AMPARO PAOLA

The Condition of the ship and its equipment shall be maintained to confirm with the provisions of the present regulations to ensure the ship in all aspects will remain fir to proceed to sea without danger to the ship or persons on board. PSCO observed the following the steering: Pump Combination Nos. 2 & 3: 1. Steering Gear was found to function normally through a full range of motion in Follow-Up and Non-Follow-Up modes in both Steering Systems Nos. 1 & 2. 2. Steering Gear was operationally tested in Auto-Pilot in both Steering Systems Nos. 1 & 2 and considered satisfactory. Pump Combination Nos. 1 & 2: 1. Steering Gear was operationally tested through a full range of motion in Follow-Up and Non-Follow-Up modes in both Steering Systems Nos. 1 & 2 and found as follows: 1. System No. 1, Follow-Up Mode - Port Rudder satisfactory, however the Starboard Rudder was found to hunt over 2-3 degrees for a period of 1-2 seconds before settling on the given command. 2. System No. 1, Non-Follow-Up Mode - Starboard Rudder satisfactory, however the Port Rudder was found out of alignment by approximately 5 degrees to starboard. 3. System No. 2, Follow-Up Mode - Port Rudder satisfactory, however the Starboard Rudder was found to hunt over 2-3 degrees for a period of 1-2 seconds before settling on the given command. 4. System No. 2 - Non-Follow-Up Mode - Satisfactory through full range of motion 2. Steering Gear was operationally tested in Auto-Pilot in both Steering Systems Nos. 1 & 2 and considered satisfactory. Pump Combination 1 & 3: 1. Steering Gear was operationally tested through a full range of motion in Follow-Up and Non-Follow-Up modes in both Steering Systems Nos. 1 & 2 and found as follows: 1. System No. 1, Follow-Up Mode - Unsatisfactory. Port and Starboard Rudders were found out of alignment. 2. System No. 1, Non-Follow-Up Mode - Unsatisfactory. Port and Starboard Rudders were found out of alignment. 3. System No. 2, Follow-Up Mode - Satisfactory through full range of motion 4. System No. 2 - Non-Follow-Up Mode - Unsatisfactory. Port and Starboard Rudders were found out of alignment.

After any survey of the ship under Regulations 7, 8, 9, or 10 of this Chapter has been completed, no change shall be made in the structural arrangements, machinery, equipment, etc. covered by the survey, without the sanction of the Administration. PSCO noted lagging on both main engines was oil soaked.

After survey of the ship, no change shall be made to machinery covered by survery without sanction of the Administration; Starbord main engine cylinder head #4 is leaking oil through seals.

The machinery associated piping systems and fittings shall be of a design and construction adequate for the service for which they are intended. The mounting hardware for the salt water cooling piping is deteriorated and does not meet design specifications.

Electrical installations shall be such that the safety of passengers, crew and ship from electrical hazards shall be ensured. Numerous light fixture installations throughout the vessel are missing covers.

74SOLAS(UNAM) II-2/33(a) In a ship in which oil fuel is used the arrangements for the storage, distribution and utilization of the oil fuel shall be such as to ensure the safety of the ship and persons on board. PSCO observed a leacking seal on fuel oil transfer pumpleading to a plastic container containing approximately 3 liters of fuel oil.

Oil filtering equipment referred to in paragraph 1 of this regulation shall be of a design approved by the administration and shall be such as will ensure that any oil mixture discharged into the sea after passing through the system has an oil content not exceeding 15 ppm. In considering the design of such equipment, the administration shall have regard to the specification recommended by the organization. Vessel is fitted with a MEPC A.393X OWS and a MEPC 107(49) OCM. Crew is unable to process bilge water to less than 15 ppm. Multiple functional issues were noted during 5 hours of testing. 1) The sample line from the discharge piping of the OWS was clogged and did not provide a sample to the OCM, allowing for unmonitored bilge water to be discharged to overboard valve, when the sample line was cleared, the OCM read “EE” proving that the OWS is not processing bilge water. 2) The MEPC 107(49) OCM does not match oil record book entries. Most notably, the last recorded operation on 16MAY19 from 1900-2300 is not in the OCM history. 3) When the OCM alarmed over 15 ppm, the did not stop and allowed water to be delivered to the overboard valve. MARPOL Annex I/14.6 30abc

