SULPHUR ENTERPRISE

74SOLAS20 II-1 26.1 The machinery, boilers, and other pressure vessels, associates in piping systems and fittings shall be of a design and construction adequate for the service for which they are intended and shall be so installed and protected as to reduce to a minimum any danger to persons on board die to regard to materials used in construction, the purpose for which the equipment is intended, the working conditions to which it will be subjected to and the environmental conditions on board. Vessel reported a loss of propulsion during outbound transit. Vessel must enact permanent repairs to the satisfaction of ABS.

The machinery, boilers, and other pressure vessels, associated piping systems and fittings shall be of a design and construction adequate for the service for which they are intended. MI received NRC notification stating vessel's crew discovered oil in the water around the vessel upon arrival to terminal. Oil was determined to originate from a propeller blade seal failure. Provide TPO finding number and technical report from ABS attesting to proper functioning propeller blade seal 74 SOLAS (04) II-1/26.1

The applicable standards established by the ABS Marine Vessel Rules may be used as the standard for the design, construction, and testing of main and auxiliary machinery. MI received notification from vessel representative stating vessel experienced loss of propulsion due to a failed sensor on the mechanical overspeed trip mechanism for the main engine. Provide TPO finding number and technical report from ABS attesting to proper operation of the vessel. 46CFR31.35-1 46CFR111.12-1 46CFR58.01-5

No repairs or alterations affecting the safety of the vessel or its machinery shall be made unless applicable requirements in this chapter are met. Vessel reported newly replaced booster relief valve(V1) failed. Notifications shall be conducted in accordance with the Alternate Compliance Program. Repairs shall be made to the satisfaction of the RO and Coast Guard. Coast Guard Marine Inspector attendance will be required prior to clearing deficiency. Repair report from tech/OEM and/or RO should discuss root cause and all corrective actions. No movement from the pier authorized unless authorized by the OCMI/COTP.

74 SOLAS (97) II-2/15.2 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. #1 fuel supply pump in purifier room was leaking fuel.

MARPOL 73/78 1/14.2 Any ship of 10,000 gross tonnage and above shall be fitted with oil filtering equipment complying with paragraph 7 of this regulation. OWS was not operational.

74 SOLAS (04) II-1/44.2 A second source of energy shall be provided for an additional three starts within 30 minutes. Emergency generator would not start using second source.

The main steering gear and rudder stock must be operated by power when necessary to comply with paragraph (b)(2) of this section. Vessel suffered loss of steering capabilities on the starboard steering gear pump. Prove proper operation of power steering prior to departure from the Gulf Sulphur Services dock in Tampa, FL to the satisfaction of attending ABS class surveyor. 46 CFR 58.25-10(b)(3)

The machinery, boilers, and other pressure vessels, associated piping systems and fittings shall be of a design and construction adequate for the service for which they are intended. CPP system controls do not operate in "follow up" mode as designed. Repair to the satisfaction of the vessel's classification society and the Coast Guard. 74SOLAS(04)II-1/26.1

The machinery, boilers, and other pressure vessels, associated piping systems and fittings shall be of a design and construction adequate for the service for which they are intended. Vessel stern tube is leaking oil through the seal and into the ocean. Repair to the satisfaction of the vessel's classification society and the Coast Guard. 74 SOLAS (04) II-1/26.1

Except as provided in paragraph (d) of this section, this subpart applies to each self-propelled vessel that- (1) Carries oil of any kind as fuel for main propulsion; (2) Is not a tank vessel or is not certificated as a tank vessel; (3) Operates upon the navigable waters of the United States, as defined in 46 U.S.C. 2101(17a); and (4) Is 400 gross tons or more as measured under the convention measurement system in 46 U.S.C. 14302 or the regulatory measurement system of 46 U.S.C. 14502 for vessels not measured under 46 U.S.C. 14302. Vessel must activate NTVRP and notify OSRO prior to transiting. 33 CFR 155.5015

