AGP, MARINE SERVICES AND GENERAL

TRANSPORTATION

Contingency Plan / Oil Spill Response Plan

The Contingency Plan is intended to provide responses and examples of

contingency planning as a reference when a facility determines that the
required secondary containment, present at sight or on the Containment /
transfer location is impracticable. The Contingency Plan presents a variety of
scenarios for purposes of illustration only. It is not an absolute template to be
adopted by a facility, nor is the plan a template that must be followed in order
for the facility to be considered in compliance with the contingency plan
requirement. This plan and its credentials are required to be reviewed by the
Responsible person decreed by the organization .This plan is compiled and is
to be referred in tandem with the Class approved Ships STS plan for the
involved entities.
 AGP (ARABIAN GULF PEARL)
MARINE SERVICES AND GENERAL TRANSPORTATION
OIL SPILL CONTINGENCY PLAN

PART I
Introduction
1.1 Purpose and Scope
This Oil Spill Contingency Plan is prepared in accordance with required rules to address
areas of the Operation where the risk of an accident is high and probable.

The purpose of this Oil Spill Contingency Plan (“Contingency Plan”) is to define
procedures and tactics for responding to unintentional discharges of oil including and not
limited into navigable waters or adjoining shorelines of the Iraqi Waters, The
Contingency Plan is implemented whenever the oil is discharged into the environment
unintentionally.

The objective of procedures described in this Contingency Plan is to protect

environment, the public, AGP personnel, and other responders during oil discharges. In
addition, the Plan is intended to minimize damage to the environment, natural
resources, and facility installations from a discharge of oil. This Oil Spill Contingency
Plan is meant to be addressing areas of the operation that have inadequate secondary
containment(For Tier 2 and 3) and impacts that may result from a discharge in these
areas.

AGP – Oil Spill Response Plan, Version 1

1.2 Resources at Risk
This plan intends to cover the STS operations of which AGP forms a part by rendering
expertise and support required to mitigate the risks and create an action plan to contain
the damage of the event.

1.3 Risk Assessment

AGP ensures that the RA is created and reviewed by all parties for each STS operation
covering the Job specific risks such as age of the vessel , level of experience and
expertise of the professionals in the job , Weather forecast , Pumping capacity of the
vessels involved , Sensitivities of the geographic location and much more . The RA
prepared is then further reviewed by the Mooring masters and the vessel Masters to
ensure that it is simple , practical and S.M.A.R.T (Specific, Measurable, Achievable,
Relevant, and Time- Bound).
Risk calculation on tanker ships involves assessing various factors to ensure the safety of
operations. The ALARP (As Low As Reasonably Practicable) principle is a risk
management concept that aims to minimize risks to a level that is both practical and
feasible. In the context of tanker ships, risk assessment often involves the use of risk
matrices. The Risk is calculated and mitigated with the following guidelines:

1. **Risk Matrix:**
- A risk matrix is a tool used to assess and prioritize risks based on their likelihood and
consequences. It typically consists of a grid where the likelihood of an event is plotted on
one axis, and the consequences of that event are plotted on the other axis.
- The matrix is divided into different zones or levels, each corresponding to a different
level of risk. Common risk levels include low, medium, high, and extreme.

2. **ALARP Principle:**
- The ALARP principle is a risk management guideline that suggests that risks should be
reduced to a level that is as low as reasonably practicable, taking into account factors
such as cost, time, and effort.
- The goal is not necessarily to eliminate all risks but to reduce them to an acceptable
level, considering the overall context.

3. **Risk Calculation on Tanker Ships:**

- In the context of tanker ships, various risks can be identified, including but not limited to:
- Cargo-related risks (e.g., hazardous materials).
- Navigation and collision risks.
- Operational risks (e.g., maintenance and crew training).
- Environmental risks (e.g., oil spills).
- Regulatory compliance risks.

- The risk assessment process typically involves:

- Identifying potential hazards.
AGP – Oil Spill Response Plan, Version 1
 - Assessing the likelihood and consequences of each hazard.
- Using a risk matrix to categorize and prioritize risks.
- Evaluating current risk control measures.

- The ALARP principle guides AGP’s decision-making in selecting and implementing risk
control measures. It involves finding a balance between the cost and effort associated
with risk reduction and the level of risk that is deemed acceptable.

