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1 SEPTEMBER 2015 ISSUE 03 IN THIS ISSUE INTERNAL AREA COMPANY VESSELS INCIDENT ANALYSIS SHARING ACROSS THE FLEET MARINE SEP AREA Soft Bottom Touch - Port Arthur Ship Channel TX (U.S.A) Contact during STS with daughter vessel off shore - Lomè Spark and smoke Emission during discharging operation while at berthed - Trieste (ITALY) at berth SIOT # 1 Near collision and attendance on board - IMTT Bayonne, New Jersey, Pier A EDITOR: FINAVAL S.P.A PRINTED BY: Self-Published PRINTED ON : 02/09/2015 EDITORIAL DIRECTOR: Gabriele Arveda REGISTERED OFFICE: viale Regina Margherita, 42 - 00198 (Rome) Registered with Court of Rome N. 7/2011 on 20/01/2011

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S E P T E M B E R 2 0 1 5 I S S U E 0 3

IN TH IS I S SUE

INTERNAL AREA

COMPANY VESSELS

INCIDENT ANALYSIS

SHARING ACROSS THE

FLEET

MARINE SEP AREA

• Soft Bottom Touch - Port Arthur Ship Channel TX (U.S.A)

• Contact during STS with daughter vessel off shore - Lomè

• Spark and smoke Emission during discharging operation

while at berthed - Trieste (ITALY) at berth SIOT # 1

• Near collision and attendance on board - IMTT Bayonne,

New Jersey, Pier A

EDITOR: FINAVAL S.P.A PRINTED BY: Self-Published PRINTED ON : 02/09/2015

EDITORIAL DIRECTOR: Gabriele Arveda REGISTERED OFFICE: viale Regina Margherita, 42 - 00198 (Rome)

Registered with Court of Rome N. 7/2011 on 20/01/2011

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SOFT BOTTOM TOUCH

INDEX 1. SYNOPSIS

2. Notification

3. Attached documents

4. Description of events

5. Summary of findings

6. Particular Circumstances

7. Abstract of Company’s policy

8. Language

9. Health and fatigue

10. Security procedures

11. Deviation from rules and root causes analysis

12. Immediate action and corrective actions

13. Lessons learned / preventive measures

14. Summary

1.SYNOPSIS:

Incident Details Date Occurred: 20th July 2015 Time Occurred: 18:36LT (-5 GMT)

Incident location: Port Arthur Ship Channel – TX (USA) Injuries, fatalities: No injuries, No fatalities, No Pollution Persons on board: 22 Crew members

2.Notification:

Following Persons: Company DPA,

• Company DPA

• Q.I. - USCG

• Charterers

• Local Agent

• H&M and PANDI

• Flag State AUTHORITY

Soft Bottom Touch - Port Arthur Ship Channel TX (U.S.A.)

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3.Attached documents:

• Crew Matrix at the time of Incident

• Passage Plan

• UKC and Squat calculation

• Bridge and Engine Supporting Documents, including check list, Log Book and Bridge Navigational equipment

printers record and E/R list of alarm.

• Vessel stability condition printed out from class approved CBP BEFORE AND AFTER GROUNDING

• RINa Class Inspection Report

• DONJON SMIT diver’s Company inspection report

• Rolls Royce Rudder maker’s technician inspection report

• VDR’s maker’s authorised technician attendance report

• Autopilot maker’s technician inspection report

• COTP Section Port Arthur post incident declaration of Realising of Vessel

• USCG PSC & COC report after incident reports with no observation and no outstanding reported

4.DESCRIPTION OF EVENTS:

On 20th July, 2015, during the transit from Sabine Pilot to Beaumont Enterprise Terminal with Pilot on board, Vessel

steering course 292° and speed 7.8 kts, Pilot order 10° to Starboard the rudder, but the steering fail.

Immediately Mater informed Chief Engineer, which was attending in ECR, to standby in Emergency Steering Gear station.

In the meantime Master changed the steering mode from “follow up to non-follow up” and stopped the Main Engine.

Master attempt with no succeed to steer with “NFU”, the Pilot ordered to drop Starboard Anchor.

At that time Vessel aground in soft mud patch in Position 29°46.11 N – 093°55’.57 W, immediately Pilot ordered to drop

Port Anchor.

Master immediately informed DPA and all Notification have been carried out as required by OPA 90 TVRP, SMPEP

PLAN AND COMPANY’S EEMERGENCY PROCEDURES.

5.SUMMARY OF FINDINGS

INVESTIGATION TEAM:

On board team :

- Master (

- Ch. Engineer

- C/O

- 2/O

- 2/O

- Technical Manager (A.MARESCA)

- Q.I. ECM Rappresentative (J.L.MELLEN)

Operational Office team:

- DPA/Fleet Manager (Capt. F.SABIA)

- Marine Manager (Capt. P.PANDOLFI)

- Operations Manager (Mrs. C.ORTOLANO)

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6.PARTICULAR CIRCUMSTANCES

CREWPARTICULARS AND EXPERIENCE The vessel is a new building delivered July 2008 from the SPP Shipyard in Korea. The vessel trade unmanned

for which in accordance with the Minimum Safe Manning certificate she should be manned by a minimum

complement of 8 officers (including Master and Chief Engineer) and 8 ratings, however, as per Company

policy we keep on board at all-time a minimum of 8 officers + 1 Electrical officer , 11 ratings and 2 cadets. At

the time of the incident in command there was a loyalty Master with 15.1 years in the Company and 2.7 years

in rank.

Capt. joined Finaval on 03rd August 2000 as Deck Cadet, he performed the first assignment as a Master on

board our good vessel on 09 th March 2013, having rotated always on board our good vessel and sister Vessel,

having reach 2.7 years in rank.

Chief Mate is already paid two contracts as Chief Officer on our good vessel and on board sister vessel having

seniority of 2.5 years in rank.

Chief Engineer joint first time Finaval on 09 th December 2005 as Chief Engineer, and is very experienced in

ranks having 9.2 years.

He has frequently rotated on board of our good vessel and Sister Vessel.

All Indian crew are regularly rotated on this and sister Vessel.

All Deck & Engine officers were fully certified & properly trained for the navigation and cargo control room

watch. Officer’s certifications & training were over & above the STCW requirements, which are considered as

minimum by the company.

Furthermore the value added in-house courses has been also conducted by the Company from time to time as

per the Company training policy.

7.ABSTRACT OF COMPANY’S POLICY

=======================quote=============================

PURPOSE AND SCOPE This section is a comprehensive document to respond to any emergency that may involve any Owned vessels.

It is designated to ensure that both shore and shipboard contingency planning are well integrated and proper and well defined actions are taken during an emergency; however, regardless of its nature and scope it does not replace any of the following processes:

• Vessel’s OPA 90 VRP (when applicable);

• Vessel’s Emergency plans as required by local States (as applicable);

• Vessel’s SOPE Plan or SMPEP including Emergency Response Service (Yearly Basis DPA has to perform check of SOPEP/SMPEP manual and response equipment countersign FCM.59.03 DPA Annual check of SOPEP / SMPEP plan and related on-board response equipment)

• Ship Security Plan Codes like SOLAS, MARPOL, etc.

This section gives guidance on how to deal with an emergency in order to:

• Establish personnel responsibility /authority in emergency situations.

• Establish efficient flow of emergency communication between all involved parties.

• Inform owners, involved communities, charterers, media, Port Authorities, Coast Guard, etc. Train the personnel in order to timely respond to an emergency.

In the aim of:

• Protecting the life of the crew on board.

• Protecting the ship and her cargo. Avoid any possible damage to the environment.

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2.0 RESPONSIBILITIES The Master has the overriding authority and responsibility to take whatever decisions he deems necessary in order to save the human life and protect the environment. Economics and/or other external influences should not interfere with his decision in this regard. 3.0 STRUCTURE OF CRISIS MANAGEMENT 3.1 PURPOSE As soon as notification of a contingency situation on board a vessel is received in the company’s office at the dedicated emergency number, the DPA or the Incident Coordinator if the DPA is not available, will inform the Crisis Management Team and in due course also the Owners Board. Whether available any member of the Crisis Management Team shall meet in the Emergency Room.

If an emergency persists for a long period of time, proper procedures should be implemented to ensure that rotation of the responsible personnel is possible in order to make sure that everybody takes sufficient rest and in the mean time support to the vessel is continued.

The Crisis Management structure may be expanded or contracted based on the size and complexity of the emergency. The crisis management team should be kept as small as possible, however sufficient support to the vessel should be provided at all times. More than one position may be undertaken by a single person. Crisis management team should include at least: DPA – Technical Manager - Crew Manager, and Operation manager & Insurance Manager, Marine manager, other marine and technical superintendents as the case may require. 3.2 CRISIS MANAGEMENT TEAM (CMT) The crisis management team require attendance of various members (at least three of them) from the Company’s office staff and is coordinated by the DPA whether available or by the Incident Coordinator. It shall respond to any contingency situation by giving all necessary assistance and support.

The CMT includes the (DPA), the Marine SEP manager, the Technical Manager, the Crew manager the Operation manager, the Insurance manager, the EDP manager and Technical and Marine superintendents. The Company Security Officer (CSO) can also participate in the event of security-related incidents, as well as the CEO.

