SANMAR SAROD

The company should ensure that the environmental protection policy is implemented and maintained at all levels of the organization, both ship-based and shore-based Deficiencies #1, #2, and #5 provide objective evidence that the company’s environmental-protection policy is not currently implemented and maintained onboard the vessel. The following items were identified as examples of the Company’s environmental-protection policy in Prime Tanker Management Inc. Environmental Manual not being implemented and maintained: The standing orders for the weekly OWS test is not posted near the OWS (page 4/14). The Sample line from the OWS discharge connection to the sample/flush line control valve is not painted a bright color to distinguish it from the other tubing and piping in the area (page 9/14). No additional connection or tags of any kind may be added to the line (page 9/14). As detailed deficiency #5, a valve is installed on the line that is not on the ship’s drawing (page 9/14). On all manned ships, the OCM requires a sample flow for a normal operation and control. Any OCM that allows the OWS to function normally without sample flow is prohibited. As detailed in deficiency #1, the OWS will function normally when the valve on the sample line is closed (page 4/14). All hoses in the Engine Room should be recorded in the monthly form “Hose Inspection List” where their tags and use shall be recorded (page 11/14) Form SF/TEC/145 has 6 hoses listed. PSCOs found multiple hoses not listed and without identifying tags. The above is not to be considered all-inclusive. An additional external ISM audit, with a focus on compliance with MARPOL Annex I and the company’s environmental manual, is requested. 74SOLAS(14)IX/3.1 REF ISM 2.2 17AC (extended to 50ac)

Unless operating exclusively on voyages between ports or places within a COTP (single), the master, owner, operator, agent or person in charge of a vessel subject to this subpart and section must submit a ballast water report to the NBIC by electronic ballast water report format. Vessel did not submit ballast water reports to the NBIC for the last (3) U.S. ports of call including St Croix, U.S. Virgin Islands from 27FEB2019 – 05MAR2019, Port Everglades, Florida from 06MAR2019 – 12MAR2019, and Houston, Texas 05APR2019. 33 CFR 151.2060(b) 17C

The company should ensure that obsolete documents are promptly removed (ISM 11.2.3) The master, owner, operator, agent or person in charge of any vessel equipped with ballast tanks that operates in the waters of the United States must maintain a ballast water management plan that has been developed specifically for the vessel and allow those responsible for the plan implementation to understand and follow the vessels BWM strategy and comply with the requirements of this subpart. Vessel’s ballast water management plan still has information from previous technical operator [name withheld] Ballast water management plan only references 1999 version of U.S. ballast water regulations. The regulations were updated in 2013. 74SOLAS(14)IX/3.1 REF ISM 11.2.3 and 33 CFR 151.2050(g) 50c

Any ship of 10,000 gross tonnage and above shall be fitted with oil filtering equipment complying with paragraph 7 of this regulation [14.2]. Oil filtering equipment referred to in paragraph 2 of this regulation shall comply with paragraph 6 of this regulation [14.7]. Oil filtering equipment 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 15 ppm. [14.6] PSCOs requested crew to demonstrate an operational test of the oily water separator (OWS). The second engineer ran the OWS in tank-to-tank mode for approximately 5 minutes. The Oil Content Meter (OCM) read 2 to 3 ppm for the entire time. PSCOs observed bilge water from bilge tank flowing through visual observation port on the test recirculation pipe on bilge overboard line with the 3-way valve set to overboard. Upon closer visual inspection, PSCOs identified that there was no water flow to the OCM. PSCOs identified that the valve on the sample line to the OCM from the OWS discharge was closed, resulting in no flow to the OCM. When the crew opened the valve, OCM alarmed and the 3-way valve closed. After more than 6 hours, crew was still unable to demonstrate proper operation of OWS during the tank-to-tank operational test; it remained in an alarm condition at all times. In total, the observed conditions provide objective evidence that the OWS was operated in a manner that did not ensure that any oily mixture discharged into the sea after passing through the system has an oil content of less than or equal to 15 ppm. MARPOL I/14 30ABC

The Oil Record Book (ORB) shall be in the form specified in Appendix III to this Annex [17.1]. The ORB Part 1 shall be completed on each occasion, whenever any of the following machinery space operations take place on the ship: collection and disposal of oil residues (sludge); discharge overboard or disposal otherwise of bilge water [17.2]. Each operation described in paragraph 2 of this regulation shall be fully recorded without delay in the ORB Part I, so that all entries in the book appropriate to that operation are completed [17.4]. The ORB Part I presented to the PSCOs was factually inaccurate and does not correspond to actual tank levels found onboard during examination and the ship's daily sounding reports for the past month. During interview with PSCOs, Chief Engineer stated that he believes the daily sounding logs are accurate. For example, soundings taken in presence of PSCOs indicated the following tank volumes: waste oil tank 15.7 cubic meters, No. 2 waste oil settling tank 0.9 cubic meters, waste oil service tank 1.1 cubic meters, bilge tank 22.5 cubic meters. According to entries in the ORB Part 1, on 31MAR2019, the tank volumes were as follows: waste oil tank 13.9 cubic meters No. 2 waste oil settling tank 0.0 cubic meters, waste oil service tank 0.12 cubic meters, bilge tank 19.0 cubic meters. There are no more recent entries in the ORB Part 1. Furthermore, the tank volumes recorded in the ORB Part 1 do not correspond with the daily sounding logs completed by the Fourth Engineer. For example, on 31MAR2019, the entries in the ORB Part 1 list the current quantity of the waste oil settling tank No. 2 and bilge water tank as 0.0 cubic meters and 19.0 cubic meters, respectively. The quantities listed in the 31MAR2019 sounding logs are 1.5 cubic meters and 22.4 cubic meters, respectively. There are no entries in the ORB Part 1 on 31MAR2019 or adjacent days showing transfers to or from these tanks. As a second example, on 03Mar2019, the entries in the ORB Part 1 list the current quantity of the waste oil tank and bilge water tank as 8.2 cubic meters and 5.0 cubic meters, respectively. The quantity listed in the 03MAR2019 sounding logs are 14.0 cubic meters and 15.1 cubic meters, respectively. MARPOL I/17 30abc

