PILARGAS

The condition of the ship and its equipment should be maintained to conform with the provisions of the Code to ensure that the ship will remain fit to proceed to sea without danger to the ship or persons on board. PSCO was made aware of several intermittent vapor leaks as detected by the Marine Chemist and crew to include the #1 cargo tank "B" pump gauge, the #1 cargo tank "B" pump shaft seal, and from an unknown source in the starboard compressor room. PSCO cannot verify that the cargo containment system and associated piping is vapor tight.

To assist in casualty investigations, ships, when engaged on international voyages... shall be fitted with a voyage data recorder (VDR) as follows: ships, other than passenger ships, of 3000 gross tonnage and upwards constructed on or after 1 July 2002. VDR is in-operable due to these following codes: 18, 22, and 174. 74 SOLAS (2020 Cons.) V/20.1.4. Action code: 17ac.

Oil filtering equipment referred to in paragraph 1 of this regulation shall be of a design approved by the Administration and shall be such as will ensure that any oily mixture discharged into the sea... PSCO observed OCM flickering during operational test and reviewing history of the OWS. MARPOL (2022 Cons) Annex I/14.6. Action code: 17ac.

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 entries in the book appropriate to the operation are completed. Each completed operation shall be signed by the officer or officers in charge of the operations concerned and each completed page shall be signed by the master of the ship. The entries in the Oil Record Book (ORB) Part 1 for ships holding and International Oil Pollution Prevention Certificate, shall be at least in English, French, or Spanish. Where entries in an official language of the state whose flag the ship is entitled to fly are also used, this shall prevail in case of dispute or discrepancy. PSCO observed the following entries in the ORB: 16APR24, 09AUG24, and 22SEP24. The entries did not match for length, throughput, and times. After review, C/E signs all operations even though 2/E completed transfer. Also had missing entry of transfer completed after 22SEP24. Reviewed sounding log and soundings did not match operation on 22SEP24. MARPOL (2022 Cons) Annex I/17.4.

Ship staff training should include familiriazation in the operation and maintenance of the equipment. PSCO observed crew using a brush to test OWS and did not follow proper testing procedures. MARPOL (2022 Cons) Annex I/14.6, MEPC.107(49) 1.1.5. Action code: 40ac.

Each fire drill shall inclide: Checking of fireman's outfit and other personal rescure equipment. PSCO ovserved 01 firefighters wearing improper headgear. PSCO also observed 01 crewmembers holding door without firefighting equipment. 74SOLAS (2020 Cons) III/19.3.5.2.3. Action code: 10c.

The rescue boat embarkation and launching arrangements shall be such that the rescue boat can be boarded and launched in the shortest possible time." Davit arm required 2 minutes and 56 seconds to swing from rescue boat launching station to lowering position, and swung in a bouncing manor that is unsafe for any crew on board the rescue boat. 74 SOLAS (20) III/17.1

Every inflatable liferaft shall be serviced: at intervals not exceeding 12 months2. PSCO observed wrong liferaft SN on servicing record resulting in uncertainty of liferaft servicing. 74 SOLAS (20) III/20.8.1

Machinery spaces of category A shall be adequately ventilated so as to ensure that when machinery or boilers therein are operating at full power and adequate supply of air is maintained to the space for the safety and comfort of personnel and the operations of the machinery. Any other machinery space shall be adequately ventilated appropriate for the purpose of that machinery space. PSCO and PSCE's 4 gas alarmed while observing the Emergency Diesel Generator (EDG) exhaust ventilating back into the EDG compartment filling it with carbon dioxide. 74 SOLAS (04) II-1/35

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. PSCO observed gear adrift throughout steering gear space. 74 SOLAS (04) I/11 (a)

No electrical equipment shall be installed in any space where flammable mixtures are liable to collect, unless the Administration is satisfied that such equipment is of a type which will not ignite the mixture concerned. PSCO observed 1 cracked EX lens in compressor room. SOLAS II-1/45.10.2

Suitably marked decontamination shower and eyewash should be available on deck in convenient locations. The showers and eyewash should be operable in all ambient conditions. PSCO observed eye wash station to have insufficient water pressure. Crew was able to clean eye wash station and increase pressure and flow. Deficiency cleared. 74 SOLAS VIII/13.1 IGC Code 14.4.3

Objective evidence discovered in an expanded ISM exam revealed the following major non-conformity; the vessel failed to fully implement the requirements of the SMS as evident by deficiencies # 1-10. An external audit is required. 74 SOLAS (2020 cons) IX/3 ISM Code Part A 9

In meeting these requirements, the company should ensure that: .1 inspections are held at appropriate intervals. The main diesel engine had maintenance overdue up to 5004 hours as of 29FEB2024 which includes the fuel valves, cross head bearing, crank pin bearing, and main bearing. Main diesel engine turbo had maintenance overdue by up to 5004 hours as of 29FEB2024 which includes the safety valves, exhaust valves, scavenge inspection, deflection gauging and hydraulic valve actuator. Shipboard diesel generator #1 was overdue for inspection by up to 4853 hours to include the cylinder cover and fuel valves as of 29FEB2024. 74 SOLAS (2020 cons) IX/3 ISM Code Part A 10.2.1