Media Coordinator shall be appointed time to time by the DPA or by the Incident Coordinator. 3.2.1 Incident Coordinator During normal working hours whether available the DPA is the Incident Coordinator. Whether an incident happens after office hours and for whatever reason the DPA is not reachable on the mobile, the first person who will respond to the emergency call will become the Incident Coordinator. The DPA will in any case be informed about the incident as soon as possible. 3.2.2. Means of contact during and after Normal Office Hours The Company has arranged an emergency contact Number with a dedicated shore line which is ringing directly in the Emergency Room and alarm repeaters will ring also in the following departments/area: Reception area, Marine SEP, Technical, Operation, Crewing, CEO. Whether within 30 seconds no-one will pick up the handset in the Emergency room, the emergency call will be automatically diverted in turn to the following mobile numbers:

DPA DPA Deputy, DPA Deputy, Technical Manager , Alternate network mobile phone number.

If no one will pick up the phone, than, the calling cycle will be repeated again in the same consecutive way until someone amongst the 5 contacts as listed above will finally be reached. The alternate network mobile phone number is usually carried by the DPA. When DPA is not available, the alternate network mobile phone number will be carried by an available person amongst Deputies of DPA – Technical manager.

THE EMERGENCY PHONE NUMBER IS + 39 0522 688659

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Emergency calls have to be addressed only and exclusively to the above number. Phone calls to any different number will not be diverted in case of missed answer. This process includes also direct calls to the DPA- Deputies DPA-Technical manager and Alternate network mobile number. The Company Emergency Contact number shall be kept readily available in the GMDSS room and in the Master’s Office. All the persons being part of the Emergency Response Team have to carry a Pocket Book. The pocket Book should contain all the Emergency contact Numbers which have to include and not limited to: • The Company Emergency Contact Number + 39 0522 688659 • All vessels contact numbers and E-mail • Company Board Contact Numbers including CEO • All the A.O.H. contact numbers of the Emergency Response Team • Flag State authorities • Class contact numbers • Technical Advisor • Qualified Individual • Salvage Companies • P & I Contact Numbers • Hull and Machineries underwriters contact numbers • Media training Coordinator contact number

Periodically, it will be care of the DPA to check the respond of the above contact numbers over the weekend and AOH in order to make sure that the numbers are correct and there is always attendance.

Furthermore in the pocket booklet there must be guidance on how to deal with the Master reporting at the initial stage of a contingency situation. The reporting is an essential part of a contingency scenario in order to make sure that only essential and correct information/data are being reported to third parties. 3.3 VESSEL EMERGENCY RESPONSE TEAM The Vessel’s Emergency organization include all members of the ship’s who will be directly involved in responding to a general emergency. It may not include supernumeraries. The Master is in charge of the Vessel Emergency Response Team (VERT). He commands an Emergency Team that includes a number of selected officers and ratings. When the emergency signal or the fire alarms sound, the Emergency Team will muster without delay at the designated emergency station. Visitors and supernumeraries will muster as instructed by the Master.

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3.3.1 CREW TRAINING The ship’s entire staff has to be involved in the contingency operations at different levels. Therefore they are continuously trained to respond to various situations in the most professional way. Details of their training are provided under Section 11 of this manual.

Supernumeraries shall not participate in crisis management operations. They shall muster as instructed at the time of boarding. 3.4 COMPANY’S EMERGENCY ROOM To optimize the response in an emergency, the emergency room is fitted with:

• Means of communication (Telephones + DEDICATE EMERGENCY TELEPHONE, Fax, E-mail and Internet wireless );

• Geographic MAP • TV receiver WITH ACCESS TO International network. • Office equipment (white board, message sorting box, etc.) • Nautical charts and plotting and correction tools three marine type clocks: Rome time –

Scenario Time – GMT Time • Drawings wall support • Ship’s specific emergency plans and documentations, as required, will be brought by the

Technical Manager/Superintendent meanwhile the SOPEP / SMPEP and or VRP will be brought by the Marine SEP Manager or Superintendent.

All documentation and equipment shall be reviewed on a yearly basis during the management review and the date shall be recorded accordingly. Accuracy of the plans and relevance of mentioned information are checked in cooperation with fleet Masters.

In order to make sure that an incoming emergency call can be attended without delay, a remote dedicated visible and audible alarm which is being activated as soon as the emergency phone starts ringing, has been arranged in the following departments: Marine SEP-Technical-Operation-Crew as well as at the switch board position. 4.0 INDIVIDUAL ROLES AND RESPONSIBILITIES IN CRISIS MANAGEMENT Ship Master

The Master is responsible for:

• Taking immediate measures to protect the crew. • Mobilizing the onboard emergency team making sure that any possible action which can mitigate the

potential damage the contingency situation may be cause of, is being taken. • Contacting the Emergency Number • Informing the relevant Coastal State authority and third parties. • In case of un-expected contact from the media the Master shall report following standard message:

“In order to better support the report of information the Company has reached an agreement with Professional Media Coordinator Organization for the release of any information related to the contingency situation, therefore we would appreciate if you refrain to contact the vessel in order to leave the contact lines free for emergency purposes. This is the phone Number that you should fill free to contact in order to have the latest updates. Furthermore, the Company in its website www.finaval.com which is accessible to everybody in the Multimedia news- Emergency has arranged a dedicated area where is kept updated the status of the situation. Thanks for your kind understanding and support.” Above area is being activated only in an emergency, it is the IC responsibility to make sure that the area is activated at the earliest possible stage in case of any contingency situation,.

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Incident Coordinator – IC

The IC is responsible for:

• If available the DPA will be the Incident Coordinator, otherwise the incident Co-ordinator responsibilities will be covered by who first receive the diverted emergency phone call. It will be therefore responsibility of the established Incident Coordinator to bring forward the management of the emergency.

• Assessing the situation and gathering the Crisis Management Team as needed. • Determining if a Company representative is to be sent on board and appointing a Media Coordinator. • Co-ordinating various activities carried out ashore. • Co-ordinating communications during emergency. • Notifying the CEO and Ship Owners. • Co-ordinating any necessary meeting for updates and event strategies. • Keep contact with the Master throughout the event, giving the best possible advice and support,. • Co-ordinating with the Master the contact with various parties • Preparing internal statements; • Appointing the person(s) who will collect in and out communication (fax, e-mail). • Keep the CEO as well as Board of Directors advised of all activities. If the event involves media

interest, the IC shall update the Media Coordinator throughout the event. • Review with the CEO and approve any generated media statements prior to release. • Once the emergency is ended, the IC will gather all the produced documentation and prepare a written

report. This report shall be submitted to the CEO for approval and will than distributed to the external agencies or authority as required.

Marine SEP Manager

The Marine SEP Manager is responsible for:

• Whether the Marine SEP manager and the DPA are not the same person, the Marine SEP manager will provide shore based support to the DPA as the scenario may require

• Furthermore he will:

• Prepare the sea maps/nautical charts which are available in the emergency room as the area/

scenario may require. • Coordinating and maintaining incident documentation, including but not limited to: communication logs,

incident reports, progressing status reports and set the Scenario watch.

Technical Manager

The Technical Manager is responsible for:

• Ensuring that all the technical documentation related to that particular vessel and scenario will be available in the emergency room in the shortest possible period of time, the technical documentation include and is not limited to technical manuals and drawings.

• For this task he will be supported by the Technical Superintendent/s:

• Informing and liaising with classification society / emergency response services. • Appointing experts and consultants on technical matters. • Advising the IC of any recent vessel deficiencies. • Coordinating the efforts of the Superintendent and reporting to the IC. • Plan, arrange, negotiate and appoint shipyards for any needed repairs. • Assist the vessel with any action necessary to minimise the consequences of the event. • Provide copies of the vessel’s technical documentation as required by third parties.

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Crew Manager

• The Crew Manager is requested to participate in Crisis management by co-ordinating efforts to notify the family / next of kin on the condition of each crew member and by providing a list of all onboard crew members to the IC, along with their condition.

• In case of extra European crew members, the Crew Manager will be supported in this task by the appointed person in the Recruiting Agency.

Insurance Manager • Managing any Technical/Crew claims with the P&I Club and / or Hull & Machinery Underwriters.

Media Response Coordinator

The DPA or in his absence the IC is also the Media Response Coordinator (MRC). Even thought the company has signed agreement with a Professional Media Coordinator Organization (PMCO) any release for information outside the Company must be authorized by the MRC:

• The MRC must agree with the CEO any limits on information to be released to the media. • Developing material for use in media briefings. • Keep the PMCO updated to inform media and conducting media briefings.

Professional media Coordinator Organization

A Professional Media Coordinator Organization has been appointed by the company in order to coordinate the release of information in case of an emergency. Information released to the media has to be in any case authorized by the CEO. Release of information

Apart from the release of information via the Professional Media Coordinator Organization, the company has provide a dedicated area in the wed site www.finaval.com at multimedia news-emergency, where an update of the progressing of the contingency status of the scenario is kept updated. The web site is accessible to all parties and can be easily visited by any interested party. It is the duty of the EDP manager or his alternate to keep this area of the web site updated. Data uploaded into the Emergency area of the website has to be authorized by the CEO. EDP manager

The EDP manager or in his absence his alternate must be available and attend at all time during an emergency in order to make sure that all the electronic device available in the Emergency Room are perfectly working at all time. CEO In case of major event, the CEO will take care of the Company Interests and reputation, and in any case whether reasonable he will provide the best possible support to the Crisis Management Team in any area, depending on circumstances. Company Security Officer

The CSO is responsible for co-ordinating the ship security officer in any action related to security. Furthermore, the CSO shall liaise with competent authorities in this respect. Secretary and Switchboard operators

The Marine Sep Assistant will attend the emergency room and she will act as Secretary/Switch board operator in order to record all the communications in/out and keeping truck as customary.

