STENA IMPECCABLE

Companies shall comply with the relevant requirements of part A of the International Safety Management Code. Every Company should develop, implement and maintain a Safety Management System which includes the following functional requirements: instructions and procedures to ensure safe operation of ships and protection of the environment in compliance with relevant international and flag State legislation. The vessel failed to follow approved procedures for cargo tank washing overboard discharge. Cargo tank washings were discharged overboard without being processed through and monitored by the Oil Discharge Monitoring and Control Equipment(ODME)MARPOL Annex I.34 requires that any discharge of oil or oily mixtures from the cargo area of oil tankers be continuously monitored and controlled by an approved ODME and meet all prescribed discharge conditions. Objective evidence observed show a failure of the Safety Management System on board. An internal SMC audit is required to be scheduled within 30 days and conducted within 90 days from the date on this CG-835V.

Where cables which are installed in hazardous areas introduce the risk of fire or explosion in the event of an electical fault in such areas, special precautions against such risks shall be taken to the satisfaction of the Administration. Attending MI noted three packing glands two for control valves and one for a lighting circuit that were not adequately maintained. SOLAS II-1/.45.5.4

The Company should establish procedures and to ensure that the ship is maintained in conformity with the provisions of the relevant rules and regulations and with any additional requirements which maby be established by the company. The vessel is currently utilizing an antiquated planned maintenance system identified as “Aurora.” This system lacks integration with on board inventory management and does not effectively link maintenance tasks with required spare parts or parts availability. As a result, maintenance planning and execution are highly dependent on individual crew capability rather than a reliable system.

Fire protection system and fire extinguishing systems shall be maintained in good working order and reaily available for immediate use. The attending MI noted that the liquid level in the PV breaker on the cargo deck was lower than the required amount additionally the minimum required amount was not properly labeled on the unit.SOLAS II-2/14.4.1

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.During the inspection, the attending Marine Inspector identified the following deficiencies related to cargo deck equipment and lifesaving appliances. An allen wrench key was observed being used as a temporary securing device to attach a cargo tank access hatch valve to the valve stem. The No. 2 cargo tank radar was observed with approximately 50 percent of required securing hardware missing. The retro-reflective tape on the life ring located at the bow end of the catwalk was missing. The retro-reflective tape on the lifeboat was observed to be significantly deteriorated. Required IMO emergency cargo stop placards were faded and or missing at designated locations. Cargo bonding straps were observed loose or missing securing hardware at several locations. The eyewash station located near the cargo manifold was observed without an available water supply. All items listed above were corrected prior to the vessel’s departure and before the conclusion of the inspection. However,while the identified deficiencies were rectified in a timely manner, their cumulative presence indicates a lack of attention to detail in the maintenance and oversight of cargo-related safety systems and equipment. Continued emphasis on routine inspection, verification, and preventive maintenance of cargo deck systems and lifesaving is necessary to ensure ongoing compliance and operational readiness. SOALS I-11

The vessel’s Shipboard Oil Pollution Emergency Plan (SOPEP) locker inventory did not accurately reflect equipment onboard. Required pollution response equipment listed in the approved SOPEP inventory was missing or incomplete. The condition represents a failure to maintain approved pollution response arrangements in accordance with SOLAS and MARPOL requirements.SOALS I-11, MARPOL I,II 33CFR156.26

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. A tube/wire was noted running between the engine casing and the nitrogen generator space through a structural closure as opposed to ulizing a stuffing tube or rox bloc for designed bulkhead penetration. SOALS I-11

CO2 fixed system is missing a bottle causing dislocation of an activation line. Restore to orignal configuration.SOLAS II-2/14.4.1

The inspection and survey of ships, so far as regards the enforcement of the provisions of the present regulations and the granting of exemptions therefrom, shall be carried out by officers of the Administration. The vessel must remain at anchorage in Ulsan, ROK until a periodic oversight inspection is conducted by USCG Marine Inspectors. 74 SOLAS (20) / I.6 (a)

The arrangements for the ready availability of water supply shall be to the satisfaction of the administration. When asked to test the emergency fire pump no water pressure was achieved. The suction valve for the sea water supply was inoperable and in the closed position. Remote hydraulic actuation was found to be the cause of the inoperable valve. Make permanent repairs to the satisfaction of the attending marine inspector. SOLAS II-2 reg 10.2.1.2

