CAPE RAY

Each emergency generator set arranged to be automatically started shall be equipped with starting devices approved by the Administration with a stored energy capability of at least three consecutive starts. A second source of energy shall be provided for an additional three starts within 30 min unless manual starting can be demonstrated to be effective. Vessel was unable to demonstrate the required amount of starts. 74 SOLAS (97) II-1/44.2

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. General Emergency alarm in steering gear room found inoperable. 74 SOLAS (20) III/20.2

The following fire protection systems shall be kept in good order so as to ensure their required performance if a fire occurs: protection of openings and penetrations in these divisions. Found engine room #3 supply fan closure missing a section of gasket material, causing a gap in the closure. 74 SOLAS (20) II-2/14.2.1.1.1

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. The visual indicator for loss of power alarm of both steering gear pumps on the bridge is inoperable. 74SOLAS(20) I/11

Life-saving appliances and arrangements shall be approved by the Administration. The following approval series indicate approval to the SOLAS requirements: 160.122 Floating orange smoke signals Smoke for the bridge wing life buoy on the STBD side does not meet 160.122. 74 SOLAS(20) III/4.1 US Supplement to ABS Rules for Steel Vessels for Vessels on International Voyages 74SOLAS(20) III/4.1 US Supplement to ABS Rules for Steel Vessels for Vessels on International Voyages

Each item of radio communications equipment must be type accepted by the Federal Communications Commission. Two-way VHF radiotelephone apparatuses must conform to performance standards as specified in § 80.1101.The equipment specified in this subpart must also conform to the appropriate performance standards listed: (7) Two-Way VHF radiotelephone: (i) IMO Resolution A.809(19), as revised by IMO Resolution MSC.149(77). Vessel’s required three sealed primary batteries for the three two-way VHF radios are not FCC approved. US Supplement to ABS Rules for Steel Vessels for Vessels on International Voyages 47 CFR 80.1095(a) 47 CFR 80.1101(a)

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. 03 dampers on the STBD side would not close. 74SOLAS(20) I/11

The following fire protection systems shall be kept in good order so as to ensure their required performance if a fire occurs: fire detection. Found two smoke detectors in the steering gear room, and one in the lower-level engine room port side were not installed. 74 SOLAS (20) II-2/14.2.1.1.2 74 SOLAS (20) II-2/14.2.1.1.2

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure that the ship in all respects will remain fit to proceed to sea without danger to the ship or persons on board. Vessel reported 01 of 02 hydraulic pumps for the controllable-pitch propeller inoperable due to a failed seal. 74 SOLAS(20)I/11(a)

Each District Commander or Captain of the Port may order a vessel to operate or anchor in the manner directed when: it has determined that such order is justified in the interest of safety by reason of weather, visibility, sea conditions, temporary port congestion, other temporary hazardous circumstances, or the condition of the vessel. Vessel is required 01 tug of 3,000 HP or 02 tugs of 2,000 HP escort tugs for transit to berth. 33 CFR 160.111(c)

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. The launching mechanism shall be so arranged that it may be actuated by one person from a position of the ships deck and from a position within the survival craft. Remote cable for #1 lifeboat did not operate as originally designed when used through the cable port hole on top of the lifeboat. 20 SOLAS III/20.2 & LSA Code 6.1.2.2

A food ration, determined by the Administration, for each person the lifeboat is certificated to carry. These rations shall be kept in airtight receptacles. STBD lifeboat did not have required amount of food rations after 8 packages were found with loss of vacuum, vessel is restricted to carrying 39 Crew. Reg III/20 SOLAS (2020 edition)

All the lifesaving appliances shall be kept in working order and be available for immediate use before the ship leaves port and at all times during the voyage. Vessel's STBD lifeboat navigational light was inoperable. Repair or test to the satisfaction of classification society. Reg III/20 SOLAS (2020 edition)

Fire extinguishing appliances in new and existing cargo ships shall be kept in good working order and available for immediate use at all times during a voyage. Multiple fixed CO2 hoses with sharp bends were found to have the outer rubber layer dry-rotted exposing the inner layers of the hoses in both Port & STBD CO2 rooms. Replace or test to the satisfaction of classification society. Reg II-2/14 SOLAS (2020 edition)