She will also be responsible to follow the IC instructions and to arrange Accommodation, victualling and transportation as required.

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4.1 EMERGENCY KEY STAFF AND ALTERNATE

4.2 OFFICE ORGANIZATION DURING EMERGENCY

4.2.1 Staff Turnover

Sufficient staff shall always be available to deal with an emergency. For this purpose, at least one person from the Technical Department, one person from the Marine SEP department and one person from the Crew department shall be available at all times. When dealing with an emergency, the Incident Coordinator shall arrange periods of rest by alternate people as required. The typical organization to be followed during an emergency is as follows:

1ST 8-hours period MAIN TEAM: Incident Coordinator, Technical Manager, Marine manager/Supt, Crew manager Tech Superintend., Secretary. .

2nd 8-hours period SUPPORTING TEAM: basis on above Table “Emergency Key Staff and Alternate”.

4.2.2 Travel Arrangements In case of emergency the following travel agents will provide flight tickets and other required world wide travel arrangements 24 hrs a day, 365 days a year: GRIFFIN MARINE TEL +44 20 78149966 FAX +44 207 8149979 e-mail: [email protected]

5.0 CONTINGENCY RESPONSE COMMUNICATIONS 5.1 EMERGENCY ALARM SIGNALS Personnel on board will be warned by appropriate signals in the event of an emergency. The signals for emergency situations are the following:

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The “abandon ship” order will be given in case of real need to abandon. (See Muster List) The Master is the only person who has the authority and the responsibility to give the order to abandon the ship. This order is given in clear wording directly by the Master. 5.1.1 MUSTER LIST A copy of Muster list must be always available for quick reference and should be exposed at least one for each vessel deck starting from upper deck to navigation bridge. In E/R a copy must be exposed in Engine Control Room. Muster list at every crew change and any time when required must be updated, moreover an entry with last update date must be posted on the same in view to give evidence to last updating and ensuring that all muster list on board have been updated with last changes.

5.2 ACTIONS TO REGAIN CONTROL OF THE SITUATION The circumstances of a real emergency will differ from a drill; however preparedness planning ensures that required actions in case of a real emergency can be taken quickly and required decisions can be taken in an orderly manner, for this reason any drill has to be simulated as close as possible to a real scenario.

In case of an emergency, the Master must: • Assess the situation identifying risk affecting the crew, the ship and the environment. • Decide what action to be taken i immediately. • Plan following actions as soon as the situation may allow to do it • Decide if outside assistance is required. • Inform shore management and shore authorities.

The Company provides emergency procedures and instructions as a support to the Master on how to deal in an emergency, however the Master has the overriding authority and responsibility to take whatever decisions he deems necessary for the safety of the personnel, the ship, and for the protection of the environment.

Financial/Economical interests and/or other pressures on the Master should not at any time interfere with the decisions he intends to take regarding personnel safety and pollution prevention.

The Company has identified potential emergency and crisis scenarios which may affect the safety of the personnel and that of the ship & cargo, or cause damage to the environment. For each identified emergency scenario the Company has established procedures aimed to guide/support the master in case of need.

Identified emergency scenarios: Pollution or risk of pollution.* Abandoning the ship. Fire and Explosion.* Man overboard. Collision.* Grounding and stranding.* Accidental flooding. Breaking away from the jetty. Vessel disabled (engine failure, steering gear failure). Gyrocompass failure. Black-out. Medical Emergency Release of toxic cargo.* Release of Toxic/Hazardous Vapour Jettisoning of cargo. Cargo hoses burst or pipe leaking.* Casualty and enclosed spaces rescue. Search and rescue operations. Salvage.* Tank failure or leakage.* Tank overflow.* Excessive list.*

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*The scenarios printed in bold are also included in the SOPEP/SMPEP and VRP manuals. Various scenarios include mitigating measures which aim is to guide the personnel on board when dealing with an emergency, however, in case of real scenario, whenever decision has to be taken on how to proceed, consideration has to be given to any particular circumstances. 5.2.1 Emergency Drill The Company has developed an annual drill schedule for both: the vessels as well as the office. Deviation from the schedule, if any, has to be analysed by the DPA / Crisis Management Team, and, root causes with corrective actions have to be identified in order to make sure that exercise/drill are carried out in due course. Lesson learnt from each exercise and corrective actions to the any non-conformity/finding must be identified. Evidence of the effectiveness and follow up to the corrective actions has to be recorded and maintained and shared with the entire fleet. The follow up must follow the required process till the closure of the entire corrective cycle. As far as practicable in the shore premises all the members of the emergency Team will participate to the drill/exercise, furthermore, the Company will make sure that a minimum number of senior sailing personnel on leave will participate to the shore drill too. All documents and evidences regarding ship/shore annual drill are available In Common Portal at the following path: Ship Portal >> Application >> Fleet Documents >> Fleet Distribution >> Marine Sep >> Documentation >> 9-Ship / Shore Annual Drill 5.3 COMMUNICATION 5.3.1 Communication on board On board communications should be maintained by using portable radio sets, this will allow the personnel to remain in contact even when located in remote areas of the vessel where there are no fixed communication facilities. 5.3.2 Requesting assistance from third parties In case of distress the master may require assistance to third parties Request of assistance has to be done with the use of the international recognised alerting system

• A distress signal indicates that a vessel is in imminent danger and requests immediate assistance.

• An urgency call indicates that the calling vessel has a very urgent message to transmit • A safety call indicates that the vessel is going to send an important navigational or

meteorological warning. Only the master is authorised or may authorise the release of a distress signal. A distress signal has the priority over all other transmissions in the following order:

• Distress - Signal is MAYDAY MAYDAY MAYDAY • Urgency - Signal is PANPAN PANPAN PANPAN • Safety - Signal is SECURITÉ SECURITÉ SECURITÉ.

The Master and/or the officer responsible for the use of the GMDSS station shall send messages according to the procedures written in the Radio Regulation. A copy of the manual is on board all company managed vessels. 5.3.3 Notifying the Authorities In case of emergency, the Master should immediately inform the nearest coast government agency or port authority. SOPEP/ SMPEP and the VRP contain details of port and flag state authorities to be contacted in case of emergency. The Master should send a message using the format described in these plans that is in compliance with the IMO requirements. 5.3.4 Notification to technical advisor The company has signed an agreement with technical advisors. In case of need the Master will be in direct contact with them for whatever technical assistance he does requires, however both side will keep always the owners advise during various exchange of communications. 5.3.5 Notifying Owners, Charterer and Cargo Owners In order to keep the cargo owner always informed and updated, the Master of a vessel shall immediately contact the IC/DPA which is included in the Emergency Contact List provided in Annex Sec.59.

Finaval in the role of Owners /manager shall have the entire responsibility for managing all the process related to any casualty involving the owned vessels.

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The communication flow is the following:

• Master notifies Owners, Charterers and Cargo owners • Charterers notify Cargo Owners • Owners handles the Emergency and informs all interested parties

The Master shall address the initial notification to the Owner and in copy to the Ship Owner. The notification should comply with VRP / SOPEP – SMPEP and should contain the following information:

• Name of the vessel. • Date and time of the report. • Date and time of the event. • Geographical position of the vessel. • Course. • Speed. • Weather conditions. • The essential details of the event. • The degree of danger to personnel, ship and environment. • Kind of assistance required. • The parties already notified by the Master.

• Company Incident Co-ordinator name. • The parties the Master requires the incident co-ordinator to contact. • Miscellaneous information.

• The time of the next calls to the company and the phone number to be used. • Communication system to be used (E.G. Coastal station, Satellite system, GSM Phone).

All information to/from the vessels is made through the Incident co-ordinator.

All messages must be prefixed by the words “Contingency Priority” and can be sent by voice, but written confirmation shall follow.

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5.3.6 Media In order to better support and coordinate the communication with the media, the company will appoint a media coordinator each and every time a case may require. The media coordinator is normally the DPA, however circumstances may require the appointment of a different person. Press media consultants (MTI Network) may be called to assist the media coordinator and the company in dealing with the media.

No one except the Media Coordinator is authorised to release information to the Media, not even the Master who will in any case be kept informed.

Suitable training on how to deal with the media shall be periodically arranged by the Company. As all of you are well aware, world of media is in continuous improving / evolution, so is very important to know how answer to any question submitted from reporters for your reputation and company reputation / image Masters and Bridge Teams should be aware that the media may try to telephone their vessel to obtain information during, or following, an incident or accident. This is happening with greater frequency during casualty situations. We do not recommend that any information is provided via this channel. Instead the Master or Bridge Team should ensure that their Ship management Office is immediately notified of the media interest and the following message given to the caller: If you have been advised that the office has established a dedicated “Information Centre” to deal with the emergency and you have been given the number, then you should respond: Crew use of Social Media during an emergency All crew should be conscious of the wider implications when posting status updates, tweets and pictures etc. on social media platforms. Employment contracts often forbid the disclosure of sensitive commercial and company information but it can sometimes be unclear what is acceptable information to publish online during a major (or minor) casualty. Seafarers are always advised to respect the appropriate communication channels that their respective employers have in place for the release of information to the public, whether that be to the media or on social media platforms. Managing the release of information post-incident is vital if you want to coordinate with authorities and establish facts, protect the privacy or those involved and respect the rights of their families, consult the many stakeholders concerned, and address any reputational issues that may arise. When crew post information about an incident on social media it becomes public information and, even without malice, it can negatively impact the emergency response process. Take the Facebook post below as an example. It was posted by a crew member on a ship just minutes after an incident occurred.

