BADLANDS TRADER

Windows and side scuttles in bulkheads within accommodation and service spaces and control stations other than those to which the provisions of paragraphs 4.1.1.6 and 4.1.2.3 apply shall be so constructed as to preserve the integrity requirements of the type of bulkheads in which they are fitted, this being determined in accordance with the Fire Test Procedure Code. During the COI inspection, MI identified window defects in the [name withheld] cabin and office space located just starboard side of the Cargo Control Room. Replace windows with in-kind approved type to the satisfaction of the attending RO. 74 SOLAS (24) II-2 Regulation 9.4.1.3.1

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure that the ship in all respects will remain fit to proceed to sea without danger to the ship or persons on board. Vessels captain self reported that they experienced a failure with the ballast water treatment system while conducting ballast operations. Vessel shall continued to conduct open ocean water exchanges until the system is restored to normal operations.

The person in command of a documented vessel must have on board that vessel the original Certificate of Documentation currently in effect for that vessel. Vessel did not have original COD on board.

First Assistant Engineers on tankships operating past the boundary line are required to either hold a tankerman PIC or engineer license. 1st AE currently serving onboard does not hold any STCW or national endorsements for tank/chem cargo operations. Cargo operations are restricted to a maximum of eight (08) hours in any 24 hour period. Flag State Dispensation: 1st AE is authorized to remain onboard for duration of current contract (departing o/a June 2024) and serve in billeted position as 1st AE. Member is not authorized to be assigned any cargo related duties. Internal SMS audit requirement: The company should ensure that each ship is manned with qualified, and certificated seafarers in accordance with national and international requirements. Limited scope audit (root cause analysis) and corrective action plan to be submitted to local OCMI for review w/in 30 days. Findings should be shared with managed vessel fleet and relevant persons to prevent recurrence. 46 CFR 15.860(a)Table 2 74SOLAS(2020)IX/3.1 ISM (2018) 6.2.1

Test procedure documents must specify equipment status, safety precautions, control/alarm set points, and steps to be followed. Revisions required to automation test procedures (PSTPs) to update testing instructions for SSDG overspeed (OEM has provided instructions for electronic testing methods vs. mechanical governor control). Revisions due w/in 30 days. 46 CFR 61.40-10(a)

Every steam boiler and every unfired steam generator shall be provided with not less than two safety valves of adequate capacity. Auxiliary boiler safeties missing data plates to document set pressure and bench test date (according to CHENG and our records, these safeties were tested in 2023 while in Greece during MSP reflag and set relief pressure was 9 Bar - unable to verify during inspection due to lack of appropriate documentation). Satisfactory bench testing and documentation/equipment marking to be provided w/in 30 days. 74SOLAS(2014)II-1/32.1

Each Captain of the Port may order a vessel to operate in the manner directed when the captian of the port has determined that such order is justified in the interest of safety by reaason of weather, visibility, sea conditions, temporary port congestion, other temporary hazardous cirmcumstances, or the condition of the vessel. your vessel shall be escorted by a towing vessel of adquate size and capacity to the satisfaction of the Virginia Pilot Associations, during the inbound transit of the regulated navigation area, as defined by 33 CFR 165.501

Fire-fighting systems… shall be kept in good working order and readily available for immediate use. The CO2 mechanical ventilation is inoperable. Lockout valve is missing from CO2 system piping (install in accordance with 46 CFR 34.15-50 and Gap Analysis). Complete annual servicing of CO2 system. Cite: SOLAS (2014) II-2/Reg 2.1.2

Every steam boiler and every unfired steam generator shall be provided with not less than two safety valves of adequate capacity. Both the auxiliary and composite boiler safety valves were not set to MAWP and require retesting. Cite: SOLAS (2014) II-1/ Reg 32

Before the ship leaves port and at all times during the voyage, all life-saving appliances shall be in working order and ready for immediate use. The port lifeboat remote control wire (inside the lifeboat) did not function. Conduct operational test of starboard lifeboat, including a test of the remote control wire. Cite: SOLAS (2014) III/ Reg 20.2

Cargo tanks shall be fitted with a visual and audible high-level alarm which complies with 15.19.1 to 15.19.5 and which indicates when the liquid level in the cargo tank approaches the normal full condition. The overfill alarm on tank 2s annunciated before the high level alarm. 705: Prior to cargo operations in tank 2s. Cite: SOLAS (2014) VII/Reg 10.1, IBC 15.9.6

Oil fuel pipes, which, if damaged, would allow oil to escape from a storage, settling or daily service tank having a capacity of 500l and above situated above the double bottom, shall be fitted with a cock or valve directly on the tank capable of being closed from a safe position outside the space concerned in the event of a fire occurring in the space in which such tanks are situated. Quick closing valves for #2 and #3 SSDGs did not function properly (new O-rings are required for air cylinders). Cite: SOLAS (2014) II-2/Reg 4.2.2.3.4

Provision shall be made to facilitate cleaning, inspection and maintenance of main propulsion and auxiliary machinery including boilers and pressure vessels. The boiler(s) safety valve gags were not on board. Cite: SOLAS II-1/ Reg 26.4.7

Engines installed on vessels that were constructed on or after January 1, 2000, with power output of more than 130 kW must be covered by a valid EIAPP certificate, certifying the engine meets the applicable emission standards of Annex MARPOL Annex VI. Provide documentation of completed EPA submission for EIAPP certificates to meet MARPOL Annex VI/ Reg 13. Provide EIAPP Certificates for all applicable marine diesel engines as proof of emissions compliance with the IAPP. 705: Due in 3 months / 23Jul2023. Cite: 40 CFR 1043.30, MARPOL Annex VI/Reg 13.8

Periodic Safety Test Procedures (aka Automation Test Procedures) must be developed, tested, and approved by USCG Marine Safety Center (MSC) or authorized classification society (ACS) under 46 CFR 8.420. Vessel was missing class or USCG approved PUMS to meet or reach equivalency of 46 CFR 62.50-30 for PUMS endorsement. Vessel is authorized PUMS in interim status, which procedure is completed and submitted to MSC or ACS. If ACS is utilized, ACS must certify to the OCMI the periodical safety tests have been approved on behalf of the U.S. Coast Guard and verified and satisfactorily demonstrated. 705: Due by next drydock (not including UWILD) on or about 31Jan2026. Cite: 46 CFR 61.40-6(a)

07106: Fire detection and fire alarm systems shall be kept in good order so as to ensure their required performance if a fire occurs. PSCO observed a plastic bag covering a smoke detector above the boiler air intake blower and a flame detector with a piece of tape covering the flame sensor lense. Vessel crew removed the obsrtuctions and did not have an answer why they were put there. PSCO observed a satisfactory test of the smoke and flame detector. SOLAS 74 (2014) II-2/14.2.1.1.2.