ALGOMA VICTORY

THE COMPANY AND THE SHIP SHALL COMPLY WITH THE REQUIREMENTS OF THE INTERNATIONAL SAFETY MANAGEMENT CODE. THE COMPANY SHOULD ESTABLISH PROCEDURES TO ENSURE THAT THE SHIP IS MAINTAINED IN ACCORDANCE WITH THE PROVISIONS OF THE RELEVANT RULES AND REGULATIONS ESTABLISHED BY THE COMPANY. THE TECHNICAL AND/OR OPERATIONAL NATURE OF DEFICIENCES 02, 03, 04, 05, 06, AND 07 PROVIDE OBJECTIVE EVIDENCE OF A SERIOUS FAILURE, OR LACK OF EFFECTIVENESS, OF THE IMPLEMENTATION OF THE ISM CODE. AN EXTERNAL AUDIT REPORT SATISFACTORY TO THE OCMI MUST BE SUBMITTED PRIOR TO THE CLEARANCE OF THIS DEFICIENCY. 74SOLAS (2020) IV/3.1 ISM CODE 10.13 ABC

EVERY TOTALLY ENCLOSED LIFEBOAT SHALL BE PROVIDED WITH A RIGID WATERTIGHT ENCLOSURE WHICH COMPLETELY ENCLOSES THE LIFEBOAT. PSCO OBSERVED THE KNIFE EDGE OF THE STERN LIFEBOAT HATCH HAD 02 NOTCHES CUT OUT THAT COMPROMISE THE LIFEBOATS WATERTIGHT INTEGRITY. SOLAS 1997 III/44.2 30ABC

WATERTIGHT TUNNELS SHALL BE OF THE SAME STRENGTH AS WATERTIGHT BULKHEADS AT THE CORRESPONDING LEVELS. THE MEANS USED FOR MAKING THEM WATERTIGHT, AND THE ARRANGEMENTS ADOPTED FOR CLOSING OPENINGS IN THEM, SHALL BE TO THE SATISFACTION OF THE ADMINISTRATION. PSCO OBSERVED WATERTIGHT SLIDING DOOR BETWEEN THE ENGINE ROOM AND CARGO TUNNEL WITH GAPS LARGE ENOUGH FOR LIGHT TO BE SEEN THROUGH WHEN FULLY CLOSED. SOLAS 2004 II-1/19.1 30ABC GAPS LARGE ENOUGH FOR LIGHT TO BE SEEN THROUGH WHEN FULLY CLOSED.

THE OIL RESIDUES WHICH CANNOT BE DISCHARGED INTO THE SEA IN COMPLIANCE WITH THE REGULATION SHALL BE RETAINED ON BOARD FOR SUBSEQUENT DISCHARGE TO RECEPTION FACILITIES. ANY DISCHARGE INTO THE SEA OF OIL OR OILY MIXTURES SHALL BE PROHIBITED EXCEPT WHEN THE OILY MIXTURE IS PROCESSED THROUGH AN OIL FILTERING EQUIPMENT MEETING THE REQUIREMENTS OF REGULATION 14.7 OF THIS ANNEX. PSCO OBSERVED SIGNIFICANT AMOUNT OF WATER IN THE CARGO TUNNEL MIXED WITH HYDRAULIC FLUID OIL AND COAL DUST RESIDUE CREATING AN OILY WATER MIX. WHEN [name withheld] HOW THE CARGO TUNNEL IS DE-WATERED, THE CREW EXPLAINED IT WAS COMPLETED BY PUMPING THE WATER MIX INTO TANK TST #7 PORT THEN DISCHARGED OVERBOARD ONCE OFFSHORE. MARPOL I/15.3.2 & 15.9 30ABC

THE PROVISION OF SAFE MEANS OF ACCESS TO AND THROUGHOUT THE SHIP, AND THE SATISFACTORY PHYSICAL CONDITIONS OF LADDERS, DECKS, BULWARKS. FENCING, HANDRAILS. ETC. PSCO OBSERVED 07 STEPS THROUGHOUT THE CARGO TUNNEL THAT WERE DETERIORATED, RUSTED THROUGH, OR COMPLETED WASTED. ILO 147 PREVENTION OF OCCUPATIONAL ACCIDENTS/STRUCTURAL FEATURES OF THE SHIP/PARAGRAPH 1 //and// PWSA 46 USC 70002 & 33 USC 1223(B) 17BC

