PAC ATHENA

The substandard conditions identified during each of the three detentions gives reasonable cause to believe the Athena Maritime Pte Ltd and the vessel's senior officers have failed to effectively and systematically implement the Safety Management System as required by the International Safety Management Code. See documents for Letter of Denial.

In a ship in which oil fuel is used, the storage, distribution and utilization of the fuel oil shall be such as to ensure the safety of the ship and persons on board. PSCO observed excessive fuel oil leakage on the No.4 cylinder fuel injectors and fuel pump. Additionally, the No.4 cylinder fuel oil supply line had heavily soaked lagging. Cite: SOLAS 74(a) 2001(cons)/15.2

PSCO obsereved both ventilation dampers were unable to be secured from inside the engine room. -SOLAS 74am II-2/5/1/4

PSCO observed 15+ deck and emergency lights that were inoperable. -SOLAS 74am II-1/41.2.1

PSCO obsereved heavily deteriorated, wasted and missing insulation in the purifier space and emergency fire pump boundaries; both A-60 required spaces. -SOLAS 74 am II-2/5.1.4

PSCO obsereved exposed wires on multiple sensors on the main deisel engine, fuel oil pumping system adn lighting system throughout the cargo deck. -SOLAS 74 am II-1/40/1/3

PSCO observed no relief valve on the aft mooring winch pressure vessel. Provide clarificaiton from certificate issuing authority on the acceptability of the mooring system. -SOLAS 74 I/11

PSCO observed jackete water leaking from the MDE cylinder exhaust. -SOLAS 74am I/11

PSCO obsereved the fire damper control system's cylinder leaking air. -SOLAS 74am I/11

PSCO obsereved the self-closing door into the engine control room did not latch. -SOLAS 74am II-2/47.1

PSCO observed the double jacketing fuel line on the No 1 cylinder was loose and no anti spray tape installed. -SOLAS 74 am II-2/15.2

Before the ship leaves port and at all times during the voyage, all lifesaving appliances shall be in working order and ready for immediate use. The limit switch for the rescue boat that was found seized was unable to be verified operational by attending PSCO due to the delamination and separation of the STBD aft lifting cleat. In addition the port forward lifting cleat was found warped and suspect in way of the rescue boat hull. As noted in Lloyds class reports dated 28AUG2019, report number 2044916: 1. Free-fall lifeboat hook plate was found wasted. 2. Rescue boat davit winch drum side plates found wasted 3. Rescue boat davit accumulator lower fitting was found leaking and repaired during class survey on 28AUG2019 The annual rescue boat and free-fall lifeboat technician report from Gateway Fire & Safety Pte Ltd, dated 7JUN2019 was reviewed with no discrepancies. Due to the above findings a new technician report for the lifesaving equipment (rescue boat, free-fall life boat) from the manufacture approved technician attesting to the proper repairs and full operation of rescue boat and free-fall boat to be submitted prior to departure. The following deficiencies from PSC examination conducted on 21AUG2019 have been cleared; 01, 03, 04, 05, 06, 07, 08, 09, 10, 11, and 12. Deficiencies 02 and 13 remain outstanding. 74 SOLAS (2014) III/20.2

Structural fire protection, including fire resisting divisions, and protection of openings and penetrations in these divisions shall be kept in good order so as to ensure their required performance if a fire occurs. 80 percent of all ventilator ducts from the bridge to the main deck are severely wasted, seized and unable to provide a complete seal due to the wastage, to include the emergency generator and CO2 storage space. As per SMS procedures, crew to provide maintenance monthly. 74 Solas (04) II-2/14.2.1.1.1

Recovery time of the rescue boat shall be not more than 5 min in moderate sea conditions when loaded with its full complement of persons and equipment. Rescue boat davit limit switch seized during the recovery of the rescue boat. As per SMS procedures, crew is to check condition of the limit switch every 3 months. 74 Solas (14) III/ 17.4

Air and overflow pipes and relief valves shall discharge to a position where there is no risk of fire or explosion from the emergence of oils and vapor. Multiple fuel vents on the deck and in the house found wasted, covers holed, and damage flame screens. As per the vessels SMS procedures, the fuel vents are to be examined and checked operational monthly. 74 Solas (04) II-2/4.2.2.4

Before the ship leaves port and at all times during the voyage, all life-saving appliances shall be in working order and ready for immediate use. Four life rafts were found improperly stowed which would prevent the life rafts from floating free in the case of an emergency. As per the vessels SMS procedures, crew to provide examination weekly. 74 Solas (14) III/20.2

Objective evidence discovered in an expanded ISM exam revealed the following major non-conformity; the vessel failed to fully implement the requirements of the SMS as evident by def. #01, 02, 03 and 04. An external audit is required. 74 Solas (14) IX/3&5 ISM code 10