The individual’s name and the vessel name have been removed for privacy reasons but it is evident that information which should have been released through official company channels was made public prematurely and unprofessionally. There have been many cases where social media posts have been highly publicised and used by journalists, often at great cost to reputation. We strongly urge seafarers to think carefully before making any information available on social media networks regarding an incident on board a vessel. If a seafarer is unsure whether a post is appropriate, they should be encouraged to check with the Master. Social media is a fabulous tool when used responsibly. Always remember that it is not just a conversation between “you and me”. It is a global, public resource and each post has the power to reach a much larger audience than you imagine.

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Additional supporting documents are available in Common Portal in the following path: Ship Portal >> Application >> Fleet Documents >> Fleet Distribution >> Marine Sep >> Documentation >> 10-MTI Social Media Guidelines 5.3.7 VDR Retrieval in case of casualty/abandon ship Recovery of the VDR information should be undertaken as soon as possible after an accident to best preserve the relevant evidence for the following investigation. The owner must include on its on-board standing orders guidance on how to proceed in this cases. In the case of abandonment of a vessel, masters should whether practicable, take the necessary steps to preserve the VDR information until it can be passed to the investigator. The Data retrieval has to be done as per the manufacturers instruction, which has to be posted near the VDR. 5.3.8 Missing Vessel This procedure applies 36 hours after an owned/managed vessel fails to send the daily position message.

The operation department is responsible to monitor that each vessel send the daily position message. Should a vessel fail to report her position/status during thirty-six consecutive hours, the Operations Manager will enforce this procedure.

Before activating these procedures the Operation manager will make sure that no any other department has received messages from the vessel, accordingly he will check with all the head of departments whether any message has been received from the vessel. In case the search does not give result, the Operations manager will inform the DPA.

The DPA and or the Marine SEP Manager will contact any coastal radio stations located in the area of the vessel’s last known position.

If all the above measures fail to locate the vessel, the ship shall than be considered missing and the DPA

shall alert the Emergency Team and will appoint an Incident Coordinator accordingly.

The DPA can appoint self as Incident coordinator.

The Incident Coordinator designates the team member who shall inform the vessel’s Flag State authority and the Coastal State agency(s) in the area of the vessel’s last known position. The Crisis Management Team will treat this scenario as any other contingency situation. Each member of the Crisis Management Team shall keep a record of the measures taken and notes the time. All records are to be given to the Incident Coordinator. 5.3.9 Review of Emergency Organization After the contingency has been overcome, any member of the Crisis Management Team may request that a debriefing be held to review the effectiveness of the organization, procedures, and instructions, with a view towards implementing improvements to the Crisis Management Plan and structure. 6.0 STANDARD INFORMATION

In every crisis situation and incident, it is important to have a standardized structure in place to capture the information in an accurate, concise format

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6.1 CRISIS MANAGEMENT TEAM ROSTER & EXTERNAL CONTACTS FORMS The CRISIS MANAGEMENT TEAM ROSTER and EXTERNAL CONTACTS forms were designed for internal use. These forms should be updated and kept available for any required use in the emergency room. . 7.0 EMERGENCY PREPAREDNESS AND INSTRUCTIONS A description of possible casualty events that could occur on board and the emergency response procedures to be considered are provided below. In order to properly deal with a real casualty scenario in case of need, the company has prepared a dedicated Check List (CCM.59) for each described scenario which should be used as a guidance when the drills are carried out. 7.5 STRANDING AND GROUNDING The general guidelines given in the above paragraph also apply if the vessel is aground or is stranding.

If the Officer of the Watch realises that the vessel is going to ground or strand, he will steer to minimise the effect of the grounding. In case of stranding or grounding the Officer of the Watch shall:

• Raise the general alarm and inform the Master. • Stop engines. • Switch on all lights during night time. • Alert the fire squad. • Assess if there are any casualty. • Fix the vessel position in the nautical chart. • Take sounding of all ship compartments immediately.

Apply relevant SOPEP/SMPEP/VRP procedures if there is risk of pollution. 7.8.2 Steering Gear Failure The use of the engine when the steering gear has failed should be carefully evaluated by the Master considering that:

• With full or emergency power astern, it is possible to bring the stern of a single propeller ship up wind.

• If the rudder is jammed in hard over position, moving ahead can keep the ship’s head up wind.

• The effect of the propeller running on a free flapping rudder is such that the rudder will generally go to a hard port or starboard position with either the propeller running ahead or astern and will stay there as long as the engine revolutions are maintained.

• Whether practicable repair a damaged steering gear before running the engine. In case of steering gear failure, the Officer of the Watch shall:

• Inform the Master and the Chief Engineer. • If in shallow water, prepare anchors. • Try to steer outside the traffic area using the emergency steering gear, particularly if in high-

density traffic area. • Stop the vessel in a safe area, if practicable. • Update the vessel position. • Exhibit “Not Under Command” signs. • Plot the vessel’s position every 5 minutes and estimate the drift direction and speed. • Transmit the “safety” message.

8.LANGUAGE:

The working language on-board is English, & all the crew is proficient in English language.

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9.HEALTH AND FATIGUE

Available records and statements have confirmed that personnel on watch were adequately rested and

that none of them has suffered health problems since they have joined the vessel.

The company Drug & Alcohol Policy has banned alcohol from all its managed vessels, implementing an

alcohol free policy.

The crew involved in the Manoeuvre have been alcohol tested suddenly after incident with on board test kit,

resulting all negative, furthermore Company’s ordered the Authorised shore Company to carried out alcohol and

drug test as well.

10.SECURITY PROCEDURES

In USA waters and Port, for the Italian Flag is required Marsec Level 1.

11.DEVIATION FROM RULES AND ROOT CAUSES ANALYSIS

The Vessel carried out all test as required by 33 CFR 165.25 ON 19TH July 2015 from 20:32 lt to 21:00lt and

pre arrival test as required by SOLAS and Company policy on 20th at 16:16, and all found in good orders.

During the transit of Sabine passage Pilot order to helmsman to A/C of 10° to starboard and wheel was set

accordingly but the rudder doesn’t respond.

Master Immediately inform Chief Engineer to attend Steering Gear room in order to check if situation and in the

meantime He try to steer by NFU control that did not respond as well.

At that time, due to the shortage of sea room the Vessel was already aground.

Upon reviewing among all parties on site and in the office the root cause of the incident seems to be the lower

relays on the back of no 1 and no 2 at servo control board which was found with the upper part of the relays not

fully seated in the assembling block. This is the only item found to which we can attribute the cause of the

rudder failure We want to point out that if the Master instead to follow correctly procedures to try to steer with

NFU system would ordered to steer by local emergency station, we would assume that the Rudder would have

responded according by passing the electric command from the bridge. In view of the above and deeply analyse the Company’s Procedures, it result that they are not comprehensive of

correct analysis of the mentioned scenario as well as Company’s Risk Assessment, even though is developed

time by time for each scenario, was not including the electrical failure caused by interruption of electrical signal

from Auto Pilot to Steering Machinery.

12.IMMEDIATE AND CORRECTIVE ACTIONS

The Pilot order 1 tug and the vessel was quickly re-floated.

The Pilot took the vessel back to Fairway Anchorage to await further instructions.

Master Immediately ordered to sound all COT, Void space and Bunker Tanks, and every 4 hours after first

positive assessment and up to diving inspection have been carried out, no any variation or damages have been

relived.

Company representative Technical Manager reach the Vessel on 21st July together with Diving Company,

Rudder Maker’s Technician, Autopilot Technician, VDR Technician, RINa Class Surveyor and Shore

authorised drug and alcohol control surveyor required by the Company, in order to investigate on the

occurrences.All these operation has been attended by Q.I. representative ECM, which assist Master and

Company’ s Technical Manager to manage and conduct Incident Investigation as external Supervisor as

required by Company’s Procedures.The Vessel after all reports and attendance of USCG (COC and PSC) post

incident has been declared safety to enter removing all restriction placed on the movement of the Vessel,

escorted by Tug.

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13.LESSONS LEARNED / PREVENTIVE MEASURES

- The two relays panels have been fit with mechanical stopping device in order to avoid uncontrolled un-seated

from the assembly block caused from hard vibration of the Vessel.

Company’s Procedures have been amended with new checks to be carried out before arrival in Port, narrow

passage, congested waters, Chanel Transit, Pilotage waters, and whenever it deems necessary by the sensitive

scenario.

Test and check will made part of pre arrival check list and must be recorded in the Official Log book.

-The company’s Depth affected waters risk assessment / training / familiarisation / briefing procedures have

been revised, drawing from experience gained from this incident;

-The Company ‘ Emergency procedures have been amended in way of Steering Failure, state that in case of any

Steering Failure the first step to be done is to manoeuvre locally from Emergency Steering Station by passing all

Bridge electrical device and remote Control.

-The incident to be included as a case study in the company’s risk management training programme during

annual session in the Company’ shore Premise Seminary.

- The incident analysis will be shared within the Fleet Vessels

14.SUMMARY

The safety of the human life, the vessel itself, the cargo & the protection of the environment is the

foremost objective of the Company, & after incident investigation this is of paramount importance for

the Company to avoid reoccurrence of such kind of event with all resource available like Company’s

seminaries, on board training highlighting the importance of strictly following company policy all time.

To be highlighted that since the beginning the cooperation, proactive and total aim to collaborate has

been received by Master and all the Crew .

