GREEN PIONEER

A single failure in a technical system or component shall not lead to an unsafe or unreliable situation. Vessel is arranged with a fumigation style ammonia fuel system. This system allows the flow of ammonia to the consumer via a single wall piping manifold. This single wall piping located in engine room creates an unsafe condition. 74 SOLAS (2024) II-1/57;Ref IGF Code 3.2.18

Unless exhaust systems are designed with the strength to withstand the worst case over pressure due to ignited gas leaks, explosion relief systems shall be suitably designed and fitted. Vessel is not equipped with an explosion relief system. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 / 5.5.1.1

Administration shall not allow operational methods or procedures to be applied as an alternative to a particular fitting, material, appliance, apparatus, item of equipment, prescribed by this Code. Administration allowed operational methods and procedures for the following designs: - Single wall Pipe - Explosion Exhaust Relief - Spaces containing potential ammonia releases SOLAS II-1/57;Ref IGF Code 2.3.3

An operational manual shall be prepared as required by the IGF Code Ch.18, with additional requirements specific to ammonia fuel. As designed, the vessel's engine room is not gas safe. PSCO discovered the operational manual states engine room is a Gas Safe Engine Room. See piping diagram. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 / 1.9.1.1

Hazardous areas zone 1 includes, but is not limited to: Tank connection spaces, fuel preparation rooms, fuel storage hold spaces, inter barrier spaces, enclosed bunkering stations and other enclosed spaces where leakage of ammonia may occur. Engine room is equipped with single wall pipe resulting in an enclosed space where leakage of ammonia may occur, making it a hazardous area zone 1. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 / 9.1.2.2.1

Direct access shall not be permitted from a non-hazardous area to a hazardous area. Where such access is necessary, an air lock shall be provided. Engine room is equipped with single wall pipe making the engine room an enclosed space where leakage of ammonia may occur resulting in a zone 1 hazardous area requiring an airlock.

Electrical equipment and wiring shall in general not to be installed in hazardous areas unless essential for operational purposes. The type of equipment and installation requirements shall comply with Pt.4 Ch.8 Sec.11 according to the area classification as specified in [9.1]. Engine room is equipped with single wall pipe making the engine room an enclosed space where leakage of ammonia may occur resulting in a zone 1 hazardous area. Electrical equipment in engine room is not certified for zone 1. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 / 8.1.1.3

An inspection/survey plan for the liquefied gas fuel containment system shall be developed and approved by the Society. Vessel could not provide Inspection/survey plan. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 / 4.3.1.8

The inspection and maintenance of electrical installations in explosion hazardous spaces shall be performed in accordance with a recognized standard. PSCO could not verify, that the required crewmember/s hold the documentary proof to conduct inspections and maintenance of explosion hazardous spaces/areas. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-5, Chpt-7, Sec-10 / 3.1.6-4

An audible and visual alarm system to give a warning on both sides of the air lock shall be provided to indicate if more than one door is moved from the closed position. Vessel's airlock is not equipped with audible and visual alarm system to give a warning on both sides of the air lock. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 / 3.4.2.1

An air lock doors shall be self-closing. Vessel's airlock doors did not self close. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 / 3.4.1.1

Air lock doors shall be without any holding back arrangements. PSCO observed block of wood on airlock doors to hold open. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 / 3.4.1.1

Hazardous area classification drawing G080 is required to comply with the requirements of IEC 60079-10-1 (2008). PSCO observed multiple Hazardous Area Classification areas do not comply with the requirements of IEC. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 / 9.1.1.1

Signboards are required at the operating station and in the machinery space to prevent the risk of personnel exposure to ammonia fuel. Signage is not posted in the ECR instructing crew to rectify causes of ammonia fuel supply system shutdown prior to restarting the fuel supply system. Similar signage is not posted in the machinery space, specifying not to restart ammonia fuel supply after shutdown due to gas leak. Machinery space does not have signage prohibiting heavy lifting near gas fuel piping while engines operate on ammonia fuel. Hatches to E-GVU's inside machinery space are not marked to prohibit opening unless the ammonia fuel system is shut down and gas free. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 / 1.10.1; 1.10.2; 1.10.3; 1.10.4

A plan for periodic test of all field instruments specified in these rules shall be kept on board. The plan shall include test intervals, description of how to perform the tests and description of what to observe during the tests. Plan does not provide a description of how to perform the tests and description of what to observe during the tests. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 / 1.9.1.2

Drip trays of sufficient size to limit the extent of the spill shall be fitted under bunkering manifolds and other leakage points. Structural brackets were found in way of leak points and drip tray. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 /3.3.4.4

Spray shields shall be arranged around potential leakage points from the ammonia system in the bunkering station. Bunkering station was not appropriately fitted with spray shields. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024Ref DNV Pt-6, Chpt-2, Sec-14 / 3.3.4.5

A water spray system shall be installed to cover exposed parts of fuel tanks. During operational test of installed water spray system, PSCO found inadequate tank and deck coverage in multiple areas. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 /7.3.2.1

Ships shall be designed, constructed, and maintained in compliance with the structural, mechanical, and electrical requirements of a Classification Society which is recognized by the Administration. Vessel’s currently issued Certificate of Class approves 5 Conditions of Class that are effectively approvals of an alternative design, and not the intended use of Class Conditions as temporary acceptance of inoperable equipment required to be repaired/replaced. 74 SOLAS (2020) II-1/3-1

A permanently installed gas detection system shall be provided in required locations. During operational test of gas detection PSCO witnessed failure to valve to close as required. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 /10.2.4.1

The requirements in [10.3.1] to [10.3.5] and Table 12 specify fuel installation safety actions required to limit the consequences of system failures. Crew was unable to demonstrate automatic safety actions Loss of Ventilation in the Tank Connection Space IAW Table 12. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 /10.3.6.1

The requirements in [10.3.1] to [10.3.5] and Table 12 specify fuel installation safety actions required to limit the consequences of system failures. Crew was unable to demonstrate automatic safety actions for Tank Connection Space Low Temperature in Bilge Well IAW Table 12. SOLAS II-1/57;Ref IGF Code 2.3;Ref MPA Alt Design Feb 2024;Ref DNV Pt-6, Chpt-2, Sec-14 /10.3.6.1