EDWARD L RYERSON

During the Internal Structural Exam, marine inspectors identified widespread deterioration and deflection of steel structures and plating in way of the cargo holds. These areas include the following: cargo hold bottom plating and the associated longitudinal and transverse structures within the double bottom void spaces, cargo hold arch brackets and associated damaged structures, shedder void vertical stiffeners and associated struts, and exterior cargo hold vertical stiffeners and associated overhead frames visible from the port and starboard ballast tanks. Further additional steel structure deformities were identified throughout the course of the inspection and noted by Fraser Shipyard’s steel report. Submit repair proposal and receive approval for the identified steel structure deficiencies from the local Officer in Charge of Marine Inspections prior to further Coast Guard inspection for certification aboard the vessel.

Throughout the course of inspection on 3/6/23-3/9/23, marine inspectors observed potentially inadequate asbestos abatement procedures onboard the vessel, specifically in the port and starboard cargo walkway tunnels. Areas around patch work previously conducted to contain Asbestos Containing Material (ACM) did not appear to be cleaned as indicated by the surrounding dirt, dust, and general shipboard debris. Furthermore, the documentation provided to the Coast Guard regarding the asbestos containment project does not indicate initial monitoring of the workplace was completed to determine if airborne concentrations of asbestos is at or above the time weighted average permissible exposure limit, as described in 29 CFR 1910.1001 (d). The documentation also does not specify that housekeeping of ACM waste and accompanying dust was mitigated using a HEPA-filtered vacuum, as required by 29 CFR 1910.1001 (k). Provide documentation attesting to the time weighted average measurement of airborne concentrations of asbestos in areas where ACM may be exposed/disturbed aboard the vessel and the proper housekeeping surrounding the abatement of ACM as described in 29 CFR 1910.1001 (k), prior to further inspections conducted by Coast Guard marine inspectors.