THE CONDITION OF THE SHIP AND ITS EQUIPMENT SHALL BE MAINTAINED TO ENSURE THE SHIP IN ALL MEANS,"AND SHALL REMAIN FIT TO PROCEDE TO SEA WITHOUT DANGER TO SHIP OR PERSONS ONBOARD. PSCO OBSERVED MULTIPLE HYDRAULIC PIPE CONNECTIONS, HOSES, AND FITTINGS LEAKING AND ACCUMULATIONS ON THE DECK THROUGHOUT THE CARGO TUNNEL 74 SOLAS (2020) I/11A 17BC

ALL ELECTRICAL APPARATUS SHALL BE SO CONSTRUCTED AND SO INSTALLED AS NOT TO CAUSE INJURY WHEN HANDLED OR TOUCHED IN THE NORMAL MANNER. PSCO OBSERVED WATER INTRUSION FROM THE JACKET WATER COOLING OF GENERATOR INGRESSING INTO AN ELECTRICAL JUNCTION BOX. SOLAS (2004) II-1/45.1.3 17BC

“A’ CLASS DIVISIONS ARE THOSE DIVISIONS FORMED BY BULKHEADS AND DECKS WHICH COMPLY WITH...THE CAPABILITY OF PREVENTING THE PASSAGE OF SMOKE AND FLAME TO THE END OF THE ONE HOUR STANDARD FIRE TEST. PSCO OBSERVED MULTIPLE DRILLED HOLES THROUGH THE DOOR ELIMINATING THE INTEGRITY OF THE BOUNDARY. SOLAS (1997) II-2/3.3 17BC

THE SAFETY OF PASSENGERS, CREW AND SHIP FROM ELECTRICAL HAZARDS WILL BE ENSURED. PSCO OBSERVED GROUND ON 220V DISTROBUTION PANEL IN THE ENGINE CONTROL ROOM. 74 SOLAS(04) II-1/40.1.3 10c

04114 - Emergency Systems - Started Automatically upon failure of the main source of electrical power supply, a second source independent means of starting the emergency generator is provided. PSCO observed batteries for emergency generator depleted and unable to start generator. 74 SOLAS (97). II-1, Reg: 43.3.1.2.

02129 - Structural Conditions - Each watertight subdivision bulkhead shall be constructed in such a manner that it shall be capable of supporting the pressure due to the maximum head of water. PSCO observed 7 bulkheads in Cargo Tunnel with wires running through tubes without packing to ensure watertight integrity. 74 SOLAS (97). II-1, Reg: 14.1.

12107 - Dangerous Goods - Where cables which are installed in hazardous areas introduce the risk of fire or explosion in the event of an electrical fault in such areas, special precautions against such risk shall be taken to the satisfaction of the administration. PSCO observed 7 light fixtures in the cargo tunnel with exposed wiring, insufficient packing glands, or open electrical boxes. 74 SOLAS (97). II-1, Reg: 45.5.4.

04110 - Abandon ship drills - Each abandon ship drill shall include reporting to stations and preparing for the duties described in the muster list. PSCO observed crew members report without billeted items and unfamiliar with muster list. 74 SOLAS 20 III/19.3.4.1. 17.c

11131 - On board training and instructions - The training manual shall contain instructions and information on the life saving appliances in the ship. PSCO observed Life Jacket and Ring Buoy lights of different manufacturer type without operating procedures in the ship's training manual. 74 SOLAS 20 III/35.3. 10.c

11105 - Rescue boat inventory - All items of rescue boat equipment, with the exception of boat hooks, shall be secured within the rescue boat by lashings, storage in lockers or compartments. PSCO observed rescue boat not contain buoyant oars. LSA Code 5.1.2. 10.c

15109 The company should establish proceedures to ensure that the ship is maintained in accordance with the provisions of the relevant rules and regulations established by the company. The technical and/or operational nature of the deficiencies noted below provide objective evidence of a serious failure of the implementation of the ISM Code. An external audit report satisfactory to the OCMI must be submitted prior to clearance of this deficiency. 74SOLAS(20)IV/3.1 ISM Code 10.1 30ac

