CAPE WRATH

The machinery, boilers and other pressure vessels, and associated piping systems and fittings shall be of a design and construction adequate for the service for which they are intended. During inspection, ship’s crew stated that there was no determination made for the cause to the multiple blackouts that occurred during the transit to and from Europe. It was also noted at some point there were fuel boost pumps installed for the generators and have since been removed but the controls remained in the ECR. Crew believes this could be the causative factor for the black outs. Trouble shoot generator to identify cause of failures and make repairs. SOLAS 74/81/83 Amended II-2/26.1

Fire-fighting systems and appliances shall be kept in good working order and readily available for immediate use. LPCO2 gaging system has inaccurate gauge and showed 110% full. Crew stated that the level was approximately 65%, which was enough for all spaces with the exception of #5 cargo deck. 74 SOLAS 20 II-2/14.2.1.2 a

- A ‘critical maintenance list’ of 73-line items, items was provided to the Coast Guard the day of the inspection. These items pertain to the major issues with a variety of critical equipment and key safety systems onboard including machinery, propulsion, and watertight integrity. All items are to be rectified to the satisfaction of the attending ABS surveyor (with CG oversight). Any deviations from this time frame for rectification form specific listed items must be agreed upon by both ABS and CG. ISM Code A/10.1 MARAD-CG MOU VIII ABS Rules for Classification, Part 1A, Section 1.1 and 1.3

To maintain a valid Certificate of Inspection, you must complete your annual and periodic inspections within the periods specified in 91.27-1(a) and (b) and your Certificate of Inspection must be endorsed. Vessel's COI has an expiration date of 31 Jan 2027 and is required to complete annual inspections within a 3 month before or after each anniversary date. Vessel failed to have annual inspection completed by 01 May 2024. 46 CFR 91.27-5 c

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. Due to the objective evidence in deficiencies # 1, 2, and 3, the vessel is not in substantial compliance with relevant conventions. An external SMS audit conducted by the vessel’s RO should be conducted prior to being released from detention. This audit should be focused to include engineering preventative maintenance program, procedures, reporting to company, sufficient spare parts and company engagement for maintenance/repairs needed. In addition, this audit should include a focus on ISM clauses 6.1 and 9.1. 74 SOLAS 20 IX/3.1 ISM Code 10.1

Pilot ladder winch reel as currently arranged does not meet the applicable statutory requirements. The pilot ladder is not secured at the deck level >915mm horizontally inward from the ship’s side, and weight of the pilot ladder can still be partially hanging on the reel. ABS to carry out full evaluation of onboard pilot embarkation arrangements against the applicable standards. 74 SOLAS 20 V/23.1.1.2 IMO Resolution A.1045(27), 7.4 a

While transiting through the Sector Virginia regulated navigation area, your vessel must have tug assist by at least (2) tugs with an aggregate total horsepower of at least 6,000 HP or 40 ton bollard pull.

While pressure testing the port side S/W elbow (def 30) observed an approximate 3 inch crack on the 20" discharge/outlet piping of the outboard raw water cooler. Make permanent repairs or provide acceptable temporary repair proposal to USCG & ABS. SOLAS 74/81/83 Amend II-1/26.3 (Update- Temp repair authorized to sail to Port of Baltimore.)

High pressure CO2 for firefighting system protecting the incinerator space found with one empty cylinder and the paint store cylinder found half empty during annual servicing. Make repairs to incinerator CO2 system, refilling the empty cylinder and verify the CO2 cylinder for the paint store has remained full. 74 SOLAS 74/81/83 II-2/5 & 7

Deck 5 ramp (at bulkhead deck) forward section two locking pins/securing devices were removed to secure ramp for return voyage. Replace damaged securing devices and make permanent repairs. SOLAS 74/81/83 Amended II-1/25-9.4

Properly repair engine room door to cargo deck 5 to make reasonably gas-tight. SOLAS 74/81/83 Amended II-2/5.1.4

Properly stow O2 & Acetylene cylinders in authorized location(s). SOLAS 74/81/83 Amended II-2/51 (Update- O2/Acetelyne stowed on cargo deck. Cargo deck 5 fans shall be operating while underway.)