The oil record book, whether part of the ship’s official logbook or otherwise, shall be in the form specified in appendix III to this Annex [MARPOL 17.1]. Additionally, the ORB Part I shall be completed on each occasion, on a tank to tank basis if appropriate, whenever any of the following machinery space operations take place in the ship; discharge of dirty ballast or cleaning water from oil fuel tanks, collection and disposal of oil residues, discharge overboard or disposal otherwise of bilge water which has accumulated in machinery spaces, and bunkering of fuel or bulk lubricating oil [MARPOL 17.2]. Oil record book code entries do not align with Appendix III of MARPOL Annex I. Codes pre-date 2006 amendments. Additionally, crew is not recording bilge well to bilge tank transfers as well as transfers from sludge tank to bilge tank. Furthermore, OWS operations do not align with daily sounding logs and recorded data on the OCM. MARPOL Annex I/17.1 MARPOL Annex I/17.2 30abc

The company should ensure that all personnel involved in the company’s safety management system have an adequate understanding of relevant rules, regulations, codes and guidelines [ISM 6.4]. Additionally, 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 [ISM 10.1]. In meeting these requirements, the company should ensure that; inspections are held at appropriate intervals [ISM 10.2.1], any non-conformity is reported with its possible cause, if known [ISM 10.2.2]. The objective evidence delineated in deficiencies #1 and #2 attests to the vessel's company failing to ensure that the engineering crew-members had an adequate understanding of how to properly operate the onboard oily water separator in accordance with the appropriate operating procedures while abiding by the relevant rules and regulations. Additionally, the Chief Engineer and Second Engineer informed PSCOs that they received no training pertaining to the newly installed Oil Content Meter (MEPC 107(49)). Also, as denoted in deficiencies #1 and #2, crew did not provide any evidence that inspections and scheduled maintenance were held at appropriate intervals for the OWS. 74 SOLAS (14) IX/3.1 ISM Code 6.4 ISM Code 10.1 & 10.2 30abc

Oil residue (sludge) tanks shall be provided and shall have no discharge connections to the bilge system, oily bilge water holding tank, tank top or oily water separators. PSCO identified a permanent connection from sludge pump discharge piping to the bilge tank. MARPOL Annex I/12.3.3 17ac

The hull, superstructure, structural bulkheads, decks and and deckhouses shall be constructed of steel, having in mind the risk of fire. PSCO’s observed a penetration above Engine Control Room (ECR) to engine room without any insulation, thus compromising the Category “A” boundary. 74 SOLAS II-2/Part D/ 51 (a) 17ac

Fire door in the main vertical zone bulkheads and stairway enclosures shall be of self-closing type. Hold-back hooks, not subject to control station release, will not be permitted. PSCO's identified hold back hooks located on multiple fire doors in the stairwell and main vertical zone compromising the fire boundary integrity. 74 SOLAS II-2/23(f) 10c

CODE:07117 OIL FUEL PIPES SHALL BE OF STEEL OR OTHER APPROVED MATERIAL PROVIDED THAT RESTRICTED USE OF FLEXIBLE PIPES SHALL BE PERMISIBLE IN POSITIONS WHERE THE ADMINISTRATION IS SATISFIED THAT THEY ARE NECESSARY. SUCH FLEXIBLE PIPES AND END ATTACHMENTS SHALL BE APPROVED FIRE-RESISTANT MATERIALS OF ADEQUATE STRENGTH AND SHALL BE CONSTRUCTED TO THE SATISFACTION OF THE ADMINISTRATION. PSCO OBSERVED A FUEL OIL SPRAY COMING FROM THE STARBOARD #4 CYLINDER HIGH PRESSURE FUEL LINE COMING FROM THE FUEL PUMP. CITE:74SOLAS/CH.II-2/REG.33(a)(viii) ACTION TAKEN:17abc

CODE:07126 IN A SHIP WHICH OIL FUEL IS USED, THE ARRANGEMENTS FOR THE STORAGE DISTRIBUTION AND UTILIZATION OF THE OIL FUEL SHALL BE SUCH AS TO ENSURE THE SAFETY OF THE SHIP AND PERSONS ON BOARD. PSCO OBSERVED APPROXIMATELY 30 GALLONS OF OIL AND FUEL OIL AND FUEL OIL UNDER THE MAIN ENGINES. CITE:74SOLAS/CH.II-2/REG.33(a) ACTION TAKEN:17abc