A liferaft for use with an approved launching appliance shall: be provided with means for bringing the liferaft alongside the embarkation deck and holding it securely during embarkation. Marine Inspectors observed that the starboard side davit-launched liferaft cannot be brought alongside the embarkation deck due to its location relative to the installed davit, which was installed to replace an existing davit on September 2021. Additionally, the davit-launched liferaft exceeds the newly installed davit's service workload and therefore requires an approved launching appliance. This deficiency is to be rectified to the satisfaction of the vessel's Recognized Organization. 74SOLAS(97)III/38.4.1.2

In lieu of meeting the requirements of paragraph 1.1, cargo ships may carry: (In addition to one or more lifeboats) one or more liferafts complying with the requirements of regulation 39 or 40, on each side of the ship, of such aggregate capacity as will accommodate the total number of persons on board. Marine Inspectors observed life rafts with a capacity of 25 persons, which is less than the 27 total personsallowed onboard per the Certificate of Inspection (COI). Therefore, the vessel is allowed to carry no more than 25 persons onboard. The COI will be amended to reflect this change. 74SOLAS(97)III/26.1.2.2

Unless otherwise expressly provided...the master, owner, operator, agent, or person in charge of vessels employing a CG approved BWMS must meet the applicable ballast water discharge standard, found in 151.2030 of this subpart, at all times of discharge into the waters of the US. Master of vessel reported discharging of untreated ballast from aft peak tank, which is not IAW with vessels BWMP. Vessel is prohibited BW discharge of AP tank in US waters, and master must submit contingency plan to verify how the vessel is intending to comply with the BWM requirement to the satisfaction of the local COTP.

THE MACHINERY, BOILERS, AND OTHER PRESSURE VESSELS, ASSOCIATED PIPING SYSTEMS AND FITTINGS SHALL BE OF A DESIGN AND CONSTRUCTION ADEQUATE FOR THE SERVICE FOR WHICH THEY ARE INTENDED. #2 GENERATOR WAS REPORTED INOPERABLE. 74SOLAS(04) II-1/26.1

Administrations shall require that records of daily hours of rest of seafarers be maintained in a standardized format, in the working language or languages of the ship and English, to allow monitoring and verification of compliance with the provisions of this section. The seafarers shall receive a copy of the records pertaining to them which shall be endorsed by the master or by a person authorized by the master and by the seafarers. Identified engineer officers logged import hours while vessel was in transit. Underway watch hours were corrected onscene.

Each operation described in paragraph 2 of this regulation shall be fully recorded without delay in the ORB I so that all entries in the book appropriate to that operation are completed. Entries in Oil Record Book for sludge tank to tank transfers were entered incorrectly under code (C) 12.1. Tank to tank transfers should be entered under (C) 12.2.

The electrical power available shall be sufficient to supply all those services that are essential for safety in an emergency, for a period of 18h emergency lighting: accomodation alleyways, stairway and exits. Identified 2 interior lights 01 deck & 1 exterior light on the 02 deck that are extinguished.

Escape routes shall be maintained in a safe condition, clear of obstacles. Deck plating in engine room around emergency escape are missing, rendering the emergency escape inaccessible. 74SOLAS(14) II-2/13.1.2

To maintain a valid Certificate of Inspection, you must complete your annual and periodic inspections within the periods specified in 31.10-17 (a) and (b) and your Certificate of Inspection must be endorsed. Vessel's anniversary date is July 10th. The annual inspection was due by 10OCT2020 to maintain a valid Certificate of Inspection. Prior to conducting cargo operations complete an annual inspection. 46 CFR 31.10-17a

Any ship of 10,000 Gt and above shall be fitted with oil filtering equipment complying with par. 7 of this reg. After reviewing the ORB and speaking with the C/E it was discovered that the OWS has been inpoperable since March 15, 2019. Class (ABS) issued the IOPP but had rcvd no notification of the OWS being inoperable prior to this inspection. Make permanent repairs of the OWS and prove proper working condition.

