged in reporting of hazardous conditions, whenever and wherever it occurs to their supervisor and report such hazardous conditions to OSHA authorities, if employers do not solve the issue. AM HSE will ensure strict compliance of all Safety Standards.

GENERAL SAFTEY AND HEALTH RULES

1. All work-related injuries/illnesses or vehicle collision, no matter how small / minor they are, shall be reported immediately to the supervisor / safety in charge.

2. All fires, spills, and releases, no matter how small, shall be reported immediately to the supervisor/ HSE dept.

3. Immediately report any unsafe condition, practices, near miss or incident to the supervisor /HSE dept.

4. All personnel shall wear seatbelt while in Company vehicles, including rental car and personal cars utilized on business travel/ official travel.

5. Possession, use, distribution or being under the influence of prohibited drugs or alcohol while on the job or company premises is strictly prohibited.

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6. The use or possession of firearms, deadly weapons or unauthorized explosives on Company premises is strictly prohibited.

7. Smoking is permitted in designated areas only. 8. No unauthorized work be started in any area or on any equipment without

consent of the Company’s Person-In-Charge (PIC)9. Operation of equipment having a “DANGER, DO NOT OPERATE” tag is strictly

prohibited. 10. Under normal operation, all operating machinery and electrical switchgear must

have all safety guard, switches and alarm in place and be functional. 11. Finger rings, wristwatches, and other jewelries, along with loose clothing,

unsecured long hair and other loose accessories shall not be worn when within arm’s reach of unguarded operating machinery or electrical switchgear.

12. Do not apply compressed air to yourself or others. 13. When ascending / descending stairways, use the handrail &take one step at time. 14. Running in work areas, except for emergency purpose, is prohibited. 15. Use only proper tools and equipment maintained in good working condition. 16. Ladders, work platforms, scaffolding, personal lifts or fall protection must be used

when working at heights greater than 6 ft (1.8m) and the potential for falling exists.

17. Fire extinguisher and all other emergency equipment must be in good condition, inspected regularly and kept clear of any obstruction.

18. Use proper lifting techniques such as bending of the knees, obtaining assistance, or mechanical lifting loads.

19. Approved hard hats shall be worn in field operations and other designated areas. 20. Approved foot protection is required in field operations &other designated areas. 21. Approved safety eyewear shall be worn in field operations & other designated

areas.22. Eye/face protection such as goggles and a face shield shall be worn during

grinding, welding, drilling, scraping or any operation where foreign objects may enter and damage the eyes.

23. Personnel handling chemicals or other agents shall wear proper eye or face protection gears and other PPEs as recommended by the HSE department in conformity with MSDS.

24. Hearing protection/ ear defenders shall be worn in high noise areas (85dB or higher).

25. Personnel shall wear proper hand protection when performing tasks that may present injury to hands.

26. Personnel shall wear an approved Personal Flotation Device (PFD) securely fastened during exposed offshore / vessel jobs.

27. Personnel shall also secure themselves with suitable life line while working above water line and while working on high masts or poles etc.

HAZARDOUS CHEMICALS AND MATERIALS

BASIC COMMON RULES AND PROCEDURES WHILE WORKING WITH CHEMICALS

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1. In case of eye contact, promptly flush eyes with clean fresh water for a prolonged period (15 to 30 Minutes)

2. In case of skin contact, promptly flush the affected area with water (15 Minutes), remove contaminated clothing and seek medical attention.

3. Do not smell or taste chemicals to find out the identity.4. Do not eat, drink, smoke, chew gum or apply cosmetics in areas where

hazardous chemicals are in use. Wash hands before conducting these activities.

5. All Chemical and equipment containers shall be properly labeled duly mentioning their shelf life and then stored.

6. HSE in-charge must ensure that all persons, including visitors, wear appropriate eye protection where chemicals are stored or handled.

7. Wear appropriate gloves when the potential for contact with hazardous materials exists, inspect the gloves before each use, wash them before removal and replace them periodically and always use dry gloves to work.

8. A material safety Data sheet (MSDS) for each chemical is must and shall be readily available as well as pasted on the container.

9. No hazardous chemical shall be accepted without appropriate labeling and MSDS.

10. Toxic substances shall be segregated in a well-identified area with adequate exhaust ventilation.

11. Stored chemical shall be examined periodically for container integrity.

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6. COMMUNICATIONS

6.1 INCIDENT CONTROL ROOM AND FACILITIES

The Conference Hall of the HMPL (Control Building) is the room earmarked as the Incident Control Room. This room may also be referred as Emergency Control Room (ECR). The ECR is used for Emergency Control Team (ECT) to assemble and operate from here. Entire OSR operations will be observed, directed, and reviewed from this room.

It will also require two members from any section to be nominated to assist ECT in its functions. In the event of an Oil Spill Emergency, they shall be stationed at ECR and would be working under the direct control of IC right from the beginning to end of the events.

Duties assigned to these personnel are

Help IC to run ECR proceedings during oil spill emergency, in this they will maintain all the office equipment, documents, records required during such operations. They will man communication systems and suitably log all the events for report making and debriefing. Plotting of spill movement on charts, updating all charts and records is also part of their duty. They will keep IC updated of all the information reports, weather data etc. as received from outside sources. These people will revert to their respective departments only on clearance from IC.

Following facilities are available in ECR

a. Conference table & chairs to accommodate at least 10-12 senior officers. b. All conference room facilities. c. VHF Communication facilities with ships and other vessels d. VHF Walkie Talkie communication facilities with OSC and ERTs. e. Internal & External Telephone directories. f. List of Important personnel and their Cell Phone numbers. g. Copies of Emergency Response Plan (ERP), Oil Spill Contingency Plan

(OSCP)and HSE Policy,h. Charts and Map showing sensitive areas with priorities for protection duly

marked, and their approaches with distances, condition of roads etc. i. Stationary for day to day requirement j. Distance of nearest Port, Airport, Railway Station and the hospital facilities

available.

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6.2 FIELD COMMUNICATIONS EQUIPMENT

a. The HMPL, Mundra possess highly effective communication system to establish communication among various agencies associated with oil spill response.

b. Communication with Coast Guard aircrafts can be established on 118.2 Mhz, VHF MMB when flying in the sector of operation.

c. Listening watch is maintained on channel MMB 16/08 (or as decided) throughout,for communication with surface crafts.

d. The communication channel between the port facility, port control and the vessels operating under her directives would be Primary CH 16 and thereafter shift to desired channel

List of telephone and mobile phones numbers for immediate contact in emergency are provided at APPENDIX-14.

6.3 REPORTS, MANUALS, MAPS, CHARTS AND INCIDENT LOGS

It is to be ensured that the basic information about the particulars of oil are ascertained from Oil Spilled Report Form. This is essential in formulating a good and effective response strategy to combat offshore emergency. The OSC shall complete the Oil Spill Emergency Report Form and forward it to IC. In all cases the original report forms will be handed over to the IC as soon opportunity arises.

The logs maintained by every individual is an important document, as it narrates all the happenings and events taking place with the person concern during the course of his duties. These logs are to reach IC / OSC for preparation of Reports, Debrief and Record. These logs are the testimony of true happenings and experiences of persons involved in the operations and serve as a helping tool in the CASE STUDY in future course of time.

The formats of reports are placed at APPENDIX-15, 16, 17 & 18

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ACTION ANDOPERATIONS

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7. INITIAL PROCEDURES

7.1 NOTIFIYING OF OIL SPILL TO CONCERNED AUTHORITIES

The person giving information of a spill may inform to HMPL as well as Port Signal Station for fastest delivery of the message to the concern persons at the same time. However this information may be passed directly to the HMPL Control Room, who in turn will inform the IC/OSC directly. The IC and ECT members will immediately activate oil spill emergency alarm, call up procedures will be followed as per the laid down rules of the company.

IC will also initiate necessary measures to inform the concerned regulatory authorities including Coast Guard as soon as possible.

7.2 PRELIMINARY ESTIMATE OF RESPONSE TIER

In the event of OSC getting the spill information, he will immediately assess the quantum of spill, location, cause of sill, environment, threat to other sensitive areas etc. and inform IC accordingly. IC will immediately assemble his ECT members and assess the situation for the action and strategy required, whether the situation warrants to raise the Tier level, or can be undertaken by our responders, or response work can be under taken with the help of additional manpower and equipments from the neighbors.

The concept of Tiered Response is placed at APPENDIX-19.

7.3 NOTIFYING KEY TEAM MEMBERS AND AUTHORITIES

The incident of the oil spill will be informed by the OSC to the IC who in turn will inform all the concerned members and the authorities as per the existing Information System prevailing. The Communication Channel is placed at APPENDIX-20.

7.4 MANNING CONTROL ROOM

On receipt of spill information, Emergency Control Team will assemble at the Emergency Control Room (ECR). Their constitution and individual roles has been explained in chapter 5.

7.5 COLLECTING INFORMATION (Oil Type, Sea /Wind Weather Forecast, Aerial Surveillance, Beach Reports)

In the event of an Oil Spill, the following information are essential to be collected by the OSC immediately.

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a. Time of the spill incident b. Position in Latitude/ Longitude if possible c. Reference of prominent landmark if close to the shore. d. Visual appearance, apparent thickness of oil and extent of area covered e. Percentage cover of various thickness of oil f. Existing weather condition and weather forecast g. Current, tide and wind conditions h. Immediate availability of support vessels, equipment and manpower specifying

time factor as well i. Estimated oil spill trajectory and likely area and time of making landfall

7.6 ESTIMATING FATE OF SLICK (24, 48 AND 72 HOURS)

What happens to the spilled oil?

Immediately after an oil spill incident happens, the spilled oil undergoes a variety of complex physical, chemical and biological change processes, and also the oil keeps drifting from place to place due winds, surface currents tide variations etc. This gives rise to change of the properties of the spilled oil. The important mass transport or weathering processes are:

- Spreading - Dispersion - Evaporation - Emulsification - Dissolution - Photo oxidation - Biodegradation - Sedimentation - Consumption by planktons

The last four are slow processes and take considerable time, hence can be neglected while predicting the weathering of an oil spill within a week after the spill.

The evaporation losses from the oil spill constitute a fast weathering process lighter fractions of the hydrocarbons from the spill are lost very fast through the evaporation process during the first hour after the spill.

In the event of the spill reaching the shoreline, the time interval after which the spill is likely to reach the coast, its probable location and the length of impacted shoreline can be predicted on the chart No. 2079 available in ECR. Since the time interval after which the spill reaches the coast is more or less independent of its magnitude, the extent of impacted coastline for spill of various magnitudes can readily be estimated from the plotted position.

7.7 IDENTIFYING RESOURCES IMMEDIATELY AT RISK, INFORMING PARTIES

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In view of the SW monsoon being quiet vigorous in this area, cyclones occurring in NE monsoon also, and also depending on the area likely to be affected, concerned Port authorities, Coast Guard and other statutory authorities / agencies as applicable are required to be informed as soon as possible. Such details of various addresses and telephone nos. are placed asAPPENDIX-14. Now since it is clear that the South West monsoon is quiet Vigorous on the west coast and also this area is not sheltered from any side the ships in at anchorage or at SBM are not safe from adverse weather conditions. The effect of the sea is felt during South West monsoon and during cyclones in North East monsoon. The areas which are at the risk have been discussed earlier and prioritised as follows:

(i) Luni Beach (ii) Mangroves area (Mundra Port) (iii) Salt Water Pond (iv) Fishing Harbour, Tuna Port (v) Channel of Adani& Mundra Port Harbour (vi) Adani West Port (vii) Sea Intake of Adani Power Plant (viii) Sea Intake of Tata Power Plant

Oil Spill likely to hit at Month Technique used and Position

1At serial (i) to (vi) above All months. (a) Interception Booming of operation

2 At serial (vii) to (viii) above All months (a)Diversion & Collectionoperation Booming “A” : “B” : “C”

7.7.1 SHORELINE PROTECTIONS, DIVERSION AND RECOVERY

In order to save the sensitive areas, which have already been prioritised, Interception, Shore Protection, and Diversion/ Deflection booming technique using a combination of Shore Sealing Boom, Foam filled boom etc., has been adopted.