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CONTACT DURING STS WITH DAUGHTER VESSEL OFF SHORE LOME' FINAL REPORT

INDEX 1. SYNOPSIS

2. Notification

3. Attached documents

4. Description of events

5. Summary of findings

6. Particular Circumstances

7. Abstract of Company’s policy

8. Language

9. Health and fatigue

10. Security procedures

11. Deviation from rules

12. Immediate action

13. Corrective action

14. Root causes analysis

15. Lessons learned / preventive measures

16. Summary

1.SYNOPSIS:

Incident Details Date Occurred: 07th March 2015

Time Occurred: 18:24LT (GMT) Incident location: LOME- TOGO

Injuries, fatalities: No injuries, No fatalities, No Pollution Persons on board: 22 Crewmembers plus 1 Passenger (Training Cook)

2.Notification: Following Persons:

Company DPA, • Company DPA

• Malta Authority

• Charterers

Contact during STS with daughter vessel off shore - Lomè

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3.Attached documents: • Crew List

• Crew Matrix at the time of Incident

• Minimum Safe Manning Certificate

• Rest Hours Report up from 01ST March up to 25th March

• Alcohol Test report suddenly post Incident

• Malta Flag Authority waiver authorisation letter

• Class post incident attendance report

• Class Survey Status dated 25-03-2015

• Short Term Safety Equipment Certificate

• PandI post incident attendance report

• Risk Assessment sheet to perform voyage from Lome to Rotterdam

• Bridge and Engine Supporting Documents

• Vessel Specific STS Plan first page and approval letter

• Class Survey Status and Survey Endorsement Sheet after Repairs at Rotterdam published on 07-04-2015

• Various pictures during Rotterdam repairs and drills carried out.

4.DESCRIPTION OF EVENTS:

On 07th March 2015 at 18:24lt (GMT ), our good Vessel was coming in contact with daughter Vessel while approaching to

perform STS operation at Lome anchorage area.

After having successfully completed STS check lists and exchanges of information was carried out, being mother Vessel

was approached on her starboard side by daughter Vessel, that was manoeuvring with Mooring Master and fenders on

board.

During second attempt of approaching manoeuvre daughter Vessel was proceeding on her port side towards our good

Vessel, both maintain parallel course approx. 20 mts away between each other’s, and daughter Vessel bow was forward of

our good Vessel manifold, at this time they lost Main Engine and dropped their port Anchor, causing suddenly swinging of

their bow on our good Vessel starboard side.

Master of our good Vessel tried to be clear putting full ahead and hard to starboard the rudder, but unfortunately could not

be avoided the contact with Daughter Vessel.

Daughter Vessel bow area port side made contact with the our good Vessel starboard lifeboat and davit,

causing damages for which the lifeboat result out of orders.

5.SUMMARY OF FINDINGS

INVESTIGATION TEAM:

On board team :

- Master

- Ch. Engineer

- C/O

- 2/O

- Maintenance Manager (D.MALERBA)

Operational Office team:

- DPA/Fleet Manager (Capt. F.SABIA)

- Technical Manager (Mr. A.MARESCA)

- Marine Manager (Capt. P.PANDOLFI)

- Operations Manager (Mrs. C.ORTOLANO)

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6.PARTICULAR CIRCUMSTANCES

CREWPARTICULARS AND EXPERIENCE The vessel is a new building delivered July 2008 from the SPP Shipyard in Korea. The vessel trade unmanned

for which in accordance with the Minimum Safe Manning certificate she should be manned by a minimum

complement of 6 officers (including Master and Chief Engineer) and 8 ratings, however, as per Company

policy we keep on board at all time a minimum of 8 officers + 1 Electrical officer , 11 ratings and 2 cadets. At

the time of the incident in command there was a first assigned with Company Master.

Capt. joined Finaval on February 02nd 2015, before joining the our good Vessel he has performed 2 full contracts

on board other owned tankers.

On February 02nd 2015 he joined our good Vessel as Supernumerary Master at Lome Anchorage area and on

February 21ST 2015 he has taken the Command at Huelva, paying 19 days of overlapping, performing several

STS operation and sea passage from Lome to Huelva in parallel with previous Senior Master; Company’s

Policy required at least 5 days being first assignment in the Company.

Chief Mate joned Finaval the first time on July 2010 as Chief Officer .

He perform several contracts on two of our good Vessels as Chief mate, and his first assignments in rank was on

2001 and since then he has made up a seniority in rank of 6.2 years.

All Indian crew are regularly rotated on this and sister Vessel.

All Deck & Engine officers were fully certified & properly trained for the navigation and cargo control room

watch. Officer’s certifications & training were over & above the STCW requirements, which are considered as

minimum by the company.

All personnel involved have many experience in ship-to-ship (STS) operations.

Furthermore the value added in-house courses has been also conducted by the Company from time to time as

per the Company training policy.

7.ABSTRACT OF COMPANY’S POLICY

=======================quote=============================

SECTION 35 – SHIP TO SHIP TRANSFER OPERATIONS 1.0 PURPOSE AND SCOPE This section deals directly with STS transfer and Lightering operations undertaken at sea and it shall be considered as a complement recommendation to ICS Ship to Ship Transfer Guide (Petroleum). 2.0 RESPONSIBILITIES The Master is responsible for safe STS Transfer operations at all times. He shall ensure integration of the Mooring Master into his/her Bridge Team, such that a proper navigation watch is kept at all times, whether anchored, steaming, or drifting. This includes monitoring traffic using all available means at his/her disposal. The Master has the authority to refuse commencement of mooring operations, abort or terminate lightering operations should he determine it is unsafe due to weather or other reason. Moreover the Master shall ensure that recommendations described in the ICS Ship to Ship Transfer Guide are observed while performing STS Operations.

When appointed, the mooring Master shall provide ship staff with adequate advice and guidance on the lightering operation including; mooring plan, communications, safety advice, transfer advice, and unmooring procedures. The Mooring Master shall be on the service vessel (Receiving Ship); however he shall instruct the discharging ship on courses and speed to maintain during the mooring, lightering and unmooring operations.

The Mooring Master has the authority to abort or terminate lightering operations should he determine that it is unsafe to continue due to weather deterioration or any other reason. The mooring Master shall never relieve the Ship’s Master of any of his duties or responsibilities. In accordance with the MEPC Resolution 186(59) a new Marpol Annex I - Chapter 8 has been added and it will enter into force April 1st, 2012. The new Marpol requirement is related to the STS Operations for which to all the Vessels is issued a Class approved STS Operations Plan. Masters are strongly recommended to make reference to this Plan whenever the Vessel is required to carry out STS Operation.

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3.0 SAFE CONDITIONS FOR SHIP TO SHIP TRANSFER Before STS Transfer operations begin, the Master should ensure that acceptable conditions for STS exist and must ensure that:

• CCB 37.02 Ship/Shore Pre - Transfer Check List to be completed by both vessels (or Mooring Master on behalf of Other Vessel)

• Adequate procedures have been established in accordance with the Company Policy; • Cargo and safety equipment have been tested and found in good order; • Steering gear, engine controls and all navigational equipment are tested and found in good

working condition; • Mooring equipment was prepared in accordance with the mooring plan; • The Ship complies with all requirements of OCIMF Ship To Ship Transfer Guide Check List :

After

Accordingly following checks has to completed according to the operations schedule: A) Before start the STS Operations / Cargo Transfer

1.Pre- fixture information’ (Company’s Check List CMO.35.01 Ship-to-Ship Transfer n.1) 2.Before Operation Commence 3.Before Run-in and Mooring 4,Before Cargo Transfer

A) Before unmooring after the completion of the cargo transfer

5.Before Unmooring

STS Operations must be carried out only in conditions of reasonable weather and visibility. Berthing arrangements and procedures have to be agreed to beforehand. Ship engines must be in readiness during the operations.

Close liaison between both vessels is required to avoid oil spillage especially when topping off and disconnecting operations.

Fire precaution must be observed and the safety data sheet related to the cargo being handled must also be taken into consideration. 3.1 STS TRANSFER AREA In addition to the OCIMF STS transfer Guide, Masters should refer to and comply with local regulations or procedures that may apply to STS Operations.

Special attention should be paid to the ship’s fendering and moorings. In some cases it may be necessary to increase the equipment - the Master should consequently advise the Operations department of the details.

Occasions may arise where a STS Superintendent (Loading Master) will be appointed for an STS Operation. His particular responsibilities will be to observe the rigging and un-rigging of fenders, act as a pilot for berthing /un-berthing and to monitor the transfer operations to ensure compliance with the STS Guidelines. Master Should refer to the STS operation plan for proper guidance in this regard. Prior Starting the STS Operations , minimum 24 hours before, maximum 7 days before, and in any case as soon as all the STS transferring details are known, it will be the master care to carry out a risk assessment in order to make sure that all the preventive measures required for a safe operation are identified and put in place. Copy of the risk assessment carried out will be kept filed in the Folder 35 together with the related Check List.

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4.0 QUALIFICATION AND TRAINING Masters and senior officers shall have STS transfer experience (in open sea) within the last 12 months.

In case the Master is unfamiliar with such operations, an STS transfer superintendent shall be employed in order to give him proper advise during the operations..

The following minimum qualification and training requirements shall be satisfied:

Operations department shall ensure, by involving the charterers that above mentioned requirements are met by mooring master and STS Transfer superintendent. Personnel involved in STS transfer operations MUST be able to understand and speak English. 4.1 STS FAMILIARISATION A dedicated STS familiarization session should be held within 24 hours but not more than 7 days preceding the STS transfer operation. In case of consecutive operations Drill/familiarization should be carried out at once.