Electrical installations shall be such that the safety of crew and the ship from electrical hazards will be ensured. The door to the battery locker on the bridge was found in a wasted condition. As per the vessel's SMS procedures, weather tight doors shall be checked and descaled every three months. 74 Solas (04) II-1/40.1.3

Terminations and joints in all conductors shall be so made as to retain the original electrical, mechanical, flame retarding and where necessary, fire resisting properties of the cable. Wiring for the exhaust temperature sensors for (MDE) cylinders 3 to 6 were spliced, versus continually ran from distribution panel. 74 Solas (04) II-1/45.5.6

The alarm system shall be able to indicate at the same time more than one fault and the acceptance of any alarm shall not inhibit another alarm. The Kongsberg Data Chief C20 control system for the main engine control room alarm monitoring system was malfunctioning causing 16 faults for the main engine. Ship's crew has parts on board for repair. 74 Solas (04) II-1/51.3.1

After any survey of the ship under paragraph 1 of this regulation has been completed, no change shall be made in the structure, equipment, systems, fitting, arrangements or material covered by the survey, without the sanction of the Administration, except the direct replacement of such equipment and fittings, 3 inch cement patches found on port and starboard bunkering station discharge containment on the main deck. Condition of the main deck in way of the discharge containment to be examined and verified by class. MARPOL Annex I/6.4.2

All access openings in bulkheads at ends of enclosed superstructures shall be fitted with doors of steel or other equivalent material, permanently and strongly attached to bulkheads and framed, stiffened and fitted so that the whole structure is of equivalent strength and watertight when closed. The starboard side bridge wing door frame was found wasted and holed, the port side bridge wing door frame was found with an unapproved repair to the lower door frame. As per vessel's SMS procedures, crew to examine the doors monthly. ICLL 66/88 Annex I/ 12(1)

All access openings in bulkheads at ends of enclosed superstructures shall be fitted with doors of steel or other equivalent material, permanently and strongly attached to bulkheads and framed, stiffened and fitted so that the whole structure is of equivalent strength and watertight when closed. The forward forecastle door and the port aft forecastle door were found wasted and knife edge unable to seal. As per the vessel's SMS procedures, crew to provide examination monthly. ICLL 66/88 Annex I/ 12(1)

The Administration shall be satisfied that adequate arrangements are in place to ensure that the performance of the equipment required by this chapter is maintained. Mast light and running light not watertight. The bottom most port and starboard running lights on the bridge mast were found without proper packing glands and open to the environment. 74 Solas (14) V/16.1

Ventilator opening shall be provided with weather tight closing appliances. Multiple ballast and fuel vent heads found with wasted covers and missing 50% securing bolts attach attaching to vent flanges. As per the vessel's SMS procedures, crew to provide maintenance monthly. ICLL 66/88 Annex I/ 19 (4)

11132-Maintenance and Inspections-Maintenance, testing, and inspections of life-saving appliances shall be carried out based on guidelines developed by the organization and in a manner having due regard to ensuring reliability of such appliances. PSCO observed wasted SOLAS reflective tape on the port and starboard side of the free fall life boat.-74 SOLAS 14 con. III/20.3.1

13101- The purpose of this regulation is to prevent the ignition of combustible material or flammable liquids. For this purpose, the following functional requirements shall be met: Means shall be provided to control leaks of flammable liquids. PSCO found evidence of fuel oil leaks from the emergency generator and #5 injector on the main diesel engine. 74 SOLAS(14)II-2/4.1 60a

13101- The machinery, boilers and other pressure vessels, associated piping systems and fitting shall be of the 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 onboard, due regard being paid to moving parts, hot surfaces and other hazards. PSCO observed evidence of lube oil leaks on #3 and #5 cylinder heads on the main diesel engine. A lube oil leak was found on the main diesel engine lube oil cooler. 74 SOLAS (14)II-1/26.1

02108- All electrical apparatus shall be so constructed and so installed as not to cause injurywhen handled or touched in the normal manner. PSCO observed exposed electrical wires on the bulkhead by the drier room. 74 SOLAS(14)II-1/45.1.3 17a

07101- For the purpose of this regulation is to limit the fire growth potential in every space of the ship. PSCO observed fire slide doors in galley unable to remained closed (windows between officers mess, crew mess and galley. 74 SOLAS(14)II-2/5.1 17a

07105- Machinery space openings in position 1 or 2 shall be properly framed and efficiently enclosed by steel casings of ample strength and where the castings are not protected by other structures their strength shall be specilally considered. Access openings and such shall be fitted with doors complying with the requirements of regulation 12(1). PSCO observed a cable penetration open on the bulkhead between steering compartment and the engineroom. ICLL I/17 17a