CODE:07105 FIRE DOORS IN MAIN VERTICAL ZONE BULKHEADS AND STAIRWAY ENCLOSURES, SHALL BE OF THE SELF-CLOSING TYPE. HOLD-BACK HOOKS, NOT SUBJECT TO CONTROL STATION RELEASE, WILL NOT BE PERMITED. PSCO OBSERVED THE FIRE DOORS IN THE STAIRWELL AND MAIN VERTICAL ZONE WERE EQUIPPED WITH HOLD BACK HOOKS AND WERE NOT SELF-CLOSING. CITE:74SOLASII-2/23(f) ACTION TAKEN:17abc

CODE:01117 EVERY SHIP OF 400 GROSS TONNAGE AND ABOVE IS SUBJECT TO SURVEY. AFTER ANY SURVEY OF THE SHIP, NO CHANGE BE MADE IN THE STRUCTURE, EQUIPMENT, SYSTEMS, FITTINGS ARRANGEMENTS OR MATERIAL COVERED BY THE SURVEY. IOPP CERTIFICATE STATES THAT THE VESSEL IS EQUIPPE WITH AN OIL CONTENT METER MEETINTG RESOLUTION A.393. PSCO OBSERVED AN OIL CONTENT METER MEETING RESOLUTION MEPC 107.49 INSTALLED. CITE:MARPOL(73/78)ANNEXI/CH.2REG6.4.2 ACTION TAKEN:50abc

CODE:15106 A VESSEL EQUIPED WITH A BALLAST WATER TANK THAT OPERATES IN THE WATERS OF THE UNITED STATES MUST MAINTAIN A BALLAST WATER MANAGEMENT PLAN THAT WILL ALLOW THOSE RESPONSIBLE FOR THE PLANS IMPLEMENTATION TO UNDERSTAND AND FOLLOW THE VESSEL'S BALLAST WATER MANAGEMENT STRATEGY AND COMPLY WITH THE REQUIREMENTS OF THIS SUBPART. VESSEL'S BALLAST MANAGEMENT PLAN DOES NOT REFERENCE THE MUST UP-TO-DATE VERSION OF THE US REGULATIONS. VESSEL IS PAST COMPLIANCE DATE AND SHALL NOT DISCHARGE BALLAST IN US WATERS. CITE:33CFR151.2050(g) ACTION TAKEN:50c

0611 The normal equipment of every lifeboat shall consist of a food ration for each person the life boat is certified to carry kept in airtight receptacles. Food rations storage was not air tight. 74 SOLAS III reg. 11.a.xii

0520 Cargo ships of 1600 GT and upward the administration shall ensure that the lighting of the alleyways, stairways and exits is such that the access of all persons to the launching stations and stowage postions of lifebaots and liferafts is not impeded. PSCO observed 02 extinguished emergency lights on the meain deck by the cargo pump room. 74 SOLAS III reg. 38 10c

0725-Fixed fire fighting. Condition of ship and equipment shall be maintained to conform w/provisions of present regulations;ensure vessel remain fit for sea w/out danger to vessel or crew. PSCO observed disconnected hose from main service manifold to CO2 bottle. 74SOLAS(09)CON. 1/11.4

2515- Company responsibility and authority. Company should establish procedures to maintain confomity w/relevant rules and regulations established by company. Further inspection of fire fighting maintenance logs showed that actual inspection of CO2 lines are not being made monthly with other CO2 rooms maintenance procedures. 74SOLAS(09)1X/3.1; ISM CODE A.10.1

0613- Stowage of lifeboats; Where davits are recovered by action of the fall by power, safety devices shall be fitted which will automatically cut-off the power before the davits come against the stops. PSCO observed davit limit switch inoperable. 74SOLAS(09)III/36(k)

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations. Vessel's emergency generator has a fuel leak. SOLAS 04 CHI-Reg11 (17ABC).

The condition of the ship and its equipment shall be maintained to conform with provisions of the present regualtions. Vessel's #3 steering pump has a hydraulic leak. SOLAS 04 CHI Reg11 (17abc).

Where necessary non-conducting mats or gratings shall be provided at the front and rear of the switchboard. (SOLAS 04 CHII-I REG45 (17C).

Maintnance, testing, and inspections 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. Vessel has no procedures for testing smoke alarms. SOLAS 04 CHII-2 Reg14.2.2 (50AB).