The purpose of this regulation is to prevent the ignition of combustible materials or flammable liquids [4.1]. In a ship in which oil fuel is used, the arrangements for the storage, distribution, and utilization of the oil fuel shall be such as to ensure the safety of the ship and persons on board [4.2.2]. PSCOs observed pooled and standing fuel oil in multiple locations in engine room, most notably on top of the Heavy Fuel Oil service tank, waste oil settling tanks No. 1 and No. 2, and waste oil service tank. 74SOLAS(14) II-2/4 30abc

The machinery, associated piping systems and fittings shall be of a design and construction adequate for the service for which they are intended. PSCOs found a fire hose in the engine room connected to the cooling system for the ship's service air compressor and the main fire pump was running continuously. Ship's crew stated that additional cooling via the fire hose and the fire pump was required when running both air compressors. Crew also stated that the fire pump was running continuously due to fact that the lubrication oil seawater cooling pump was inoperable. 74SOLAS(04) II-1/26 17ac

In considering the design of oil filtering equipment, the Administration shall have regard to the specification recommended by the Organization [14.7]. Resolution MEPC.107(49), section 6.2 states that the arrangement on board for the extraction of samples from the 15 ppm Bilge Separator discharge line to the 15 ppm Bilge Alarm should give a truly representative sample of the effluent with the adequate pressure and flow. After any survey of the ship under paragraph 1 of the regulation has been completed, no change shall be made in the structure, equipment, systems, fittings, arrangements, or material covered by the survey without the Satisfaction of the Administration [6.4.2]. The vessel is fitted with a MEPC.107(49) OWS and OCM per the IOPP Form B. Bilge piping diagram, drawing No. M694 shows no valves in OWS overboard sample line to OCM. As detailed in deficiency No. 1, the actual onboard arrangement has a valve on the sample line from the OWS discharge to the OCM, the closing of which causes no pressure or flow to the OCM and allows the 3-way valve to remain in the open/overboard position (less than or equal to 15ppm) even when there is no representative sample flowing to the OCM. MARPOL I/6.4.2 and 14.7 17ac

The Safety Management System should ensure compliance with mandatory rules and regulations. Vessel requested and received a dispensation letter from the flag state for an inoperable incinerator on 22FEB2019. One of the requirements in the flag state dispensation letter is that the "Oil Record Book and other appropriate logs shall document the condition of the incinerator." There are no entries in the ORB Part 1 documenting that the incinerator was inoperative. 74 SOLAS (14) IX/3.1 REF ISM 1.2.3.2 17bc

The IOPP Form B shall be drawn up in the form corresponding to the model given in Appendix II of this Annex [9]. After any survey of the ship has been completed, no change shall be made in the structure, equipment, systems, fittings, arrangements or material covered by the survey without the satisfaction of the Administration [6.4.2]. Per Appendix II, sections 3.1 and 3.3 of the IOPP Form B shall list the oil residue (sludge) tanks for retention of oil residues (sludge) and holding tanks for the retention on board of oily bilge water, respectively. Vessel has a primary bilge tank (2.0 cubic meter capacity) that is not listed on block 3.1 or 3.3 of the IOPP Form B. MARPOL I/6.4.2 and 9 50ac

1400 - The machinery, boilers and other pressure vessels, associated piping systems and fittings shall be of a 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 on board, due regard being paid to... other hazards. The vessel expreienced an equipment failure while transiting the navigable waters of the United States which adversely affected its maneuverability and posed a hazard to vessels and infrasucture along the Houston Ship Channel. SOLAS(2004 CONS.) II-I/26 - 60ac

On board training in the use of ships lifesaving appliances and ships fire extinguishing appliances shall be given to a crew member within two weeks after joining the ship. During fire drill one of the SCBA firefighing ensembles was not connected and firmly secured to firefighter. Additionally, environmental factors with the diretion of wind and space for fire drill. The medical team and chief mate were in hazardous zone. Lastly, during abandon ship drill muster testing crew knowledge, they failed to answer basic fire safety designations for fire classes. 74 SOLAS (14) III/19.4.1 15c