SLNC CORSICA

The ship shall remain safe to proceed to sea. Concrete box patch found on tank top of Tank 51 in ER.

A seaman shall be served at least 3 meals a day suitable in respect to quantity, nutritive value, and quality. The freezer designated for storage of meat fails to maintain a temperature below freezing and meat was found thawed posing a potential health risk to the crew. *while the US is not signatory to the MLC 2006, the vessel maintains a MLC Statement of Voluntary Compliance issued by ABS agreeing to conform with its provisions. See NVIC 02-13, Ch 1. 46 USC 10303 ILO 68 Article 5 MLC(2006) Reg 3.2* 17c

Independently driven emergency pump which shall be capable of supplying two jets of water to the satisfaction of the administration. Emergency fire pump discharge capacity has degraded, repair to OEM specifications. 74 SOLAS (97) CH II-2 Reg 4.3.3.2

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. Rescue boat patch kit missing approved adhesive. 74 SOLAS(2020) Ch. III Reg. 20.2

The fire resistance of doors shall, as far as practicable, be equivalent to that of the division in which they are fitted. Identified modifications to bridge stairwell A-0 self closing door lock and sill strike plate, large gaps in door and sill without fire resistant material, making it susceptible to fire and smoke. repair/replace to OEM specifications. 74 SOLAS(97) Ch. II-2/Reg. 47

The fire resistance of doors shall, as far as practicable, be equivalent to that of the division in which they are fitted. A-0 door from oil purification room to emergency escape does not secure, repair/replace to OEM specifications. 74 SOLAS(97) Ch. II-2/Reg. 47)

Structural fire protection and protection of openings should be kept in good order and ready for immediate use. During document review, an internal report was found indicating that the crew had identified 57 of 81 fire dampers either failed internal tests or required maintenance. This report was filed by 2/M on March 31, 2022 and was not acknowledged by the Master or Company. A previous report citing similar conditions was filed in December 2021. There was no documentation that any action was taken. Attending Marine Inspectors validated that several dampers were in poor condition. Note: An ISM Audit had previously been conducted 1 day before this inspection w/ Major Non Conformity identified. Flag State instructions to be provided to RO to verify corrective action plan at follow up audit due NLT 08 August 2022.

Bridge shall be provided with clear-view windows. It was noted that one of the bridge windows was broken and completely spider webbed. *repairs due on next arrival in Singapore following call in [name withheld].

Cables and wiring shall be installed and supported in such a manner as to avoid chafing and damage. Damaged/cracked electrical cable splices noted in port side grease locker in way of emergency fire pump control panel.

Fire-fighting systems and appliances should be kept in good working order. Controls for emergency fire pump were found to be loose/dangling and not correctly mounted. In addition, the ventilation over the fire pump motor controller allows condensation/moisture to drip on the motor controller panel which is not fitted with a drip shield.

Ship shall be maintained to conform to regulations and no changes shall be made to structural arrangements without the approval of the Administration. Company conducted steel work in way of emergency generator room and used epoxy at intersection of deck/bulkhead rather than welding.

Vessel is to be fitted with standard discharge connection. Standard discharge connection is missing from both port/stbd piping. This deficiency has been written multiple times.

Life saving appliances shall be kept in working order and ready for immediate use. Rescue boat compass is cracked and filled with moisture. Crew identified this issue during routine on-board inspections and first documented the issue in May 2021. No action has been taken to date. In addition, the fire extinguisher is heavily corroded and unserviceable.

Penetrations of A class divisions shall be in accordance with the FTP Code. Electrical cable penetration in the overhead of engine room in way of Reverse Osmosis unit.

Condition of ship/equipment shall be maintained to conform w/ MARPOL Convention. Sludge pump is inadequate to effectively discharge without the assistance of an additional pump. Discharge arrangement to be reviewed by class and modified if necessary with approved modifications.