The main inlets and outlets of all ventilation systems shall be capable of closing from outside the spaces being ventilated. Bow thruster room ventilation closure inoperable in the open position. Make permanenet repairs and prove proper operation.

Fire doors in main vertical zone bulkheads shall be self closing and be capable of self closing with an angle of inclination of up to 35 degrees. Cargo control room door not fully closing when released. Adjust door and prove proper closure. SOLAS CH. II-2 Reg. 9.4.1.1.4.1

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations. Port main deck weather tight door showed day light through gasket when closed. Make neccessary adjusts to ensure weather tight integrity of the door.

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations. Upon activation of the general alarm system it was observed that in the pump room the general alarm only produced a visual alarm and no audible. Repair or replace alarm and prove proper operation.

Maintenance, testing and inspections of life saving appliances shall be carried out based on the guidelines of the organization and in a manner having due regard to ensuring reliability of such appliances. During inspection it was observed that the retro tape on the rescue boat was severly worn and in poor condition, also the fwd painter line for the rescue boat was sun damaged and frayed and in extremely poor condition. Replace as neccessary.

After 1 July 2002 all vessels shall comply with the International Safety Management (ISM) Code as amended. Preliminary assessment of the vessel’s Safety Management System (SMS). Interviews with the Master, Chief Engineer, Port Engineer [name withheld] (DPA), along with review of previous internal and external audits provide objective evidence that a SMS has not been fully implemented. Essential elements of the code have not been fully addressed or implemented, additionally non-conformity corrective actions required by the Recognized Organization (RO) in external audits conducted on 28 Dec 2017 and 10 Apr 2018 have not been completed. An external audit, attended by the Coast Guard, is required prior to release from detention.

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. Clear grounds as a result of the vessel having suffered multiple equipment failures, onboard fires & propulsion losses identified in either the below deficiencies or previous vessel history led to an expanded ISM exam revealing the vessel/company did not document and report non-conformities in accordance with the requirements of the ISM Code, and failed to follow procedures for implementing corrective action.

The Company should identify equipment and technical systems 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 stand-by arrangements and equipment or technical systems that are not in continuous use. The master and DPA stated there was not a list of equipment or technical systems identified as required by the Code. This non-conformity was previously identified by the RO in external audits conducted 28 Dec 2017 and 25 Jan 2018.

The Company should establish procedures, plans and instructions, including checklists as appropriate, for key shipboard operations concerning the safety of the personnel, ship and protection of the environment. The various tasks should be defined and assigned to qualified personnel. Shipboard and company personnel stated that since the requirements of ISM Code, Part A, Clause 10.3 had not been complied with, procedures to address those technical systems and equipment have not yet been established.

Companies should include procedures ensuring non-conformities, accidents and hazardous situations are reported to the Company, investigated and analyzed with the objective of improving safety and pollution prevention. Since issuance of the vessel’s SMC in Jan 2018 and despite multiple equipment failures, an onboard fire and casualties only two “Event Reports” have been submitted by the vessel. One personnel casualty dated 24 Oct 2018 and one non-conformity dated 28 Oct 2018.

Personnel carrying out audits should be independent of the areas being audited. The internal audit conducted on the vessel 15-16 Sep 2017 and internal audits conducted on two other company vessels were independently completed by the DPA. These audits included “Findings” that should have been identified as non-conformities, for example; “FMS has not fully been integrated”, “SMS required Crewmember sign-on sheet (MPM Form 3.01) was fond missing from the SMS documentation and not in use” and “SCBAs were reported as not operational, no records of inspection could be found. It was reported by the crew that SCBAs had not worked properly for months."