The fixed fire detection and fire alarm system required in paragraph 4.1.1 shall be so designed and the detectors so positioned as to detect rapidly the onset of fire in any part of those spaces and under any normal conditions of operation of the machinery and variations of ventilation as required by the possible range of ambient temperatures. Except in spaces of restricted height and where their use is specially appropriate, detection systems using only thermal detectors shall not be permitted. The detection system shall initiate audible and visual alarms distinct in both respects from the alarms of any other system not indicating fire, in sufficient places to ensure that the alarms are heard and observed on the navigation bridge and by a responsible engineer officer. Heat and flame detectors above the Comb. Boiler burner did not initiate an alarm when activated with artificial smoke and infrared light. This test should also have initiated the release of the hyper mist system zone 8, however there were negative results. Make repairs and prove proper operation prior to the use of the comb boiler. SOLAS II-2 Reg. 7.4.2

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure the ship in all respects will remain fit to proceed to sea without danger to the ship or persons on board. The junction box for number 2 ship’s service generator was found broken and held shut with duct tape. Make permanent repairs to the satisfaction of attending class surveyor or Coast Guard marine inspector. SOLAS I reg 11.

The construction of doors and and door frames in “A” class divisions, with the means of securing them when closed, shall provide resistance to fire as well as the passage of smoke and flame equivalent to that of the bulkhead. The port door latch to the main engine room was inoperable not securing the door when closed. Make permanent repairs to the satisfaction of the attending marine inspector. SOLAS II-2 reg 9.4.1.1.2.

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure the ship in all respects will remain fit to proceed to sea without danger to the ship or persons on board. The junction box for number 2 ship’s service generator was found broken and held shut with duct tape. Make permanent repairs to the satisfaction of attending class surveyor or Coast Guard marine inspector. SOLAS I reg 11.

The company should ensure that valid documents are available at all relevant locations. The vessel is required to maintain a USCG issued Certificate of Inspection (COI). An annual inspection must be completed within 3 months on either side of the COI’s anniversary date (anniversary date corresponds to the day and month of each year of the COI expiration date). The vessel’s anniversary date was 07 Mar, so the annual inspection required completion by 07Jun2024. On 09Jul2024, USCG ACTEUR was made aware the vessel missed its annual inspection, which invalidated the COI, so the certificate was not maintained. Conduct an internal audit of the policies and procedures related to maintaining valid documents. Provide the audit results and corrective action to USCG ACTEUR by 19Oct2024. Have the procedures verified at the next external audit. Cite: SOLAS (2020) IX / Reg 3, ISM Code Part A 11.2.1

Every company should develop, implement and maintain a safety management system which includes the following functional requirements: procedures for reporting accidents and non-conformities with the provisions of this Code; and procedures to prepare for and respond to emergency situations. The SMS does not capture reporting harassment, sexual harassment, or sexual assault. In addition, the SMS does not establish mandatory reporting as required by 46 USC 10104 for any complaint or incident of harassment, sexual harassment, or sexual assault in violation of employer policy or law to include requirements for an after-action summary. Develop and update the missing policies and procedures. Provide the updated policies to USCG for review by 23Dec2024. Have the procedures verified at next external audit. Cite: SOLAS IX/Reg 3.1, ISM Code 1.4.4 and 1.4.5, CVC-WI-004(3)

The company should identify equipment and technical systems the sudden operational failure of which may result in hazardous situations. The safety management system should provide for specific measures aimed at promoting the reliability of such equipment or systems. These measures should include the regular testing of stand-by equipment or technical systems that are not in continuous use. The inspections mentioned in 10.2 as well as the measures referred to in 10.3 should be integrated into the ship’s operations maintenance routine. • 35 critical spares are identified in Aurora and no cargo safety related critical spares are identified. The ship has one reliable oxygen sensor to calibrate the N2 inert gas generator. The redundant oxygen sensor is installed in the system but is approaching the end of its life cycle and there are no spares on board. A spare O2 sensor was ordered on 10Jun2024 with an “Urgent” priority but has not arrived to the vessel and no estimated arrival date identified. In the requisition, one commenter stated, “span of the sensors is out of range. Sensor only good for 2 years. Require replacing.” Sensors may not last two years. • Preventive maintenance on the #2 exhaust valve can’t be completed until the valve spindles arrive to the vessel. The requisition for the spindles was placed in Aurora on 03May2024. • The #3 SSDG is out of service due to an inoperable PLC but this condition was not reflected in Aurora. • The crew is unable to update or add to the critical spares. A Fleet Memo was sent advising the TSP fleet of a forthcoming updated critical spares list. • 371 overdue items identified in Aurora. The oldest item is dated 18May2024 for the “Provision refrigeration Compressor No.2." Conduct an internal safety audit and corrective action of the critical spares, critical equipment, and preventive maintenance system. Provide the audit results and corrective action to USCG ACTEUR by 19Oct2024. Have the procedure verified by the Recognized Organization at the next external audit. Cite: SOLAS (2020) IX / Reg 3, ISM Code Part A 10.3, 10.4