In the situation of Adani Port, the spilled oil has to be intercepted and contained as fast as possible. Under no circumstances the spill is allowed to hit the shores. This is important to protect the Luni Beach, Intake of Power Plants and Mangroves. However if the oil slick has already hit the shore; shore clean up is the only option available. In that case all the Interception and shore clean up resources including available manpower and are to be mobilised to the site without much of delay. On reaching the site the OSC is to inspect the site thoroughly and inform the ECR about the scenario prevailing. On reaching the desired spot before starting any work the OSC must obtain the weather forecast and tide position at that time (flooding or ebbing) and brief the IC and strategy to be adopted. Utmost safety and adequate lighting arrangement is also to be made if the decision is taken for shore cleanup to be carried out during dark hours also.

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8. OPERATIONS PLANNING

Reliable and effective communication for having a positive control of the OSR operations among various agencies involved, both at field level as well as at Emergency Control Room is highly essential. Exchange of information / status reporting etc. is to be carried out with the assistance of various forms / logs etc. as per NOS DCP.

INITIAL POLLUTION REPORT FORMAT

The “Oil Spill Report Form” (placed at APPENDIX-15) is essentially to be used by the OSC to pass on the relevant information to the ECR. The details about the information asked in the pollution report format are as follows:

Date & time pollution observed and identity of observer / reporter. Position and extent of pollution. Name and position of polluting vessel and

estimated amount of pollution. Wind speed and direction. Weather conditions and sea state. Characteristics of pollution. (Give type of pollution, e.g. type of oil, lubricants or

otherwise. Also give appearance, e.g. liquid, floating solid, liquid oil). Source and cause of pollution. (e.g. name of the vessel, give brief description). State whether photographs have been taken, and/ or samples taken for analysis. Forecast of likely effect of pollution, with approximate timing of likely hood of

making landfall or hitting the coast. . Any other relevant information. (e.g. Action taken or intended)

Telephone / mobile/ VHF calls can cover the above information, which has to be sent in writing in appropriate formats, later on.

POLREP

Information about the incident is to be intimated to the Operations Centre, Coast Guard Station Mundra. It is to be noted that even smallest amount of oil spill has to be reported to Coast Guard. The POLREP format is placed at APPENDIX-16.

8.1 ASSEMBLING FULL RESPONSE TEAM

Once the oil spill emergency is declared and, OSC has briefed the IC about the response priorities, he will assemble his OSR team at the pollution response centre at designated place and conduct thorough briefing about each individual’s role and responsibilities. The required extra equipments are also simultaneously embarked on board support vessel and are checked for their availability for deployment.

There may be a need to escalate response to a higher tier as per need of the hour. OSC will establish, justify this and advise IC to alert ECT to be standby for mobilising additional resources when required. As the response activities progresses and results are visible

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the ECT will decide upon the stoppage or continuation of operations based on the observation of OSC and recommendation of IC.

8.2 IDENTIFYING IMMEDIATE RESPONSE PRIORITIES

Since most of the sensitive areas are situated near the Adani Port and are situated on the North West side of Gulf of Kutch which are not far off, most of the spill and activities will be visual. However in case of spill outside the harbour, the ECT with the help of oil slick movement track plotted on the chart no.2079 & prevailing weather condition would taken action which area needs to be protected first. The immediate response priorities have already discussed in chapter 7.7

8.3 MOBILISING IMMEDIATE RESPONSE

The OSR equipments hired by HMPL need to be augmented with through mutual aid partners or extended sources and also as per classification of ports by Indian Coast Guard. These OSR equipments will be positioned onboard vessels and places from where they can be deployed on immediate notice.This is in line with the worst case scenario of 1000 tones of spill. These equipments will be operated keeping existing weather conditions in mind.

Once the booms are in place and the recovery started, the oily water mixture will be pumped into the tanks on vessel or the open storage tank as per the requirement of the situation.

8.4 MEDIA BRIEFING

It is to be ensured that the initial press statement for media briefing be prepared with great care and accuracy as no changes in the subsequent statements would be possible and difficult to answer if there are any differences. Therefore in order to avoid any confusion / misunderstanding, a press statement format has been suggested. This statement has to be signed by the competent releasing authority for release to media and then only it is to be issued by Public Relations Officer or Media Coordinator. Initial press statement format is placed at APPENDIX-21.

8.5 PLANNING MEDIUM TERM OPERATIONS (24, 48 AND 72 HOUR)

In case oil slick hits the shore, Shore Cleanup is the only alternative. But in case, slick remains away from the coast, recovery has to be continued with the help of booms and skimmer. The use of dispersants may also be resorted to as per the demand of the situation, keeping in view type of oil spilled and the -

a. Prevailing adverse weather conditions and deployment feasibility of spill response equipments.

b. Oil Spill Response equipments could not be deployed due paucity of time and Oil slick is too close to shallow waters and thereby likely to damage ecosystem of the sensitive area nearby.

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The dispersant may be sprayed over the diesel oil slick by the manual spray system or helicopter, due to surrounding area of shallow waters, subject to prior clearance from Coast Guard authorities

PLANNING FOR BOOM DEPLOYMENT WITH SHORE SEALING BOOM

The deployment of booms is to be done from the seaward side by the tugs or any other support vessel deployed for the job. Once the vessel reaches close to the shore, (keeping safety factor in mind) the boom with the connecter end is passed on to the shore by means of heaving line or by help of a work boat / country boat. Once the boom connecter end reaches the shore, it is to be connected up with seaward end of Shore Sealing Boom. Once these are connected and made ready, the Shore Sealing boom is paid out about 1/3rd to ½ of it’s length, thereafter filled with air fully and about half with seawater. This procedure would allow the boom to float on water and also provide stability to the shore-sealing boom on soft mud. The land ward end of the Shore Sealing Boom is to be firmly secured to any strong point or be anchored with the help of shore anchor, prior to connecting it with the boom from the vessel.

Once the booms are connected up, the boat is to be directed to pull the boom away from the shore. Once the boom takes the desired shape, the boat is to be directed to drop the anchor attached to the boom connecter connecting shore sealing boom and sea boom; this will hold the boom firmly in its place. This anchoring of the boom is to be done at every alternate section of the boom connector, to the shackle provided below the connector point. Great care is to be exercised while boom anchoring, as sufficient rope is to be paid out keeping in view of local sounding and the range of tide, prevailing in the area.

Once all the desired sections of the booms are properly laid and firmly secured, the last end of the boom is connected with the Towing Bridal, which is to be connected with two anchors. Thereafter the first anchor is dropped in the direction of the tide coming from, then the second anchor is dropped in the direction of tide going to, thus giving it a shape which could hold the boom in its place, both in flood tide as well as ebb tide conditions. It is important to note that an anchor buoy has to be attached with each anchor with the eye provided so as to indicate the exact position of the anchor, during flood and ebb tide conditions. Once the boom acquires the desired shape, the shore sealing boom is to be filled up with full water and air as required so that it firmly sits on the soft mud and the area being washed by seawater is sealed perfectly.

While recovering the booms; the seaward side booms are to be recovered first and the shore-sealing boom at the last. In this process the boat is to approach towards anchor buoy at the downstream first, and pull the anchor up with the help of anchor buoy rope. This way it would come up easily as the load/ strain would not be on the anchor rope, as it would be almost in vertical position and easier to pull.

The above procedure is to be followed in respect of all the locations selected above. However, if the OSR equipment is to be deployed, it is to be done in the place where the

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oil gets accumulated and sufficient depth is available for the boom to float and recovery equipment to operate.

8.6 DECIDING TO ESCALATE RESPONSE TO HIGHER TIER

Once the Spill Response action has started and personnel deployed, the OSC takes stock of the situation and discovers or feels that the quantum of the oil spilled is much more than assessed, and the situation may go beyond their capability to handle the spill response. Then he must immediately inform the ECR and request IC and other ECT members to inspect the site for their view. If the IC and his team members feel that the Spill Response needs revision to higher Tier, then the decision is to be taken without much delay, as this needs much of preparation for movement of men and machinery from other institutions / agencies as soon as possible. This upward revision to higher Tier of spill response needs to be informed to Coast Guard authorities at Mundra, Porbander &Gandhinagar, Gujarat Pollution Control Board (GPCB), and other mandatory authorities.

The procedure of informing all concerned agencies / organizations of heightened spilled oil threat perception remains the same. The concept of Tiered Response is placed at APPENDIX-19.

8.7 MOBILISING OR PLACING ON STANDBY RESOURCES REQUIRED

As the decision to raise the Tier level of oil spill is under progress, a review or introspection of HMPL’s own spill response capability is also to be assessed simultaneously. Once it is decided that additional resources (like mutual aid partners) are required to be informed immediately. Mobilisation action for required spill response equipments / items should also be taken simultaneously It should be borne in mind that mobilization of resources both, from out stations as well as locally, is a time consuming and painstaking exercise. Therefore it will be a wise decision to anticipate such requirements during table top exercises / actual drills and keep all the data ready for immediate actions, i.e. the anticipated arrival time of the Pollution Response Equipments as there may be delay on account of:-

(i) Transportation time by rail / road / sea / air. (ii) Time taken in loading / unloading. (iii) Availability of specialised loading / unloading machineries and accessories. (iv) Availability of suitable berthing / landing facility for the craft intended to be used. (v) Availability of suitable airport for landing of specialised aircraft (in case the

equipments are to come from abroad, their customs clearance etc.) (vi) Custom and Immigration formalities.

It is also very important to keep in mind about operations of those pollution response equipments, which are being mobilised. Who is going to operate them? In case the equipments are coming with one set of manpower, then from where their relief would come? And in case only equipments are provided then, does management of HMPL possess required trained manpower for operating these equipment? All such points are

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essentially to be deliberated upon by the OSC and ECT together during debriefing of the operation or exercise planning stage itself. This is highly essential for the establishments who are involved in discharging of Crude Oil and fall in the category “A” and “B”, as formulated Indian Coast Guard and report of National Shipping Board 2013.

For obtaining additional equipments, HMPL management should have a MoU with the local Oil handling organisations and nearby ports. This can also be resolved by undergoing a contract with a reputed Oil Spill Response Organisations (OSROs) for providing OSR services as recommended by National Shipping Board in their report of 2013. It should be borne in mind, that the compatibility of our equipments to theirs should been established prior to signing of MoU itself. This will eliminate all the technical hassles arising at the last moment when the response level is raised to a higher Tier.

Requirement of extra manpower for running these equipments has to be taken care off well in advance .The best possible solution is to send Our Men for on the on job training, whenever those organisations are conducting Pollution Response Exercises. After attending three or four such exercises, our personnel will be quiet familiar on other’s equipment as well. This will give us an opportunity of possessing trained manpower,without having purchased the expensive equipments. This trained manpower may come very handy at the time of real requirement for both the organisations. Also with this HMPL Management can provide trained manpower to all organizations either “Free” or “at a price” or as decided by the management. The requirement of consumable pollution response items like sorbents pads, sorbent booms, dispersants etc can be worked out separately.

In case of an Oil Spill, a general alert can be sounded to these Members (MoU signing Organisations) or OSROs requesting to keep the required items as stand by.

As mention in above guidelines, HMPL has mutual agreement with Adani Port and SEZ which we have mentioned in article 1.4

Once it is decided that additional resources are required then HMPL may call it’s mutual aid partner as per mutual aid agreement and use their resources like OSR equipment, boats and manpower as per agreement at site.

8.8 ESTABLISHING FIELD COMMAND POST AND COMMUNICATIONS

It is essential that a field Command Post is established as soon as the spill response operation starts. This room should have the facilities for working of OSC, battery charging facilities for the VHFs and mobile phones, and VHF antenna for getting better reception and transmission facilities. This will greatly help in case the operational area is far off from the base station. As far as the OSC is concerned, he will be equipped with portable VHF and mobile phone. The ERT leaders would also be having hand held VHF sets and or with mobile phones. The OSC is required to be in regular communication with ECR for his all the reports and requirements. In case of requirement this place can act as shelter from extreme weather conditions or as a First Aid Post also.

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9. CONTROL OF OPERATIONS

9.1 ESTABLISHING A MANAGEMENT TEAM WITH EXPERTS AND ADVISORS

The Emergency Control Team of HMPL has been formed out of highly competent persons from various departments who have bearing on oil spill operations and are considered as Experts and Advisors of their respective fields. The details in this respect are placed at section 5.5. In case if any additional help is required, it may be sought from Coast Guard; NIO Goa and other private experts in this field.