The company should establish procedures to ensure that the ship is maintained in conformity with relevant rules and regulations. From February 2019, five external and at least two internal SMS audits, all resulting either Major Non-Conformities (MNC), non-conformity (NC), or observations related to shipboard maintenance. In each case, after immediate corrective actions are completed, objective evidence indicates that the Company's procedures are ineffective to maintain the ship in a continual state of compliance for any significant period of time. As a result of habitual non-compliance, the Certificate of Inspection (COI) and Safety Management Certificate (SMC) were withdrawn. The Company is directed to develop and implement a meaningful corrective action plan (CAP) with specific procedures to maintain and continually assess the vessel's status. The CAP must be submitted to the Coast Guard and the Recognized Organization (RO) for review. The following deficient items constitute objective evidence of ineffective maintenance procedures: .1 The incinerator for discharging oil residue (sludge) processing was inoperable during operational testing, misfiring during attempted starting, and damaged refractory was noted. .2 The fixed CO2 fire extinguishing system discharge nozzle, located in the workshop space connecting to the ECR, is obstructed with foreign rod-like object, rendering it ineffective when discharged. .3 Fire detector at upper level of fiddly found inoperable during operational testing. .4 The structural fire protection rating of the A-60 door from the ECR to transformer space has been compromised and the door is in need of replacement. .5 During operational testing, the fire damper at the incinerator was found in the closed position. Upon reset, the damper was unable to be closed and the pull cable broke. .6 Bilge alarm level sensor at the forward port side of the E/R was found removed from the bilge, laying across piping approximately four feet above bilge well. .7 Hydraulic leaks are present on the forward mooring winch motors and piping in the foc’sle with standing hydraulic fluid and soiled sorbent pads present. .8 Fuel Oil transfer pump in forward pump room is leaking. .9 Over-speed and low lube oil pressure were not able to be demonstrated on auxiliary or emergency diesel generator prime movers. .10 Exhaust leak is present on the exhaust casing in the fiddley (second deck), with evidence of potential water leak on piping below. .11 Heat exchanger for thermal fluid heater has visible oil leak thru the insulation and has leaking gauge at pump in E/R. .12 A directional control valve for the CPP system is disconnected with block sitting near controls with no explanation available for reason it was removed or current operational status. .13Sight glass is missing on D.O. Day Tank 32.A.

Note - sub deficiencies listed below are related to previously issued deficiencies. As such additional deficiency details were intentionally left blank. .14 Scupper located on the port side of the vessel in way of tank 125 was clogged and did not allow deck to drain. .15 Piping in aft steering overhead is leaking. .16 High level sensor missing on Tank 35. .17 Piping at fuel skid is being used as a step which is damaging the installed installation. .18 Bilge suction line in E/R has unapproved hose connection permanently installed on suction side. .19 Quick Closing valve on Tank 35 secured with bailing wire and there is an active leak on the attached piping. .20 Valve handle for Tank 23 is missing a securing nut to ensure handle is attached for use. .21 Fire pump #2 has exposed wires protruding from stuffing tube. .22 Light fixture across from Tank 23 has improper cable termination. .23 Lube oil transfer pump has improper cable termination at the motor junction box. .24 The jacking gear has exposed cable protruding from stuffing tube. .25 Multiple lighting fixtures were found missing covers in the E/R and fiddly. .26 Lighting fixture in Grease Locker is damaged and light bulb appears to be installed and attached by its wiring. .27 Potable water lines thru E/R on the expansion tank level have soft patches.

Fire detection and alarm systems shall be kept in good working order. Cargo hold smoke detection sample extraction system was found in ‘fault’ condition with extraction fans inoperable and motherboard in need of replacement due to standing alarm. The Marine Inspector was informed the replacement motherboard had been purchased and was onboard but the Port Engineer had not arranged the required electrician for installation. 74 SOLAS(20) II-2/14.2

Doors fitted in boundary bulkheads of machinery spaces of category A shall be reasonably gas tight and self-closing. Multiple self-closing doors penetrating the engine room casing and stair tower are not self-closing, do not latch, have been modified, or are damaged, compromising the A-60 boundary rating. Multiple deficiencies have been identified regarding self-closing doors on previous inspections. 74 SOLAS(01)II-2/47.1

No person may operate any vessel with installed toilet facilities unless it is equipped with an operable Type II device. The Marine Sanitation Device has documented history of maintenance issues. Internal audit report from February 21-23, 2020 states “the waste system on board the vessel is very problematic, and system regularly breaks down and spare parts are difficult to obtain.” The MSD was inoperable during shipyard attendance in March 2021 (see activity 7156911) and was found operating without chemicals necessary to treat sewage during in-service inspection on October 18, 2021. MARPOL Annex IV/9.1.1* (U.S. Not signatory but vessel carries SOVC) 33 CFR 159.1(a)(1)

The fire integrity of divisions shall be maintained at openings and penetrations. During an inspection, it was noted that an A-class boundary was improperly penetrated to install an additional air receiver/compressor on deck. It is unclear whether or not this was a modification that occurred post MSP -reflag (there is no mention of this arrangement in MSP gap analysis*) and the air receiver data plate was illegible so MIs were not able to determine if is an approved type suitable for use onboard the vessel, Restore fire integrity at penetration and provide approval documentation for air compressor/receiver or remove it. *Note - NVIC 01-13, Change 1, Enclosure 3, 1.4 74 SOLAS (01) II-2/44 74 SOLAS (20) II-1/26.1