The following areas shall be cleaned of oil soaked trash/debris: - MDE top of scavenge air box below turbos; - Oil soaked sorbent around JW cooling pipe (aft DG #5); - Open buckets of oil near air receivers; - Bilges/voids under Deck 5 ramp hydraulic rams; - Under emergency fire pump discharge valve. SOLAS 74am (04ConsEd) II-2/4.1

Aft peak tank valve found with piping into E/R removed and valve dripping. Determine reason piping was removed and reinstall or blank. SOLAS 74am (20ConsEd) II-1/3-1 Update- valve/piping are for cargo deck drains.

Repair/replace pin holed fuel piping found in purifier flat marked with 25-23 and secure tank flange leaking directly above. SOLAS 74am (20ConsEd) II-1/3-1

On day of inspection, only 1 of 5 generators were identified as a reliable power generation source. SSDG#1 requires manual priming to start from a cold condition. SSDG#3 is down for unknown reasons. SSDG#4 and SSDG#5 will not stay on line and intermittently shutdown due to possible fuel pressure issues. Trouble shoot generators to identify cause of failures and make repairs.

Installed power management automation system was failing to properly adjust/share generator loads causing blackouts and losses of propulsion. Crew identified failed phase current transformers for SSDG’s #3 & #5 within electrical switchboard and which required “jumping” connections. This alone should not cause failure of the power management system. Identify root cause and make appropriate repairs.

Observed Auxiliary Lube Oil purifier in alarm status. When questioned, engineer stated temperature probe needed to be moved from other purifiers to make operational. Replace malfunctioning temperature probe. In addition, fuel purifiers may not be operating at manufacturer’s recommended fuel throughput. Follow manufacturer’s recommendations or provide confirmation from manufacturer that a lower throughput is acceptable.

The following areas found with excessive fuel/oil accumulation: tank top under and around main engine/shaft alley, fuel transfer room, purifier room, under SSDG's, aft generator flat, under generator lube oil strainers and bilge in workshop near generator flat. Drain pipe to oily waste tank from oily machinery parts cleaning basin in workshop near generators found cut and allowed to drain straight to bilge. Main engine piston cooling chambers on port side found with flexible hoses to drain to deck level onto sorbent pads. Properly clean all areas of excessive fuel and oily waste.

Main cooling water pump starboard was tested on standby automatic start. With port pump running, manual valve between both pumps was opened. Observed starboard pump shaft begin to spin indicating failure of check valve between pumps. Weight on check valve handle was not installed. Upon automatic start of pump, excessive vibration was observed and temperature of pump shaft seal rose from 16C to 30C within ten minutes. Port pump was running all day w/ temperature at 16C when starting test. Shutdown starboard due to temperature rise. Trouble shoot heat rise/vibration/valve failures and make repairs.

Observed portable diaphragm pumps and flexible hoses (some with oil residue) at tank top deck. When questioned, engineers stated the installed sludge pump and sewage pumps were not operational. The dedicated bilge water pump (with a garden hose attached to prime pump) wasn’t able to pull suction from rose boxes. Portable pumps and hoses were used to transfer via sounding tubes of sludge from tank to tank, sewage/grey water from tank to tank. Crew must use back-up general service/fire/bilge pump to transfer oily bilge slops to oily waste tank. Repair/replace non-operational or failing pumps.

Oil content meter for OWS was recently replaced by Chief Engineer. No notification was made to IOPP issuing authority (ABS). No valid calibration certificate found. Provide calibration certificate and notify ABS.