Refer to Section 60 for details. 5.0 COMMUNICATIONS Adequate communications have to be maintained throughout the operations and procedures to be agreed in advance among all parties involved. The Chief Mate shall ensure that emergency signals are established prior to starting STS operations. 6.0 FENDERING AND TRANSFER HOSES To protect both vessels from possible damages, fenders must be of sufficient size and strength and must be properly placed to ensure that:

Impact energy will be absorbed during berthing/un-berthing; Adequate space will be maintained between the two ships to allow normal movement and list.

Fenders are usually provided by shore firm or agents; however the Master shall ensure that they are available before STS transfers take place.

Throughout STS operations, hoses should be inspected for leaks. Hoses should be adequately supported to avoid chafing and kinking and adjusted as freeboard changes. Hoses should be ready for emergency disconnection. The safety of operations during transfers relies on each ship monitoring the other ships procedures, as well as its own. A Master may find it necessary to suspend operations because of default of the other ship. 7.0 MANAGEMENT OF HUMAN RESOURCES DURING STS TRANSFER OPERATIONS On vessels conducting STS Transfer operations, watch keeping personnel including Mooring Masters, shall be sufficiently rested at all times. Rest hours policy shall always be observed.

In case of single operation, the Master may be requested to relieve the officer on duty (on Navigation Bridge) in order to give to him sufficient rest. As far as practicable, In the event of multiple Ship to Ship lightering operations, the Crewing department shall arrange an additional deck officer in order to safely manage periods of on duty and rest times.

The following are recommended officer watches for multiple STS Transfer Operations: 00-06 / 12-18 Chief Officer on CCR – 3rd Mate on the Bridge 06-12 / 18-24 2nd Mate in CCR – Master/ Additional 3rd Mate on the Bridge

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8.0 PERSONNEL TRANSFER Personnel shall be transferred from ship to shore installation by approved Personnel Transfer Basket.

When using the Personnel Transfer Basket, personnel should stand on the outside of the basket with both hands through the rope netting, crossed, and securely holding on to the basket netting.

No more than 4 persons should use the Personnel Transfer Basket at same time, and they shall stand opposite to each other so as to balance the load. Personnel transfer basket is to be provided by the STS organizer.

The basket is fitted with tag lines which need to be monitored by ship personnel so that they do not become fouled. Ships crews should man the tag lines to help keep the Personnel Transfer Basket clear of obstructions.

Once the Personnel Transfer Basket lifts off the deck, the workboat can move out from under the Personnel Transfer Basket so that in the event of crane failure, personnel will land in water instead of the boat deck.

A life ring shall be kept in the vicinity of the manifold, which can be used in the event personnel should fall in water during the transfer. 9. RECORD KEEPING A Folder 35 shall be maintained for the filing of all 5 STS checks Lists. Check list will be grouped for operation and not spread by number sequence.

10.0 REFERENCES OCIMF: ISGOTT ICS Ship to Ship Transfer guide (Petroleum) OCIMF : Effective Mooring OCIMF : Mooring Equipment Guidelines US 33CFR part 156

SECTION 60 - STS EMERGENCY PROCEDURES

1.0 PURPOSE AND SCOPE The purpose of this section is to guide response personnel through the processes required to manage an oil spill originating from ship to ship transfer operations. This section takes account of the spill risks associated with the ship to ship transfer operations, the nature of the hydrocarbons that could be spilled; the prevailing meteorological and hydrographical conditions and environmental sensitivity.

This section is applicable to those vessels that perform STS transfer / Lightering at sea .

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2.0 RESPONSIBILITIES The Master is overall responsible for safe transfer operations. He must ensure that these procedures are interfaced with SOPEP/SMPEP and Terminal/Port Contingency Plan. It is the responsibility of the Duty Officer and all other crew members on board to report oil spills immediately to the Master. 3.0 TRAINING AND EXERCISES Personnel involved in STS transfer operations MUST be able to understand and speak English.

An appropriate STS Transfer Operations drill should be held within 24 hours but not more than 7 days preceding the STS transfer operation. In case of consecutive operations Drill/familiarization should be carried out at once. During the drill the ship’s personnel shall be made aware of:

• Emergency signals; • Procedures for raising the alarm; • Cases when the cargo operations shall be ceased; • Location of muster and emergency stations; • Emergency unmooring and deployment of mooring gangs; • Clearing and emergency disconnection of cargo hose(s); • Readiness of engines; • SOPEP/SMPEP response requirements

4.0 RISK ASSESSMENT Based on the risk assessment performed by the company, the following significant hazards have been identified:

• Human Error in conducting STS operations; • Adverse weather including poor visibility during STS operations; • Heavy traffic conditions; • Inadequate communication between two ships; • Hull contact with other ship involved in STS operations; • Non Compatibility with other ship involved in STS operations; • Lack of Training and experience; • Cargo spillage; • Inadequate Equipment; • Equipment failure;

The Master shall review the company Risk assessment, identify any further hazards connected to particular cases and take all the required preventive actions prior to commencing STS operations. 5.0 OIL SPILL EMERGENCY RESPONSE In the event of an oil spill, the Master shall follow SOPEP/SMEP or TVRP instructions related to mitigating actions, notifications, cleaning up and structural issues.

Particularly for STS or Lightering operations, the following instructions shall also be observed and integrated with those available in the above-mentioned manuals.

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5.1 INITIAL REPORTING Spillage of hydrocarbons include:

• Any spillage of crude oil, fuel oil, diesel, kerosene or petrol, lubes or hydraulic oils; • Any visible sheen of oil on the seas’ surface;

It is the responsibility of the person observing (either crew member or visitor) the spill to report this immediately to the Master or Chief Officer. Provide as much information as possible on the spill including:

• Name and position; • Type of oil and size of spill; • Location and source of spill;

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5.2 INDIVIDUAL ACTIONS

5.3. ESTIMATING THE EXTENSION OF THE OIL SPILL It is important to determine the size of the spill and to classify it. Where possible, calculate the volume of oil spilled from methods other than the evaluation of a spill on the sea, such as by means of:

Volume of hydrocarbon in containing system; Lost or unaccounted volume of oil.

If an estimate of the spill size cannot be determined from operational information, observing the slick on the sea surface may provide a visual estimate. Although this can be performed from a vessel, best estimates are made from aerial surveillance flights. When using this technique, bear in mind that the entire area of the slick may not be visible and that this can only provide an order of magnitude estimate of the amount of oil spilled. The following tables and graphs should be used to estimate spill size.

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Calculation of the Volume of oil spilled from appearance of oil film on water

• Estimate total size of the area as a square or rectangle (in km) i.e. maximum extremities of the slick.

• Assess the area affected by the slick in km2 calculated as a % of the total area in (1). • Estimate the area covered by each colour of oil, calculated as a % of the total area affected. • Multiply the area covered by each colour by the appropriate figure in the oil quantity table

above. • Adding all the colour figures will give the total quantity of oil in m3 within the slick.

5.4 ASSESSMENT OF WEATHER AND SEA STATE The weather and sea state conditions are crucial in deciding on a practical response strategy for an incident. Where possible the following parameters should be determined and reported:

• Wind speed and direction; • Wave height/period; • Air temperature; • Sea surface temperature.

6.0 RECORD KEEPING - 7.0 REFERENCES Section 35 of the present manual.

=======================unquote===========================

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8.LANGUAGE: The working language on-board is English, & all the crew is proficient in English language.

9.HEALTH AND FATIGUE Available records and statements have confirmed that personnel on watch were adequately rested and

that none of them has suffered health problems since they have joined the vessel.

The company Drug & Alcohol Policy has banned alcohol from all its managed vessels, implementing an

alcohol free policy.

10.SECURITY PROCEDURES Except for the specified Port or sea area, where for the Malta Flag is required Marsec Level 2, on board vessel

during stay at anchorage and employed in STS operation, in all Gulf of Guinea area they maintain Marsec level

1, and as per Company’ guidance they apply all Security measures as per Marsec level 2.

11.DEVIATION FROM RULES

There were no deviation from rules from our good Vessel.

12.IMMEDIATE ACTION

The Vessel was safely anchored and Master and on board team immediately assess the damage and secure the

lifeboat.

Company’ Superintendent (Maintenance Manager) boarded the Vessel in order to aim the Master, on board

team to assess the damage, develop Incident Investigation, and attend the visit of Class Surveyor.

Class Surveyor boarded the Vessel in order to assess the damage and issue a Short Term Safety Equipment

Certificate according with permission and recommendations of the Malta Flag Authority.

PandI Surveyor boarded the Vessel in order to assess the damage.

After assess that no damage on STBD shell plating or structure were noted and STBD Life Boat was completely

unusable, Company together with Master and on board Team developed a comprehensive dedicated Risk

Assessment in order to permit the Vessel to safely sail from Lomè and reach suitable Port where dock the

Vessel for repair the damages caused by the contact and replace the Life Boat.

Following briefly description of actions taken:

- Risk assessment and enforcement of preventive measures are in place before departure Lome. Risk

assessment has been submitted to the Company, Who review the measures, giving further suggestions.

Third parties concerned have been informed by Company.

Permission from flag state to be obtained and in turn inform Master to proceed for sailing.

- Damaged life boat to be taken extra lashing, preventing it to accidentally fall or release.

Any jobs concerning from the suspension platform or the height to be carried out to secure the life boat have

done have been done in safety way, a FHS.17.06 Working Aloft, Overside, on Stage Permit have been issued .