Accommodation spaces shall be properly ventilated and ensure sufficiency of air movement in all climates in order to promote seafarers' health and well-being. The vessel's air conditioning system is inoperable and does not provide adequate ventilation. Internal temperature inside the accommodation was ~85 deg ( F ) during the inspection and one of the air condition condenser was found to be excessively iced. *note that the U.S. is not signatory to the MLC, however this vessel maintains an MLC 2006 Statement of Voluntary Compliance 46 USC 11101 ( a ) (3) ILO C092 Article 7 MLC (2006) Reg 3.1*

International shore connection shall be available to enable use on either side of the ship. Due to equipment configuration on deck, the International Shore Connection cannot be reached and is unavailable for use. 74 SOLAS (01) II-2/19

The ship and its equipment shall be maintained to proceed to sea without danger to the crew. The forward pump room did not have adequate illumination with only one overhead light illuminated for the entire space. 74 SOLAS (20) I/11(a)

Oil level gauges (i.e., sight glass) used on fuel or lube oil tanks shall have self-closing valves between the gauges and the tanks to prevent the release of fuel or lube oil in the event of damage to the gauge. The oil level gauge on the thermal fluid tank located in the fiddley is fitted directly to the tank with no valves to stop leaks in the event of damage to the sight glass. 74 SOLAS (01) II-2/2.2.3.5.2.2 and 2.3.1

Oil residue (sludge) tanks shall be provided with a designated pump. Controls for the sludge pump are not permanently installed and an unapproved installation of a newer secondary pump back feeds sludge thru the original approved installation. It is unclear if this arrangement was approved by class. MARPOL Annex I/12.3.2

A standard discharge connection shall be fitted on the oil residue (sludge) and machinery bilge lines. Standard discharge connection on the port side was missing and the starboard side standard discharge connection was found disconnected, laying in containment with improper connection fitted. MARPOL Annex I/13

Fire detection systems shall be properly tested by appropriate means. No manufacturer’s instructions were available to determine the equipment required for testing heat detectors. 74 SOLAS (01) II-2/13.1.13

The SMS should provide for specific measures to promote the reliability of equipment and technical systems. There were no testing procedures available for OWS Oil Content Meter. Of note, the Company's internal audit completed on 23 Feb 2020, notes that "reports of leaking and patch work which has been performed. The company should as a measure of proactive maintenance to replace this critical equipment." SOLAS IX/3.1 ISM Code 10.3

It shall be possible for all machinery essential for the safe operation of the ship to be controlled from a local position. The emergency fire pump is unable to be started or stopped from the ‘local position’ at the emergency fire pump and vessel configuration prevents radio communication between the remote control locations in the Grease Locker and the Bridge. 74 SOLAS (04) II-1/49.4

Escape routes shall be maintained clear of obstacles and have clear marking. Emergency escape door in Engine Room at "bilge water pump" is not marked and landing is being used for storage, blocking egress. 74 SOLAS (01) II-2/45

Machinery shall be adequate for the purpose for which it is intended. "Bilge water pump" in engine room has leaking fitting and leaking seal with pooled oil in the bilge below the pump. 74 SOLAS (20) II-1/26.1

Non-conducting mats shall be provided at the front and rear of the switchboard. Non-conducting mat at front of main switchboard in engine room is warped, creating a tripping hazard. 74 SOLAS (04) II-1/45.2

The safety management system should promote the reliability of equipment and technical systems. During review of maintenance records in NSE, there are several overdue standard jobs, no list of critical spares, and no available inventory for parts. It is unclear whether overdue jobs have been completed or if NSE has not been updated upon standard job completion. Company is required to conduct internal audit limited to NSE standard job implementation and accuracy. 74 SOLAS (20) IX/5 ISM Code 10.3

Electrical equipment shall be easily accessible. Distribution panels and transformers located in the port tunnel outside the ECR are inaccessible due to haphazard storage of items in the space. 74 SOLAS (04) II-1/40 DNV Rules 4-8-10/2.1.1(c)

Means shall be provided to keep the starting air pressure at the required level where internal combustion engines are used for main propulsion. Starting air receivers shall be automatically charged. Air compressors charging the receivers must be changed to "manual" prior to starting the main engine to build adequate start air pressure. 74 SOLAS (04) II-1/53.5 DNV Rules 6-2-2/2.2.1.2

Machinery spaces shall be adequately ventilated. Thermal fluid heater control panel has temporary installation of flexible plastic tubing supplying air condition from ventilation duct through unapproved installation into side of control panel. 74 SOLAS (04) II-1/35

Machinery spaces shall be adequately ventilated. The ventilation fan at the entrance to the cargo hold bilge pumproom and ventilation fan in the anti-heeling room are inoperable. A purchase request, REQ9300371, was initiated on 01Feb2021 for delivery by 18Mar2021 and remains unfulfilled. 74 SOLAS (20) IX/5 ISM Code 3.3