9.2 UPGRADING INFORMATION (Sea/Wind/Weather Forecasts, Aerial Surveillance, Beach Reports)

Although the OSC is responsible for all the actions at spill site, he is also required to keep information on time, quantity and type of spill, wind, current tide information. He is also to gather information on local prevailing weather parameters with the help of masters of the vessels i.e. wave height, swell, weather warnings etc. He is also to keep a sharp lookout for any Coast Guard / Naval ships, air craft or helicopter flying in the operational area. All such information are to be passed on immediately to ECR and a regular updates are given to ECR as required by the circumstances. ECR in turn is also required to provide and update OSC on weather reports / weather warnings received from Meteorological Departments, movements of merchant ships, Coast Guard / Naval / Research / Survey ships in that area. The ECR may also inform OSC of on going exercises of Navy / Coast Guard in that area so as to take necessary and timely action.

Such feeding of information and subsequent up gradation, proves to be highly beneficial, both to OSC and ECR as well and helps to function smoothly.

9.3 REVIEWING AND PLANNING OPERATIONS

Review of operations is an on going process and should be the integral part of any on going operations. Accordingly, the planning is to be reoriented in order to get the maximum output and better utilisation of men and machinery. It should be ensured that there is no compromise on any count on safety of both, men as well as material. However operational rest to men and machinery need to be kept in mind. This will give us a data that how much a man and machinery can be utilised without any harm to them. This would also suggest ideal time frame for rotational intervals for the responders and machines.

However not withstanding above, ongoing operations should be assessed and reviewed as and when the ECT considers it necessary or suggested by OSC. This is necessary to upgrade the level of operations or scale down the operations due to changing scenarios.

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9.4 OBTAINING ADDITIONAL EQUIPMENT, SUPPLIES AND MANPOWER

In case of requirement for obtaining additional equipment arises, the ECT may establish contact to the following.

a) Contact local offshore oil companies engaged in exploration and production activities (E&P), nearby ports. However in this case the compatibility of their equipments and training of our manpower be also ascertained well before hand. If necessary a Memorandum of Understanding (MoU) shall be signed. Alternatively HMPL may enter into an agreement with any reputed OSRO for such requirements.

b) Requirement of extra manpower to meet the requirement of running these equipments may be entrusted to an OSRO.

c) Logistics support for the extra equipment and men shall be planned, responsibilities entrusted by name/ post and documented in advance, so that crucial time and effort is not wasted in allocation of assignments at the last moment.

In an event of Oil Spill, along with the general alarm sounded, these Friendly Members are to also be informed and alerted by IC, ECT, requesting to keep the required items, as stand by.

9.5 PREPARING DAILY INCIDENT LOG AND MANAGEMENT REPORTS

As per the normal practice all the log sheets are required to be filled for running of all operations and equipments during operations itself, as filling it later increases the chances of missing vital information. In addition at the end of the normal working shift, time ending at 2000 hours, starting from 2001 hours of the previous day, (or it may be from 0801 hours to 0800 hours of the previous day) a Daily Summery of Events is to be prepared and submitted to the IC, who in turn would prepare the report in consultation with all the members of the ECT and forward it to management.

The report prepared by the IC must invariably cover following details:

(a) Quantity of oil recovered from sea (b) Quantity of oil transferred for storage / disposal (c) Manpower deployed (d) Equipments deployed (e) Numbers of equipments run (f) Numbers of man hours utilised (g) Weather conditions encountered (h) Progress on shore cleaning efforts (as the case may be) (i) Difficulties encountered (j) Lessons learnt

A draft Daily Incident Log is placed at APPENDIX-17.

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9.6 PREPARING OPERATIONS ACCOUNTING AND FINANCING REPORTS

As the OSR operation progresses, the Finance Head being the member of the ECR will automatically direct his department to keep monitoring the day to day expenditures on all accounts. This will be necessary to prepare and initiate claims / compensation or build up case for the legal action against the offender. Also the department would find it easier to take stock of the situation and prepare the accounts and report on a day-to-day basis to the management.

9.7 PREPARING RELEASES FOR PUBLIC AND PRESS CONFERENCES

As discussed earlier, only ECT Leader is an authorised person issues / releases information to public and press. Under no circumstances print or electronic media is given any information, interview etc. without the clearance / permission by the IC. A format in this regard is also provided at APPENDIX-21.

9.8 BRIEFING LOCAL AND GOVERNMENT OFFICIALS

It is of the utmost importance that releases cleared by competent authority for local and government officials are to be checked thoroughly and then briefed by the PRO / Media Coordinator or any other person authorised to do so. Reason being, that once govt. officials are briefed verbally, it becomes official and a written statement has to be given subsequently, which cannot be changed or amended later. This briefing may be carried out once or twice a day at fixed timings, as per media and press policy of HMPL.

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10. TERMINATION OF OPERATIONS

During any oil spill response operation, even if majority of the oil is collected at sea, some amount of oil tends to escape the sharp eyes of OSC due to dark hours or unfavourable weather conditions, and over a span of time reaches the shoreline. This small amount of oil is good enough to create a storm in the tea cup. However at times it is seen that due to stormy weather condition or other constraints, a good amount of oil reaches the shoreline. Therefore, the termination of the operations will always be with the shoreline cleanup operation.

10.1 Deciding Final and Optimal Levels of BEACH Clean-up It is well understood that most of the beaches are quiet frequented by the public daily and in large numbers during weekends and holidays in particular. Therefore the level of beach or shore cleanup required is quite significant, since these are frequented by public / tourists, hence are highly prone to criticism, leading to media and public outcry. In the present area of operation, the Ministry of Environment and Forest (MoEF) and fishing harbour is bubbling with activities during non-monsoon season and so is the beach next to it used by boat repairers and the local residents.

The other authorities / agencies i.e. Coast Guard Station Mundra, Gujarat Pollution Control Board , State Forest and Fisheries department officials etc. are to be consulted prior to starting and during such cleanup operations, as they may not have much to advise but certainly may come up with something to criticise.

10.2 Standing Down equipment, cleaning, maintaining & replacing

Any response operations can be termed completed only when all the machineries equipments and consumables are accounted for, checked, their maintenance carried out and made ready for next operation and then stored in their respective places.

During maintenance all equipments and machineries are to be thoroughly washed with Fresh Water as per the OEM’s guidelines, necessary repairs, servicing, oiling /greasing etc. be carried out and then only the equipments be considered as secured

10.3 PREPARING FINAL DETAILED REPORT On completion of the OSR Operation, the OSC is to prepare a detailed report covering all the aspects of the oil spill cleanup, including success and failures as well, lessons learnt, recommendations about equipments, man power, plans etc. The report is to be as realistic as possible so that it gives a clear picture as to how, all the operations went on. Basically intention behind this should be to suggest room for improvements required and lessons learnt for not making such mistakes in future, thereafter forward it to IC, who in turn will forward his report with the comments to the Management / Board of Directors.

10.4 REVIEWING PLANS AND PROCEDURES FROM LESSONS LEARNT

It is very important that ECT should carryout critical analysis and honest deliberations on the report received from OSC / IC and give its clear recommendations to CEO for putting it to Board of Directors for necessary action.

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PART – III

DATA DIRECTORY

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DATA DIRECTORY - APPENDICES

Appendix-01 Area of Operation – SPM and Adani Port lay out Appendix-02 Emergency response Organisation Appendix-03 Weather Condition Appendix-04 Statutory requirements- Relevant agreements Appendix-05 Sensitive Area Map Appendix-06 Shore Clean-up Techniques Exposed Tidal Flats Appendix-07 Oil Spill Response Decision Making Tree Appendix-08 CPCB Approved Oil Recyclers Appendix-09 List of OSR offshore equipment Appendix-10 Information System Flow Chart Appendix-11 Manpower Details for OSR Team Appendix-12 Training and Competency Appendix-13 HSE Policy of HMPL Appendix-14 Emergency Contact Numbers Appendix-15 Oil Spill Report Form Appendix-16 POLREP Appendix-17 Daily Incident Log Appendix-18 Personal Log Form Appendix-19 Tiered Response Concept Appendix-20 Communication Channels Appendix-21 Initial Press Statement Form-Pollution Incident Appendix-22 NOSDCP Circular No. 03/2013 (Certificate of Endorsement) Appendix-23 NOSDCP Circular No. 02/2015 (Guidelines for Net Environmental Benefit Analysis) Appendix-24 Mutual Agreement between HMPL & Adani Port Appendix-25 Contingency Planning Compliance Checklist (Appendix E5) Appendix-26 Abbreviations

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APPENDIX-1

AREA OF OPERATION – ADANI PORT & SPM LAYOUT

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Appendix-02

EMERGENCY RESPONSE ORGANISATION CHART

DY. GENERAL

MANAGER PIPELINES

Dy. MANAGER

MARINE

MANAGER

MAINTENANCE

ON SCENE COMMANDER

ASST. MANAGER

HSE

ASST.

MANAGER

FINANCE

DY. MANAGER

ADMIN

MANAGER

OPERATIONS

ASST. MANAGER

SECURITY MEDICAL TEAM

OFFSHORE TEAM LEADER

ONSHORE TEAM LEADER

GENERAL MANAGER

PIPELINES

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APPENDIX-03

WEATHER CONDITIONS

The meteorological and the oceanographic data collected from India Meteorological Department (IMD) and other secondary sources to represent the metrological conditions of the project area has been reviewed for various attributes such as Temperature, Wind, Cloud Cover, Humidity, Rainfall, Cyclone, and Visibility.

TEMPERATURE AND RAINFALL:

The climate at the site is tropical. December and January are the coolest months of the year, while the period from July to October is the rainy season

Month

Temperature °F Average Rainfall (mm)

Average

snow days

Average Fog

days Average Absolute

Daily Monthly max min max Min

January 69.8 51.3 86.0 35.6 0 0 0 0

February 70.0 47.3 95.0 26.6 0 0 1 2

March 73.4 53.1 96.8 -

22.00 0 1 1

April 65.3 51.6 107.6 66.2 0 0 0 0

May 71.6 61.0 100.4 37.4 0 0 0 0

June 68.7 64.6 98.6 39.2 1.1 33 0 1

July 64.0 59.4 98.6 -

18.41 30 0 0

August 73.8 63.3 91.4 75.2 0.2 6 0 0

September 67.8 62.4 102.2 68.0 0 0 0 0

October 81.5 67.3 105.8 14.0 0.9 27 1 0

November 72.9 59.4 98.6 -

31.00.7 21 0 2

December 75.6 61.7 89.6 53.6 0 0 0 1

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WIND

S No. Month Wind Speed Max. Sustained wind Speed Wind Direction (Approx.)Km/Hr Knots Km/Hr Knots

01. Jan 4 2 81 44 WNW 02. Feb 6 3 74 40 WNW 03. Mar 7 4 93 50 NW 04 Apr 11 6 74 40 SW 05. May 15 8 89 48 W 06. Jun 15 8 61 38 SW 07. Jul 15 8 57 31 W 08. Aug 13 7 93 50 WNW 09. Sep 9 5 94 51 W 10. Oct 5 3 63 34 NW 11. Nov. 4 2 74 40 NW 12. Dec 4 2 30 16 NW

The chart below plots the average daily wind speed you can expect for any month. It also shows the maximum recorded sustained wind speed for each month.

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TIDAL DATA

Tides

Tidal range is between +0.37 m during Neaps and + 6.40 m during springs.Tidal streams flow 0700 – 2500 at an average rate of 3 kts and 4-5 kts during spring tide. Wave height is about 0.14-1.30 m and wave period is about 6.50 sec-17.0 sec.

Tidal Level at Mundra

Maximum High Water Spring (MHWS) - 5.8 Mtr. Maximum High Water Neap (MHWN) - 4.6 Mtr. Maximum Low Water Neap(MLWN) - 2.1 Mtr. Maximum Low Water Spring(MLWS) - 1.0 Mtr. Mean Sea Level (MSL) - 3.4 Mtr.

