HELLAS POSEIDON

1138- Cargo (Liquefied gasses in bulk)- A permanently installed system of gas detection with audible and visual alarms shall be provided. Alarms should be activated when the vapor concentration reaches 30% LEL (or earlier). Testing and calibration should be carried out at regular intervals. When PSCOs requested to test fixed gas detection, crew applied 50% LEL propane span gas to test point in panel while in calibration mode (alarm inhibited). System never read higher than 22% LEL. On this ship LEL alarm is set at 20% LEL (with high-high alarm at 30% LEL). Crew could not demonstrate audible or visual LEL alarm. 74 SOLAS (14) VII/13.1; IGC 93/13.6

2550- ISM related deficiencies (Maintenance of ship and equipment)- The safety management system should ensure compliance with mandatory rules and regulations [ISM 1.2.3.1]. The company should establish procedures to ensure the ship is maintained in conformity with the relevant rules and regulations and any additional requirements established by the company [ISM 10.1] Vessel's COF authorizes 0.275 bar “at sea” and 0.40 bar “in harbor” MARV setting IAW IGC 4.2.6.4, 8.2.6.2, and 8.2.7. From review of IAS printout and interview of crew, vessel was using 0.40 bar “in harbor” marvs while underway from Cristobal anchorage to Houston, TX. Printouts of IAS shows that pressure in tanks was between 0.26 - 0.287 bar on 10-11mar2018. “In harbor” MARV setting shall not be used when underway at sea. Additionally, pressure exceeded 0.275 “at sea” MARV setting. Shipboard SMS, cargo operation and handling manual, section 2.1.4 states "the cargo tank is designed for a maximum internal pressure of the 0.275 bar during sea condition. Consequently, prior to leaving harbor, set point of safety relief valves shall be properly adjusted… omission of this precaution can jeopardize the safety of the crew and ship.” This procedure was not followed as “in harbor” marvs was used while underway. Shipboard SMS, cargo operations and handling manual, section 1.3 requires monthly calibration and function check of fixed gas detection using 50% LEL propane span gas. Last two recorded calibrations per shipboard records were 10OCT17 and 18JAN18. From interviews with crew, function checks have been conducted using cargo rather than span gas. This is not permitted by SMS procedure. 74 SOLAS (14) IX/3.1; ISM 1.2.3.1 & 10.1

1138- Cargo (Liquefied gasses in bulk)- Electrical installations should be such as to minimize the risk of fire and explosion from flammable products. Upon examination of compressor room, PSCO identified an explosion proof junction box on the back flush sea water cooling system with an O-ring not properly fitted, causing a 02 inch gap compromising the integrity of the junction box. 74 SOLAS(14) VII/13.1; IGC 93/10.1.2

1138- Cargo (Liquefied gasses in bulk)- In the case of cargo tanks permitted to have more than 01 relief valve setting, changes in set pressure should be recorded in the ship’s log. Vessel is authorized multiple relief valve settings (0.275 bar “at sea”, 0.40 bar “in harbor”). According to ship’s logbook, ship changed to 0.275 bar “at sea” setting on 04FEB18, and ship remained at “at sea” setting until arrival in Houston on 13MAR2018. However, from interview with vessel master, ship switched to 0.40 bar “in harbor” setting on 02mar18 upon arrival at balboa anchorage for passage of Panama Canal. There is no record in ship’s log to document this changing of MARV setting. 74 SOLAS(14) VII/13.1; IGC 93/8.2.6-8.2.7

1138- Cargo (Liquefied gasses in bulk)- All gas carriers should be issued a certificate of fitness, and the ship shall be operated iaw the cof. Vessel’s COF states that the maximum density of cargo is 610 kg/m3 in all tanks. However, the vessel’s cargo list authorizes the carriage of butadeine. Butadeine has a density of 650 kg/m3 fully refrigerated (-5 c) and 642.9 kg/m3 at +1.9 c. Therefore, COF is contradictory as it authorizes carriage of a cargo with a higher density than allowed. Vessel was unable to produce any documentation as required by IGC 15.2 for a lower loading/filling limit for cargos with a density of >610 kg/m3. 74 SOLAS(14) VII/13.1; IGC 93/1.5.4 & 15.2

1138- Cargo (Liquefied gasses in bulk)- For vessels authorized multiple relief valve settings, the changing of set pressures under the provisions of 8.2.6, and the corresponding resetting of alarms referred to in 13.4.1, should be carried out in accordance with procedures approved by the administration. Shipboard procedure for changing safety relief valves, cargo operation and handling manual, section 2.1.4, is not approved by flag (MALTA) or RO (DNV-GL). In addition, procedure as written does not state what alarm set-points are (separate sign in CCR lists alarm set-points as 0.19 bar "at-sea", 0.28 bar "in-port"); these figures must be incorporated into approved procedure. 74 SOLAS(14) VII/13.1; IGC 8.2.7