Means of illuminating the lifeboats and their launching gears during preparation for and the process of launching, and also for illuminating the water into which the lifeboats are launches until the process of launching is completed. Vessels STBD aft liferaft, STBD lifeboat, and fwd liferaft embarkation lights were inop. Replace or test to the satisfaction of classification society. Reg III/20 SOLAS (2020 edition)

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. Audible & Visual steering alarms were not operating on the bridge. Corrected on the spot. 74 SOLAS (20) I/11(a)

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. Found sewage tank lower level port side engine room leaking at the chlorinator. 74 SOLAS (20) I/11(a)

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. Found engine room ventilation supply fans #1 and #4 not operational. 74 SOLAS (20) I/11(a)

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. Found ships service & control air compressors and associated piping removed from service. New piping is currently being fabricated and installed. New compressors are on order. 74 SOLAS (20) I/11(a)

Structural fire protection, including fire-resisting divisions, and protection of openings and penetrations shall be kept in good order so as to ensure their required performance if a fire occurs. Multiple cable transits in bridge deck and electrical space 02-29 have been disturbed and need repaired to OEM specs. 74 SOLAS (20) II-2/14.2.1.1.1

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure ship is fit to proceed to sea without danger to ship or persons aboard. Several ring life buoys need retro-reflective tape renewed. 74 SOLAS (20) I/11(a)

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure ship is fit to proceed to sea without danger to ship or persons aboard. Ring life buoy iwo of No. 2 lifeboat had plug removed and filled with epoxy. 74 SOLAS (20) I/11(a)

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure ship is fit to proceed to sea without danger to ship or persons aboard. Exhaust on the emergency diesel generator was leaking. 74 SOLAS (20) I/11(a)

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure ship is fit to proceed to sea without danger to ship or persons aboard. Deck underneath the engine control room was wasted. 74 SOLAS (20) I/11(a)

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure ship is fit to proceed to sea without danger to ship or persons aboard. Steel iwo fire station No. 46 and starboard CO2 compartment deck found wasted. 74 SOLAS (20) I/11(a)

After any survey of the ship under regulations 7, 8, 9, or 10 has been completed, no change shall be made in the structural arrangements, machinery, equipment, and other items covered by the survey. Found space heater in 02-27 pway, hard-wired into 440V installation in electrical distribution room. 74 SOLAS (20) I/11(a)

Structural fire protection, including fire-resisting divisions, and protection of openings and penetrations shall be kept in good order so as to ensure their required performance if a fire occurs. Found galley service door unable to close and latch.74 SOLAS (20) II-2/14.2.1.1.1

The Administration shall be satisfied that adequate arrangements are in place to ensure that the performance of the equipment required by this chapter is maintained. SARTs, EPIRB, lifeboat radios, and batteries were not stowed in proper locations. 74 SOLAS (20) V/16.1

Fire extinguishing appliances in new and existing passenger ships and cargo ships shall be kept in good order and available for immediate use at all times during the voyage. Found fire hose nozzles plugged with sediment upon testing fire pumps. 60 SOLAS II/66

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. Found expired lifebuoy self-activating smoke signal stowed with all in-use pyro. 74 SOLASD (20) III/20.2

Fire-fighting systems shall be kept in good working order and readily available for immediate use. One pilot bottle of first bank stbd side CO2 room was not connected. Found 5 flex loop hoses in disrepair and need to be replaced. SOLAS 74(14) II-2/14.2.1.2

The fire detection and fire alarm systems shall be kept in good order so as to ensure their required performance if a fire occurs. The cargo deck fire detection system has a trouble alarm that will not clear. SOLAS 74(14) II-2/14.2.1.1.2

Means of illuminating the liferaft and their launching gear during preparation and for the process of launching, and also for illumination the water into which the liferaft are launched until the process of launching is completed. Aft port and stbd liferaft station embarkation lights were inop. SOLAS 60 III/19.b.iii