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Appendix -04

STATUTORY REQUIREMENTS, RELEVANT AGREEMENTS

MARPOL 73/78

India has ratified the International Convention for the Prevention of Pollution from Ships, 1973 and the Protocol of 1978 relating to the convention, which is generally known as MARPOL 73/78.

The term “Ships’ includes fixed or floating off shore installation or structure engaged in gas or oil exploration, exploration or production activities or unloading or loading oil.

Annex 1 of MARPOL 73/78 comprises of regulation for the prevention of pollution by oil. Regulation 21 stipulates “Special requirement for drilling rigs and other platforms”. Briefly, these requirements are:

Installation of oil filtering equipment to ensure that any oily mixture discharges into the sea after passing through the system has an oil content not exceeding 15-ppm.

Maintenance of an oil record book as specified in appendix-ii of annexure 1 of MARPOL 73/78

Prohibition of discharged of oil or oily discharges with oil content exceeding 15 ppm (without dilution)

An approved “shipboard oil pollution emergency plan” to be carried on board.

International Convention on Oil Pollution Preparedness, Response and Cooperation (OPRC), 1990

International Convention on Oil Pollution Preparedness, Response and Cooperation (OPRC) was adopted in London on 30 November 1990 and entered into force on May 13, 1995. Even before the OPRC Convention entered into force, its provisions on cooperation were effectively put into practice on a provisional basis to respond to the oil pollution caused by the 1991 War in the Persian Gulf.

The OPRC Convention provides an international framework for cooperation in combating and responding to major incidents or threats of oil pollution. The Convention strives:

- to prevent marine pollution by oil, in accordance with the precautionary principle; - to advance the adoption of adequate response measures in the event that oil

pollution does occur; - to provide for mutual assistance and cooperation between States for these aims.

The Parties to the OPRC Convention are required to establish measures for dealing with pollution incidents, either nationally or at a regional and global level, in cooperation with other countries. The convention calls for the establishment of stockpiles of oil spill

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combating equipment, for the conduct of oil spill combating exercise, and for the development of detailed plans for dealing with pollution incidents. Parties must ensure that ships, offshore units, and seaports under their jurisdiction have oil pollution emergency plans. Such plans are required for:

- oil tankers of 150 gross tons & above, and other ships of 400 gross tons & above; - any fixed or floating offshore installation or structure engaged in gas or oil

exploration, exploitation, production activities, or loading or unloading oil (the operators of offshore units could have arrangements similar to oil pollution emergency plans, however, these must be coordinated with national systems for responding promptly and effectively to oil pollution incidents).

- any seaport and oil handling facility that presents a risk of an oil pollution incident.

Parties to the convention are required to provide assistance to others in the event of a pollution emergency and a special Annex to the Convention provides for the reimbursement of any such assistance provided.

Merchant Shipping Act 1958

Require oil operators to clean up any oil spill from off shore petroleum operations whether at sea or ashore.

Part XI-A refer to the prevention and containment of pollution of the sea by oil and applies to tankers of 150 tonnes gross or more, other ships of 500 tonnes gross and more offshore installation. The provision for prevention of pollution refers to prohibition as to discharge of oil or oily mixture, equipment to prevent oil pollution, oil record book, inspection and EEZ control and information regarding contravention.

National Legislation on Oil Pollution Prevention from ships

The provisions of MARPOL 73/78 are incorporated in the MS Act 1958under Part XIA Prevention and containment of pollution of the sea by oil and outlined in the ensuing table.

Section Remarks

356 A Application to ships and incidents at high seas 356 B Definitions as per MARPOL, 1973/78 and UNCLOS, 1982 356 C Issue of Pollution Prevention Certificate 356 D Issue of certificates to foreign ships in India and Indian ships in foreign

countries356 E Requirements for construction and equipments in ships 356 F Record Books for Indian oil tanker or other Indian ship 356 G Inspection and control of oil tankers and other ships 356 H Information regarding contravention of MARPOL, 1973/78 356 I Reception facilities at ports in India 356 J Power to give notice to owner of polluting ship

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356 K Power to take measures for preventing pollution 356 L Power of CG to give directions to certain ships to render certain services 356 M Oil pollution cess at 50 paisa per ton of cargo carried in bulk by oil tankers 356 N Refusal of Port clearances to ships not paying oil cess

Section 356 O empowers the Central Government to make rules under the M.S. Act 1958. The detailed technical standards for ships under Annex I of MARPOL 73/78 for the purpose of preventing oil pollution are included in the Merchant Shipping (Prevention of pollution from ships) Rules 2010 framed under the Act. The provisions include inter alia obligation of ships to prevent pollution, Survey and certification, requirements for machinery spaces of all ships and the cargo area of oil tankers, maintenance of Shipboard Oil Pollution Emergency plan, Reception Facilities.

Coast Guard Act, 1978

The Coast Guard is the national coordinating authority for marine oil spill response, and under the Act:

a) All spills are required to be reported to the Coast Guard. b) When Spills are reported, the Coast Guard will respond as follow-up action

monitoring agency. c) Monitoring the movement of spill as long as situation is under control d) If HMPL COT’s Management is not capable, or delays response action, then the

Coast Guard will take remedial measure. Response action will be at a cost to the company.

Joint Inspections of Tier 1 Preparedness

During the 9th NOSDCP meeting held on 29th September 2006, a decision was taken to conduct a joint inspection of the tier 1 oil spill response facilities of ports by a Coast Guard representative along with representatives of the Ministry of Shipping for ports. Accordingly, the Coast Guard in coordination with Ministry of Shipping has been undertaking joint inspection of tier 1 oil spill response facility at ports since 2007, for checking the preparedness level and recommending suitable remedial action

Planning of joint inspection of ports is a coordinated effort between the Coast Guard and Ministry of Shipping. To streamline the procedure, it was decided during the 18th NOSDCP meeting conducted on 31st May 13 at Dehradun to work out an annual schedule for joint inspection in consultation with the Ministry of Shipping.

Environment Protection Act 1986

Ministry of Environmental and Forest (MoEF) while granting environmental clearance to oil/gas projects requires oil operators to establish oil spill control capabilities. Under section 6 and 25 of Environment Protection Act, 1986 the Government of India has stipulated discharge standards for several industrial activities, operations and process,

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including the drilling and gas extraction industry, where standards for liquid effluent for offshore and onshore facilities (requiring marine disposal) have been fixed.

Coastal Regulation Zones Notification -1991

MOEF has declared the coastal stretches of seas, bays, backwaters etc that are influenced by tidal action (in the landward side) up to 500 meters from the High Tide Line (HTL) and the land between the Low Tide Line (LTL) and the HTL as Coastal Regulation Zone (CRZ)

CRZ is classified into four categories i.e. CRZ-I, CRZ-II, CRZ-III, CRZ-IV

CRZ-I: includes areas that are ecologically sensitive and important e.g. mangroves and spawning ground for fish and marine life. In CRZ-I area, transfer and storage of crude oil from terminal to ship and vice versa required permission of the Central Government. The operator has to ensure proper safeguard against exigencies arising due to any spill.

CRZ-II: the area that has already been developed up to or close to the shoreline. For this purpose, “developed area” is referred to as that area within the municipal limits or in other legally designated urban area which is already substantially built up and which has been provided with drainage approach roads and other infrastructure facilities, such as water supply and sewage mains.

CRZ-III: areas that are relatively undisturbed and those which do not belong to either category I or II. These will include coastal zone in the rural area (developed and underdeveloped) and also areas within Municipal limits or other legally designated urban areas, which are not substantially built.

CRZ-IV: Coastal stretches in the Andaman and Nicobar, Lakshadweep and small islands except those designated as CRZ-I, CRZ-I, OR CRZ-III

Environment Impact Assessment Notification, 1994

Under the provision of EIA notification, 1994, all major development project , including exploration for oil and gas and their production, transportation and storage, ports/harbours and all tourism projects in the CRZ are required to obtain environmental clearances from Ministry of Environment & Forests.

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APPENDIX 5

SENSITIVE MAP

Priority for protection of shoreline zone areas is to protect those areas which have great economic, environmental and social importance. As compare to other & according to importance following areas found more sensitive in above survey map:

1. Luni Beach 2. Mangroves area (Mundra Port) 3. Tata Power Plant 4. Adani Power Plant 5. Adani& Mundra Port Harbour

2.6 SHORELINE RESOURCES, PRIORITIES FOR PROTECTION

1. Luni Beach: Mundra coast has the characteristics of very high currents, wind and tide level as well. Thus in case of any oil spill, the spill is likely to spread rapidly and move along in the direction of the prevailing current. However the spill is likely to move up and down with the tidal current and likely to hit the northern coast of Mundra at Luni during high tide level. But during low tide or ebbing, the spill is likely to go into the channel due to storage ebb current, and not likely to hit the coast but remain into channel due to tidal activities. However in any case HMPL OSR team and it’s

HMEL SPM 220 40.88’ N 0690 37.48’ E

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resources are capable to prevent the spilled oil before hitting the beach,as the SPM is far away from Luni beach & in the worst cases also it will take more than one day for the oil slick to reach the beach in a hypothetical case of no OSR action taken.

Wind Data for 2013-2014

Month Max. Speed (knots) Direction June 21.4 353 July 29.2 277 August 23.2 289 September 41.2 275 October 13.3 300 November 15.1 314 December 12.8 327 January 2014 14.9 287 February 2014 14.9 293 March 2014 16.7 330 April 2014 9.1 225 May 2014 22.1 280 June 2014 19.0 217

2. Mundra Port Mangroves Area

If oil spill is near to the Mundra port and response time available is less than 03 to 04 hours, in that case boom barrier can be deployed directly on the oil slick towards Luni Beach, so that the sensitive vegetation of Mangroves can be saved and shore clean up can be undertaken at Luni marshland area by anchoring the boom at suitable place with the help of small country boats.However if Oil slick has already entered the creek leading to Mundra Port then in that case since the port is tidal port and presence of water is always there, feasibility for the deployment of Skimmer can be done and oil can be recovered from shallow and deep waters or else OSD can be applied by back pack spray system to neutralize the spill. The use of sorbent resorted pads can also be initiated if it’s feasible and situation permits.

2.7 SPECIAL LOCAL CONSIDERATIONS

Local considerations have their own importance and need to be addressed logically and thoughtfully. As Luni village is situated nearby the beach which has high importance in social life and economically for fishing so that these areas need to be kept in mind while planning spill response operations. Also HMPL has a Mutual Aid Agreement with Mundra port therefore in case of any exigency at off-shore as well as on-shore Mundra port is also capable to prevent spilled oil by their boats and OSR resources.

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APPENDIX-06

SHORE CLEAN-UP TECHNIQUES : EXPOSED TIDAL FLATS

Description

They are composed primarily of sand and mud. The presence of sand indicates that tidal or wind-driven currents and waves are strong enough to mobilize the sediments. They are always associated with another shoreline type on the landward side of the flat.The sediments are water-saturated, with only the topographically higher ridges drying out during low tide. Biological utilization can be very high, with large numbers of fauna and heavy use by birds for roosting and foraging.

Predicted Oil Impact

Oil does not usually adhere to the surface of exposed tidal flats, but rather moves across the flat and accumulates at the high-tide line. Deposition of oil on the flat may occur on a falling tide if concentrations are heavy. Oil does not penetrate the water-saturated sediments. Biological damage may be severe, primarily to fauna, thereby reducing food sources for birds and other predators.

Recommended Response Activity

Currents and waves can be very effective in natural removal of the oil. Cleanup is very difficult (and possible only during low tides). The use of heavy machinery should be restricted to prevent mixing of oil into the sediments. On sand flats, oil will be removed naturally from the flat and deposited on the adjacent beaches where cleanup is more feasible.

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APPENDIX-07

OIL SPILL RESPONSE DECISION MAKING TREE

Oil Spill Occurs

Gather Spill Information Gather Environmental Information

Evaluate Oil Characteristics & Behaviour

Evaluate Spill Location

and MovementGather Weather And Wave Forecasts

Is Shoreline Contamination

Expected?Undertake Surveillance and Monitoring

Implement Shoreline Protection YN

NCan Oil Type and Condition Be Chemically Dispersed? N

Is Mechanical Containment & Recovery Possible?