4. **Implementation of Risk Control Measures:**

- After the risk assessment, appropriate risk control measures are implemented to
mitigate identified risks.
- These measures can include engineering controls, administrative controls, and
procedural controls.
- Continuous monitoring and review of these measures are essential to ensure they
remain effective and relevant.

5. **Regulatory Compliance:**
- Tanker ships are subject to various international and national regulations, such as the
International Maritime Organization's (IMO) regulations.
- Compliance with these regulations is crucial for minimizing risks, and failure to comply
can lead to significant consequences.
AGP ensures that the risk calculation on tanker ships involves a systematic assessment
using risk matrices and aligning risk control measures with the ALARP principle. The goal
is to ensure the safety of operations while taking into account practical and feasible
considerations.
The RA will always be used along with the Contingency checklists from the involved
vessels companies safety management system. Please find a ref RA at the end of this
document to be used as ref for all the STS operations

1.4 Response Strategy

AGP, on various occasions may involve personnel and contractors that are equipped
and trained to respond to certain discharges confined within the facility (Vessel). Minor
discharges can generally be described as those where the quantity of product
discharged is small(Tier 1 - Upto 40 Litre or 0.04 M3 ), the discharged material can be
easily stopped and controlled, the discharge is localized, and the oil is not likely to seep
overboard or reach surface water or adjoining shorelines. Procedures for responding to
these minor discharges are covered in the Ship Specific plans including but not limited
to the action plan mentioned in the Company SMS for the vessels involved.

This Contingency Plan addresses all discharge incidents, including those that affect
navigable waters or during which the oil cannot be safely controlled by facility personnel
and confined within the boundaries of the facility. Response to such incidents may
necessitate the assistance of outside contractors or other responders to prevent
imminent impact to navigable waters.

AGP – Oil Spill Response Plan, Version 1

 PART II
Spill Discovery and Response
2.1 Distribution of Responsibilities
AGP and its Subcontractors (If any) hold the primary responsibility for providing the
initial response to oil discharge incidents during the STS operation. To accomplish this,
AGP has designated the ERS(Emergency Response Squad) Leader , Mr Omar - +964-
781-999-1990, as the oil discharge Response Coordinator (RC) in the event of an oil
discharge.

The RC plays a central coordinating role in any emergency.

The RC has the authority to commit the necessary services and equipment to respond to
the discharge and to request assistance from Govt fire and/or police departments,
contractors, or other responders, as appropriate.

The RC in close co-ordination with the vessels master will direct notifications and initial
response actions in accordance with training and capabilities. In the event of a fire or
emergency situation that threatens the health and safety of those present at the site, the
RC will direct evacuations and contact the capable Tugs and fire, Medical teams and
police departments.

In the event of an emergency involving outside response agencies, the RC’s primary
responsibility is to provide information regarding the characteristics of the materials and
equipment involved and to provide access to AGP resources as requested. The RC
shall also take necessary measures to control the flow of people, emergency
equipment, and supplies and obtain the support of the Govt Agencies such as Fire and
Police Department as needed to maintain control of the site. These controls may be
necessary to minimize injuries and confusion.

Finally, the RC serves as the coordinator for radio communications by acquiring all
essential information and ensuring clear communication of information to emergency
response personnel. The RC has access to reference material at the field office either as
printed material or on computer files that can further assist the response activities.

AGP – Oil Spill Response Plan, Version 1

Whenever circumstances permit, the RC transmits assessments and recommendations
to AGP Senior Management for direction. Senior Management is contacted in the
following order:

(1) Mr Maher Faisal - +964-781-169-1912

(2) Capt Hazim Ahmed - +964-780-102-9330 (Lead – Management )

In the event that the Field Operator is not available or incapacitated, the responsibility
and authority for initiating a response to a discharge rests with the most senior AGP
employee on site at the time the discharge is discovered (Crew Lead) or with the
contractor Field Supervisor (or next person in command) if contractor personnel are the
only personnel on site.

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2.2 Response Activities
In the event of a discharge, the first priority is to stop the product flow and to shut off all
ignition sources, followed by the containment, control, and mitigation of the discharge.
This Contingency Plan breaks actions to be performed to respond to an oil discharge
into different phases, described in greater detail in the checklists below.