Posters or signs shall be provided on or in the vicinity of survival craft and their launching controls and shall be easily seen under emergency lighting conditions. Instructions for stbd lifeboat operations were not illuminated properly. SOLAS 74(14) III/9.2.2

Fire and abandonship drills not observed because of ROS status. Conduct drills in the presence of CG inpsector upon activation. All lifesaving equipment to be on station during drills. SOLAS 74(14) II-1/19.3

Charts and publications not examined because of ROS status. Provide up-to-date charts and publications to CG inspector upon activation. 33 CFR 164

Vessel's crew documents not examined because of ROS status. Provide MMCs, medical certification, and TWIC certificate for all crew upon manning for activation. 46 CFR 15.401

The Company should establish procedures in SMS to identify equipment and technical systems that the sudden operational failure of which may result in hazardous situations. The SMS should provide for specific measures aimed at promoting the reliability of such equipment or system. These measures should include the regular testing of standy-by arrangements and equipment or technical systems that are not in continuous use and justify appropriate maintenance intervals. The main engine air cooler was identified by NS5 as a critical piece of equipment. After a malfunction of the port air cooler resulting in a reduction of propulsion marine casualty on the port main engine, it was discovered that the current maintenance procedures are based on hours of operation. The vessel is in ROS status for long periods and does not accumulate engine hours like a normal commercial vessel.The company shall conduct a root cause analysis to determine if the hours of operation preventative maintenance interval model is satisfactory for systems not in continuous use. The historical record shows the air cooler preventative maintenance was last completed on 28 July 2005 and is currently estimated to be examined on 18 November 2019 (14 year interval). The company shall provide the results of the root cause analysis to the Recognized Organization (ABS). THe Recognized Organization shall attest to the findings in the Root Cause Analysis provided by the company.

The operation of the fire main system pumps, hydrants, piping, and nozzles shall be in good condition and available for immediate use. The discharge relief valve casing on the main fire pump was found wasted and leaking excessively. Crew temporarily isolated valve through use of a flange blank. Repair and verify integrity of the system to the satisfaction of a USCG Marine Inspector.

Vessel is in ROS status and is minimally manned. Provide complete crew with credentials to the satisfaction of a Marine Inspector prior to activation.

Vessel is in ROS status and does not have updated charts/publications. Provide updated charts and publications to the satisfaction of a Coast Guard Marine Inspector prior to activation.

Vessel is in ROS status and minimally manned. Vessel shall conduct fire and abandon ship drill to the satisfaction of a Marine Inspector prior to activation.

Prove proper operation of all steering gear alarms and provide evidence that the rudder angle indicator on the bridge matches the rudder angle indicator in the steering compartment.

Place blanks in all openings on the front of the emergency generator switchboard to the satisfaction of the attending class surveyor NLT 12 May 2005.

Place blanks in all openings on the front of the auxiliary switchboard in the engine control room to the satisfaction of the attending class surveyor NLT 12 May 2005.

Prove proper operation of steering gear power failure audible alarm on the bridge NLT 12 May 2005 to the satisfaction of the class surveyor.

Conduct lifeboat and fire drills upon activation to the satisfaction of the attending Marine Inspector.

Provide current navigational charts and publications

Adjust center rudder angle indicator to concur with reading in steering gear room. LEGACY COMPONENT DESC: Rudder angle indicator

Repair steering system to permit passing control from steering gear room to pilot house. Demonstrate proper operation with non-follow up system in steering gear room and pilot house.

Provide crews licenses and required documentation.

Conduct a fire and an abandon boat drill.

Upon activation of vessel, conduct satisfactory fire/boat drills in the presence of a Coast Guard Marine Inspector.

Reissue IOPP form A to indicate alarm/autostop for OWS as required by MARPOL regulation. LEGACY COMPONENT DESC: IOPP Certificate

Repair as new, fire main pressure guage on bridge.