YeYe

NIs Dispersion

Operation Possible?Is In Situ Burning Operation Possible? N

YeYe

Implement Use of

Dispersants Implement

In Situ Burning

Implement Mechanical Containment and

Recovery

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Are Wildlife Contacted by Oil ? No

Ye

Implement Wildlife Rescue & Rehabilitation

No Are Shoreline Contacted by Oil ?

Ye

Implement Shoreline Cleanup

Complete Actions

Transfer & Storage of Oil & Debris

Disposal of Oil & Oily Waste

Document Actions & Demobilize

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APPENDIX-08

GPCB/CPCB APPROVED OIL RECYCLERS (GUJARAT)

Sr. No.

Name of the Unit Waste permitted

and Quantity allowed

Registration Valid Upto (DD-MM-YYYY)

01 M/s Suraj Barrel Supply Co. Opp. PWD Store, ChandolaTalav, Ahmedabad, Gujarat

Used Oil - 2700 KLA

No expiry date.Validity as per the Terms & Conditionsspecified in the registration certificate

02 M/s Bombay Barrel Supply Co. Danilimda, Chandola Highway Ahmedabad – 380028 (Gujarat)

Used Oil - 600 KLA

No expiry date.Validity as per the Terms & Conditionsspecified in the registration certificate

03 M/s Gujarat Mobil Pvt. Ltd. R. Survery No. 62, Paiki, Behind Plot No. 69/A, B, C, Village Mamsa, Ta. Ghogha Dist. Bhavnagar, Gujarat

Used Oil - 2208 KLA

Waste Oil - 5160 KLA

No expiry date.Validity as per the Terms & Conditionsspecified in the registration certificate

04 M/s Fine Refiners Pvt. Ltd. Plot No. 40, GIDC, Vartej Dist. Bhavnagar Gujarat

Used Oil - 2400 KLA Waste Oil

- 12000 KLA

No expiry date. Validity as per the Terms &Conditions specified in the registration certificate

05 M/s AlicidOraganic Industries Ltd., 208, HanumantHenduva, Opp.Gujcomasoi Nr. Kharai River, Highway Post. Palavaasana, Mehsana-2 Gujarat

Used Oil - 3600 KLA

Waste Oil - 18000 KLA

No expiry date. Validity as per the Terms & Conditionsspecified in the registration certificate

06 M/s Western India Petrochem Industries, 62-63, GIDC, Vartej, Dist. Bhavnagar (Gujarat)

Used Oil - 1800 KLA

No expiry date.Validity as per the Terms & Conditionsspecified in the registration certificate

07 M/s Jawrawala Petroleum 200/33, B/H, Kashiram Mill, Narol Ahmedabad - 382 405 Gujarat

Used Oil - 4800 KLA

No expiry date.Validity as per the Terms & Conditionsspecified in the registration certificate

08 M/s Gujarat Petrochem, Plot No. 48/49/50, GIDC Vartej, Dist. Bhavnagar,Gujarat

Used Oil – 1800 KLA Waste Oil

- 7200 KLA

No expiry date.Validity as per the Terms & Conditionsspecified in the registration certificate

09 M/s Reliance Barrel Supply Co. 200/34, B/h, Kasiram Mill, Narol Ahmedabad, Gujarat - 382 405 E-Mail :- [email protected]

Used Oil

– 7200 KLA Waste Oil

– 7200 KLA

No expiry date.Validity as per the Terms & Conditionsspecified in the registration certificate 13/07/2014

10 M/s Unity Petroleum Co., Panjetani Estate, Opp. PWD Store, Chandola, Ahmedabad-28, Gujarat

Used Oil - 600 KLA

No expiry date.Validity as per the Terms & Conditionsspecified in the registration certificate

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SNo.

Name of the Unit Waste permitted

and Quantity allowed

Registration Valid Upto (DD-MM-YYYY)

11 M/s Mercury Enterprises, Plot No. 2106/07, Phase-III, GIDC, Vatva,Ahmedabad (Gujarat)

Used Oil - 480 KLA

No expiry date.Validity as per the Terms & Conditions specified in the registration certificate

12 M/s R.K.Steel, Plot No.21, GIDC Estate, Phase-1, Narmadanagar, Bharuch,Gujarat-392 015

Used Oil - 4320 KLA

17/12/2013

13 M/s Kheezer Industries 206/B, Vartej-Budhel Road, Vartej, Bhavnagar, Gujarat-364 060

Used Oil - 8550 KLA

No expiry date.Validity as per the Terms & Conditions specified in the registration certificate

14 M/s Jai AmbeThinchem Plot No.C-1/B-2010 Phase – IV, GIDC Vapi,Gujarat– 396 195

Waste Oil - 3000 KLA

No expiry date.Validity as per the Terms & Conditions specified in the registration certificate

15 M/s Hind Petrochem & Refinery S.No.109/11, Village : Pratapnagar Taluka – Savli District – Vadodara, Gujarat

Waste Oil - 25000 KLA

No expiry date.Validity as per the Terms & Conditions specified in the registration certificate

16 M/s Vadiwala Industries 24, New Ahmedabad Industrial Estate Babla – Sarkhej Highway Village – Moraiya, District – Ahmedabad Gujarat – 382 213

Used Oil - 2400 KLA

27/10/2014

17 M/s Welknown Industries 43, New Ahmedabad Industrial Estate Nova Petro Chemical Lane Babla – Sarkhej Highway Village – Moraiya, District – Ahmedabad Gujarat – 382 405

Used Oil - 600 KLA

No expiry date. Validity as per the Terms & Conditions specified in the registration certificate

18 M/s Jai Ambe Industries II, Uma Indl. Estate Opp. Bhagwati Ice Factory Vasna-lyava Village Tahsil – Sanand, Distt.Ahmedabad, Gujarat

Used Oil - 3600

Waste Oil - 3600 KLA

No expiry date.Validity as per the Terms & Conditions specified in the registration certificate

19 M/s Shana Oil Process New GoodluckMarket Opp.PWD Store, Chandola Lake Narol Road, Ahmedabad,Gujarat [email protected]

Used Oil - 910 KLA

No expiry date. Validity as per the Terms & Conditions specified in the registration certificate

20 M/s ABC Organics & Chemicals 605, GIDC Panoli Tal – Ankleshwar, Distt.-Bharuch Gujarat

Used Oil - 1500 KLA

No expiry date. Validity as per the Terms & Conditions specified in the registration certificate

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SNo.

Name of the Unit Waste permitted

and Quantity allowed

Registration Valid Upto (DD-MM-YYYY)

21 M/s Shana Petrochem Opp.P.W.D. Stores Nr. Eagle Traders, Chandola Lake Narol Road, Ahmedabad Gujarat – 382 028

Used Oil - 3960 KLA

No expiry date. Validity as per the Terms & Conditions specified in the registration certificate

22 M/s N.K. Lubricants Pvt. Ltd. Block No.741/A Village – VasnaBuzarg, Ta: Kheda Distt.Kheda,Gujarat- 387 560

Used Oil - 2400 KLA

Waste Oil - 1800 KLA

18/01/2015

23 M/s Star International Petroleum Plot No.175, Village – Shahwadi Narol-Vasna Road Narol, Ahmedabad

Used Oil - 3150 KLA

21/01/2015

24 M/s Navkar Enterprises Block No.185,186 Village – Chacharvadi (Vasana) Ta-Sanand, Distt.Ahmedabad Gujarat – 382 213

Waste Oil - 4800 KLA

08/02/2015

25 M/s Sahkar Industrial Corporation Plot No.44, Alang Industrial Yard Opp.Mahalaxmi Oxy Mamsa Ghogha Distt. Bhavnagar, Gujarat

Used Oil - 500 KLA

No expiry date. Validity as per the Terms & Conditions specified in the registration certificate

26 M/s Deepak Petrochem Limited 56/2, Rameshwar Road Village : Vasenti,Near Baska, Tal. Halol,Panchmahal, Gujarat – 389 350

Waste Oil - 50400 KLA

06/05/2015

27 M/s Aman Petroleum Plot No.34(Sr.No.163), Opp.PWD Store, Nr.Bhavna Textile, Chandola Highway, Ahmedabad – 28

Used Oil - 1350 KLA

16/05/2015

28 M/s Rajasthan Petroleum 115-A/2, ShriHari Saw Mill Compound Opp. Bombay Hotel Behind Maniar Petrol Pump Narol Road,DaniLimda Ahmedabad,Gujarat -382 405

Used Oil - 5400 KLA

No expiry date.Validity as per the Terms & Conditions specified in the registration certificate

29 M/s S.R.Lubricants Plot No.22, JagannathMaharaj Farm Danilimda, Ahmedabad Gujarat – 380 028

Used Oil - 2400 KLA

18/07/2015

30 M/s Kutch Petrochem Pvt.Ltd. Plot No.12-14 & 23-25, Survey No.105/1 Village – Padana,Tal.Gandhidham Kutch-370 201Gujarat

Used Oil - 2400 KLA

Waste Oil - 10800 KLA

16/08/2015

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SNo.

Name of the Unit Waste permitted

and Quantity allowed

Registration Valid Upto (DD-MM-YYYY)

31 M/s Sainath Industrial Fuels Pvt.Ltd. S.R.No.44, Paiki 2/1Sartanpur, Tal.Bhavnagar Distt.Bhavnagar,Gujarat

Used Oil - 21000 KLA

Waste Oil - 24000 KLA

16/08/2015

32 M/s Good Earth Commodities (India)Pvt.Ltd. Plot No.1110-1111, Dholka GIDC, Dholka, District-Ahmedabad- Gujarat - 387810

Used Oil - 3600 KLA

30/08/2015

33 M/s Rajdeep Enterprises Survey No.246, Plot No.5, Industrial Area Opp.Galaxy Bearing Ltd. Rajkot – Gondal Road 8-B, ShapurVeraval Rajkot(Gujarat)

Used Oil - 3600 KLA

30/08/2015

34 M/s R.V.Bio-Coal Survey No.205/p, National Highway-8B Opposite Alakh Hotel, Village – Gomta Taluka – Gondal, Distt.Rajkot Gujarat – 360 311

Waste Oil - 26250 KLA

30/08/2015

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APPENDIX-09

LIST OF OIL SPILL RESPONSE OFFSHORE EQUIPMENT AT HMPL COT,Mundra

OIL SPILL RESPONSE EQUIPMENT

Sl. No. Details of Equipment Quantity (No.)

1 300 Mt ECO Air Boom with Accessories 1 2 250 Mt ECO Fence Boom with Accessories 1 3 ECO Power Pack for Boom Reel with Hydraulic Hoses 2 4 ECO 10 TPH Multi Skimmer with Pump 4 5 ECO Power Pack for Simmers with Hydraulic Hoses 4 6 Floating Tank – 25 Tons 2 7 Floating Tank – 5 Tons 5 8 ECO Foot Pump for Floating Tanks 6 9 Markleen Air Inflatable Boom with Accessories / Hydraulic Reel

(250 Mt. Each) 2

10 Markleen Power Pack (20 KV) for Skimmers with Hydraulic Hoses

2

11 Markleen Air Inflators (Petrol Engine) 2 12 ECO Air Inflators (Petrol Engine) 1 13 Markleen Multi Skimmer (30 TPH) with Pump 1 14 Markleen Power Pack (20 Kv) for Skimmer with Hydraulic

Hoses 1

15 Markleen Two Way Control Panel with Hydraulic Hoses (5 mm)

1

16 Markleen Power Pack Trolley 3 17 ECO Rachet Belt 10 18 ECO Tool Box 6 19 Absorbents Pads 900 20 Oil Spill Dispersants – Type III (Nova) 5050 L

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APPENDIX-10

INFORMATION SYSTEM FLOW CHART

IC/ In Charge ECT

Manager Acctounts

OSC Asst.

CEO

DGM Operations

Other Govt.