The grey water and black water skin valves both leak by as identified by crew and confirmed by testing with divers. Grey water tank overflowed into bilge and sludge tanks through interconnected tank vent piping manifold. Questioned crew if any other skin valves were not working properly. It is suspected the main cooling water valve to stbd pump off sea chest is not closing fully. Make repairs/replace leaking skin valves.

Plastic waste receptacles for used and oily rags found in machinery spaces. Replace with waste receptacles constructed of non-combustible materials.

Focused SMS audit required prior to departure from port. This audit shall focus on the deficiencies marked as SMS Related to include engineering preventative maintenance program, unauthorized repairs/alterations/procedures, reporting to company, sufficient spare parts and company engagement for maintenance/repairs needed.

Low oil pressure alarmed when testing free-fall lifeboat engine. Investigate cause and make repairs. (Update- Upon testing FFLB engine failed to stop with stop button- corrected) (Update 2- Water ingress identified around stern plate at cort-nozzle, further inspection by BW found GRP cracks on internal GRP layer)

The installation of all systems of a marine engineering nature, together with the details of design, construction, and installation, shall be in accordance with the requirements of subchapter F (Marine Engineering) of this chapter. Systems of this type include the following: Steering Systems. Bilge and Ballast Systems. Tank Vent and Sounding Systems. Overboard Discharges and Shell Connections. Pipe and Pressure Systems. Liquefied Petroleum Gas For Cooking and Heating. Fix and verify proper operation of vessels propulsion equipment. Provide class report to CG Marine inspector.

Before the ship leaves port and at all times during the voyage, all life-saving appliances shall be in working order and readily available for immediate use. During in-water maneuvering test of the freefall lifeboat, the main/primary steering was found to not be working properly. Steering via the emergency tiller verified as working as designed/intended. Make permanent repairs to the main/primary steering to the satisfaction of the attending ABS surveyor prior to departure from the next port of call (reported to be Beaumont, TX).

To discharge ballast water into the waters of the United States, the master, owner, operator, agent, or person in charge of a vessel subject to 151.2025 of this subpart must either ensure that the ballast water meets the ballast water discharge standards in 151.2030 (a) [e.g. install and use a CG-approved ballast water treatment system] or ballast with water from a U.S. public water system as described in 151.2025(a)(2), according to the schedule in paragraph (b) of this part. The Cape Wrath completed a scheduled dry dock in 2022, and thus is past its compliance date as listed in 151.2035 (b). The vessel’s ballast water records indicate that seawater was taken on in Bayonne, NJ and subsequently discharged in Baltimore, MD in January 2023. The vessel is not equipped with a ballast water treatment system; thus, this water was not managed via one of the allowable methods in 33 CFR 151.2025. Provide a corrective action plan for how the subject vessel will meet the U.S. ballast water regulations moving forward, taking into account the vessel’s purpose of providing sealift service for worldwide deployment. *Note: 151.2025 (a)(3) – ballast water exchange >200nm from any shore – is not a permissible ballast water management method for the subject vessel, as this is only a permitted ballast water management method for vessels not yet past their compliance date. Updated 4/24/23: the due date for this deficiency has been extended to 5/24/23, to facilitate updates to the BWMP to accurately reflect the permissible ballast water management options under 33 CFR 151 for this vessel based on the implementation schedule in 33 CFR 151.2035. Updated 5/19/23: the due date for this deficiency has been extended to 6/10/23, as discussions are reportedly still on-going with MARAD and Crowley regarding this matter, and the vessel has received turbo-activation orders.

A minimum of 2 two-way portable radiotelephone apparatus for each fire party for fire-fighter’s communication shall be carried onboard. Those two-way portable radiotelephone apparatus shall be of an explosion-proof or intrinsically safe type. The label for the Motorola fire-fighter radios onboard indicate that a NNTN4852A battery must be used in order to meet explosion-proof / intrinsically safe requirements. However, the batteries currently used with the radios are of different types (NNTN4497DR and NNTN4970A). Update 3/24/23: at the request of the operator (communicated by ABS), this deficiency has been extended until 4/24/23. A PO has been issued for ten (10) Motorola NNTN4852A batteries. Update 4/26/23: Update 3/24/23: at the request of the operator (communicated by ABS), this deficiency has been extended until 8/1/23. Reportedly the aforementioned radio batteries have a long lead-time with current estimated delivery date of 7/25.