Label and separate or remove expired pyrotechnics. LEGACY COMPONENT DESC: Storage

Prepare of immediate use four (4) line throwing guns. Separate units not armed for immediate use. LEGACY COMPONENT DESC: Stowage

Repair all leaking fire station valves. LEGACY COMPONENT DESC: Valves

Remove or replace expired medicinal oxygen bottles from Hospital. LEGACY COMPONENT DESC: Oxygen bottles

Replace all expired food in lifeboat rations such that 10,000 KJ are present for each person rated. All food rations must have good vacuum seal. LEGACY COMPONENT DESC: Food Ration

Conduct drills prior to getting vessel underway.

PROVIDE CORRECT SIZE SOLAS APPROVED CANOPY FOR OPEN STYLE LIFE BOAT OR HAVEAPPROVED FACILITY MAKE PROPER MODIFICATIONS FOR EXISTING CANOPY MOUNTING FRAMES AND PROVE ALL ASSOCIATED EQUIPMENT IS PRESENT TO THE SATISFACTION_x001C_ OF AN ATTENDING USCG MARINE INSPECTOR OR ABS SURVEYOR.

REPLACE CYALUME STICKS, FIRST AID ASPIRIN, FIRE EXTINGUISHER, AND SEA SICK PILLS FOR LIFEBAOTS.

REPAIR SELF CLOSING DEVICE ON FIRE DOOR AT AREA 03-29 AND PROVE TO COAST GUARD INSPECTOR OR ABS SURVEYOR.

REPLACE 11 EXPIRED PORTABLE EXTINGUISHERS AND SERVICE REMAINING BOTTLES.

SERVICE VESSEL'S FIXED FIRE DETECTION SYSTEM AND FIXED FIRE EXTINGUISHING SYSTEM TO THE SATISFACTION OF AN ATTENDING COAST GUARD INSPECTOR OR ABS SURVEYOR.

CONDUCT FIRE AND ABANDON SHIP DRILLS WITH AN ATTENDING COAST GUARD INSPECTOR PRIOR TO ACTIVATION OF VESSEL.

PROVIDE NEW EMBARKATION LADDER OF A LENGTH THAT WOULD REACH THE WATER WITH THE VESSEL AT LIGHTEST SEA GOING CONDITION AND A 15 DEGREE LIST AND PROVE TO AN ATTENDING COAST GUARD INSPECTOR OR ABS SURVEYOR.

REPAIR LAMP INDICATORS FOR SHAFT RPM AND CPP, ON THE BRIDGE, TO COAST GUARDINSPECTOR OR ABS SURVEYOR APPROVAL.

CALIBRATE COMPASS 11 DEGREES OFF OF GYRO AND PROVE TO EITHER COAST GUARD INSPECTOR OR ABS SURVEYOR.

[withheld — contains personal information; the deficiency system, dates, and resolution status are shown above]

CONDUCT FIRE AND BOAT DRILLS,WITH FULL CREW, TO THE SATISFACTION OF THE ATTENDING MARINE INSPECTOR AT NEXT ACTIVATION.

SUBMIT DRAWING OF SMOKE/FIRE DETECTION SYSTEM REVISION OF ZONES 4-14 TO MAFINE SAFETY CENTER FOR APPROVAL.

CHANGE LENS COLOR OF MACHINERY SPACES TELEPHONE BEACON FROM RED TO ANOTHER COLOR TO AVOID CONFUSION WITH RED GENERAL ALARM BEACON.

PROVE PROPER OPERATION OF ALL CO2 TIME DELAYS, WHILE CONNECTED TO THE CO2 SYSTEM, PRIOR TO GETTING UNDERWAY UNDER SHIP'S POWER AND OR LOADING VEHICLES

DEMOSTRATE FIRE AND BOAT DRILLS TO THE ATTENDING CG INSPECTOR PRIOR TO GETTING UNDERWAY UNDER SHIP'S POWER.

RENEW EMERGENCY GENERATOR'S FUEL OIL AND LUBE OIL HOSES WITH APPROVED FIRE RESISTANT HOSES OR INSTALL APPROVED FIRE SLEVE OVER EXISTING HOSES.

