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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 oily mixture discharged into the sea after passing through the system has an oil content not exceeding 15 parts per million. Oily water separator would not run continuously for more than 2 minutes without bilge pump losing suction from bilge tank. Pump would only run with supply water from sea chest opened. 2017 MARPOL ANNEX I Reg 14/6 30ac

The Oil Record Book Part I shall be completed on each occasion, on a tank-to-tank basis if appropriate, whenever any of the following machinery space operations takes place in the ship: discharge overboard or disposal otherwise of bilge water which has accumulated in machinery spaces. On 06 Mar 2023, C/E recorded running OWS for 4 hours and discharging 8 cubic meters overboard. Oil content meter (OCM) history only shows OWS running for approximately 30 minutes. 2017 MARPOL ANNEX I Reg 17/2.4 30ac

The Oil Record Book Part I shall be completed on each occasion, on a tank-to-tank basis if appropriate, whenever any of the following machinery space operations takes place in the ship: discharge overboard or disposal otherwise of bilge water which has accumulated in machinery spaces. On 17 Mar 2023, OCM shows OWS run for approximately 1.5 hours with no corresponding entry into the Oil Record Book Part I. C/E stated he ran the OWS and did not enter in ORB. 2017 MARPOL ANNEX I Reg 17/2.4 30ac

The Oil Record Book Part I shall be completed on each occasion, on a tank-to-tank basis if appropriate, whenever any of the following machinery space operations takes place in the ship: discharge overboard or disposal otherwise of bilge water which has accumulated in machinery spaces. On 17 Apr 2023, ORB states OWS running for 2hr 10mins with a total of 6 cubic meters throughput which exceeded their maximum possible throughput of 2 cubic meters per hour. OCM verified run time of approximately 2 hours. 2017 MARPOL ANNEX I Reg 17/2.4 30ac

Every company should develop, implement, and maintain a safety management system which includes the following functional requirements: instructions and procedures to ensure safe operation of ships and protection of the environment in compliance with relevant international and Flag State legislation. Due to deficiencies noted, the vessel is unable to comply with environmental protection policies which presents a pollution hazard. Provide corrective action plan and failure analysis with concurrence from class and flag state. Vessel shall be audited and results forwarded to Coast Guard. ISM Code 1.4 50ac

The company shall 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. Oil content meter manual states clock batteries shall be replaced every 2 years. Batteries are overdue and SMS does not include replacement intervals. ISM Code 10.1 50c

Each liferaft or group of liferafts shall be stowed with a float free arrangement complying with the requirements of paragraph 4.1.6 of the Code so that each floats free. Liferaft painter line was not shackled to the weak link preventing float free arrangement. 74 SOLAS Amend. 2020 Chapter III/13.4.2 10c

During the inspection of the vessels records, the PSCO found that the vessel had conducted test of the bunkering lines in Dec 2007, however the test was conducted using air as the test medium. Vessel is prohibited from bunkering operations in US waters until hydrostatic test is conducted to the bunker lines. 33 CFR 156.170