Means shall be provided to control leaks of flammable liquids. Containment around thermal fluid heater has recurrence of standing oil. Clean prior to departure and identify source. 74 SOLAS (20) II-2/4.1.1

Means shall be provided to keep the starting air pressure at the required level where internal combustion engines are used for main propulsion. Two or more compressors shall be installed with a total capacity sufficient for charging the air receivers from atmospheric to full pressure in one hour. During operational testing, air compressor #2 shut down due to "high air temperature" alarm prior to the completion of one hour. Air compressor #1 could not maintain acquired pressure in air receiver and pressure in both air receivers dropped by 10 bar after air compressor #2 shut down. 74 SOLAS (04) II-1/53.5 DNV Rules 4-6-5/9.4.4

Means shall be provided to control leaks of flammable liquids. Oil is present throughout engine room bilges creating a fire hazard. 74 SOLAS (20) II-2/4.1.1

Machinery shall be adequate for the purpose for which it is intended. During operational testing of the main diesel engine, a lube oil leak developed at the expansion bellows on the supply side of the lube oil pump. 74 SOLAS (20) II-1/26.1

Machinery shall be adequate for the purpose for which it is intended. Lube oil plate cooler has reoccurence of accumulation of drippage beneath, which appears to be both oil and water, not rectified since identification at shipyard in March 2021. 74 SOLAS (20) II-1/26.1

74 SOLAS (2020) Chapter 1, Part B, Regulation 11: The condition of the ship and its equipment shall be maintained to conform with the provision of the present regulations to ensure that the ship in all respects will remain fit to sea without danger to the ship or persons on board. Remove and properly dispose of pockets of oily waste, contaminated rags & debris in engine room bilge and maintain general housekeeping throughout entire engine room and all machinery spaces.

74 SOLAS (2004) Chapter II-1, Regulation 29/12.3: Hydraulic power-operated steering gear shall be provided with a fixed storage tank having sufficient capacity to recharge at least one power actuating system including the reservoir, where the main steering gear is required to be power-operated. CG MIs identified the storage tank did not have enough oil to refill the reservoir.

74 SOLAS (2004) Chapter II-1, Regulation 40.1.3: Electrical installations shall be such that the safety of passengers, crew and ship from electrical hazards shall be ensured. Terminate dead end wires into a junction box in engine room on starboard side bottom flat.

74 SOLAS (2004) Chapter II-1, Regulation 40.1.3: Electrical installations shall be such that the safety of passengers, crew and ship from electrical hazards shall be ensured. Repair ground wire not connected inside solenoid valve control station cabinet.

74 SOLAS (2004) Chapter II-1/40.1.3: Electrical installations shall be such that the safety of passengers, crew and ship from electrical hazards shall be ensured. Repair light fixture hanging from rusted/broken bracket above rescue boat.

74 SOLAS (2020) Chapter 1, Part B, Regulation 11: The condition of the ship and its equipment shall be maintained to conform with the provision of the present regulations to ensure that the ship in all respects will remain fit to sea without danger to the ship or persons on board. Replace missing safety shields on bench grinders in machinery workshop to the satisfaction of RO and USCG MI.

MARPOL ANNEX I/CH.3/12.2: Oil residue(sludge) may be disposed of directly from the oil residue (sludge) tank(s) to reception facilities through the standard discharge connection or to any other approved means of disposal of oil residue (sludge), such as an incinerator. CG MI observed that approximately 12” by 14” of refractory on the incinerator base is missing, the vessel primarily uses the incinerator to burn operational waste.

74 SOLAS (2001) Chapter II-2, Regulation 21: Fire-extinguishing appliances shall be kept in good order and be available for immediate use at all times. CG MIs identified several portable fire extinguishers throughout ships spaces such as reefer compressor room and forward paint locker that were secured with nylon rope or an unapproved strap preventing the apparatus from quickly and easily being released.

SOLAS CH.IX/REG.3.1, ISM CODE 7: The company should establish procedures, plans, and instructions including checklists as appropriate, for key shipboard operations concerning the safety of personnel, ship and protection of the environment. CG MI observed the following nonconformities: (1) several temporary repairs were made in the engine room and were not reported to the Certificate Issuing Authority. SMS procedures does not indicate notifications or reports to their Recognize Organization (DNV-GL) and (2) SMS did not have/lacking drug and alcohol testing requirements as per 46 CFR 4 & 16.

74 SOLAS (2020) Chapter 1, Part B, Regulation 11: The condition of the ship and its equipment shall be maintained to conform with the provision of the present regulations to ensure that the ship in all respects will remain fit to sea without danger to the ship or persons on board. Replace missing cotter pins on all weathertight doors on house.