CoastGuard

Additional Support Team

CoastalClean-up

Team

Base Support

OSCCoastGuard

OffshoreERT

Offshore Support Team

Offshore

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APPENDIX-11

MANPOWER DETAILS FOR OSR TEAM

OFFSHORE - OSR TEAM “A “ OFFSHORE - OSR TEAM “B”

1) On scene commander 1 (1)On Scene Commander 1 2) OSR Team 6 (2) Port’s OSR Team 6 3) Supporting/Boat crew 4 (3) Supporting/Boat crew 4

ONSHORE - OSR TEAM “A” ONSHORE - OSR TEAM “B”

1) Team Leader 1 (1) Team Leader 1 2) OSR Team 3 (2) OSR Team 3 3) Workers As required (3) Workers As required

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APPENDIX-12

TRAINING AND COMPETENCY PURPOSE

The Dy. General Manager Pipelines / OSC in consultation with the HSE /Training Department shall determine the oil spill training needs and priorities on an annual basis. This will be presented in a matrix form and shall be mandatory

ATTENDANCE

All the HMPL employees and OSR Teams shall attend OSR awareness training. Personnel having specific roles to play in the plan shall be trained in areas specific to their needs. IMO divides the OSR training in three different levels, as given below

Level - 1

To provide field personnel and Supervisor, responsible for undertaking on site cleanup operations, an overview of the techniques available for recovering spilled oil and cleaning polluted shorelines.

Level – 2

Supervisor / On-scene Commander / Incident Controller: To provide senior personnel with the skills necessary to co-operate and supervise response operations, in a timely, organised and effective manner.

Level – 3

Administrators and Senior Managers: to provide senior personnel with an awareness of the role and responsibilities requires in the management of spills of national signification.

RECORDS

Records demonstrating that personnel have satisfactorily completed the designated training course shall be maintained.

TRAINING MATRIX:

OIL SPILL TRAINING IMO Level 1 IMO Level 2 IMO Level 3

Course Description First Responders

Supervisors/OnScene Commander

Administrators & Senior Managers

ECT members * * OSC * ERTs * Oil Spill Co coordinator * * * OSVs - Vessel Marine Crew * Retraining Frequency 3 years 3 years 3 years

Note: Annual refresher course of 8 hours duration for level 1 & 2, and for 4 hours…duration for level 3 will be given to personnel as appropriate to their training needs.

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Appendix-13

HSE POLICY

Occupational Health, Safety & Environment Management Plan (OHSEMP)

General

This Occupational Health, Safety & Environment Management Plan is an implementation plan consisting of mitigation measures, monitoring program and institutional measures to be adopted during the operation phases to minimize the Occupational Health & Safety, Environmental and social impacts. In this chapter, the OHSEMP formulated for the existing operational facilities at HMPL COT, is presented. The OHSEMP would be a dynamic document, which would be reviewed periodically and amended for improvements based on the Occupational Health Safety & Environmental Monitoring Programme.

Environment Policy

We at HMPL shall endeavour to ensure our operations complying with all the applicable legislation and continually strive to improve our existing environmental performance with sound environmental practices and ensure awareness among all the employees and port users

Health and Safety Policy

HMPL shall constantly promote safe operating practices, safety awareness among its employees and associated personal during its operations and shall abide to applicable legislations for continual improvement in occupational, health and safety

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APPENDIX-14

EMERGENCY CONTACT NUMBERS

SNo.

Company Name Designation Contact No.

01. HMPL Pawan Kumar Agrawal General Manager-Pipelines

078383828570120-4634603

02. HMPL Partha Chakraborty Dy. General Manager –Pipeline

09712548999

03. HMPL N Karthikeyan AGM- IPS 3 09982288833 04. HMPL Dhiraj Kumar Agrawal Manager – CRT 09991140529 05. HMPL Tridib Hazarika Manager –

Maintenance09727785329

06. HMPL Ramesh Rojasara Manager – Ops 09727785306 07. HMPL Milap Thaker DM- F&A 09727785324 08. HMPL Rajendra Singh DM – HL 09727785316 09. HMPL Jayantilal B Vamja Dy M – Marine 09727792863 10. HMPL Ashok Tiwary DyM– Marine 09099915625 11. HMPL Duty officer AM – Security 09099052990 12. HMPL Control Room SIC – Ops 02838-271240

1800-233-214809727747284/09727747286

13. HMPL Laxmikant Kolapkar Safety Officer 09727785318 14. AIMS Ambulance Room COT

Mundra,Medical Asst. 09727785319

15. IFSS Fire Station COT-Mundra Shift LFM 09727747288 16. HMPL Security Control Centre AM/Exe. Shift 09099052990 17. VirajCSE HMPL COT Mundra Project In-

chargeShift In-Charge

0909990404709099904049

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COAST GUARD REGION (NW) EMERGENCYCONTACT NUMBERS

Emergency Contact Numbers (External)

S No. Office Address Contact No. Remarks

01. District Collector Office- Bhuj 02832 – 250020 02. Additional Collector Office – Bhuj 02832 - 250650

0997840521203. Disaster Management Cell (District

Project Officer) – Bhuj 02832 – 252347, 224150

04. Emergency Response Centre (GSDMA) – Gandhidham

09925977795,09825572188

05. Bhuj Nagar palika Fire Brigade- Bhuj 02838 – 299080 09925170506

06. Dy. Director (Industrial Safety & Health) – Adipur

02836 – 260020

07. Dy Chief Controller of Explosive, Vadodara

0265 – 2225159 2361035

08. Superintendent of Police (SP Office) – Bhuj

02832 – 250444

09. Civil Hospital Mundra 02838 – 222144 09825171144

10. Adani Hospital (Emergency Desk) – Mundra

02838 – 619666, 619555

11. GK General Hospital – Bhuj 02832 – 250150, 220852

12. Emergency Ambulance 108 13. Coast Guard Commandant 02838- 271400

02838 – 271402/03/04

14. Mundra Police Station 02838 - 222121 15. Marine Control Room - Adani Port 02838 – 289221

09825228673

Mutual Aid Member Representatives (Offshore)

S No. Company Co-ordinator Designation Contact No.

S No. Coast Guard Gujarat Contact No.

01. Headquarters Coast Guard (NW) 079-23243241 079-23243264079-23243283 Fax

02. Headquarters Coast Guard District No. 0286-2242451 0286-2210559 Fax

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01. Adani Port & SEZ

Capt. Sansar Choubey GM - Marine 09925223674 Capt. Rhul Agrawal DGM -Marine 09687678479 Capt. Pankaj Sinha DGM -Marine 07574894206 Mr Sudhakar Dy PFSO 02838 255787

07069083039

Mutual Aid Member Representatives (Onshore)

S No. Company Co-ordinator Designation Contact No. 01. HPCL , Mundra

Terminal Chhatter Singh Chief Resident

Co-ordinator09909904572

Anil Pandey Operation Head 09602047704 Control Room Shift In-charge 02838 –

296218

27104002. IOCL, Mundra

Terminal Jawahar Lal DGM - PL 09426712770 Mohit Saxena Sr. Manager

(T&I)09099080667

Pankaj Gurjar Officer HSE 09409102859 03. Jindal Saw Ltd.

Mundra D Chandra Sony Sr. GM – HR 09925150767 Prabhakar HOD Fire &

Safety09925150270

04. Adani Power Ltd. Mundra

Anil Datar DGM – Fire & Safety

09687660356

Kiran Kumar Sr. Manager – Fire & Safety

09687660428

05. Coastal Gujarat Power Ltd.

Pramod Singh Safety In-charge 09227295495

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APPENDIX-15

OIL SPILL REPORT FORM

Particular of Person /organization

Reporting Incident

Title :…………………………………………………………………………………………… Organisation :……………………………………………………………….………..……….Telephone / Mobile / Telex/ Fax Number : ………………………………………….……..Date / Time :…………………………………………………………………………………..Diesel oil spill location: ….………………..………………………………………………… Type and quantity of Diesel oil spill :..…………………………………………..………… Cause of Diesel oil spill :…………………………………………………………………….Response to Diesel oil spillage, if any :…………………………………….…………….. Any other information :…………………………………………………………………..…

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APPENDIX-16 POLREP

Address From …………. To …………… Date Time Time Group Identification Serial Number

Part 1 1. Date and Time (POLWARN) 2. Position

3. Incident 4. Outflow

Acknowledge40. Date and time

41. Position 42. Characteristics of pollution 43. Source and cause of pollution 44. Wind direction and speed 45. Current or tide 46. Sea state and pollution 47. Drift of pollution

Part II 48. Forecast (POLINF) 49. Identify of observer and ship on scene

50. Action taken 51. Photographs or samples

52. Names of other agencies informed 53-59. Spare 60 Acknowledge

Acknowledge 80. Date and time

81. Request for assistance 82. Coast 83. Pre-arrangements for the delivery 84. Assistance to where and how 85. Other agencies requested

Part III 86. Change of command(POLFAC) 87. Exchange of information

88. Names and number of 89. Description of equipment 90. ETA and arrival information 91. Place of embarkation 92. Place of disembarkation 93-98. Spare 99. Acknowledge

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APPENDIX-17

DAILY INCIDENT LOG

DAILY INCIDENT LOG –TEAM LEADER –OIL SPILL RESPONSE GROUP

Name……………………………………….………..….… Rank…………….....….....…….. Notification received. ONSHORE / OFFSHORE Time …………….… Date ……………….. Day………………… Shift………………...

LOCATION OF THE INCIDENT

Name of the AREA / PLACE………….…….........…Area ……………........……….....… Latitude ……………………………………… Longitude ………………………..…….…....Distance from Prominent Object ………….NM Sounding ........................... -----------------------------------------------------------------------------------------------------------------------Incident occurred Incident Severity (tick one) Time …………. Date ………….. Minor / Major/ Tier I/ Tier II/ Tier III

Brief details of incident and action taken. ………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………

WEATHER DATA

Wind Speed …..…………..… Wind Direction …….…….…. Sea State …………..….. Current Speed..………….….. Current Direction ..………..… Visibility ……………….… Sea Temperature ……….…… Air Temperature ……….….... Fog / Mist ………….…… Rain/Precipitation ….…………. Humidity ……………………... Cloud Cover .…….……..

OPERATION DATA

Type of Boom /Booms deployed…………... Total Length………….. In Depth ………. Power Pack Running hrs …..……………….. Skimmer Running hrs ……..............…… Oil Recovered from water …..…................… Lt / Tons Oil transferred ashore ……......................…. Lt / Tons Oil /Sludge cleared from shore …......….Kg. Sorbents pads used …….....….. Nos. O.S.D. used ……...............................Lt Saw Dust used……................… Kg.

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LOGISTICS AND MANPOWER

Number and type of vessel/boats available for assistance ………………………………Number and type of vehicles available for assistance ……………………………………Manpower utilized:

Fireman………….… Security Services men ….……... Casual Labourers……….. Others ………….

Signature…………………………………………………..….

Time……………… Date……………………………..…

On completion, this form is to be handed over to OSC, who in turn after his comments would hand over this form to Incident Controller, who in turn with his comments would forward it to IC. In absence of any OSC/ IC it may be handed over to ECR Team Leader directly.

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APPENDIX-18

TIME(24 hour clock)

COMMUNICATION(To / From)

ACTION / MESSAGE

PERSONAL LOG FORM

(To be forwarded to OSC (DGM Operations)

Form Completed By :

Name ……………………………………….

Designation ……………………………………….

Signed ……………………………………… Date ………./….……/……….

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APPENDIX-19

TIER-wise RESPONSE CONCEPT

Note: Oil spill – Tier I 700 tonnes of oil spill is classified as Tier I as per National / Coast Guard definitions. 700 Tons oil spills or even spills of lesser volume may involve calling out the ECT, seeking external support to handle the oil spills, handling media etc.

Incident Controller responsible for:1. Overall site operational incident response 2. Determining initial ’ Alert level (or Tier) of incident, and /or

potential incident escalation. 3. Ensuring necessary resources are available at site 4. Notifying, and communicating directly with, the ERT (if

required) 5. All DHAMRAPORT employee / contractor issues at site 6. Notifying, and communicating with regulatory authorities (if

required)

External Alert (TIER III) Crisis Situation

External Alert incidents are beyond site resources with potential to impact beyond IIL site limit, External assistance requited ERT leader inform Crisis, Response Team VP O&M

Site Alert (TIER II) Substantial Incident Site Alert incidents may impact entire site. ERT Duty Leader decision to call out ERT members. ERT Leader MUST notify ECT/IC.

Local Alert (TIER I) Minor Incident

Local Alert incidents require no external assistance and can be controlled using site resources. The ERT Leader MUST be notified but ERT will not be called out. Standard incident reporting.