A main source of electrical power of sufficient capacity to supply all those services mentioned in regulation 40.1.1 shall be provided. This main source of electrical power shall consist of at least two generating sets. Vessel Captain reported generator #3 is down for repair, generator #2 intermittently fails to hold the electrical load, and generator #1 is operational but is emitting excessive white smoke. Make permanent repairs and prove proper operation and reliability to the satisfaction of the attending ACP ACS.

The electrical power available shall be sufficient to supply all those services that are essential for the safety in an emergency, due regard being paid to such services as may have to be operated simultaneously. Vessel Captain reported the emergency generator has failed to pick up the emergency load during vessel blackouts. Make permanent repairs and prove proper operation and reliability to the satisfaction of the attending ACP ACS.

The main steering gear shall be so arranged that in the event of loss of steering capability due to a single failure in any part of one of the power actuating systems of the main steering gear, excluding the tiller, quadrant or components service the same purpose, or seizure of the rudder actuators, steering capability shall be regained in not more than 45 s after the loss of one power actuating system. Vessel Captain reported the vessel is experiencing issues with the automatic switching between steering pumps. Make permanent repairs and prove proper operation and reliability to the satisfaction of the attending ACP ACS.

The vessel's main storage fuel tank, settling tank and day tank have been contaminated with bad fuel causing fuel system to clog and prevent MDE and SSDGs to run properly. Remove contaminated fuel, clean all tanks and restore fuel supply system to satisfactory condition. Provide class report attesting to the proper operation of the fuel supply system.

The vessel has a new/updated Automation system installed. PSTPs need to be updated and approved to reflect new system. Also, until ABS issues final approval and the OCMI witnesses proper operation of the system, PUMS is not authorized.

Vessel's SMS requires the use of a Fleet Management Software (FMS)(i.e NSE). Vessel is currently using excel spreadsheets as thier preventitive maintenance system which is contrary to the RO approved SMS.

The knife edge leading into the CO2 room is wasted and no longer capable of maintaining a weather tight seal. Make repairs to the satisfaction of the attending ACP ACS. (reissued from Act # 6326784)

Every ship of 400 GT and above other than an oil tanker shall be provided with an Oil Record Book (ORB) Part 1 (Machinery space operations). The ORB shall be in the form specified in appendix III of MARPOL Annex I. The vessel is maintaining ORB CG-4602A (Rev.01-07). Rev 11-16 is the current version of ORB CG-4602A, which complies with MARPOL. Provide correct version of ORB to the satisfaction of the attending ACP ACS. (reissued from Act # 6326784)

The general emergency alarm system shall be supplemented by either a public address system or other suitable means of communication capable of broadcasting messages into all spaces where crew members are normally present. the installed system is not fully functional. Make repairs and demonstrate functionality to the satisfaction of the attending ACP ACS. (reissued from Act # 6326784)

Master, chief engineers, chief mates, and second (1st A/E) engineers on chemical tankers shall hold a certificate in advanced training for chemical tanker cargo operations. The chief engineer's MMC is not endorsed as required. Provide onboard as required in compliance with the minimum safe manning document to the satisfaction of the USCG.(reissued from Act # 6326784)

Before ship leaves port and at all times during the voyage, all life saving appliances shall be in working order and ready for immediate use. Upon examination, the freefall lifeboat rudder found cracked through at the lower post and in three locations on the rudder skeg. make temp repairs to the satisfaction of the USCG or ACP ACS prior to departure from port.

After Jan 1, 2017 all persons employed or engaged on board vessels to which STCW applies must hold a medical certificate valid for 2 years. Three crew members (AB, DEU, Steward) found on board with expired medical certificates. Provide on board prior to sailing in compliance with the minimum safe manning document to the satisfaction fot the USCG.

On board a seagoing vessel, no person may assign a shipboard duty or responsibility to any person who is assigned a responsibility on the muster list unless the person can produce evidence of having recieved appropriate approved STCW basic training. One crew member (DEU) found on board could not produce evidence of completing approved STCW basic training. Provide on board prior to sailing in compliance with the minimum safe manning document to the satisfaction fot the USCG.