09233 In a ship in which fuel oil is used, the arrangement for the storage, distribution and utilization of the oil shall ensure the safety of the ship. PSCO observed an oil leak from a high—pressure fuel line and lube oil line, both attached to the main engine, at a rate of 2—3 drops a minute. These conditions allowed for the introduction of flammable oils into the engine room, creating a hazardous condition. 74SOLAS(97 cons) II-2/15.2 17ac

09233 Satisfactory means (in the form of guard rails...) shall be provided for the protection of the crew in getting to and from the machinery space. A guard rail on the starboard side of the engine in the tween deck was missing, creating a hazard whereby personnel could fall 15 to 20 feet. ICLL(66)REG 25(4) 17ac

02107 Following installation, the master, owner, operator, agent, or person in charge of the vessel subject to this subpart must properly maintain the BWMS in accordance with manufacturer specifications. There is a leak of approximately 6—10 gallons per day of treated ballast streaming in from a clean water ballast tank valve causing water to enter the engine room. 33CFR151.2025(a)(1) 17ac

07126 The condition of the ship and its equipment should 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 persons on board. Holding devices were found to be in place pressing down on the pressure valves for sight glasses on the lube oil tank and HFO settling tank. The use of these devices creates a risk for large amounts of oil to spill into engine room spaces and a potential hazard to the ship and its crew.

15109-In meeting these requirements, the company should ensure that: inspections are held at appropriate intervals; appropriate corrective action is taken; and records of these activities are maintained. PSCO observed two crew cabins and several locations thought accommodation spaces with excessive and disorganized items stored preventing safe access to the space and showing that good house keeping practices are not being followed as required by the company. The remarks on the deck and accommodation inspections and the crew quarter inspections do not reflect the conditions of the vessel at the time of the exam. Additionally, the monthly deck maintenance inspections are not being conducted as required by company procedures and the remarks on the weekly inspections for the pilot ladders and embarkation ladder do not reflect the condition of the fwd embarkation ladder as stated in deficiency #3. Furthermore, The liferaft testing log form for the 2022 inspection is not properly filled out and the crew has not conducted the 2023 liferaft inspections. Due to the objective evidence in the above deficiency and as stated in deficiencies 2,3,4,5,6 and 7 the vessel is not in substantial compliance with the relevant conventions. The Captain of the Port questions the adequacy and overall implementation of the vessel's SMS under the ISM Code. An external audit conducted by Flag or RO is required to determine whether the ship is operating in accordance with the ISM Code. Provide a copy of the completed audit report to the Coast Guard prior to departure from port. 74SOLAS(20)IX/3.1 ISM Code 10.2

07123-Fire fighting systems and appliances shall be kept in good working order and readily available for immediate use. PSCO observed that safety pins on all CO2 bottles were in place. Per manufacture instructions safety pins shall be removed. 74SOLAS(20) II-2/14.2.1.2

11112-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. PSCO observed forward embarkation ladder with seized shackles and wasted side ropes. Additionally,PSCO observed wasted retro tape on forward liferaft and damage to the outside shell. Furthermore, the crew was not able to provide documentation for the 2023 liferaft inspections. 74SOLAS(20) III/20.1

07105- The fire resistance doors shall, as far as practicable be equivalent to that of the division in which they are fitted. PSCO observed the emergency escape door in lower deck of engine room, an A-60 boundary space, was warped and wasted to the point it did not properly close. 74SOLAS(20) II-2/47.1

All access openings in bulkheads at ends of enclosed superstructures and hull be fitted with doors of steel or other equivalent material permanently and strongly attached to the bulkhead and framed, stiffened and fitted so that the whole structure is of equivalent strength to the unpierced bulkhead and weathertight when closed. PSCO Observed several weathertight doors on deck that were not able to be fully closed. Additionally missing doggs and excessive wastage and cracks were observed in coaming and bulkhead around door in "A-Frame SUL hydraulic room" ICLL Reg 12.1

09210-The condition of the ship and its equipment shall be maintained to ensure the ship in all means will remain fit to proceed to sea without danger to ship or person's on board. PSCO observed multiple hydraulic pipe connections, hoses and fittings leaking and accumulation on deck between the cargo holds frames and under hydraulic control stations. Additionally, excessive corrosion and cracks were found in port side cargo hold #1 hatch motor support bracket. 74SOLAS(20) I/11a

