EVRIDIKI

OIL FILTERING EQUIPMENT REQUIRED BY MARPOL ANNEX I/14.1 SHALL ENSURE THAT ANY OILY MIXTURE DISCHARGED INTO THE SEA AFTER PASSING THROUGH THE SYSTEM HAS AN OIL CONTENT NOT EXCEEDING 15 PARTS PER MILLION. AFTER THE VESSEL'S OWS WAS CLEANED AND OCM WAS REPLACED, THE PSCO OBSERVED THAT THE VESSEL'S OWS WAS UNABLE TO PRODUCE AN EFFLUENT CONTAINING LESS THAN 15 PPM OF OIL. CITE: MARPOL 73/78 I/14.6 50ac

THE SYSTEM SHOULD REQUIRE MINIMUM ATTENTION TO BRING IT INTO OPERATION. IN THE CASE OF EQUIPMENT USED FOR ENGINE ROOM BILGES, THERE SHOULD BE NO NEED FOR ANY ADJUSTMENT TO VALVES AND OTHER EQUIPMENT TO BRING THE SYSTEM INTO OPERATION. THE SYSTEM SHOULD BE CAPABLE OF OPERATING FOR AT LEAST 24 HOURS OF NORMAL DUTY WITHOUT ATTENTION. DURING AN INTERNAL EXAMINATION OF THE VESSEL'S OWS AND BILGE HOLDING TANK, THE PSCO IDENTIFIED LARGE QUANTITIES OF SOOT AND OIL IN THE OWS FILTERING MEDIA AND IN THE OILY BILGE WATER. AFTER THE OWS AND ALL FILTERING MEDIA WERE CLEANED, THE OWS WAS STILL UNABLE TO PRODUCE AN EFFLUENT BELOW 15 PPM. THE [name withheld] DRAINAGE/DISPOSAL ARRANGMENT ON BOARD THE VESSEL THAT PERMITS SOOT AND OTHER PARTICULATES TO CONTAMINATE THE CONTENTS OF THE BILGE HOLDING TANK AND SUBSEQUENTLY IMPEDE THE OIL FILTERING ABILITY OF THE OWS. CITE: MARPOL 73/78 I/14.7, MEPC.107(49) 4.1.5 50ac

The company and the ship shall comply with the requirements of the ISM Code. The company should establish a safety and environmental protection policy. The company should ensure that the policy is implemented and maintained at all levels of the organization, both ship-based and shore-based. Posted instructions for operating the ship's oily water separator (OWS) state "open the sampling water inlet valve to the sensing unit for the 15 PPM alarm." PSCO observed that during testing of the OWS and the Oil Content Meter (OCM) the crew was unable to demonstrate proper operation of the system. The samplue inlet valve from the OWS was secured by the ship's crew thereby simulating 0 PPM of oil in the discharge effluent and allowing for an overboard discharge of unmonitored oily bilge water. When the sample valve inlet was opened, the OCM immediately sensed an oil content above 15 PPM and alarmed. 74 SOLAS (2014) IX/3/1, ISM Code Part A/2 30abc

THE 15 PPM BILGE ALARM WILL BE CALIBRATED AND ZEROED AS PER THE MANUFACTURER'S INSTRUCTIONS. IT WILL BE TESTED WITH THREE TEST FLUIDS: 0 PPM, 15 PPM, AND FULL SCALE OF THE METER. EACH CONCENTRATION TEST WILL LAST 15 MINUTES. THE VESSEL'S CREW PROVIDED PSCO WITH CALIBRATION CERTIFICATES DATED 31MAR18 AND 11JAN19. EACH CALIBRATION CERT. STATED THE TEST LIQUID OF 0 PPM, 10 PPM, AND 15 PPM. IN ADDITION, A REVIEW OF THE VESSEL'S OCM DATA SHOWS THE OCM WAS RAN FOR APPROXIMATELY 2 MINS ON 31MAR18 AND WAS NEVER RAN ON 11JAN19. THE [name withheld] OF THESE CALIBRATION CERTIFICATES. MARPOL 73/78 ANNEX 1 REG.14.7 MEPC 107(49) ANNEX PART 2.2.5 17abc