The Detcon Model 10 fixed gas detection system is not functioning as designed and not capable of detecting H2S. Make repairs and prove proper operation to the satisfaction of the attending ACP ACS. IBC Code Ch. 17

The knife edge leading into the CO2 room is wasted and no longer capable of maintaining a weathertight seal. Make repairs to the satisfaction of the attending ACP ACS.

Any STCW Certificate must be kept available in its original form on board the ship on which the holder is serving. The original certificates for one AB/RFPNW were not available on board, copies were presented for inspection. Provide original certificates (MMC/TWIC/Medical Certificate) on board as required in compliance with the minimum safe manning to the satisfaction of the USCG. STCW Reg. I/2.11

Main and auxiliary machinery essential for the propulsion and safety of the ship shall be provided with the effective means for its operation and control. The RPM gauges for the #2 and 3 SSDGs were not operable and the #1 could not be verified. Make repairs and prove operation to the satisfaction of the attending ACP ACS. 74 SOLAS (1997 Cons.) II-1/26.1

The machinery shall be of a design and construction adequate for the service for which they are intended and shall be so installed and protected as to reduce to a minimum any danger to persons on board, due regard being paid to hot surfaces and other hazards. Evidence of an exhaust leak noted from the main engine air box. Make repairs to the satisfaction of the attending ACP ACS. 74 SOLAS (1997 Cons.) II-1/26.1

The machinery shall be of a design and construction adequate for the service for which they are intended and 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. Safety guards for moving parts associated with the raw water cooling pumps and EDG missing. Install to the satisfaction of the attending ACP ACS. 74 SOLAS (1997 Cons.) II-1/31.1

Masters, chief engineers, chief mates, and second (1st A/E) engineers on chemical tankers shall hold a certificate in advanced training for chemical tanker cargo operations. The chief engineer's MMC is not endorsed as required. Provide on board as required in compliance with the minimum safe manning document to the satisfaction of the USCG. STCW Reg. V/1-1.5

Upon application for any Certificate of Documentation (COD), the owner of a vessel must designate a hailing port to be marked upon the vessel. The current COD, issued 20 July 2017, reflects a hailing port of Tampa, FL. The stern has been marked Mobile, AL. The stern is to be marked to confirm with the hailing port in accordance with 46 CFR 67.123 to the satisfaction of the USCG. 46 CFR 67.119

International certificates shall be drawn up in a form corresponding to the model given in the respective Convention. Convention certificates reflect the Port of Registry as Mobile, AL. Vessels registration has been updated for Tampa, FL. Provide revised Convention certificates on board to the satisfaction of the USCG. 74 SOLAS (2014 Cons.) I/15 All Ships MARPOL I/9; VI/8; LLC, IAFSC, etc.

Every ship to which chapter I applies shall be issued with a Continuous Synopsis Record (CSR) which shall contain the identification of the Company (as defined in regulation IX/1) the ISM SMC and DOC list the Company ID number as 5951433, whereas the CSR lists 5951671. Revise and provide on board to the satisfaction of the USCG 74 SOLAS (2014 Cons.) XI-1/5

Every ship of 400 GT and above other than an oil tanker shall be provided with an Oil Record Book (ORB) Part 1 (Machinery space operations). The ORB shall be in the form specified in appendix III of MARPOL Annex I. The vessel is maintaining ORB CG-4602A (Rev.01-07). Rev 11-16 is the current version of ORB CG-4602A, which complies with MARPOL. Provide correct version of ORB to the satisfaction of the attending ACP ACS. MARPOL Annex I/17.1

The general emergency alarm system shall be supplemented by either a public address system or other suitable means of communication capable of broadcasting messages into all spaces where crew members are normally present. The installed system is not fully functional. Make repairs and demonstrate functionality to the satisfaction of the attending ACS ACS. 74 SOLAS (1997 Cons.) III/4.2

