EPIC HEDRON

No ship to which the present convention applies shall proceed to sea on an international voyage after the date on which present Convention comes into force unless it has been surveyed, marked and provided with an International Load Line Certificate, or where appropriate, an International Load Line Exemption Certificate in accordance with the provisions of the present Convention. Barge missing deck line.

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present convention to ensure that the ship in all respects will remain fit to proceed to sea without presenting an unreasonable threat of harm to the marine environment. Current condition of barge does not meet the requirements of the certificate.

The purpose of this regulation is to contain a fire in the space of origin. For this purpose, the following functional requirements shall be met; the fire integrity of the divisions shall be maintained at openings and penetrations. It was discovered that the crew modified Class B fire door louvers to use portable A/C's. Have returned to approved door spec. and ABS to verify once certs issued. 74SOLAS(04)II-2 9.1.3

The certificates issued under regulations 12 and 13 shall be readily available on board for examination at all times. The Cargo Ship Safety Radio Certificate was not readily available on board. 17bc 74SOLAS(20)I/16 FCC was emailed in regards to the document being issued by US Flag and by someone without the proper qualification to do so. The vessel is not required to have a radio certificate, but we are waiting on further instruction/guidance from FCC on the matter.

Means shall be provided to control leaks of flammable liquids. Witnessed standing oil and full oil absorbent pads throughout the engine space. 16c 74SOLAS(20)II-2/4.1

Each operation described in paragraph 2 of this regulation shall be fully recorded without delay in the Oil Record Book Part 1, so that all entires in the book appropriate to that operation are completed. Examiners noticed not all sludge and fuel receipts were being properly logged. 50c Marpol Annex 1 Reg. 17.4

The Oil Record Book shall be in the form specified in Appendix III to this Annex. Appendix III has a special note requiring all 3.1 tanks are required to be sounded and recorded weekly in the record book, no weekly entries found. 50c Marpol Annex 1 Reg. 17.1

If fixed ladders cannot be installed, alternative means of escape with sufficient capacity to permit all persons on board to descend safely to the waterline should be provided. Vessel's embarkation ladders on starboard side are wasted and inoperable. 17C MODU CODE 1989 9

14104 – Oil Filtering Equipment - After any survey of the ship, no change shall be made in the structure, equipment, systems, fittings, arrangements or material covered by the survey. PSCO observed a modified valve and arrangement on the oily water separate overboard discharge line. Provide clarification from certificate issuing authority attesting to the acceptance of modification. MARPOL 73/78 2011 cons. Annex I/Reg. 6 17a

14503 -Garbage Management Plan - Every ship of 400 gross tonnage and above, and every ship which is certified to carry 15 persons or more, shall carry a garbage management plan which the crew shall follow. The plan shall provide written procedures for collecting, storing, processing and disposing of garbage. Vessel could not produce a garbage management plan. MARPOL 73/78 2011 cons. Annex V/Reg. 9.2 17a

04103– Emergency, lighting, batteries and switches - Muster and embarkation stations should be adequately illuminated by emergency lighting. PSCO observed that there was no emergency lighting present for the port main deck embarkation areas, and that the lighting on the starboard ‘B’ deck was not functioning. - MODU Code (1989) Chapt. 10 / 10.3.3 17a

03107 – Doors - The number of openings in watertight subdivisions should be kept to a minimum compatible with the design and proper working of the unit. Where penetrations of water-tight decks and bulkheads are necessary for access, piping, ventilation, electrical cables, etc., arrangements should be made to maintain watertight integrity of the enclosed compartments. PSCO observed that a watertight door in the machinery space was not watertight.- MODU Code (1989) Chapt. 3 / 3.6.1 17a

03105 – Covers (hatchways, portable, tarpaulins, etc.) - All hatchways in position 1 and 2 shall be fitted with hatch covers of steel or other equivalent material. Such covers shall be weathertight and fitted with gaskets and clamping devices. PSCO observed that a portside hatchway on the main deck leading to a winch room had a bad gasket affecting tightness. – ICLL 88 am Annex I: II/. Reg. 16.1 17a

01315 – Oil Record Book -The Oil Record Book Part I shall be completed on each occasion, on a tank-to-tank basis if appropriate, whenever any of the following machinery space operations take place in the ship: Collection and disposal of oil residues (sludge); Discharge overboard or disposal otherwise of bilge water which has accumulated in machinery spaces. During review of the ORB, the PSCO noted that since at least 08FEB18, there have been no recordings accounting for collection or disposal of bilge/bilge holding tank water. Disposal of oil residues (sludge) has been recorded incorrectly, using the ORB format for weekly soundings. There were no discharge to reception facility receipts onboard to be provide. Provide corrective action plan from Company with concurrence from Administration. MARPOL 73/78 2011 cons. Annex I/Reg. 17 50b/a

01315 - Oil Record Book - Weekly soundings required to be recorded in the Oil Record Book (ORB) shall be completed in accordance with the Convention. During review of the ORB, the PSCO noted that Section 3.1 tanks listed on the vessel’s IOPP Form A are not being sounded. There is no record of them being sounded as far back as 08FEB18. Provide corrective action plan from Company to the satisfaction of the Administration. MARPOL 73/78 2011 cons. Annex I/Reg. 17 50b/a