14104-After any survey of the ship under paragraph 1 of this regulation has been completed, no changes shall be made in the structure, equipment, systems, fittings, arrangements or material covered by this survey, without the sanction of the administration, except the direct replacement of such equipment and fittings. PSCO Observed numerous modifications to the oily water separator, to include excess piping that is not reflected in the approved piping diagram for the OWS. MARPOL Annex I/ Reg 6.4.2

CGOO6 - Other (Safety in General) - Following installation the master, owner, operator, agent, or person in charge of the vessel subject to this subpart must properly maintain the BWMS in accordance with all manufactures specifications. PSCO observed BWMS inoperable with a leaking flange. 33CFR151.2025(a)(1)/15AC

03103 - Railing, gangway, walkway and means for safe passage - The condition of the ship and all equipment shall be maintained to ensure the ship in all means will remain fit to proceed to sea without danger to persons onboard. PSCO observed a broken railing on the self loader power pack system space ladder. 74SOLAS(2020)I/11A /15AC

07101 - Fire prevention structural integrity - ...Stairways and lift trunks which penetrate more than a single deck shall be surrounded by at least "A-0" class divisions... PSCO observed unsealed cableway through a class boundary. 74SOLAS(2001)II/2/46.1/ 15AC

Launching arrangements shall comply with requirements of Reg 16. However, all rescue boats shall be capable of being launched where necessary utilizing painters, with the ship making headway at speeds up to 5 knots in calm waters. PSCO observed the rescue boats installed lifting hook was not in accordance with the ship's SOLAS Training Manual and was not a style that could be released on load. 74 SOLAS (2001) III/17.3

Oil fuel pipes and their valves and fittings shall be of steel or other approved materials, except the restricted use of flexable pipes shall be permissable in positions where administration is satisfied they are necessary. PSCO observed multiple flexable hoses installed in the self loaded power pack hydraulic system. Some of the hoses were passing through watertight doors impeding the operation of the doors, additionally some of the hoses were damaged and actually leaking. 74SOLAS(2001) II-2/16.2.8

The condition of the ship and its equipment shall be maintained to ensure the ship in all means will remain fit to proceed to sea without danger to ship or person's on board. PSCO observed multiple hydraulic pipe connections, hoses and fittings leaking and accumulations on deck between the cargo hold frames. 74 SOLAS (2020) I/11a

The condition of the ship and its equipment shall be maintained to ensure the ship in all means will remain fit to proceed to sea without danger to persons on board. PSCO observed a broken railing on the self loader power pack system space ladder. 74 SOLAS (2020) I/11a

74 SOLAS 14 I/11(a): The condition of the ship and it's 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 fire took place on the self-discharging conveyor belt inside the conveyor gallery. Vessel is to provide USCG class report to verify structural integrity of affected area.

NOT LESS THAN ONE HALF OF THE TOTAL NUMBER OF LIFEBUOYS SHALL BE PROVIDED WITH LIFEBUOY SELF-IGNITING LIGHTS. PSCO OBSERVED 03 SELF-IGNITING LIGHTS TO BE INOPERABLE WHEN TESTED. 74 SOLAS (97) III/7.1.3

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's observed multiple hydraulic leaks on service pipelines. RO to attest to condition of on deck hydraulic lines.

Lifejackets shall be placed as to be readily accessible and their position shall be plainly indicated. PSCO's observed lifejackets blocked behind cabinets restricting accessibility and ability to be observed.

0715: The function of detection system shall be periodically tested to satisfaction of admin by means of equipment producing hot air at the appropriate temp, or smoke or aerosol particles having appropriate range of density or particle size, or other phenomena assoc. w/ incipient fires to which decetor is designed to respond. Testing equip for heat sensors not onboard. 74SOLAS(97CONS)11-2/12.1.13 40(a)(c)

1499: The machinery, boilers, and other pressure vessels, associated piping systems, and fittings shall be of a design and construction adequate for service for which intended and shall be so installed and protected as to reduce to a minimum any danger to persons on board. PSCE observed wooden plug in valve that is part of ballast system. 74SOLAS(04CONS)II-1/26.1. 50(a)(c).

Whenever an accident occurs to a ship which affects the safety of the ship, the nominated surveyor or recognized organization responsible for issuing the relevant certificate shall cause investigations to determine whether a survey is recessary. As a result of vessel grounding provide class report attesting to the condition of the hull after survey. SOLAS '14 Ch. 1 Reg. 11(c)