2.2.1 Discharge Discovery and Source Control

Tier 1 Discharge. (Qty >/= 0.04 M3 )A minor discharge (i.e., small volume leak tanks or
other equipment) will be discovered by Ships or AGP personnel or by contractor personnel
during routine watchkeeping. All Transfer lines/Tanks are visually inspected formally once
a watch during the normal inspection rounds. Vessels SOPEP units and facilities will be
deployed to mitigate and contain the Spill. A detailed record of the events will be
maintained with objective evidences to ensure that the chain of events is well accounted
for the critique in the final summery

Tier 2 Discharge. (Qty < 0.04 M3 but Less than 50 M3 ) A more severe and sudden
discharge will constitute a shut down of the pumping units.
AGP will initiate the in standby unit,
Additional Tug Crown 7 (IMO no – 9287390), can he called by the RC { Capt Tushar
Gupta(+971-521682378) } who will direct the Tug for the required assistance in
consultation with the Vessels master and the RC at the earliest and the operation specific
plan in consultation with the operation specific ready reckoner RA.This will also imply the
deployment of the AGP in house which are available on immediate basis. A detailed
record of the events will be maintained with objective evidences to ensure that the chain
of events is well accounted for the critique in the final summery

Tier 3 Discharge. (Qty equal to or more than 50 M3 ) In Addition to the measures

initiated in Tier 1 and Tier 2 , AGP may involve with the 3rd party assistance by the use of
the below mentioned agency to fight the cause and limit the damages. The below agency
will also assist in proving the additional manpower needed to contain and limit the
damages caused or may be caused
Demuzi General Trading and Marice services LLC
Baghdad Iraq
Contact – Mr Adnan Al Khdhairi +964-781-999-2990(Direct)
Office - +964-781-999-1990
+964-781-100-1922

A detailed record of the events will be maintained with objective evidences to ensure
that the chain of events is well accounted for the critique in the final summery

AGP – Oil Spill Response Plan, Version 1

 Notifications to the National Response Center, must occur immediately upon discovery of
reportable discharges using the forms provided on the AGP , These forms are to be used
with the forms and reporting requirements mentioned in the Class approved STS plan for
the vessels in operation

Completed Actions
Immediately report the discharge to the RC, providing the following information:
• Exact location;
• Material involved;
• Quantity involved;
• Topographic and environmental conditions;
• Circumstances that may hinder response; and
• Injuries, if any.
Turn off all sources of ignition.
Turn off lift pumps
Locate the leak.
If safe to do so, isolate the affected section

AGP – Oil Spill Response Plan, Version 1

2.2.2 Assessment and Notifications

Completed Actions
Investigate the discharge to assess the actual or potential threat to human health
or the environment:
• Location of the discharge relative to receiving waterbodies.
• Quantity of spilled oil.
• Ambient conditions (temperature, rain);
• Other contributing factors such as fire or explosion hazards; and

Request outside assistance from local emergency responders, as needed.

Evaluate the need to evacuate facility and evacuate employees, as needed.
Notify the fire/police departments to assess whether community evacuation is
needed.
Notify immediately:
• National Response Center
• Response contractor(s) – To be done by the RC
• Emergency teams– To be done by the RC
• Coast guard +96-4780-705-0232- To be done by the Tug /Vessel’s Master

Communicate with neighboring vessels regarding the discharge and actions taken
to mitigate the damage.
If the oil reaches (or threatens to reach) the Shore, notify the local fire/police
departments to limit access to the water by local residents until the oil has been
contained and recovered.

2.2.3 Control and Recovery

The RC directs the initial control of the oil flow by documented procedures

AGP – Oil Spill Response Plan, Version 1

If the oil has not yet reached water:

Completed Actions
Deploy sand bags and absorbent socks downgradient from the oil, or erect
temporary barriers such as trenches or mounds to prevent the oil from entering
Water. Initiate Clean up and Standby FFA Equipment
Implement land based response actions (countermeasure) such as
Confirming the closure of the boom openings, and suctions facility at the boom
Mouth when practicable
Deploy absorbent sock and sorbent material along the shoreline to prevent oil
from entering waters.