VESSEL MUST PROVIDE REVISED FIRE CONTROL PLAN TO REFLECT IMO SYMBOLOGY AND ADDITION OF SPAR DECK SPRINKLER SYSTEM.

UPDATE DEVIATION TABLE FOR MAGNETIC COMPASS.

MAKE PERMANENT REPAIRS TO INOPERABLE DIGITAL DISPLAY FOR DEPTH SOUNDER.

MAKE PERMANENT REPAIRS TO WASTED JUNCTION BOX COVER ON #1 AND #2 LIFEBOAT DAVIT WINCH MOTORS.

MAKE PERMANENT REPAIR TO UPPER FWD DAVIT SHEAVE ON #1 LIFEBOAT DAVIT.

REPAIR OR RENEW DEFECTIVE DIMMER SWITCH REOSTAT IN BRIDGE CONTROL PANEL.

MAKE PERMANENT REPAIRS TO DETERIORATED BENCH SEAT IN #1 LIFEBOAT.

MAKE PERMANENT REPAIR TO DETERIORATED CENTER DECK PLANK IN #2 LIFEBOAT.

RENEW OR REPAIR SAFETY RELIEF VALVE ON THE EMERGENCY AUX AIR RECIEVER.

INSTALL TURBO EXHAUST SIDE LAGGING ON #1 AND #2 SHIP SERVICE GENERATORS.

LABEL ALL EMERGENCY STEERING LINE UP VAVLES.

RENEW OR REPAIR EMERGENCY FIRE PUMP RELIEF VALVE.

RENEW EXPIRED SEA SICKNESS PILLS IN BOTH LIFEBOATS.

PROVIDE CREW LICENSES AND DOCUMENTS.

REPAIR OR RENEW SEWAGE HOLDING TANK VENT FAN.

PROVIDE PROPOSAL TO OCMI TO PREVENT ACCIDENTAL CO2 DISCHARGE INTO AFT STEERING ROOM FROM CARGO DECK ABOVE AND REPAIR AS APPROVED.

REPAIR INOPERATIVE AUTOMATIC VENT SHUTDOWN FOR EMERGENCY DIESEL GENERATOR.

PROVIDE REPAIR PROPOSAL FOR VENTILATION INSTALLATION IN WAY OF BATTERY ROOM

PRIOR TO DEPARTURE FROM THIS PORT, HMRMS, INSTALL PROPER ELECTRICAL CONNECTIONS I.W.O. EMERGENCY LIGHTS AND POWER TO THE DECK HOUSE IAW 46 CFR 112.20-15.

PRIOR TO DEPARTING THE PORT OF HAMPTON ROADS, PROVE THE PROPPER OPERATION OF CO2 DISCHARGE AND CHECK VALVES LOCATED IN WAY OF MAIN TRAILER DECK, STARBOARD SIDE.

PRIOR TO DEPARTING THE PORT OF HAMPTON ROADS, PROVIDE REQUIRED MEDICAL SUPPLIES.

RENEW CATWALK RAILING IN WAY OF MAIN TRAILER DECK, FWD NLT 16SEP96.

PROVIDE OPERATOR'S MANUAL AND IMO PLACARD FOR ARPA NLT 16SEP96.

PRIOR TO DEPARTING THE PORT OF HAMPTON ROADS, DEMONSTRATE PROPER OPERATION OF THE HEAT AND SMOKE DETECTION SYSTEM.

PRIOR TO DEPARTING THE PORT OF HAMPTON ROADS, MAKE PERMENANT REPAIRS TO THE3/8" CO2 PILOT LINE LOCATED IN WAY OF MAIN DECK LADDER WELL.

MAKE PERMENANT REPAIRS IN WAY OF VENT CANVAS (ROOM 02-24) NLT 16SEP96.

PRIOR TO DEPARTING THE PORT OF HAMPTON ROADS, PROVIDE FCC RADIO TELEGRAPHY CERTIFICATE.

PROVIDE COPY OF THE WELD PROCEDURES AND WELDER QUALIFICATIONS PRIOR TO MAKING WELD REPAIRS TO THE UPPER TUBE SHEET OF THE AUXILIARY BOILER. UPON COMPLETION OF REPAIRS, CONDUCT A SATISFATORY 1 1/2 MAWP HYDRO OF THE_x001C_ BOILER.