14501 – Garbage – The entry for each garbage discharge shall include date and time, position of ship, category of the garbage and the estimated amount discharged. PSCO observed that the vessel was not making adequate entries for discharges of garbage. Quantities discharged to reception facilities are being estimated as ‘bags of trash’ instead of in the correct form, cubic meters. Daily discharges of food waste into the sea (Gulf of Mexico) have occurred from 21DEC18-25JAN19, with each one being recorded as 1.0 cubic meters. Start and stop times for discharge are not being correctly recorded, and position of ship is not being correctly recorded. Provide corrective action to be taken by Company with concurrence from Administration. MARPOL 73/78 2011 cons. Annex V/Reg. 9.3 50b/a

14501 – Garbage - Disposal of food wastes into the sea is prohibited in the Wider Caribbean Region unless the food has passed through a comminutor with screen openings no greater than 25 mm. PSCO observed entries into the garbage record book where crew had disposed of food waste into the Gulf of Mexico (a special area) daily from 21DEC18-25JAN19. Crew stated that there was no comminutor onboard, and that crew simply dumped food wastes over the side of the vessel. Provide corrective action plan from Company with concurrence from Administration. MARPOL 73/78 2011 cons. Annex V/Reg. 6 50b/a

01320 – Garbage Record Book - Every ship of 400 gross tonnage and above and every ship which is certified to carry 15 or more persons engaged in voyages to ports under the jurisdiction of another Party to the Convention shall be provided with a Garbage Record Book. The Garbage Record Book, whether as part of the ship's official log book or otherwise, shall be in the form specified in the appendix to this Annex. The vessel crew has been utilizing an obsolete version of the Garbage Record Book. The Record Book being used is not in accordance with IMO Resolution MEPC.277(70) to include new categories of garbage (i.e. electronic waste) which came into effect 01MAR18. MARPOL 73/78 2011 cons. Annex V/Reg. 10.3 / MEPC.277(70) 50 b/a

11117 – Lifebuoys incl. provision and disposition - Not less than one-half of the total number of lifebuoys shall be provided with lifebuoy self-igniting lights of an approved electric battery type complying with the requirements of regulation III/31.2. Not less than two of these should also be provided with self-activating smoke signals complying with the requirements of III/31.3 and be capable of quick release from the navigation bridge. PSCO observed that the bridge buoys were not arranged to be capable of quick release from the navigation bridge. - MODU Code (1989) Chapt. 10 / 10.12.2 50a

11117 – Lifebuoys incl. provision and disposition - At least two lifebuoys in widely separated locations should each be fitted with a buoyant lifeline, the length of which should be at least one-and-a-half times the distance from the deck of stowage to the waterline at light draught, or 30 m, whichever is greater. PSCO observed buoys with lifelines stowed on the B deck that were not of adequate length. - MODU Code (1989) Chapt. 10 / 50a

99101– Other (Safety In General) -The master, owner, operator, agent, or person in charge of a vessel bound for a port or place in the United States, unless specifically exempted by §151.2015 of this subpart, must ensure the maintenance of written or digital records that include the information required to be reported by §151.2060 of this subpart. PSCO observed that the vessel does not maintain a ballast water record book, or records to indicate occurrence of ballast water exchanges. 33 CFR 151.2070 50 b/a

99101 – Other (Safety In General) - There should be non-conducting mats or gratings at the front and rear of switchboards, where necessary. PSCO observed that switchboards did not have non-conductive matting at the rear. MODU Code (1989) Chapt. 5 / 5.5.5 50a

14105 – Pumping, Piping, and discharge arrangements - Except as provided in paragraph (d) of this section, no person may use any equipment listed in paragraph (c) of this section for transfer operations unless the vessel or facility operator, as appropriate, tests and inspects the equipment in accordance with paragraphs (b), (c) and (f) of this section and the equipment is in the condition specified in paragraph (c) of this section. Each transfer pipe system, including each metallic hose, must not leak under static liquid pressure at least 11/2 times the maximum allowable working pressure. Prior to bunkering in the U.S. 33 CFR 156.170 15c

99101 – Other (Safety In General) -The master, owner, operator, agent, or person in charge of a vessel subject to this subpart and this section must submit a ballast water report to the National Ballast Information Clearinghouse (NBIC) by electronic ballast water report format using methods specified at NBIC's Web site at http://invasions.si.edu/nbic/submit.html. PSCO observed that there was no history to indicated that the vessel has, or is submitting the above reports to the NBIC. 33 CFR 151.2060 10c

STAIRWAYS WHICH PENETRATE MORE THAN A SINGLE DECK SHOULD BE SURROUNDED BY "A" CLASS DIVISIONS AND PROTECTED BY SELF CLOSING DOORS AT ALL LEVELS. FOUND 6 "A" CLASS SELF CLOSING DOORS NOT CLOSING. MODU60E(89) REG. 9.2.3

PSCO observed that the oil record book did not include the quantities retained following any soundings or oil transfers/discharges as directed in their oil record book instructions.