If the oil has reached water:

Completed Actions
Clean up and Standby FFA Equipment
Deploy floating 2nd layer booms immediately based on the tide from the release
point.

Control oil flow on the vessel by placing absorbent socks and other sorbent
material or physical barriers (e.g., “kitty litter,” sandbags, earthen berm, trenches)
across the oil flow path.
Deploy additional floating booms across the whole width the release point.

Deploy protective booming measures for receptors that may be impacted by the
spill.

2.2.4 Disposal of Recovered Product and Contaminated Response Material

The RC ensures that all contaminated materials classified as hazardous waste are
disposed of in accordance with all applicable solid and hazardous waste regulations.

Completed Actions
Place any recovered product that can be recycled into the gun barrel tank to be
separated and recycled.
Dispose of recovered product not suitable for on-site recycling with the rest of the
waste collected during the response efforts.

AGP – Oil Spill Response Plan, Version 1

 Collect all debris in properly labeled waste containers (impervious bags, drums, or
buckets).
Dispose of contaminated material in accordance with all applicable solid and
hazardous waste regulations using a licensed waste hauler and disposal facility,
after appropriately characterizing the material for collection and disposal.
Dispose of all contaminated response material within 2 weeks of the discharge.

2.2.5 Termination

The RC ensures that cleanup has been completed and that the contaminated area has
been treated or mitigated according to the applicable regulations and state/federal
cleanup action levels. The RC collaborates with the local, state and federal authorities
regarding the assessment of damages.

Completed Actions
Ensure that all repairs to the defective /Damaged equipment / section have been
completed.
Review circumstances that led to the discharge and take all necessary
precautions to prevent a recurrence.
Evaluate the effectiveness of the response activities and make adjustments as
necessary to response procedures and personnel training.
Carry out personnel and contractor debriefings as necessary to emphasize
prevention measures or to communicate changes in operations or response
procedures.
Submit any required follow-up reports to the authorities.
Within 30 days of the discharge, the RC will convene an incident critique including
all appropriate persons that responded to the spill. The goal of the incident
critique is to discuss lessons learned, the efficacy of the Contingency Plan and its
implementation, and coordination of the plan/RC and other state and local plans.

Within 60 days of the critique, the Contingency Plan will be updated (as needed)
to incorporate the results, findings, and suggestions developed during the critique.

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2.3 Discharge Notification
Instructions and phone numbers for reporting a discharge to the National Response
Center and other state, and local authorities are provided in to this Plan. Any discharge to
water must be reported immediately to the required entity. The Response Coordinator
must ensure that details of the discharge are recorded on the Discharge Notification Form
provided

AGP – Oil Spill Response Plan, Version 1

 PART III
Response Resources and Preparedness Activities
3.1 Equipment, Supplies, Services, and Manpower
Spill kits are provided in a safe and protected location that is accessible by AGP
personnel on demand .Response equipment and material present at the site include:
20pc - Empty drums to hold contaminated material
50pc - absorbent socks
2 Pc - 800mtr sections of hard skirted deployment boom
500 Kgs- “Oil-dry” Loose absorbent material
2 ft x 3 ft absorbent pads
20 Pc Chemical / Neoprene gloves
20 Pc Chemical/Vinyl/PVC pull-on overboots
Sufficient for the clean up crew
20 Non-sparking shovels
20 Brooms
50 Sand bags
10 Combustible Gas Indicator with H2S detection capabilities with
Annual service reports

Above list is not exhaustive but indicates the min required Quantities needed to be on stand by at all times.
Location of the above items is in IRAQ , ALFAW port.

This material is sufficient to respond to discharges occurring and to initially contain a

major discharge while waiting for additional material or support .The inventory is verified
on a 3 monthly basis during the scheduled safety inspection by designated personnel
and is replenished as needed.
Additional material and equipment will be arranged My Demuzi General Trading and
Marine services Company LLC as needed .
Demuzi will arrange additional man power to respond for an accidental oil discharge.
Personnel may be assisted by additional employees from the various sources. All
employees are familiar with the equipment layout, location of spill response equipment
and response strategies, and with the RA and STS Plan for the specific operation.