PROVIDE RETROREFLECTIVE TAPE ON BOTTOM OF PORT AND STARBOARD LIFEBOATS.

PROVIDE CORRECTED/CURRENT CHARTS, COAST PILOT, LIGHT LIST, AND TIDE/CURRENTTABLE.

PROVIDE RADAR TRANSPONDERS FOR PORT AND STARBOARD LIFEBOATS.

PROVE SATISFACTORY OPERATION OF ALL AUXILIARY BOILER SAFETY DEVICES.

PROVIDE SUFFICIENT EMERGENCY LIGHTING IN THE ENGINE ROOM AND THE ENGINE CONTROL ROOM TO MEET THE REQUIREMENTS OF 46CFR112.15-1(b).

PROVIDE SATISFACTORY SERVICING REPORT FOR FIXED CO2 AND SMOKE DETECTION SYSTEM.

PROVIDE REQUIRED AUXILIARY LINE FOR LINE THROWING APPARATUS.

MAKE PERMANENT REPAIRS TO THE FISH REEFER BOX ANTI-LOCK PLUNGER.

MAKE PERMANENT REPAIRS TO THE PORT LIFEBOAT EMBARKATION RAILING WHERE IT ISBENT.

PROVE PROPER OPERATION OF THE EMERGENCY (FORWARD) FIRE PUMP.

PROVE OPERATION OF THE PORT AND STARBOARD BRIDGE WING CPP AND ILLUMINATION CONTROLS.

PRIOR TO GETTING UNDERWAY, PROVE THE PROPER OPERATION OF THE FIRE AND SMOKEDETECTOR SYSTEM.

SET THE SAFETY RELIEF VALVE DURING SEA TRIALS FOR THE WASTE HEAT BOILER. LOG THE LIFT AND RESEAT PRESSURES IN THE MACHINERY LOG.

PROVE PROPER OPERATION OF THE MAIN AND AUXILIARY DIESEL GENERATORS DURING "BLACKOUT". THE STANDBY GENERATOR MUST START AND ASSUME THE LOAD AUTOMATICALLY.

PROVE PROPER OPERATION OF THE AUTOMATIC CUT-IN FOR THE SEA WATER SERVICE PUMP.

ADJUST AND PROVE THE PROPER OPERATION OF THE ENGINE ROOM RUDDER ANGLE INDICATOR.

VERFIY THE ACCURACY OF THE VESSEL'S MANEUVERING CHARACTERISTICS IAW 46CFR97.20-1(D).

A VIO OF 33CFR164.30 IN THAT THE VSL DID NOT HAVE O/B USCG LIGHT LIST, VOL II, OR ITS FOREIGN EQUIV, WHICH WAS REQ FOR THE VSL'S ROUTE FROM SAUDI ARABIA TO WILMINGTON, NC.

A VIO OF 33CFR164.30 IN THAT THE TH VSL DID NOT HAVE O/B U.S. COAST PILOT, VOL 4, OR ITS FOREIGN EQUIV, WHICH WAS REQ FOR THE VSL'S ROUTE FROM SAUDI ARABIA TO WILMINGTON, NC.

A VIO OF 33 CFR 155.750 IN THAT THE OIL TRANSFER PROCEDURES REQUIRED BY 33 CFR 155.720 WERE INCOMPLETE. THE OTP DID NOT CONTAIN PROCEDURES FOR OPERATING THE MEANS OF COMMUNICATIONS OR PROCEDURES AND DUTY ASSIGNMENTS FOR TENDING VESSEL'S MOORINGS DURING OIL TRANSFERS.

A VIO OF 33 CFR 155.740 IN THAT THE OTP REQ BY 33 CFR 155.720 WERE NOT AVAILABLE FOR INSPECTION BY THE COTP. THE VSL DID NOT HAVE ANY OTP O/B.

NO CERTIFIED LABEL ON MARINE SANITATION DEVICE.