TIER III Typical examples may include

1. Incident leading to multiple injuries or a fatality

2. Incident leading to loss of the facility

3. Incident leading to significant financial loss

4. Kidnap and extortion threat 5. Marine vessel (total loss) 6. Major oil spill >1000 tonnes

(7000 bbls) 7. Cyclone / flooding alert

within 12 hour. 8. Helicopter crash

TIER II Typical examples may include 1. Serious injury or illness requiring

evacuation 2. Marine Vessel / Helicopter SAR 3. Cyclone / flooding alert within 45

hour. 4. Civil unrest or security breach at

onshore plant or offshore platform

5. Process fire /or explosion 6. Kidnap 7. Oil spill between 100 and 1000

tonnes (700 – 7000 bbls)

TIER I Typical examples may include

1. Minor medical or injury requiring evacuation

2. Minor marine vessel incident ie loss of power.

3. Asset or equipment damage without loss of product

4. Cyclone / flooding alert within 72 hour.

5. Minor fire without injury or plant damage

6. Minor oils spills less then <100 tonnes (700 bbls)

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APPENDIX-20

COMMUNICATION CHANNELS

The communication channel between the Master of the vessel, OSC, Jetty Controller and the vessels operating under their directive would be Primary CH 16 and thereafter shift to desired channel. Although communication between vessel and the Jetty Controller is being established mostly on VHF as required, but more sets of VHF system are under stood to be under procurement by the ’s Marine department.

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APPENDIX-21

PRESS RELEASE FORMATINITIAL PRESS STATEMENT FORM-POLLUTION INCIDENT

Public Statement Number 1.

An oil spill occurred at ……..hours today at Off/onshore …………..

The location of the incident is ...... nm and ......nm. From Mundra Adani Port jetty N/S end and West Port Jetty N/S end …………………………………………

The situation is under control / not yet under control / out of control. The vessel involved in the incident / accident is in a stable and safe / unstable and unsafe condition. The Oil spill Response Team in being / has already been mobilized to deal with the situation. So far………litters / tones of Oil have been recovered.

Further statements will be issued in light of any further developments. The news media should contact PRO/ Media coordinator of the HMPL, Administrative Office for any additional information.

Signature ……………………………….Authorized Person of HMPL

Date ………………Time …………………

Place: ………..…..

NOTE: When Typed, this Form must be signed by the Emergency Control Team Leader and forwarded to appropriate authority. Under no circumstances the press statement be released to the NEWS Media without the approval of the concerned authority.

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APPENDIX-23

Annexure to NOSDCP Circular No. 02/2015

Guidelines for Net Environmental Benefit Analysis

The NEBA for oil dispersant is an assessment of positive and negative consequences of dispersant use, as compared to the use of other response techniques. Taking into consideration the biological resource and other socio-economics of the region. Such as the season, state of fisheries, economics and social values, and other biological resources.

The following documents are to be prepared before proceeding with the NEBA, in order to determine which resources may be damaged and which ones should be preserved:-

a) An inventory of the local sensitive resources. b) The vulnerability of the resources identified; and c) The definition of the importance of the resources identified.

The NEBA may be performed as follows: a) As a preliminary measure at the facility oil spill response plan development stage;

or b) In a specific situation during an oil spill.

A preliminary NEBA is preferred in order to reduce the time for decision-making.

The preliminary NEBA shall be performed for oil spill scenarios of 10 tons, and its exponential values up to and including the worst-case scenario. Each scenario will be supplemented with recommendations on practicability, from an ecological point of view, of dispersant usage or its prohibition.

Each potential oil spill scenario must address the following:-

a) Description of assets where oil spills are possible; b) Potential oil spill scenarios and spill volumes including worst case spill, physical

and chemical properties of oil, c) Result of mathematical simulation of oil spill behaviour on water (spreading,

possible drift directions, quantitative changes of oil, when presented on the sea surface, which occur due to evaporation and dispersion under the influence of wave energy and currents; amount of oil spill stranded onshore, oil remaining on the sea surface and penetrating into water column).

d) List of ecosystem components that exist within the action zone of the facility contingency plan, depending on the priority of their protection in the time of potential emergency scenarios, from the point of view of preserving national resources, and taking into amount their seasonal changes.

e) List of economically and socially valuable assets which require protection; f) Prioritization of the identified environmental and economical resources, decided

with the local stakeholders.

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g) Advantage and disadvantage of various available, in-place oil spill response methods including dispersion and an in-principle, assessment of the expected results of is possible response technique; dispersion, containment and recovery, monitoring for action; and

h) Impact of floating and dispersed oil on selected ecosystem components and state of the environment in general.

Both natural and economic resources should be considered. In general, endangered species, highly productive areas, sheltered habitats with poor flushing rates, and habits which take a long time to recover should receive top protection priority. The list should take into account factors like possible seasonal variations as well as the needed by each impacted resource to recover (demerge on a resource which can regenerate quickly is often more acceptable than damage to one which needs a very long restoration time). These factors will affect priorities.

Habitat and resources should be considered as a whole and not independently, as the decision to apply dispersant may benefit particular habitat. In term of species, the objective must be to protect the reproductive potential.

The NEBA for the use of dispersant in particular, must take the following into consideration:-

a) Consider the behaviour (drift and weathering) of the treated oil (drift according to the current and speed of dilation of the plume) and of the untreated oil (drift according to the current and wind);

b) Identify resources potentially affected by the treated oil untreated surface oil; c) Assess possible vulnerability of these resources (vulnerability = sensitivity +

restoration time); d) Rank these resources according to their vulnerability and/or importance and decide

on the priorities (what must be preserved, what could be sacrificed); e) Predict the possible impacts for the different response options (e.g. chemical

dispersion or not) and make a decision on the use of dispersants; f) In case of conflicting conclusions,

i. Preserve the habitat before the species, and ii. Preserve reproductive potential.

g) Where local birds are concentrated, accord special concern for application of dispersants to ensure that direct contact between dispersants and feathers of seabirds is absolutely avoided.

The NEBA results must include mapping of areas where dispersants should not be used according to different criteria (e.g. seasonal or at any time of year, tides or current, weather conditions, or the size of the spill – tier 1,2,3)

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The plot of valuable ecosystem components on environmental sensitivity maps and mathematical modelling of spilled oil behaviour constitutes the basis for a NEBA. The scenarios are to be supplemented with recommendations on practicability, from an ecological point of view, of dispersant usage or its prohibition. The scenarios are to be then included in the relevant facility oil spill contingency plan.

Consequent to conduct of NEBA, consideration of certain response options may be immediately ruled out because of their ineffectiveness in the given conditions and,

others ranked in terms of effectiveness and preference. The use of different techniques may be recommended for different parts of the slick. With respect to chemical dispersion, the recommendation must indicate whether it is possible or impossible to use dispersants in a given situation or which parts of the slick should be treated with dispersants.

At the time of an actual spill, approval for the use of dispersants will be given based on positive results of NEBA. Also, decision will be made on the basis of the NEBA, with adjustment if the real spill situation differs significantly from the pre-studied scenarios.

The NEBA results must be documented in a report approved by the relevant pollution control board, or environment ministry.

NEBA is a time intensive process. It is required to be conducted on scientific basis by a team of stakeholders, which preferably includes specialists in several fields (e.g. ecology; bird, mammal, fish, and benthos biology: mathematical modelling of the behaviour of spilled oil). Running the scenarios will be require specialized models designed for impact assessment.

NEBA for HMPL:

As per circular 2/2015 of CG, NEBA is a comparison of positive and negative consequences of dispersant use compared to other response options.

As per the International guidelines, the dispersants are not advised to be in use in less than 20 mtrs of water depth. However HMPL SPM is located at about 06 km away from Land Fall Point (LFP) at sea, the SBM is in 30 + mtrs of water depth and the water contours for 20 mtrs line is between the SBM and the coast line. As the water contours for 20 mtrs line is very far from SPM and chances of reaching the oil patches &crossing 20 mtrs depth contours line is very less. In view of above distance ,HMPL OSR team has enough time to prevent the patches to cross before 20 mtrs depth contour line by it’s well equipped OSR resources . Also HMPL has a Mutual Aid Agreement with Mundra port therefore in case of any exigency at off-shore as well as on-shore , Mundra port is also capable to prevent spilled oil by their boats and OSR resources.

When the spill takes place near SBM, as per chapter 2 on risk assessment, the likely areas affected by the oil spill during various seasons are given below:

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Spill Analysis

Pre monsoon(April)-During Spring Tide

Spill Location Spill quantity (t)

Losses (t)

Time taken to reach port /open boundaries (hours)

Amount of oil on surface (tones)

Remarks

SPM 158t Crude oil 90 20 68 Reaching Mundra coast

Pipe line leakage 79 t Crude oil 46 20 33 Reaching Mundra coast

Collision/Grounding 1000 t Crude oil

450 20 550 Reaching Luni in northern side of Gulf

Monsoon(Jul)-During Spring Tide

Spill Location Spill quantity (t)

Losses (t)

Time taken to reach port /open boundaries (hours)

Amount of oil on surface (tones)

Remarks

SPM 158t Crude oil 105 35 53 Reaching Luni in northern side of Gulf

Pipe line leakage 79t Crude oil 45 35 34 Reaching Luni in northern side of Gulf

Collision/Grounding 1000 t Crude oil

530 35 470 Reaching Luni in northern side of Gulf

Post Monsoon(Oct)-During Spring Tide

Spill Location Spill quantity (t)

Losses (t)

Time taken to reach port /open boundaries (hours)

Amount of oil on surface (tones)

Remarks

SPM 158t Crude oil

105 35 53 Crossing eastern open boundary

Pipe line leakage 79t Crude oil 45 35 34 Crossing eastern open boundary

Collision/Grounding 1000 t Crude oil

530 35 470 Crossing eastern open boundary

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Table 4.3 Spill landing Position and locations

Pre-Monsoon (April)

Spill Location Tide condition

Time taken to reach coast/port boundary(hrs)

Landing Position (Lat. & Long.) and Location

158t Crude oil at SPM Spring 25 Reaching Mundra coast in northern side of Gulf

9500 m3/h for 30 sec., Crude oil along pipe line

Spring 25 Reaching Mundra coast in northern side of Gulf

1000t Crude oil at SPM

Spring 25 Reaching Mundra coast in northern side of Gulf

Monsoon (July)

Spill Location Tide condition

Time taken to reach coast/port boundary(hrs)

Landing Position (Lat. & Long.) and Location

158t Crude oil at SPM

Spring 30 Reaching Luni area, in northern side of Gulf

9772 m3/h for 30 sec., Crude oil at along pipeline

Spring 30 ,,

1000t Crude oil at SPM

Spring 30 ,,

Post-Monsoon (Oct)

Spill Location Tide condition

Time taken to reach coast/port boundary(hrs)

Landing Position (Lat. & Long.) and Location

158t Crude oil at SPM Spring 35 Crossing eastern open boundary

9772 m3/h for 30 sec., Crude oil along pipe line

Spring 35 ,,

1000t Crude oil at SPM

Spring 35 Crossing eastern open boundary

Percentage of spill quantity (tonnes) reaching the coast/open boundaries

Spill volume Pre monsoon (April)

Monsoon(July)

Post monsoon (Oct)

158 t Crude oil at SPM 56 53 53 Crude oil spill of 79 T along the pipeline corridor

60 56 56

1000t Crude oil at SPM 62 64 64

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Extent of oiling on coast/open boundary, metres

Spill volume Pre monsoon (April)

Monsoon(July)

Post monsoon (Oct)

158 t Crude oil at SPM 1200 1400 1400 Crude oil spill of 79 T along the pipeline corridor

1000 1200 1200

1000 T Crude oil at SPM 2400 2800 2800

Current direction and speed in port and near the SBM in different months/seasons.