03107- All access openings in bulkheads at ends of enclosed superstructures shall be fitted with doors of steel or other equivalent material. The means for securing these doors weathertight shall consist of gaskets and clamping devices or other equivalent means. PSCO observed multiple weathertight doors not sealing properly. ICLL I/12 17a

Vessel shall carry garbage management plan which crew shall follow. PSCO observed garbage stowed in a container on deck which was not stowed in accordance with the ships plan. MARPOL V/9.2 10c

04114- The purpose of this regulation is to maintain and monitor the effectiveness of the fire safety measures the ship is provided with. PSCO observed quick closing valve was in the closed position on the fuel oil tank on the emergency generator. Crew has no procedures or checklist for weekly testing to ensure all the systems working properly. The company shall provide a corrective action plan with concurrence with administration within 14 days. 74 SOLAS(14)II-2/4.1 10c ISM Code 7 c

15109- Objective evidence revealed during expanded exam the following non comformity; The vessel failed to fully implement the required element of the SMS as evidence by the above deficiencie. An internal audit is required within three months. 74 SOLAS(14)IX/3 ISM Code 10 c

99101- A routine visual inspection must be conducted at least once per week or per voyage, whichever is more frequent. PSCO observed that required visual inspection have not been completed from 03/23/19 through 03/27/19, last inspection was carried out on 03/18/19. VGP 4.1.1 10c

THE STEERING GEAR COMPONENTS AND THE RUDDER STOCK SHALL BE OF SOUND AND RELIABLE CONSTRUCTION TO THE SATISFACTION OF THE ADMINISTRATION. BOTH NUMBER 1 AND NUMBER 2 STEERING PUMPS HAVE ACTIVE LEAKS AT APPROX 40 DROPS PER MINUTE DURING OPERATIONS.

THE MACHINERY, BOILERS AND OTHER PRESSURE VESSELS, ASSOCIATED PIPING SYSTEMS AND FITTINGS SHALL BE OF 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 ONBOARD, DUE REGARD BEING PAID TO MOVING PARTS, HOT SURFACES AND OTHER HAZARDS. PSCO OBSERVED EVIDENCE OF F/O LEAKING FROM THE #4 AND #6 FUEL PUMPS. IN ADDITION, PSCO OBSERVED MULTIPLE F/O LEAKS ON THE #2 AND #3 AUXILIARY ENGINES MANIFOLD.

AFTER ANY SURVEY OF THE SHIP, NO CHANGE SHALL BE MADE IN THE STRUCTURAL ARRANGEMENTS, MACHINERY, EQUIPMENT AND OTHER ITEMS COVERED BY THE SURVEY, WITHOUT THE SANCTION OF THE ADMINISTRATION. PSCO OBSERVED VESSELS CREW WELDED A VALVE AND FLEXABLE HOSE INTO THE A/C DRAIN LINE, DIVERTING WATER TO THE STEAM CONDENSATE TANK. PROVIDE DOCUMENTATION FROM THE CERTIFICATE ISSUING AUTHORITY ATTESTING TO THE ACCEPTANCE OF SHIPBOARD MODIFICATION.

The vessel is not in substantial compliance with relevant conventions, the COTP questions the adequacy and/or implementation of the vessel's SMS under the ISM Code. PSCO questions whether the ship will be able to safely handle and carry its cargo throughout its forthcoming voyage. An external audit is recommended to be conducted within 30 days by the flag or RO to determine whether the ship is operating in accordance with the ISM Code. 74SOLAS(14)XI-1/5

The vessel has 2,500 MT of Ferrosilicon (UN1408) loaded in cargo hold #2. PSCO noted that Ferrosilicon is not listed as a cargo permitted for carriage on the vessel's Solid Bulk Cargo Certificate of Compliance issued by Lloyd's Register. Mechanical ventilation for cargo hold #2 was not in operation during the exam, as required by the IMSBC Code. Additionally, is has been determined that the vessel's installed ventilation fans are not certified as explosion proof, which prohibits the vessel from providing mechanical ventilation to cargo hold #2 as required by the code. Vessel's inability to provide required ventilation poses a potential threat to the vessel and its crew. 74SOLAS(14)VI/1-2

The carriage of solid bulk cargos other than grain shall be in compliance with relevant provisions of the IMSBC Code. The vessel has 2,500 MT Ferrosilicon (UN 1408) loaded in cargo hold #2. PSCO noted on vessel's Solid Bulk Cargo Certificate of Compliance that Ferrosilicon is not listed as a cargo suitable for carriage upon the vessel. Additionally, PSCO observed that continuous mechanical ventilation for cargo hold #2 was not in operation as required by the Code. Class shall attest to the vessels compliance with all applicable sections of the IMSBC Code.

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. PSCO observed a fuel leak from the #5 cylinder fuel pump on the #2 generator.