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 arrangements and equipment or technical systems that are not in continuous use. The air compressor that provides starting air to the main diesel engine was inoperable, therefore the procedures for ensuring reliability were not being followed and spares were not available to ensure continuation of operation in the event of a failure. 74 SOLAS (2020 cons) IX/3 ISM Code Part A 10.3

The company should establish procedures to ensure that the ship is maintained in conformity with the provisions of the relevant rules and regulations and with any additional requirements which may be established by the company. Two of the oil mist detectors were covered by plastic bags and an additional one was found inoperable. 74 SOLAS (2020 cons) IX/3 ISM Code Part A 10.1

The company should establish and maintain procedures to control all documents and data which are relevant to the safety management system. Pre arrival checks did not include procedures for testing the standby or emergency generator. Reference SMS Form SN.02/revision 00. 74 SOLAS (2020 cons) IX/3 ISM Code Part A 11.1

The company should ensure that all personnel involved in the company’s safety management system have an adequate understanding of relevant rules regulations, codes, and guidelines. Crew could not demonstrate proficiency of vessel emergency steering and emergency fire pump procedures in a timely manner. PSCO had to show crew the posted testing procedures to conduct the emergency steering gear test. 74 SOLAS (2020 cons) IX/3 ISM Code Part A 6.4

The machinery and fittings shall be of a design and construction adequate for the service for which they are intended and shall be so installed and protected as to reduce to a minimum any danger to persons on board. The main diesel engine had a significant leak from the No.7 jacket water. 74 SOLAS (2004 cons) II-I/26.1

Means shall be provided whereby normal operation of propulsion machinery can be sustained or restored even though one of the essential auxiliaries becomes inoperative. Special consideration shall be given to the malfunctioning of: an air compressor and receiver for starting or control purposes. Only 1 (one) of the 2 (two) compressors that provide starting air was functional. 74 SOLAS (2004 cons) II-I/26.3.9

The fire resistance of doors shall be equivalent to that of the division in which they are fitted... The door for storage room “E” on the poop deck was not capable of closing. 74 SOLAS (2009 cons) II-2/9.4.2.1

"A" class divisions formed by bulkheads and decks which comply with the following criteria: they are insulated with approved non-combustible materials such that the average temperature of the unexposed side will not rise more than 140 degrees Celsius above the original temperature, nor will the temperature, at any point, including any joint, rise more than 180 degrees Celsius above the original temperature within the time listed below: class "A-60" 60 min. The class A boundary separating emergency escape from the engine room was found to be insufficient with insulation falling out and patched with non approved tape. 74 SOLAS (2009 cons) II-2/3.2.3

Whenever there is a hazardous condition either on board a vessel or caused by a vessel or its operation, the owner, agent, master, operator, or person in charge must immediately notify the nearest Coast Guard Sector Office or Group Office. The vessel failed to report the following hazardous conditions to the Coast Guard: Starting air compressor inoperable and leaking jacket water on main diesel engine. 33CFR160.216(a)

(a) Except as provided in paragraphs (b) and (c) of this section no person may cause a vessel to enter into or get underway on the navigable waters of the United States unless no more than 12 hours before entering or getting underway, the following equipment has been tested: (3) Standby or emergency generator, for as long as necessary to show proper functioning, including steady state temperature and pressure readings. Crew did not perform an emergency generator test prior to entry. 33CFR164.25(a)(3)

The system should be capable of covering all areas mentioned in 11.3.1 with a uniformity distributed water-spray of at least 10 L/m2 per minute for protected surfaces and 4 L/m2 per minute for vertical surfaces. The deck water spray system did not adequately cover the port manifold, #1 tank dome, or compressor rooms. 74SOLAS(20) VII/13.1 IGC(93) 11.3.2 17 a/c

Remote starting of pumps supplying the water-spray system and remote operation of any normally closed valves in the system should be arranged in suitable locations outside the cargo area. The water-spray remote controls from the CCR were not working. The discharge valve had to be manually opened in the engine room. 74SOLAS(20) VII/13.1 IGC(93) 11.3.6 17 a/c

The changing of the set pressure under the provisions of 8.2.6 should be carried out under the supervision of the master in accordance with procedures approved by administration and specified in the ship operating manual. The MARV setting for both cargo tanks is set at 6.6 Bar, the ICOF requires the MARVS reduce to 5.8 Bar when loading VCM. The crew stated that MARVs are never changed on board a vessel that only loads VCM in Corpus Christi. 74SOLAS(20) VII/13.1 IGC(93) 8.2.7 17 a/c

Electrical Installations should be as to minimize the risk of fire and explosion from flammable products. Two EX lights were found with cracked lenses. One in the STBD compressor room and one in the port compressor room. 74SOLAS(20) VII/13.1 IGC(93) 10.1.2 15 a/c