To respond to larger discharges and ensure the removal and disposal of cleanup debris,
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AGP has established discussions with waste contractors: Sea crown Marine Services
Phone No.:-009647809292588 ,to handle the clean up waste .

The Port has agreed to allow access to AGP personnel and contractors for response
and maintenance purposes. Although no further approval is needed prior to the
deployment of response equipment, the RC will contact the needed as necessary to
inform them of activities being carried out.

Communications and Control

A central coordination center will be set up at the field office in the event of a discharge.
The field office is equipped with a variety of fixed and mobile communication equipment
(telephone, fax, cell phones, two-way radios, computers) to ensure continuous
communication with AGP management, responders, authorities, and other interested
parties.

Communications equipment includes:

 Portable hand-held radios. AGP maintains a two-way base station and four
portable radio units. These radio units are kept at the field office as part of the
response equipment. Local emergency responders have been provided with the
response frequencies that will be used during an incident.
 Cell phones. Each field vehicle and the RC are provided with a cell phone. The RC
and/or his alternate (Site Supervisor when the Field Operations Manager is not “on
call”) can be reached by cell phone 7 days a week, 24 hours a day.
 Additional equipment. Additional equipment will be obtained in the event that more
communications equipment is necessary.

The RC is responsible for communicating the status of the response operations and for
sharing relevant information with involved parties, including local, state, authorities.

In the event that local response agencies On Site Coordinator (OSC) assumes Incident
Command, Usually the master of the Vessel who will be guided over the phone.

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 APPENDIX A
EMERGENCY CONTACTS
Facility Operations

Mr Omar Al +964-781-999-1990
Ahemed
(1) Mr Maher +964-781-169-1912

Faisal
(2) Capt Hazim +964-780-102- 9330
Ahmed - (Lead –
Management )

Local Emergency Responders

Demuzi General Trading

and Marice services LLC
Baghdad Iraq
Contact – Mr Adnam Al
Khdhairi +964-781-999-
2990(Direct)
Office - +964-781-999-1990
+964-781-100-1922

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 APPENDIX B
DISCHARGE NOTIFICATION PROCEDURES
Circumstances, instructions, and phone numbers for reporting a discharge to the National
Response Center and other state, and local agencies, and to other affected parties, are to be
provided by the Field Ops manager . They are also posted at the facility in the storage shed
containing the discharge response equipment. Note that any discharge to water must be reported
immediately to the National Response Center.

Field Operations Manager, (24 hours)

Mr Omar Al Ahemed +964-781-999-1990

All the reporting requirements to be followed as per the latest issue of ALRS and the
Local regulations to be guided by the field operations Manager. Additionally the involved
ship’s master will carry out the mandatory reporting as per the ships contingency plan and
the Approved STS Plan.

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 AFTER INCIDENT REPORTING AND RECORDS
MANAGEMENT
The person reporting the discharge must provide the following information:

 Name, location, organization, and telephone number

 Name and address of the owner/operator
 Date and time of the incident
 Location of the incident
 Source and cause of discharge
 Types of material(s) discharged
 Total quantity of materials discharged
 Quantity discharged in harmful quantity (to navigable waters or adjoining
shorelines)
 Danger or threat posed by the release or discharge
 Description of all affected area
 Number and types of injuries (if any) and damaged caused
 Weather conditions
 Actions used to stop, remove, and mitigate effects of the discharge
 Whether an evacuation is needed
 Name of individuals and/or organizations contacted
o Any other information that may help emergency personnel
respond
o to the incident

Whenever the facility discharges more than 50 m3of oil in a single event, the Manager of Field
Operations must provide the following information to the Agency’s Regional Administrator within
60 days to the Customers ( Vessels Management ) including the details but not limited to :

 Name of the facility

 Name of the owner or operator
 Location of the facility
 Corrective actions and countermeasures taken, including a description of
equipment repairs and replacements
 Description of facility, including maps, flow diagrams, and topographical maps
 Cause of the discharge(s) to navigable waters, including a failure analysis of the
system and subsystems in which the failure occurred.
 Additional preventive measures taken or contemplated to minimize possibility of
recurrence

==== END OF DOCUMENT/ OIL Spill response Plan ===

AGP – Oil Spill Response Plan, Version 1