DB HULK

Disposal of food wastes into the sea is prohibited in the Wider Caribbean Region unless the food has passed through a comminutor with scree openings no greater than 25mm. The garbage record book does not contain entries(dating back to May 2018) accounting for the disposal of any onboard food waste. Vessel personnel onboard informed the PSCO that food waste has not been disposed of using comminutor, and had been put overboard as is. Vessel personnel stated that the onboard comminutor had been inoperable but is now working. The vessel only works in the Gulf of Mexico, a Special Area. MARPOL 73/78 2011 Cons. Annex V/Reg. 6

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 take place: collection and disposal of oil residues(sludge); Discharge overboard or disposal otherwise of bilge water which has accumulated in machinery spaces. During review of the ORB, the PSCO noted that since May of 2018, there are no recordings showing collection or disposal of sludge or bilge water. Provide corrective action plan from company with concurrence from Administration. MARPOL 73/78 2011 Cons. Annex I/ Reg. 17

Weekly soundings required to be recorded in the Oil Record Book(ORB) shall be completed in accordance with the convention. During review of the ORB, the PSCO noted that the vessels only sludge tank, the waste oil tank indicated by the IOPP Form A(section 3.1) was not being sounded weekly (ORB Code: C 11.1). Vessel representatives stated that the waste oil tank is not being used, and that the vessel only puts waste oil/sludge into a portable tank onboard the vessel. Provide corrective action plan to the satisfaction of the Administration. MARPOL 73/78 2011 Cons. Annex I/Reg. 17

The entry for each garbage discharge shall include date and time, position of ship, category of the garbage and the estimated amount discharged. PSCO observed that the vessel was not producing adequate entries for category A-C garbage nor maintaining any entries for the discharge of food wastes. Provide corrective actions to be taken with concurrence from the Administration. MARPOL 73/78 2011 Cons. Annex V/Reg. 9.3(b)

Every ship 400 gross tonnage and above, and every ship which is certified to carry 15 person or more, shall carry a garbage management plan which the crew shall follow. This plan shall provide written procerdures for collecting, storing, processing, and disposing of garbage, including the use of the equipment on board. Current plan explicitly directs crew to not utilize food comminutor, which is required while discharging food waste into the Gulf of Mexico. MARPOL 73/78 2011 Cons. Annex V/Reg. 9.2

An International Oil Pollution Prevention Certificate(IOPP) shall be issued in accordance with the provisions of regulation 6 of this Annex to any ship of 400 gross tonnage and above. Such certificate shall be endorsed as appropriate either by the Administration or by any persons or organization duly authorized by it. Vessel's IOPP Supplement (Form A) states that the vessel is marked to have both MEPC.60(33) and A.393(X) oil content meter. Vessel's IOPP Supplement also does not provide the maximum throughput of the system. MARPOL 73/78 2011 Cons. Annex I/Reg. 6

Ventilators in position 1 or 2 to spaces below freeboard decks or decks of enclosed superstructures shall have coamings of steel or other equivalent material, substantially constructed and efficiently connected to the deck. PSCO observed 04 ventilators (vents both forward and aft of the number 7 port and starboard ballast water vents) leading to below decks that have were missing several bolts connecting them to the deck. ICLL 66 am Annex I: II/Reg. 19

A ship of 300 gross tons or more constructed after June 30, 1974 must have a fixed container or enclosed deck area under or around each fuel oil or bulk lubricating oil tank vent, overflow and fill pipe. PSCO observed several discharge containments missing mechanical drain plugs.

The master or person in charge of a ship to which this section applies shall ensure that the ship is not operated unless a garbage management plan meeting paragraph (b) of this section is on the ship and that each person handling garbage follows the plan. The ship has no garbage management plan.

Vessel required to have discharge placard in each machinery space or at the bilge and ballast pump control station. Vessel does not have placards near overboard discharge locations.

Vessel required to be manned in compliance with applicable safe manning requirements of the administration. Vessel does not meet their minimum safe manning certificate.

Vessel does not have an approved Garbage Management plan. PSCOs found garbage that was not segregated and vessel found to not be familiar with shipboard operations. MARPOL Annex V Reg 8 & Reg 9.2 50a, Rectify within 30 days to the satisfaction of Class.

Vessel does not maintain receipts for garbage discharges to reception facilities. MARPOL Annex V Reg 9.3 50a, Rectify within 30 days to the satisfaction of Class.

Vessel does not have a garbage management placard posted. MARPOL Annex V Reg 9.1(a) 50a, Rectify within 30 days to the satisfaction of Class.

Vessel did not submit a Ballast Water Management report when transiting from one COTP zone to another. 33CFR151.2041(3) 50ac, Rectify within 30 days to the satisfaction of Class and US Coast Guard.

Vessel is not maintaining any Ballast Water Management records. 33CFR151.2045 50ac, Rectify within 30 days to the satisfaction of Class and US Coast Guard.

Vessel does not have reciepts for discharges of oily waste to reception facilities. Conducted a satisfactory operational test of the OWS and do not suspect any MARPOL Annex I violations. MARPOL Annex I Reg 17 50a, Rectify with in 30 days to the satisfaction of Class.

The operations manual for the OWS is not approved and does not accurately reflect the installation of the OWS system. The overboard piping after the solenoid operated valves are not illustrated on the OWS drawing. MARPOL Annex I Reg 14.6 50ab, Rectify within 30 days to the satisfaction of Class and Administration.

Vessel does not have an approved Ballast Water Management Plan onboard. 33CFR151.2035(7)(8) 50ac, Rectify within 30 days to the satisfaction of Class and US Coast Guard.

Cert statement does not identify if the vsl is manned or unmanned, and if it is carrying oil as a primary or secondary cargo. The plan must also be amended to include the volume and type of oil cargo that would be involved in a WCD per 33 CFR 155.1045(c). In addition, the vessel-specific appendix must be amended to include individual tank capacities of lube oil and fresh water tanks.

The VRP must be amended to include descriptions and duties for each position of the spill management team, or state the plan incorporates the NIIMS or UCS. The VRP must also be amended to fix incorrect cross-references, and verify intended areas of operation/COTP zones.