Speed and Direction of Surface Current at SPM Location at 34 Mtr Depth Month/Year Maximum surface Current

(in Knots) Direction of Current

Jun-13 3.04 129 Jul-13 2.69 097 Aug-13 2.63 097 Sep-13 2.09 284 Oct-13 2.35 105 Nov-13 2.49 118 Dec-13 2.92 084 Jan-14 3.17 089 Feb-14 2.89 079 Mar-14 2.71 250 Apr-14 2.56 080 May-14 2.62 071 Jun-14 2.03 221

It can be considered that majority of the spills, we can contained at the site with the help of conventional OSR system by HMPL and also utilising OSR of Mundra port and facility as per Mutual Aid Agreement. The following types of areas are not recommended to be used for OSD spray, as per IMO vol 4 on oil spill response:

Where there is no wave energy available to mix the OSD with spilled oil, for examples, mudflats, marshes and mangroves etc

Luni beach has been identified by Fisheries department as a fishing area and would get badly affected if OSDs are dispersed. However, in post monsoon time commencing October, the spill has a tendency to go out in the sea, thus not creating any environmental hazard to anyone. However HMPL OSR team is well equipped & capable to prevent the oil patches before reaching the Luni beach in pre monsoon also as detailed in Section 2.6.

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Hence, the response options available to HMPL are as below:

1. Immediate use of OSDs for spills near SBM and just monitoring in post monsoon time.

2. During the pre monsoon and monsoon times, try to contain as much spill as possible by quick technical means & spray of sufficient OSD. A close watch to be kept for monitoring oil spill movement & it’s prevention to reach coast line and also to prevent massive problems to the fishing community in Luni and Mundra coastline. However HMPL has own well equipped OSR facility &also HMPL has a Mutual Aid Agreement with Mundra port therefore in case of any exigency we will be capable to contain the spilled oil before hitting the Luni beach and other part of Mundra coast line.

3. If oil is not dispersed, HMEL may have to use shore sealing booms to contain the oil and recover it.

4. In case, the spill is within the 20 mtr waterline, HMEL will have to use booms and skimmers (Conventional mechanical OS response) for collecting as much oil, as possible and then treating the leftover on the coastline with PRP.

However, during the shoreline survey carried out by HMPL along with M/s Viraj, it has been observed that the following areas near Luni and Mundra coast are reachable from the Off-shore side very easily and hence apart from land resources any response there will be carried out by boat will very simple& advisable :

1. P-19 Actual point 22 46 14 15 N 69 43 40 08 E (Actual Point) 13 KM from Mundra- towards Luni Village. By vehicle 6 KM inside the village towards shoreline – And by walk 2 KM. land mark Luni Village. Area to be protect Fishing area, Birds, mangroves. Equipment can’t be transported till the shoreline

2. P-20 Actual point 22 46 52 54 N 69 44 12 38 E (Actual Point) How to Reach, 13 KM from Mundra towards Luni Village / shoreline. By vehicle 6 KM inside the Luni Village and 01 KM towards concrete house- and by walk 02 Km. shore line features sandy, rocky and muddy. Distance approx 05 KM from shoreline to Sea. Equipment can’t be transported till the point. Manual clean ship

In light of the above explanations, it can be inferred that for any spill near SBM or surrounding area, OSD application, as the first line of oil spill response, is the best environmental friendly option and the HMEL chartered and Adani port vessels are already fitted with these systems.

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APPENDIX-24

MUTUAL AGREEMENT BETWEEN HMPL & ADANI PORT

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APPENDIX-25

Appendix E5 to NOSDCP 2015 (Para 4.5 refers)

Contingency Planning Compliance Checklist

NAME OF PORT/OIL HANDLING AGENCY HPCL MITTAL PIPELINES LTD, MUNDRA KUTCH GUJARAT

DESCRIPTION COMPLIED YES/NO

REMARKS

RISK ASSESSMENT

1 Whether the facility produces / handles / uses / imports/store any type of petroleum product

Yes Imports of Crude oil, store in COT and transferring to refinery through underground pipeline

2 Whether risk assessment is done Yes July 2008 3 Who did the risk assessment By National Institute of

Oceanography4 Whether maximum volume of oil spill that can occur

in the worst case scenario is consideredYes 158 ton/min at 9772

m3/hr pumping rate 5 Whether relative measure of the probability and

consequences of various oil spills including worst case scenario are taken into account

Yes Refer Chapter 2, S No. 2.1 on Page No. 13

6 Whether all types of spills possible in the facility are considered including Grounding, Collision, Fire, Explosion, Rupture of hoses

Yes Refer Chapter 2 S No. 2.1.1 on Page No. 13

7 Please specify the list of oils considered for risk assessment

Refer Chapter 2 S No. 2.2 on Page No. 14

8 Whether the vulnerable areas are estimated by considering maximum loss scenario and weather condition

Yes Refer Chapter 2, Page No. 18

9 Whether impacts on the vulnerable areas are estimated by considering maximum loss scenario and Weather condition

Yes Refer Chapter 2, Page No. 19

10 Whether measures for reduction of identified high risk are included by reducing the consequences through spill mitigation measures

Yes Refer Chapter 2, S No. 2.6, Page No. 21

11 Whether steps have been considered to reduce risks to the exposed population by increasing safe distances by acquiring property around the facility, if possible

Yes Refer Chapter 3, Page No. 23

12 Whether risk levels are established for each month after considering the probability with tide and current and consequences of each such spill

Yes Refer Appendix 03, Page 56

13 Whether prevention and mitigation measures are included in the plan

Yes Refer Chapter 3, S No. 3.3, 3.4 & 3.5

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14 Whether the spill may affect the shoreline. (length of the shoreline with coordinates)

Yes Refer Appendix 05, Page 64 & Appendix 23, 92

15 Whether time taken the oil spill to reach ashore in each quantity of spill in various months are mentioned in the plan

Yes Refer Chapter 3, Page 22

16 Whether sensitivity mapping has been carried out Yes Refer Chapter 2, S No. 2.5, Page 21 & Appendix-05, Page No. 63

17 Does the sensitivity mapping clearly identify the vulnerable areas along with MPAs, corals, fishermen community, saltpans, mangroves and other socioeconomic elements in the area

Yes

18 Do the sensitivity maps indicate area to be protected on priority

Yes

19 Does the map indicate boom deployment locations

20 Whether any Marine Protected Area will be affected

No

21 Whether total number of fishermen likely to be affected is mentioned in the plan

No

22 Whether any saltpan in the area is going to be affected

No.

23 Whether any mangroves in the area will be affected by a spill

Yes Refer location Chapter 02, S No. 2.6 on Page 21

Preparedness

24 Whether any containment equipment is available Yes 1050 Mtr Boom

25 Whether any recovery equipment is available Yes 05 No. 150 TPH

26 Whether the facility is having any temporary storage capacity

Yes Floating Tank – 75 Ton Open Storage Tank – 20 Ton

27 Whether location of the oil spill response equipment is mentioned in the plan

Yes Refer APPENDIX-09

28 Whether suitable vessels available for deploying the boom, skimmer etc.

Yes

29 Whether OSD held with facility Yes 5000 Ltr

30 Whether the OSD held with the facility is approved for use in Indian waters

Yes

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31 Whether the facility has MoU with other operators for tier-1 preparedness

Yes Refer Chapter 1, S No. 1.4, Page No. 11

32 Whether the list of oil spill response equipment available with each agency in MoU is deliberated

Yes Refer Chapter 1, S No. 1.4, Page No. 11

33 Whether the facility has any MoU with private OSRO Yes Refer Chapter 1, S No. 1.4, Page No. 11

34 Whether the procedure for evoking the mutual aid is clearly described in the plan

Yes

35 Whether additional manpower is available Yes Chapter 05, S No. 5.4 36 Whether list of approved recyclers is mentioned in

the planYes Appendix 08, S No. 30,

Page 71 37 Whether NEBA (Net Environmental Benefit

Analysis) has been undertakenYes Appendix 23 Page 89

38 Whether the areas from priority protection have identified in the plan

Yes Refer Chapter – 02, S No. 2.5

39 Whether relevant authorities and stakeholders ware consulted for NEBA and during the areas for priority protection

Yes

40 Whether District administration has been appraised of the risk impact of oil spills?

Yes Being appraised

Action plan

41 Whether the plan outlines procedure for reporting of oil spills to Coast Guard

Yes Refer Chapter 7, S No. 7.1, Page No. 40 Appendix 10 & Appendix 14, Page No. 77

42 Whether the oil spill response action is clearly mentioned

Yes Refer Chapter 7

43 Whether the action plan includes all duties to be attended in connection with an oil spill

Yes Refer Appendix - 02

44 Whether the action plan includes key personnel by their names and designation viz. C/C, S/C

Yes Refer Chapter 05, S No. 5.2, Page 29

45 Whether alternate coverage is planned to take care of the absence of a particular person {in cases where action plan is developed basis names}

Yes Refer Chapter 5

46 Whether the plan includes assignment of all key coordinators viz. the Communication Controller, safety Coordinator, Emergency management team, Administration and Communication Coordinator and Safety Coordinator

Yes Refer Chapter 5

47 Whether contact directory containing numbers of key response and management personnel is intimate in the plan

Yes Refer Appendix - 14

48 Whether approved recyclers are identified for processing recovered oil and only debris

Yes Kutch Petroleum, Gandhidham

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49 Whether the shoreline likely to be affected is identified

Yes Refer Page – 02, S No. 2.5

50 Whether final report on the incident is submitted CGHQ as per NOS-DCP 2014

Yes Submitted with NIL incident remark

51 Whether the spills incident and its consequences are informed to fishermen and other NGOs for environment protection through media

Yes Refer Appendix 21, Page 88

Training and Exercises

52 Whether mock fire/emergency response drills are specified in the plan

Yes yes, Refer periodicity emergency response drills- Appendix 12 & Chapter 5, S No. 5.6 Page 33

53 Whether the mock drills cover all types of probable oil spills

Yes

54 Whether the plan mentions list of trained manpower Yes Refer Chapter 5, S No. 5.6 Page 33

55 Whether records for periodic mock drills are maintained in a well defined format

Yes

56 Whether the plan to updated according to the findings in mock-drills and exercise

Yes

57 What is the frequency of updating/ review of contingency plan?

Yearly

58 Periodicity of joint exercise with mutual aid partners Yes With Mundra Port 59 Frequency of mock-drills for practice Half Yearly 60 Whether the records for periodic mock drills are

maintained in a well defined formatYes Separate file

61 Whether the plan is updated according to the findings of mock-drills and exercises

Yes

62 Frequency of updating/ review of contingency plan Yearly, Page No. 02

I, hereby, declare that the all information appended above and true and correct to my knowledge or belief.

Date: Chief Conservator /installation ManagerVERIFIED

Date: (District Commander ICG)

Of his representative

Date : (Regional Commander ICG) Or his representative

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APPENDIX-26

ABBREVIATIONS

(i) HMPL HPCL Mittal Pipelines Ltd. (ii) COT Crude Oil Terminal (iii) VLCC Very Large Crude Carrier (iv) DWT Dead weight Tonnage (v) SPM Single Point Mooring (vi) LOA Length Over All (vii) OCIMF Oil Companies International Marine Forum (viii) SWL Safe Working Load (ix) NIO National Institute of Oceanography (x) IC Incident Controller (xi) ECT Emergency Control Team (xii) OSR Oil Spill Response (xiii) ERT Emergency Response Team (xiv) OSC On Scene Commander (xv) HSE Health Safety Environmental (xvi) NSPC Navigational Safety Ports Committee (xvii) NOSDCP National Oil Spill Disaster Contingency Plan (xviii) SEZ Special Economic Zone (xix) LFP Land Fall Point (xx) HSD High Sulphur Diesel (xxi) DMP Disaster Management Plan (xxii) GMB Gujarat Maritime Board (xxiii) GPCB Gujarat Pollution Control Board (xxiv) OSD Oil Spill Dispersant (xxv) TPH Ton per Hour (xxvi) HDPE High Density Poly Ethylene (xxvii) IMO International Maritime Organisation (xxviii) OSCP Oil Spill Contingency Plan (xxix) OSHA Occupational Safety and Health Act (xxx) PFD Personal Floatation Device (xxxi) MSDS Material Safety Data Sheet (xxxii) VHF Very High Frequency (xxxiii) MMB Mercantile Marine Band (xxxiv) OSRO Oil Spill Response Organisation (xxxv) OEM Original Equipment Manufacturer (xxxvi) IMD India Meteorological Department (xxxvii) OPRC Oil Pollution Preparedness Response & Cooperation (xxxviii) CRZ Coastal Regulation Zone (xxxix) POLREP Pollution Report (xl) NEBA Net Environmental Benefit Analysis