BW TRADER

A vessel past its compliance date as outlined in 33 CFR 151.2035 must use one of the ballast water management methods listed in 33 CFR 151.2025, except that ballast water exchange (BWE) is not a permissible ballast water management strategy. This vessel has an extension letter that requires a compliance date of first scheduled dry-dock after March 1, 2016. Vessel entered dry-dock on March 14, 2016 and received hull survey credit on Safety Construction Certificate on March 20, 2016. No BWTS was installed and vessel has been conducting untreated BWE and discharging untreated ballast into U.S. waters; BWE is no longer a permissible BWM strategy for this vessel as it is past its compliance date for the purpose of U.S. regulations. 33 CFR 151.2035 40c

Where electrical equipment is installed in gas-dangerous spaces or zones as provided in 10.1.4, it should be to the satisfaction of the Administration and approved by the relevant authorities recognized by the Administration for operation in the flammable atmosphere concerned. Identified explosion proof lighting for two lights significantly cracked in deck store and one cracked explosion proof light in forward dry chemical powder room, verified both locations are located in gas dangerous zone plan located in cargo operations manual dated 2003.09.02. 74 SOLAS 14 VII/13.1 REF 1993 IGC/ 10.1.5.

The ambient design temperatures used in the design should be shown on the International Certificate of Fitness. The ambient temperatures are 5 degrees Celsius for air and 0 degrees Celsius for seawater [IGC 4.8.1] 74 SOLAS 14 VII/ 13.1, Reference [withheld] IGC/4.8.1]. U.S. regulations require lower ambient design temperatures for both U.S. and foreign-flagged vessels: the insulation for a cargo tank without a secondary barrier must be designed for the cargo tank at the design temperature and for a vessel operating in any waters in the world, except Alaskan waters, for the ambient cold condition of air at negative eighteen degrees Celsius and seawater at zero degrees Celsius [46 CFR 154.466(a)(1)]. Vessel's Certificate of Fitness, no. SNG 1600322, lists ambient design temperatures as 45 degrees Celsius air and 32 degrees Celsius water. This is incorrect and meets neither the international nor the U.S. requirements.

Maintenance 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 and appliances. The maintenance plan shall be kept on board the ship and shall be available for inspection whenever required by the Administration. According to ship's job description EXS0011A for powder fire fighting system 24 month routine, a test sample of dry chemical powder for moisture content should be done. PSCOs found that during the last 24 month routine maintenance a test sample of dry chemical powder for moisture content was not completed during the maintenance on 20FEB2017. The last sample test for moisture content was 04MAR15, which is beyond the 24 month routine maintenance required by ship's maintenance plan. 74 SOLAS 14 II-2/ 14.2.2.