74 SOLAS (2020) Chapter 1, Part B, Regulation 11: The condition of the ship and its equipment shall be maintained to conform with the provision of the present regulations to ensure that the ship in all respects will remain fit to sea without danger to the ship or persons on board. Replace missing hold backs to as original on forward hatch covers marked pump room and for bow thruster room on main deck.

74 SOLAS (2020) Chapter 1, Part B, Regulation 11: The condition of the ship and its equipment shall be maintained to conform with the provision of the present regulations to ensure that the ship in all respects will remain fit to sea without danger to the ship or persons on board. Repair lights inoperative at steering gear space and above reverse osmosis unit in engine room.

Ships, when engaged on an international voyage, shall be fitted with a VDR or S-VDR. The S-VDR onboard displayed error code “307” indicating a “mandatory serial signal has disappeared” and the input code “SI06” and “SI07” were indicated. 74 SOLAS (20) V/20

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. Both search and rescue locating devices (SART) aboard were inoperable. 74 SOLAS (20) III/20.2

The company should ensure that each ship is manned with qualified, certificated, and medically fit seafarers in accordance with national and international requirements. The vessel employs two riding gang members (a “fitter” and an “electrician”) that are not US citizens nor lawfully admitted aliens. The company has not satisfied the provisions of 46 USC 8106(f) to employ non-citizen mariners or non-lawfully admitted aliens. The riding gangs are employed for periods longer than 60 days. There were no available records indicating the riding gang members have completed Basic Training, Coast Guard-approved security training, TWIC application process, or required background checks. *** Due to government of Singapore COVID restrictions on crew change, the riding gang members cannot be immediately disembarked. Riding gang members shall be discharged by next departure from Singapore or the company must satisfy the provisions of 46 USC 8106(f). Additional explanatory details are available in Marine Safety Manual, Volume III, page B1-19. 74 SOLAS (20) IX/5 ISM Code 6.2.1 46 USC 8106 46 CFR 15.1105(a) 46 CFR 15.1113(e) and (f) and 33 CFR 104 Subpart B

The condition of the ship shall be maintained. The Hospital Space bathroom has inoperable sink, shower, and toilet. 74 SOLAS I/11(a)

Structural fire protection, including fire resisting divisions, shall be kept in good working order. The self-closing door at the Boat Deck in the interior stairwell is not self-closing. 74 SOLAS (01) II-2/14.2.1

Self-contained breathing apparatus shall be fitted with an audible alarm and a visual indicator which will alert the used before the volume of air in the cylinder has been reduced to no less than 200 liters. Audible alarms were not able to be demonstrated during onboard fire drill. 74 SOLAS (20) II-2/10.10.1.2 74 SOLAS (20) II-2/10.10.1.2

Cables and wiring shall be installed and supported in such a manner as to avoid chafing or other damage. The switch for the emergency light is hanging by cable from the light and is not attached to the bulkhead. 74 SOLAS (04) II-1/45.5.5

An initial and retraining program for all persons concerned with the transport of dangerous goods is required. No objective evidence could be provided showing crew members involved with the transport of dangerous goods shipped via IMDG have had initial or retraining on the risks involved and detailed understanding of the regulations of IMDG. 74 SOLAS (20) VII/3 IMDG 1.3.0

The owner, operator, or master shall provide the OCMI with all valid certificates and registers of cargo gear. This includes certification data related to cranes, hoists, accessory gear, chains, hooks, shackles, swivels, and blocks. Required certificates or supporting documentation were incomplete or not provided. Crane blocks are visually extremely corroded/deteriorated. Company has de-rated capacity and noted in internal risk assessment following a "near miss" incident, that "rust" can fall and "cause death." Prior to use, cranes are to be tested by national cargo Bureau, International Cargo Gear Bureau, or authorized classification society. See 46 CFR 91.25-25; SOLAS IX/5: ISM Code 11.2.1. See Marine Inspection Notice 07-12, Change 1. NOTE: Cranes are not a class item nor did SLNC use DNV-GL as an RO. As such, USCG maintained direct oversight of cranes in conjunction w/ attending International Cargo Gear Bureau.

The rudder angle, propeller revolutions, pitch if a pitch propeller is fitted, thruster speed and direction, and gyro compass heading shall be easily readable from the docking workstation. The docking workstations on both the port and starboard bridge wings are inoperable with multiple required systems having gauges that are unreadable or labeled "decommissioned." 74 SOLAS (20) II-1/3-1, DNV Rules 6-3-4/2.4.11 and 3.2.4.2

The company should ensure that inspections are held at appropriate intervals, that appropriate corrective action is taken, and records are maintained. The cargo hold bilge pumping system is inoperable and was reported to the company on 08Jan2021, the cargo hold deluge system pump is inoperable and was reported to the company on 12Jan2021, and the quick closing valves for the vessel’s fuel tanks were reported inoperable to the company on 12Dec2020 with no corrective action until 10Feb2021 while the vessel was under flag state attendance. Upon further review of Company SMS records, there was no objective evidence that the Company has implemented corrective actions effectively. An external ISM audit is required. 74 SOLAS (20) IX/5, ISM Code 10.2