A vessel at anchor shall exhibit where it can best be seen: at or near the stern, an all-around white-light. Aft starboard anchor light is alarming as inoperable on the navigation light panel on the bridge.

All ships of 150 gross tons and upwards shall have a daylight signaling lamp not solely dependent upon the ship’s power supply. Daylight signaling lamp is missing battery power pack. Update 3/24/23: at the request of the operator (communicated by ABS), this deficiency has been extended until 4/24/23. A PO has been issued for a new daytime signaling lamp with appropriate backup battery pack.

Maintenance, testing, and inspection shall be carried out based on the guidelines developed by the Organization and in a manner having due regard to ensuring the reliability of fire-fighting systems and appliances. Portable containers or portable tanks containing foam concentrate, excluding protein based concentrates, less than 10 years old, that remain factory sealed can normally be accepted without the periodical foam control tests required in MSC.1/Circ.1312 being carried out. ChemGuard AR-AFFF portable foam containers in the DC lockers have a date stamp of 2006, and there is no record of periodical foam testing being carried out. Update 3/24/23: at the request of the operator (communicated by ABS), this deficiency has been extended until 4/24/23. A PO has been issued for six new 20L foam canisters/units. Update 4/26/23: at the request of the operator (communicated by ABS), this deficiency has been extended until 5/24/23. Reportedly the aforementioned 20L foam canisters should be delivered onboard shortly.

Systems and equipment used to meet the requirements of this regulation (LRIT) shall confirm to performance standards and functional requirements not inferior to those adopted by the Organization. A Conformance test report should be issued, on satisfactory completion of a conformance test. At time of attendance, there was no objective evidence available onboard of a valid LRIT conformance test report for the current installed equipment.

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 divisions. Fire-fighting systems and appliances shall be kept in good working order and readily available for immediate use. The ventilation and fire damper panels on the bridge and at the fire control station (ballast control room) have various bulbs not properly functioning when tested. Update 3/24/23: at the request of the operator (communicated by ABS), this deficiency has been extended until 4/24/23. The crew continues to troubleshoot and address some of the malfunctioning/inoperable light indicators at this time.

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. At time of attendance on 10 March 2023, multiple radio equipment forming part of the GMDSS suite (examples: MF/HF, INMARSET-C, etc.) lists a date of 25 July 2003.

Ships shall be provided with a main steering gear and an auxiliary steering gear to the satisfaction of the Administration. Port steering pump inoperable.

All arrangements used for pilot transfer shall efficiently fulfill their purpose of enabling pilots to embark and disembark safely. The appliances shall be kept clean, properly maintained and stowed and shall be regularly inspected to ensure they are afe for use [2.1]. Arrangements shall be provided to enable the pilot to embark and disembark safely on either side of the ship [3.1]. Starboard and port side accommodation ladders found with significant wastage/corrosion near turntable.

The following fire protection systems shall be kept in good order so as to ensure their required performance if a fire occurs: [.1] structural fire protection, including fire-resisting divisions, and protections of openings in these divisions. Starboard door on aft side of accommodation will not close and latch.

The means for securing and maintaining weathertightness shall be to the satisfaction of the Administration. Light can be seen coming through the door from the galley to exterior and a section of the gasket has popped out of its seating on the door.

All electrical apparatus shall be so constructed and so installed that danger of injury in ordinary handling shall not exist. Battery charger alarm system in electrical equipment room (#432) found with open junction box. Also, multiple light fixtures in engine room found broken/missing.