09232- Cleanliness of engine room- It is the owner's responsibility to ensure that the machinery space is maintained in a clean condition. PSCO observed oily rags and trash spread around the electrician stores and poop deck locker. MSC.601 Annex 2#18/6.4 60c

13106-Insulation wetted through (oil)- All surfaces with temperatures aboce 220 C which may be impinged as a result of a fuel system failure shall be properly insulated. PSCO observed oil soaded lagging covering main engine. 74 SOLAS (01 Cons.) II-2/15.2.10 60c

07105-Fire doors/openings in fire-resisting divisions- The fire resistance of doors shall, as far as practicable, be equivalent to that of the division in which they are fitted. Doors and door frames in "A" class divisions shall be constructed of steel. PSCO observed 02 Class "A" doors in main ladder-well and 01 Class "A" window in gallery with pentrations throught the boundary. 74 SOLAS (01 Cons.) II-2/47.1

11124-Embarkation arrangment survival craft- Muster and embarkation stations shall be adequately illuminated by lighting supplied from the emergency source of electrical power required by regulation II-1/42 or II-2/43, as appropriate. PSCO observed 3 inoperable embarkation lights, 01 light for the lifeboat, 01 light for staboard side free float life rafts and 01 light for the port side davit launched life rafts. 74 SOLAS (14 Cons.)III/11.4 17c

Instructions for on-board maintenance of life-saving appliances complying with the requirements of regulation 36 shall be provided and maintenance shall be carried out accordingly. While attempting to start the lifeboat on the second battery the lifeboat failed to start, weekly maintenance is not being done according to the ships SMS procedures. 74 SOLAS (04 Cons.) III/20.3.1 17c

13101-Propulsion main engine- The condition of the ship and its equipment shall be maintained to confrom 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 person on board. PSCO observed fuel leaks on the #1 cylinder on the main engine. Lub oil leaks from the exhaust manifold on the #2 cylinder and a jacket water leak on the #2 cylinder. 74 SOLAS (14 Cons.) I/11 17c

08199- Other(alarms)- The condidiotn of the ship and its equipment shall be maintained to conform witht he provisions of the present reugaltions to ensure that thte ship in all respects will remain fit to proceed to sea without danger to the ship or persons on board. Fuel oil leak alarm was attached to the sensor location using mechanical tape as the threads were stripped on the screw. 74 SOLAS (14 Cons.) I/11 17c

02105-Steering Gear- A fixed storage tank having sufficient capacity to recharge at least one power actuated system including the reservoir, where the main steering gear is required to be power operated. PSCO observed steering gear reservoir tank level was beneath the inspection plate level. 74 SOLAS (04 Cons.) II-1/29.l2.3 10c

11104- Rescue Boats - Before the ship leaves port and at all times during the voyage, all the life saving appliances shall be in working order and ready for immediate use. PSCO observed intertwined cables for remotely operating the davit from the rescue boat when embarked, incapacitating the ability for the davit to launch the rescue boat within the time required by SOLAS. 74 SOLAS (14 Cons.) III/20.2 10c

0715- Fire-fighting appliances (Detection)- Fire protection systems shall be maintained and ready for use. PSCO observed multiple smoke detectors covered in engineering spaces including: lower engine room aft of main engine covered by plastic bag, workshop covered by plastic bag, air conditioning space by plastic cover, preventing detection of smoke as designed. SOLAS 74(2014)II-2/14.1.1

0520- Working Space (Lighting)-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 will remain fit to proceed to sea. PSCO Noted four lights near the boiler top which were extinguished. SOLAS 74(14)I/11(a)

0899- Accident Prevention (other)- Structural fire protection, including fire resisting divisions, and protection of openings and penetrations. PSCO observed starboard lower forward cable way cover removed in engine room and unattended. Additionally the cable way cover removed in space forward. SOLAS 74(14)II-2/14.2.1.1.1

0750- Fire fighting appliances (fire prevention)- Doors fitted in boundary bulkheads of machinery spaces of category A shall be reasonably gastight and self-closing. PSCO observed hold backs on self closing doors in purifier and laundry room, preventing them from operating as designed. SOLAS 74(01)II-2/47.1

0720- Fire-fighting appliances (fire fighting equipment)- Fire extinguishing appliances shall be kept in good order and be available for immediate use at all times. PSCO observed fire hose rupture during testing. SOLAS 74(01)II-2/21

0810- Accident prevention- 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. PSCO observed small steam leak from pre heater cooler on main diesel engine. SOLAS 74(14)I/11(a)

2550- ISM Related deficiencies (Masters responsibility and authority)- The company should establish procedures to ensure that the ship is maintained in accordance with the provisions. Due to objective evidence in the above def's The vsl is not in substantial compliance, the COTP questions the adequacy of the vsl's SMS. An external sudit is recommended. Provide decision to USCG prior to departure. SOLAS 74(14)XI-1/4.1