The condition of the ship shall be maintained. Steel degradation is visible in cargo hold #2 aft of Bay 17. Perform gauging of inner bottom cargo deck as necessary to the satisfaction of DNV. 74 SOLAS (20) I/11(a)

Machinery spaces shall be adequately ventilated. The forward pump room, which houses the emergency fire pump and fuel transfer pumps, has inoperable ventilation creating an atmospheric hazard to the crew. 74 SOLAS (04) II-1/35

Doors fitted in boundary bulkheads of machinery space of category A shall be reasonably gas tight and self-closing. The door separating the engine room and Engine Control Room is not self-closing. Adjust door as appropriate and demonstrate ability to self-close. 74 SOLAS (01) II-2/9.4.2.1

The ship shall have a properly adjusted magnetic compass to determine the ship's heading and display the reading at the main steering position. The magnetic compass does not display the ship’s heading and is out of calibration by approximately 8 degrees as indicated by the deviation card.

Fire-fighting systems and appliances shall be kept in good working order. The drencher system used as the means for effectively cooling the designated under-deck cargo space for the carriage of dangerous goods is inoperable. The pump supplying water to the system is inoperable and several sprinkler heads are damaged. Vessel is prohibited from carrying dangerous goods until proper operation is demonstrated. 74 SOLAS (20) II-2/14.2.1 UPDATE: Following request for reconsideration by company; original deficiency description was deemed to be overly broad. This deficiency is amended to restrict carriage of Class/Div 1.1-1.6, excluding 1.4S, in internal cargo holds until deluge system repaired.

An efficient bilge pumping system shall be be provided, capable of pumping from and draining any watertight compartment. Bilge pumping arrangements for cargo holds #1 and #2 (largest hold on vessel; ~70% of length) and forward voids are inoperable. The pumping arrangements, identified as "essential equipment" according the Company's SMS (SMS Manual-ENG-Section 05, 5.5) was reported as inoperable to the Company on January 08, 2021. In addition, the Company only entered it into the NS5 maintenance system on February 05, 2021, nearly a month after the initial failure. No report was ever made to the U.S. Coast Guard as required by the Company's SMS or (SMS Manual-SAF-Section 04, 4.4) or 46 CFR 4.05-1 (a)(4). It is noted that the Company added this issue to an upcoming yard specification, but there is no evidence the Company took any other action to immediate resolve the failure of critical equipment. SOLAS (2004 Cons) II-1/21.1.1; SOLAS IX/3.1; ISM Code 10.2.3.

All lifesaving appliances shall be in working order and ready for immediate use. Rescue boat cradle is deteriorated/wasted to the point that the cradle structure has separated from the deck. 74 SOLAS (20) III/20.1

Emergency escape door inside engine room is not self-closing or gastight. SOLAS (2001) II-2/47.1

Engine room fire damper #1 is frozen in position and fire damper #2 is wasted/corroded. SOLAS (2001) II-1/14.2.1.1.1

Found two unauthorized repairs on the OWS; soft patch on the vessel and a slugged weld on piping.

Vessel installed unauthorized flange and cam-lock fitting to transfer contents of HFO drain tank #50 to the sludge tank #44 via a portable pump through the tank #44 sounding tube. MARPOL (2001) 6.4.2

A-60 insulation on forward engine room bulkhead IWO bilge is deteriorated and/or missing. SOLAS (2001) II-1/14.2.1.1.1

The condition of the ship shall be maintained so that it is fit to proceed to sea. Vessel's sounding tube for port forward bilge well was completely deteriorated and had separated from remainder or pipe due to corrosion. SOLAS II-1/26.1

Machinery shall be adequate for intended purpose. SSDG#1 was discovered to have a sustained (continuous stream) fuel leak coming from the fuel filters. The leak was extensive enough to overfill the small discharge containment w/in ~15 mins of operation. Leak location is near top of SSDG, and fuel oil ran down exposed hot surfaces creating a fire hazard. SOLAS II-2/2.1.1.1

Vessels piping systems and fittings shall be adequate for intended purpose. The indicators for position of the vessel's ballast water control valves are not reliable and only functioning intermittently. SOLAS II-1/26.1.