Maintenance, testing, and inspections shall be carried out based on the guidelines developed by the Organization (MSC Circ 1432) and in a manner having due regard to ensuring the reliability of fire-fighting systems and appliances. Monthly inspections of fixed fire detection and alarm system shall to carried out to ensure that a sample of detectors are tested so that all devices have been tested within five years (MSC Circ 1432/5.10). Periodical testing of heat detectors using proper equipment and procedures is not being carried out at requisite intervals.

Watertight doors of satisfactory construction may be fitted in watertight bulkheads dividing cargo between deck spaces. Watertight door for B deck ramp B5 found with hydraulic leak at connection.

The material, design, construction, workmanship, and arrangement of main propulsion machinery and of each auxiliary, directly connected to the engine and supplied as such, must be at least equivalent to the standards established by the ABS Steel Vessel Rules. Deterioration of exterior insulation of SSDG exhaust trunk. Possible exhaust leak into confined space. 46 CFR 58.05-1(a)

The termination of each cable must be sealed to prevent the entrance of electrolyte by spray or creepage. Dead end wires were found in the purifier room, forward bulkhead.

It is the intent of this subpart that the accommodations provided for officers and crew on all vessels must be securely constructed, properly lighted, heated, drained, ventilated, equipped, located, arranged, and insulated from undue noise, heat, and odors. Drainage pipe coming from port side truck work shop was wasted. Location was approximately 5ft above the waterline.

Main inlets and outlets of all ventilation systems shall be capable of being closed from outside the space in the event of a fire. Noted accommodation spaces had pull closure operation / inoperable and missing label.

Each Administration shall, in accordance with the provisions of section A-I/14, hold companies responsible for the assignment of seafarers for service on their ships in accordance with the provisions of the present Convention, and shall require every such company to ensure that each seafarer assigned to any of its ships holds an appropriate certificate in accordance with the provisions of the Convention and as established by the Administration and its ships are manned in compliance with the applicable safe manning requirements of the Administration. Provide MMC for all crew members upon activation of vessel. STCW Reg I/14.1

Every crew member shall participate in at least one abandon ship drill and one fire drill every month. The drills of the crew shall take place within 24 hrs of the ship leaving a port if more than 25% of the crew have not participated in drills on board that particular ship in the previous month. Vessel unable to complete drills while in ROS status. Conduct drills upon activation of vessel. SOLAS 74 (2014) III/19.3.2

Each vessel must have the following equipment, A gyrocompass. Vessel reported that the gyrocompass was providing inaccurate readings while departing port. Prove proper operation to the attending class surveyor.

Prior to departure and upon activation provide valid crew licenses and documents.

Upon activation and prior to departure conduct satisfactory fire and abandon ship drills.

Prove proper operation of port/aft cargo hold H/W float switch.

Clean fwd and Starboard aft bilge wells in main cargo hold, and determine source of oily contamination in both locations.

Every crew member shall participate in at least one abandon ship drill and one fire drill every month. The drills of the crew shall take place within 24 h of the ship leaving a port if more than 25% of the crew have not participated in abandon ship and fire drills on board that particular ship in the previous month. Upon activation and prior to getting underway, conduct satisfactory fire and abandon ship drills. SOLAS (2014) III/19.3.2

Each vessel of 10,000 gross tons or more must have, in addition to the radar system under § 164.35(a), a second marine radar system that operates independently of the first. Provide this office with Class Report attesting to the satisfactory condition of the newly install secondary radar.

Every officer in charge of a navigational watch serving on a seagoing ship of 500 gross tonnage or more shall hold a certificate of competency. Every officer in charge of an engineering watch in a manned engine-room or designated duty engineer officer in a periodically unmanned engine-room of a seagoing ship powered by main propulsion machinery of 750kw or more shall hold a certificate of competency. Upon activation and prior to getting underway, provide crew licenses and documents IAW vessel COI. STCW II/1 and STCW III/1

Provide proof of and verify crew license, documents.

Complete Fire and Abandonship drills.