THE ARRANGEMENT ON BOARD THE SHIP FOR THE EXTRACTION OF SAMPLES FROM THE 15 PPM BILGE ALARM SHOULD GIVE A TRULY REPRESENTATIVE SAMPLE OF THE EFFLUENT WITH ADEQUATE PRESSURE & FLOW. PSCO OBSERVED TWO VALVES INSTALLED IN THE SAMPLE EXTRACTION LINE. THESE VALVES ARE INCLUDED IN THE VESSEL'S APPROVED PIPING DIAGRAM. HOWEVER, THE VESSEL'S CREW WERE UNABEL TO OPERATE THE OIL CONTENT ALARM BELOW 15 PPM WITHOUT SIGNIFICANTLY THROTTLING THE VALVE OR SHUTTING THE SAMPLE VALVE. [name withheld] THE INSTALLED VALVES IN THE SAMPLE LINE ARE PREVENTING THE OCM ALARM FROM RECIEVING A TRULY REPRESENTATIVE SAMPLE OF THE EFFLUENT OF THE OWS. MARPOL 73/78 ANNEX I REG. 14.7 MEPC 107(49) 6.2.2 17abc

TO AVOID WILLFUL MANIPULATION OF 15PPM ALARMS, EVERY ACCESS OF THE 15PPM BILGE ALARMS BEYOND THE ESSENTIAL REQ. OF PARAGRAPH 4.2.8 REQUIRES THE BREAKING OF A SEAL, PSCO OBSERVED THE OMD 2005'S TAMPER SEALS WERE BROKEN OR MISSING ON BOTHE SIDES OF THE DEVICE. MARPOL I/14.7 MEPC.107(49) 2.2.5 17abc MARPOL 73/78 ANNEX 1 REG 14.7 MEPC 107(49) 4.2.10.1

THE COMPANY SHOULD ESTABLISH PROCEDURES, PLANS, AND INSTRUCTIONS, INCLUDING CHECKLIST AS APPROPRIATE, FOR KEY SHIPBOARD OPERATIONS CONCERNING PROTECTION OF THE ENVIRONMENT. THE PSCO OBSERVED THE OWS COULD NOT PRODUCE AN EFFLUENT BELOW 15PPM, UPON INTERNAL INSPECTION OF THE OWS, PSCO FOUND THE COALESCER/FILTER HEAVILY SOILED, POTENTIALLY RENDERING THE SYSTEM INOPERABLE. THE VESSEL HAS PROCEDURES AND SCHEDULE FOR THE INSPECTION AND/OR CLEANING OF THE OWS COALESCER/FILTER. HOWEVER, CURRENT PROCEEDURES WERE INADEQUATE TO ENSURE THE SYSTEM REMAINED OPERATIONAL. 74SOLAS(2014) IX/3.1 ISM CODE A/7 17abc

THE COMPANY SHOULD ESTABLISH PROCEEDURES, PLANS, AND INSTRUCTIONS, INCLUDING CHECKLIST AS APPROPRIATE, FOR KEY SHIPBOARD OPERATIONS CONCERNING PROTECTION OF THE ENVIRONEMENT. DUE TO THE PSCO'S OBSERVATIONS OF THE INADEQUACIES OF THE VESSEL PROCEDURES TO ENSURE PROPER OPERATION OF THE VESSEL'S SMS BY THE CERTIFICATE ISSUING AUTHORITY IS RECCOMENDED, TO BE COMPLETED WITHIN 30 DAYS. PROVIDE DETERMINATION REGARDING COMPLETION OF THE AUDIT TO THE USCG PRIOR TO DEPARTURE FROM PORT. 74SOLAS(2014) IX/3.1 ISM CODE A/12.1 17ac

OIL FILTERING EQUIPMENT SHALL BE OF A DESIGN APPROVED BY THE ADMINISTRATION AND SHALL BE SUCH AS WILL ENSURE THAT ANY OILY MIXTURE DISCHARGED INTO THE SEA AFTER PASSING THROUGH THE SYSTEM HAS AN OIL CONTENT NOT EXCEEDING 15PPM. UPON CONDUCTING AN OPERATIONAL TEST OF THE OILY WATER SEPARATOR IN ACCORDANCE WITH PROCEDURES OUTLINED IN MARINE SAFETY MANUAL VOL.II, THE EFFLUENT BEING PROCESSED WOULD NOT GO BELOW 15PPM ON THE OIL CONTENT METER. THE SYSTEM WAS RAN BY THE CREW INTERMITTENTLY FOR OVER AN HOUR, AND AT NO TIME, WHILE THE SYSTEM SAMPLED EFFLUENT COULD THE SYSTEM PRODUCE AN EFFLUENT BELOW 15PPM. MARPOL I/14.6 30abc

THIS INSPECTION IS NOT COMPLETE AND WILL CONTINUE. THE VESSEL SHALL NOT ATTEMPT TO CLEAN, TAMPER, OPEN, OPERATE, OR CHANGE THE CONDITION OF THE VESSEL'S OWS, OCM, BILGE HOLDING TANKS, OR ASSOCIATED PIPINGS/FLANGES WITHOUT APPROVAL BY THE U.S. COAST GUARD.