- A meeting to be conducted with all crew for briefing present scenario. Muster list has been amended basis

present scenario.

Emergency procedure in case of abandon ship have been established and in view of that a real time Abandon

ship drill to be conducted. All necessary stores, equipment to be transferred from damaged lifeboat to good life

boat.

- Both side Life Raft to be thoroughly checked and kept ready to be used in case of emergency, additional

training to all crew have been carried out on the use of all LSA, especially how to use the Life Rafts including

worst emergency scenario.

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- All pertaining weather massages to be obtained and Weather expected during passage to be discussed and

passage plan to be made /amended accordingly.

Passage Plan will be developed, as far as practicable, in the safe navigate Territorial waters of the Country

crossed during the voyage, in order to be at VHF usable safe distance and have daily contact with them.

- Daily Master have to contact the Company' DPA about situation, planning route, weather condition and all

relevant information regarding on board situation and passage details.

Response elements to limit the impact of any unplanned occurrences

Emergency communication system to be checked and All persons concerned with emergency have been

informed, a communication plan have been developed, making clear instruction to the equipment to be

activated/used, deviation from normal emergency procedures have been clearly explained verifying the

effectiveness and acknowledgement from ALL crew and passenger on board.

- All the LSA related to the prevention to the Hypothermia, such as Immersion suite, have been thoroughly

Checked and found in good order. .

- All crew have been briefed and familiarised with emergency procedure regarding use of only port side l/boat

in case of emergency & all L/rafts as & when situation arises. Abandons ship Drill sequence to be increased by

at least one time in a week Launching procedure of L/Raft have been briefed among all crew members. All crew

to be properly rested Job involving more risk to be avoided and daily briefing will be carried out in order better

plan and minimise the stress and workload at minimum required.

Mitigation measure taken to avoid and risk of fire

The crew must be instructed that in case of fire on board and subsequent abandon ship, the use of life raft have

to be avoided, the portside lifeboat have to be used, for which reason must be equipped to accommodate ALL

the crew, the Port Life Boat will be tested and checked daily.

- In order to avoid any risk that may create the conditions for a fire or an explosion, work in the open decks, in

accommodation and in the E/R have to be limited to the strict necessary routine, and where there was needs to

perform work all risks must be assessed with greater relevance to the risks related to the fire.

The frequency of the fire drill will be weekly, so that all equipment FFE are tested and checked for their proper

functioning at least weekly.

The frequency of the tests of the smoke and flame detectors will be daily, so that in one week is controlled the

functionality of all detectors.

All staff should be empowered to follow strict Company' Smoke Policy and exercise good seamanship practice

to avoid creating any source which would trigger a fire.

Being the unladen vessel, cargo tanks must always be always with positive pressure, the officer in charge has

the daily topics of controlling the content of the gaseous mixture in the Cargo Oil Tanks, and if the value of O2

appears to be 4.5% in the vol, inert gas must be supplied in cargo tanks.

The Watch personnel (OOW and rating) will man the E/R, the safety checks and patrols will be intensified and

emergency fire pump will be tested daily.

In E/R as well as on deck any kind of routine job that has fire risk must be done, any kind of work that could

generate the flame must be made. Make all the fire night patrols in the internal spaces, accommodation,

especially in laundries and in locals where there could be sources of injection for a fire.

During the night, the washing machine must be disconnected, by forbidding the use by 2000 hours to 0800

hours.

In the kitchen, plates should be lit only in the presence of the cook, all other equipment that work with the

electrical supply to be used in the presence of the cook.

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The deep fryer must be only use when necessary and in the evening should be emptied, cleaned and unplugged.

In addition all the fire hose, either for foam and for water must be connected or tested daily together with

EM'CY fire pump.

The additional fire extinguisher present in the fire locker will be posted as additional measures in all sensitive

are in the accommodation, as in Galley, Laundries and in the alleyway; in E/R close the machineries which can

generate fire, in steering gear room and on open deck in the locker such as paint locker and fwd bosun store.

Emergency generator will be tested daily basis.

Therefore Malta Administration, basis the RINa Class Surveyor our good Vessel damages assessment,

Company's additional and dedicated temporary procedures and Risk Assessment, grant waiver to operate,

issuing Short Term Safety Equipment certificate up to 06th April 2015 to reach Rotterdam to perform the repair

to install temporary, a compatible second hand Life Boat already purchased, since the Original Asia made has

been ordered and will be ready to be installed on around 15th July, 2015 in North Europe ARA Port.

13.CORRECTIVE ACTION

The Vessel has docked from 03rd April to 07th April to repair STBD side Boat Deck plating, buckled iwo

Forward skid, Buckled area, STBD side Superstructure side plate variously dented from Boat Deck Transverse

frames (N°1 to 10), Fore Guardrail (close to Navigation light box) de-attached and Navigation light posts

buckled.

Moreover, the Vessel has been equipped with second hand compatible lifeboat, which has been tested and

approved by RINa Class attendance.

The DPA was on board for all repairing jobs, in order to complete Incident Investigation and assess damages

assisted by Company Technical and Maintenance Managers.

Company DPA has briefed Master, Deck Officers on the Bridge Management team operation, all crew members

actively employed on the STS Operations, dedicated and extensive mooring operations training, emergency

response during STS operation and Mooring operation

All crew, instructed by DPA, on the use of new life boat, all Solas Training Manual have upgraded with the new

usage lifeboat instruction, and all have attended to the Class lowering, de hook and functional lifeboat tests.

Before departure All crew have participated at abandon ship drill repeated three times at the presence of the

Company DPA and RINa Class Surveyor.

According to the above-mentioned action the Malta Authority has issued Short Term Safety Equipment

Certificate until 15th July in order to permit, the new build genuine Life Boat to be delivered to the convenient

Facility and install accordingly.

14.ROOT CAUSES ANALYSIS -The action of the Daughter Vessel dropping anchor without notice, caused the Daughter Vessel to drift into our good Vessel causing the damages to both vessels. -The Daughter Vessel anchor was dropped because of an engine failure.

-Substandard acts / practices of the Master of Daughter Vessel in emergency response during STS

operation, the manoeuvre could be aborted without to drop the anchor, which is the main factors causing

the contact.

-It is not considered that wind or sea state were responsible for the contact between vessels

15.LESSONS LEARNED / PREVENTIVE MEASURES -The company’s STS risk assessment / training / familiarisation / briefing procedures have been revised,

drawing from experience gained from this incident;

-The incident to be included as a case study in the company’s risk management training programme.

-The approach must be quickly aborted by both vessels if any yaw is detected;

-Unless there is reasonable way to avoid further issues/damages, at the stage of approaching, when the vessel

have parallel route, never drop the approaching side anchor.

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-There are some critical stages of the STS approach for which particularly thorough planning is essential to

ensure a low risk operation; these include the angle of approach, the distance between vessels and the time and

location when vessel’s headway should be taken off.

All these must be discussed in detail with the Pilot/mooring Master before commencing the approach.

- Company has identified one experienced Senior C/O which will embark once the voyage will be fixed, to

assist Vessels Bridge Team during Multiple STS operation either for navigational/manoeuvring and cargo

transfers operation purposes.

- Notwithstanding all Fleet Master have been informed and warned about incident and preventive measures to

be implemented, the final incident and analysis will be shared amongst the fleet and a fleet-wide campaign for

improving behavioural safety and introducing concepts like emergency response during STS operation has been

started

16.SUMMARY The safety of the human life, the vessel itself, the cargo & the protection of the environment is the

foremost objective of the Company, & after incident investigation this is of paramount importance for

the Company to avoid reoccurrence of such kind of event with all resource available like Company’s

seminaries, on board training highlighting the importance of strictly following company policy all time.

To be highlighted that since the beginning the cooperation, proactive and total aim to collaborate has

been received by Master and all the Crew .

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Spark and smoke Emission during discharging operation while at berthed at Trieste - Italy at berth SIOT #1

INDEX 1. SYNOPSIS

2. Notification

3. Attached documents

4. Description of events

5. Summary of findings

6. Particular Circumstances

7. Abstract of Company’s policy

8. Language

9. Health and fatigue

10. Security procedures

11. Deviation from rules

12. Immediate action and corrective actions

13. Root causes analysis

14. Lessons learned / preventive measures

15. Summary

1.SYNOPSIS:

Incident Details

Date Occurred: 13 Feb 2015

Time Occurred: 19:18LT(GMT+1)

Incident location: TRIESTE - ITALY

Injuries, fatalities: No injuries, No fatalities, No Pollution

Persons on board: 25 Crewmembers

2.Notification:

Following

Persons:

Company DPA,

> > > > Company DPA

> > > > Italian Authority (Trieste Coast

Guard)

> > > > Charterers

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3.Attached documents:

- Notice of protest

- Crew Matrix at the time of Incident

- Last Class Survey Status

- DPA Communication 06-2015 - DPA Communication 07-2015

4.DESCRIPTION OF EVENTS:

On 13th February 2015 at 1918lt (GMT +1), our good Vessel was at Trieste berthed at SIOT # 1,

while the discharging of “Arabian Heavy Crude Oil” was in progress, sparks and black stack

emission have been blow out from the Funnel and discharge at sea of carbon soots from I.G.

Scrubber occurred too.

The discharging has been immediately stoppedandafter about 15 minutes no emission have taken place any longer.

All parties have been duly noticed and Trieste Coast Guard have monitored the Vessel sea

surrounding area to control that the operations could be resumed in safety condition.