The SMS should ensure compliance with mandatory rules and regulations. The below deficiencies, read in conjunction with related non-conformities issued at the February 02, 2019 intermediate audit related to shipboard maintenance, indicate a serious failure, or lack of effectiveness of the SMS. Vessel is to conduct an external SMS audit at next port. SOLAS IX/3.1 ISM Code 1.2.3.1 (reference DNV-GL intermediate audit report - Id No. G94700)

Ships shall be provided with tanks of adequate capacity, having regard to the type of machinery and length of voyage, to receive oil residues which cannot be dealt with otherwise. As listed on IOPP Form A, vessel is equipped with two bilge holding tanks (tank #43 and #51) for machinery space oily-water w/ total capacity of 52 m3. Both of these tanks are full. As such, the vessel elected to use the cargo bilge holding tank (tank #45) to hold an additional 43 m3 of oily-water. This tank is not authorized for machinery space oily-water mixtures, is not listed on the IOPP Form A, and is intended for cargo hold bilge water only. Vessel was transferring from bilge pockets w/in machinery space to the unauthorized tank via a portable pump through an unbolted manhole cover in the bilge. MARPOL Annex 1/12.1

Machinery controls shall be provided with effective means for operation and control. The temperature sensor on the main engine turbo charger was inoperable. SOLAS II-1/31.1

Electrical installations on vessels must ensure protection of passengers, crew and other persons on the vessel from electrical hazards. The air circuit breaker on the emergency switchboard in the Engine Room Control is recessed away from the face of the panel.

Machinery shall be so installed and protected as to reduce to a minimum any danger to persons on board, due regard being paid to moving parts, hot surfaces and other hazards. Hot surfaces were exposed and not protected on 2 exhaust turbo chargers for each auxiliary generator-prime mover.

No repairs or alterations affecting the safety of the vessel with regard to the hull, machinery, or equipment shall be made without the knowledge of the Officer in Charge, Marine Inspection (OCMI). A communication cable is penetrating a watertight door frame on the 04 Deck. This penetration is without the knowledge or approval of the OCMI.

No repairs or alterations affecting the safety of the vessel with regard to the hull, machinery, or equipment shall be made without the knowledge of the Officer in Charge, Marine Inspection (OCMI). An air receiver from a possible portable wheeled compressor unit (modified as an air accumulator for tools) was attached to the ships service air.

The vessels discharge pipeline for residues from machinery bilges and from oil residue (sludge) tanks, shall be fitted with a standard discharge connection. The vessels port sludge discharge pipe has a 4 bolt flange with a cam-lock - quick disconnect hose fitting, that does not meet the standard discharge connection 6 bolt slotted flange requirement. The vessel meets the standard discharge connection requirement for the starboard sludge pipe.

The vessel shall be provided with a designated pump for disposal that is capable of taking suction from the oil residue (sludge) tank(s). The approved sludge pump system is modified for an additional diaphragm pump. Approved drawings for the modification not provided.

Each inflatable liferaft serviced by a servicing facility approved by the Coast Guard must for each liferaft that passes inspections/tests, affix an inspection sticker to the liferaft container 100mm x 150mm (4x6 inches) with the last digit of the year of expiration and marked with the Coast Guard identifying insignia. The vessel servicing certificates are current; however, the liferaft containers are not marked as required by regulation.

Each operation described in 17.2 of the regulation shall be fully recorded without delay in the oil record book part 1, so that all entries in the book are appropriate to that operation are completed. Weekly soundings identified by Code C-11 entries, do not reflect names and capacities as identified on the IOPP Supplement Form-A 3.1 Table. Retention and capacity levels of oil residues for the Waste Oil Tank (No 53) not recorded.

Paint Locker Spray Nozzel was covered by a bucket. Remove bucket to allow proper operation of fire sprinkler system.

Fire Station 17 cannot be opened.

Port Side Main engine flat Fire Station was inoperable and did not allow passage of water.

Smoke detector on bridge does not alarm. Repair or replace.

Lights in EDG, Port Engine room escape trunk, and Fire fighting locker were not operable. Repair.

EDG Ventilation damper did not close properly.

Lube oil gauges on #2 generator and EDG are broken. Repair or replace.

Inspect ballast tank vent head floats for proper seating, 02 did not seat properly. Repair any that do not seat properly.

Rescue boat does not operate properly. Repair or replace.

Demonstrate proper operation of the main engine electronic speed control unit from the Engine Control Room (ECR). Repairs to be performed to the satisfaction of attending classification society surveyor. Provide the classification society report to CG Activities Europe for review and concurrence.

Provide written procedure to test SSDGs reverse power relay function in both auto and manual mode as per manufacturer.

Replace embarkation ladders at liferaft stations (port & starboard)

Switch liferaft to placedavit launched LR on starboard side of davit.

make ship available for full internal structural exam and dry-dock/hull inspection.

Battery for SART expired

Provide vessel specific oil transfer procedure for bunkering, discharging & internal tank to tank transfers within the vessel.