The 11 April 1995 Stability Letter, cited by the Intl. Load Line Certificate (ILLC), references the ABS approved "Sulphur Enterprise Loading Manual" dated 16 March 1995. This manual could not be located on board. Provide on board or update Stability Letter and ILLC to the satisfaction of the attending ACP ACS. ILL 66 Art. 16

Containers, brackets, racks, and other similar stowage locations for life-saving equipment shall be marked with symbols in accordance with Resolution A.760(18), as amended, indicating the devices stowed in that location for that purpose. If more than one device is stowed in a location, the number of devices shall also be indicated. Mark the stowage locations for life-saving equipment as required to the satisfaction of the attending ACP ACS. 74 SOLAS (2014 Cons.) III/20/10 All Ships

Each lifebuoy shall be marked in block capitals with the port of registry of the ship on which it is carried. Mark all life-saving equipment required to be marked with the port of registry to the satisfaction of the attending ACP ACS. 74 SOLAS (1997 Cons.) II/7.1.4

The lifeboat's stbd. side aft water spray fixture was found inoperable. Make repairs and prove operation of all water spray fixturs to the satisfaction of the attending ACP ACS. 74 SOLAS (2014 Cons.) III/20.2 All ships

The port side hydraulic ram and associated control piping for the lifeboat davit found with evidence of hydraulic leakages. Make repairs and prove operation to the satisfaction of the attending ACP ACS. 74 SOLAS (2014 Cons.) III.20.2 All ships

Make permanent repairs to the lifeboat rudder, skeg and bearing in accordance with the manufacturer, to the satisfaction of the attending ACP ACS. 74 SOLAS (2014 Cons.) III 20.2

Stbd. side aft mooring chaulk found cracked. Make repairs to the satisfaction of the attending ACP ACS. Repair scheduled to be conducted at drydock. 74 SOLAS (2014. Cons.) I/11

The Class A boundary between the emergency generator space and the CO2 room found hole and temporarily repairs with epoxy and a doubler. Make permanent repairs to restore integrity of the boundary to the satisfaction of the attending ACP ACS. Repair schedualed to be done at drydock. 74 SOLAS (2014 Cons.) II-2/44.2

The company should ensure that each ship is manned with qualified, certificated and medically-fit seafarers in accordance with national and international requirements. Section 1.01 of the Savage Marine Management Company Vessel Procedures Manual (VPM)specifies the administrative procedure for crewmember sign-on, including the completion of form VPM F-1.01 (Crew Credentials Checklist). On board verification of crew credentials found the following: - 03 had expired medical certificates prior to signing-on - 01 did not have STCW basic training - 01 did not have endorsement for the required advanced training for chemical tanker cargo operations; - 01 did not have original certificates on board No records of form VPM F-1.01 were available for review on board. Following investigation and analysis, Company to provide documentation of corrective action attesting to the implementation of Section 1.01 of the company VPM. The Recognized Organization (ABS) is to attest to the verification of corrective action and conformance to ISM Code A/6.2 74 SOLAS (2014 Cons.) IX/3.1 All Ships // ISM Code Part A/6.2

Repair/replace low sea chest remote reach rod system. Machinery space to remain manned in accordance with minimally attended machinery space standards with live wach at all times until ACCU notation is restored by the vessel's ACS.

Port steering gear is experencing intermittent alarms causing changeover to stbd steering pump.

Provide short term SMS addendum for H2S training and monitoring procedures prior to arrival in Galveston TX. Submit procedures to [name withheld] and MSU Texas City for approval. Cargo operations may not commence until approval.

Voyage Data Recorder was found and reported to be inoperable. Vessel is restricted to domestic voyages only. SOLAS CH V Reg. 20

Provide liferaft capable of being launched by davit and all necessary arrangements. IAW SOLAS 97 Reg. III / 26.1.2.2

Provide onboard first assistant engineer with tankerman endorsement. IAW 46 CFR 15.860(f)(2)