Where automated systems are provided to replace specific personnel in the control and observation of the engineering plant and spaces, or reduce overall crew requirements, the arrangements must make sure that under all sailing conditions, including maneuvering, the safety of the vessel is equal to that of the same vessel with the entire plant under fully attended direct manual supervision. During review of Periodically Unattended Machinery Space operations (PUMS), the crew utilized the Stena UMS checklist instead of the CGS checklist found in the SMS. The Stena UMS checklist was reviewed and logged in the engineer’s logbook, but the checklist was not filled out. Reviewed Watchkeeper and the duty engineers had work-rest non-conformities, with 6 hours compensatory selected, but not taken (crewmember returned to work before the 6 hours compensatory rest was taken). Based on the Chief’s Standing Orders, the duty engineers stood a maximum of 8 hours of unattended watch, and pre-UMS round was completed at 2200. The UMS SMS procedure indicates the vessel can be unattended for a maximum of 12 hours. The chief engineer updated the Chief’s Standing Orders to see if this will help mitigate the STCW work/rest hour non-conformities. Evaluate PUMS for 30 days and update USCG with findings. Cite: 46 CFR 62.50-1, 46 CFR 62.50-30(j)

The training manual, which may comprise several volumes, shall contain instructions and information, in easily understood terms illustrated wherever possible, on the life-saving appliances provided in the ship and on the best methods of survival. The port side davit, used for launching the rescue boat and davit-launched liferafts is outfitted with a bridle. One side of the bridle is to connect the rescue boat to the davit via a fall link, the other side of the bridle is the hook to connect the davit launched liferafts to the fall/davit. There was no marking on the bridle to indicate which side connects to what. The SOLAS training manual does not describe or provide images of the bridle or its dual application use. Cite: SOLAS (2009) III/Reg 35.3

The company should establish procedures, plans and instructions, including checklists as appropriate, for key shipboard operations concerning the safety of the personnel, ship and protection of the environment. The #1 Aux boiler was locked out/tagged out (LOTO) due to cracks in the bellows. The boiler was locked out locally, but there was no tag. Reviewed the LOTO procedure and logbook and noted the boiler was not tagged out as required by the logbook book entry andand LOTO procedure. The locks on the boiler were not referenced in the logbook.

Maintenance, testing and inspections shall be carried out based on the guidelines developed by the Organization and in a manner having due regard to ensuring the reliability of fire-fighting systems and appliances. The flame detectors are unable to be tested. The flame detector test lamp is not holding a charge. Cite: SOLAS (2009) II-2/Reg 14.2.2.2

The company should ensure that each ship is appropriately manned in order to encompass all aspects of maintaining safe operations on board. Vessel is currently sailing short one (01) tankerman engineer. An internal SMC audit is required to be conducted.

Whenever a vessel is deprived of the service of a member of its complement, and the master is unable to find appropriate credentialed personnel to man the vessel, the master may proceed on the voyage, having determined the vessel is sufficiently manned for the voyage. Vessel reported sailing short one (01) QMED for deck department and Captain has determined vessel is safe to sail.Flag state dispensation granted: Voyage authorized to Subic Bay, Philippines with ETA of 24 November 2023.

Each emergency generator set shall be equipped with a second source of energy for an additional three starts within thirty minutes. Vessel's second means of starting did not work. 74 SOLAS(14) II-I / 44.2

Each ballast water management manufactured under Coast Guard approval must have a nameplate which is securely fastened to the ballast water management system. No name plate was found on the ballast water management system. 46CFR162.060(a)