Marine Inspectors found evidence of heavy fuel oil inside the ballast vent DBT-104. Vessel must identify source of leak. This shall include a survey of the adjacent fuel oil tanks (#24 & #23) and ballast tank 104 to properly identify the source of the HFO migration. Once properly identified the vessel must make proper repairs to the ballast tank to prevent future migration of HFO.

During the inspection it was discovered that the vessel failed to accurately report an oil spil on deck that occured on/around 31JUL16. In accordance with the vessel's SMS all spills on deck must be reported in writing. ISM Code 2.2, 5 & 9.1

During the inspection it was discovered that the vessel failed to report a potential hazardous condition to the USCG, Company and class society. In particulat, the vessel failed to report the discovery of heavy fuel oil in ballast tank 104. ISM Code 2.2, 5 & 9.1 See narrative for futher CG actions.

Make permanent repairs to the ruptured paint locker sprinkler piping.

Prevent downflooding by repairing wiring conduit near deck penetration on port side main deck.

Freefall lifeboat has not been exercised in the water or released since December 2015. SOLAS 74am (14 Cons Ed) III/3.3.4

Make stern door at poop deck and forward paint store watertight.

Replace missing stud on manhole TK41 port side void in E/R.

Replace missing securing device for fire damper above port door by liferaft.

Replace fresh water line outside purifier room above main engine.

Repair/replace overhead light fixture in machine shop.

Repair/replace missing blank on high voltage boiler control panel.

Rescue boat grablines found missing.

Life ring at pilot station found without name of vessel/port of registry marked.

Self igniting light at pilot station life ring did not work.

#2 low hydraulic level float sensor is inoperable. Vessel shall install new operable sensor to the satisfaction of the attending CG MI prior to 01 September 2016. During the interim, frequent checks must be made of the hydraulic fluid levels. Thes checks must be noted in a daily entry in the ship's log.

Vessel's steering pump #2 was not able to function properly when tested in the presence of the attending CG [name withheld] proper functioning of pump #2 to CG MI satisfaction. Cite: 74 SOLAS(2014 edition) II-1/29.1. Due date: PRIOR TO SAILING.

Vessel's hydraulic oil level sensor for #2 steering pump is inoperable. Complete repairs and demonstrate proper functioning of alarm to the satisfaction of the attending CG [name withheld]: 74 SOLAS(2014 edition) II-1/29.12.2. Due date: PRIOR TO SAILING.

The navigation bridge's control & alarm panel for the #2 steering pump is inoperable. Repair and demonstrate proper functionality to the satisfaction of the attending CG [name withheld]: 74 SOLAS(2014 edition) II-1/29.8. Due date: PRIOR TO SAILING.

Provide Class Surveyor's report attesting to rectification of deficient steering gear items, as listed in deficiencies 2-4, and attesting to a satisfactory operational test. Cite: 74 SOLAS(2014 edition) II-1/29.1. Due date: PRIOR TO SAILING.

Vessel had a three to four minute loss of steering while transiting inbound through the Port of Hampton Roads. Vessel must conduct operational test of steering system to the satisfaction of an attending marine inspector prior to getting underway.

Starboard anchor windlass brake failed during heavy weather anchoring.

Vessel lost anchor and chain after anchor windlass failed. Vessel must make in kind replacement to anchor and chain

Poop deck fire plug valve was inoperable and there was no flow on the fire plug valve in the engine room above the generator batteries.

Vessel was moored stbd side to and unable to launch rescue boat.

When testing all hoses, four were leaking and deemed unserviceable.

Cargo hold, port side, had one sprinkler diffuser crushed and one diffuser pipe bent.

Need to witness a MOB drill once the vessel is moored port side to, so that the rescue boat can be launched.

The start air receivers relief valves need to either be re-newed or bench tested or proven that they relieve properly.

Several self closing fire doors had hold backs. Bridge door, galley door and several others in the machinery spaces and stair tower.

Poop deck stbd side ring buoy light is OOC.

Main deck stbd side ring buoy, by brow, was a 4.5kg (bridge buoy). Replace with 2.5kg ring buoy.

Lifeboat needs vessel name/call sign labeled on the top.

Bridge PFD light had a broken clip.

Several vessel documents needed to be updated with the vessel name and proper call sign.

Master of vessel failed to provide a proper notice of arrival when entering the POrt of Mobile, AL.

Two engine room emergency escape fire doors to not self close completely (SOLAS 74 II-2/47).

Steering room does not have non-skid to prevent slips in the event of hydraulic fluid leak (SOLAS 74 II-1/29).

COFR INVALID DUE TO VESSEL NAME CHANGE. (33 CFR 138.90(d)) LEGACY COMPONENT DESC: Certificate of Financial Responsibility

ALL LIFESAVING APPLIANCE NOT STENCILED WITH THE VESSEL'S CURRENT NAME. E.G. LIFEBOAT, ETC. (SOLAS 74/78 REG I-11