The discharging operationhave been satisfactorily resumed at 1942 lt (GMT +1).

The discharging operation has been stopped for 24 minutes.

5.SUMMARYOF FINDINGS

INVESTIGATION TEAM:

On board team:

- Master

- Ch. Engineer

- DPA - Crew Manager (F.SABIA)

- Technical Manager (A.MARESCA)

Operational Office team:

-Marine Manager (Capt. P.PANDOLFI)

-Maintenance Manager (D.MALERBA)

-Operations Manager (C.ORTOLANO)

6.PARTICULAR CIRCUMSTANCES

CREWPARTICULARS AND EXPERIENCE

The vessel is manned by 25 crew members, Italian, Indian and Romanian nationality.

Italian Master is very experienced and is very Loyal with Company, being in force since he was Junior Officer. Master

experience in the type of Tanker is 16.2 year , 13.8 year in rank and 18.3 year with operator; Ch. Mate experience in the

type of Tanker is 3.7 year, 1.1 year in rank and 0.5 year in the Company.

Indian Ch. Engineer experience in the type of Tanker is 6.6 year, 1.2 year in rank and 2.3 year with Operator; 1st Ass

Engineer experience in the type of Tanker is 4.8 year , 2.3 year in rank and 5.3 year with operator. They have been

regularly rotated on this Vessel.

All Deck & Engine officers were fully certified & properly trained for the navigation and cargo control room watch.

Officer’s certifications & trainingwere over & above the STCW requirements, which are considered as minimum by the

company.

Furthermore the value added in-house courses has been also conducted by the Company from time to time as per the

Company training policy.

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7.ABSTRACT OF COMPANY’S POLICY

======================quote=========================== 3.0 GENERAL

The vessel must comply with all maintenance standards as prescribed in the rules and regulations of the flag state,

international conventions and Class.

On board maintenance is monitored by CBM System which assures continuous assessment of operational equipment.

These can prevent breakdown of equipment because the necessary action are taken promptly. Basis on the needs the

maintenances are carried out in following way:

• Preventive maintenance is subject to well laid out plans/routines and inspecting/ reportingpractices.

Replacements and/or repairs may be effected to ensure trouble free operation for a further period of time –

generally till a subsequent “planned maintenance” activity.

• Breakdown maintenance involvesreplacements and/or repairs. It is the company’s aim to restrict it as much as

possible.

• Replacement maintenance involves items which require little or no maintenance effort.

• Predictive maintenance isa method which monitors the condition of an equipment/system, and partly gives an

indication of its performance. It is based upon the

monitoringof vibrationlevels, the analysis of components, and for systems equipped with ball/roller bearing, the condition

of the bearing themselves. It avoids overhauling an equipment/system which has been ascertained as working in good

order. It allows determining the moment when failure is expected with excellent accuracy, and also gives significant

indication about the possible cause.

Conditions of Class are dealt with on the basis of utmost priority. It is the policy of the company to take corrective actions

for outstandingConditions of Class without delay and, wherever practicable, before the due date indicated by the Class.

CoC has to be recordedand filed as defect items in the vessel’s inspection database system (SMAD), this will allow each

superintendent to monitor and follow up the COC as standard vessel’s defect.

There isa fleet-wide system to track outstandingmaintenanceanddefect items. System generated reports are kept in a

common database in head office to allowthe Technical Department to monitor the performance of all vessels in the fleet.

The Technical Superintendent tracks the number of outstanding tasks on their ship and the Technical Manager tracks the

number of outstanding tasks across the whole fleet of ships to ensure that they are carried out quickly and efficiently.

(Note: The number of outstandingplannedmaintenance tasks is expressed as a percentage of the total number of monthly

plannedmaintenance tasks. Data is recorded monthly with a running year-to-date figure also recorded).

Maintenance of other items like cabin fittings, furniture, furnishings is carried out to provide a safe, comfortable,

hygienic, well ventilated and well lighted working/living environment for all shipboard personnel and visitors. Cosmetic

are considered also an important both for the image as well and hull and outfitting protection.

4.0 PLANNED MAINTENANCE SYSTEM (PMS)

The Technical department ensures that managed vessels are maintained in compliance with the provisions of

mandatory rules and regulations and sound technical management principles in order to achieve:

• Safety of ship andcargo.

• Environmental protection.

• Quality service for customers.

The Technical Department, through the Technical Superintendents, shall give support by providingtechnical advice and

services or spares. If deemed necessary, the Superintendent shall visit the vessel to provide his personal support. The

Technical Department has developed a planned maintenance system for each vessel.

The planned maintenance system (PMS) ensures that essential machineries and systems are kept in good working

conditions in accordance with regulations andwith the instructions of the Technical Department. PMSincludes measures

to control the reliability of equipments or systems failure of which may result in hazardous situations.

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The PMSwhich is developedon runninghours, service time andcondition monitoringtakes into

account:

The regulations requirements.

The typeof themachinery or appliance.

The instructions of the manufacturers.

The experience of the Technical Department personnel.

The maintenance criteria based on the running hours or service time is used to cover the

following main items:

Main Engines

Diesel generators

Air condition compressors

Reduction gear

HFO Transfer pump

Feeder pumps

HFO & M.D.O. Purifier

M/E Lube oil purifiers andpre-lubricating oil pumps

Ship service and control air compressors and starting air compressors.

Some machinery and systems whose maintenance criteria is based on condition monitoring are submitted to

periodical routine inspections at intervals suggestedby manufacturers and/or establishedby the Technical

department.

Equipment which requires periodical inspections include those that are not in continuous use such as redundant

systems as well as those the sudden failure of which may result in a hazardous situation.

The following isa list of equipment which requires routine and or periodical inspection:

Live saving(including free fall, life and rescue boats)

Fire Fighting system

Main engines

Diesel and emergency generators

Steeringgear

Antifouling system

Inert gas system

Mooring equipment;

Cargo pumps, including cargo pump temperature monitoring system;

ODME and Oily water separator, including filtering equipment;

Cargo pumps and heating

External cathodic protection

Tank cleaning system

Windlass and mooring

Air conditioning System

Sewage treatment

Purifier modules (controlled Is extended over the lub oil analysis)

Maintenance and inspection intervals may be extended only if no spares are available and if validtechnical reasons exist

to demonstrate that the safety of the ship is not put at risk. (Extension of inspections as scheduled have to be discussed

with and approvedby Technical Department.)

The planned maintenance system shall also provide for theregular testing of standby equipment and systems that are

not in continuoususe. Such equipment includes, but is not limitedto:

Emergency generator or backup battery system.

Emergency fire pump.

Emergency air compressor.

Routine maintenance for cosmetic shall be agreed on board with visiting Superintendents andplanned for periods of 3 - 4

months.

Defects identified items of maintenance outside the capability of ships' personnel or nonconformities of the

maintenance system shall be reported on the AVREP Database.

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6.12 AUXILIARY BOILERS General

Safe and satisfactory performance of water-tube boilers is relatedto proper purity of water and gas side preventing scale

and soot deposits that will decrease the heat transfer causing local over-heating.

Daily water analysis and chemical treatments as well as surface or bottom blow down are extremely important. Only

distilled water must be used. Soot blowers must be kept in good condition and use once a day when the boiler/s is/are in

continuous service. When engine is running exhaust gas boilers must be blown as well. Automatic combustion control as

well as automatic feed water control must always be in proper operating conditions. If the system/s is not

workingproperly, followthe maker’s instructions and advise the Technical Dept., asking for service to be carried out by

the maker’s field technician.

Boiler Water Treatment

Boiler water must be tested daily and the values should be kept as per Boiler maker/chemical supplier’s suggestion. When

necessary, chemicals shouldbe added in small quantities at regular intervals ratherthan in large amounts all at once. Water

treatment reports must be sent to the chemical supplier, with one copy filed on board and one copy forwarded to the

technical department.

6.12.1 MAINTENANCE AND CLEANING PROCEDURES TO AVOID SPARK EMISSION (Soot Blowing)

In order to be in compliance with last Industry requirements, recognizing the needful to develop a specific procedure on

the matter as per subject (Maintenance and cleaning Procedures to avoid spark emission), the Company has decided to

issue the following:

As a precaution against funnel fires and sparks, burners, tubes, uptakes, exhaust manifold and sparks arresters should be

maintainedin goodworkingcondition. If here is a funnel fir or sparks are emitted from the funnel, the tanker should, if at

sea, consider altering course as soon as possible to avoid sparks falling on the tank deck. Any cargo ballasting or tank

cleaning operations in progress must be stopped and all tank openings closed.

Boiler tubes should be soot blown prior to arrival and after departure from a port. Boiler tubes should not be soot blown

when the ship is in port. At sea, the officer on bridge watch should be consulted prior to the operation commencing and

the vessel’s course altered if necessary.

A boiler that hasbeen runningfor a longtime is sure to have soot deposits on itstubes and furnace. During the fuel oil

combustion a lot of impurities are producedincreasingthe soot quantity which will be deposited on the heating surfaces.

Such soot, as deposited inside the Boiler, create an insulation layer between the steam and the tubes, diminishing the heat

exchange (Boiler performance), other than increasing the risk to generate a fire.

In order to keep high boiler performance andprevent the development of a fire inside the chimneystack, the Chief

Engineer on board has to regularly carry out the blow of the boiler tubes by means of the soot blow arrangement. Soot

blower are standard equipment nearly on all types of large water-tube boilers. Each Boiler fitted on board the ship is

provided with a system using the steam, compressed air or water as blow medium.

Before to carry any soot blowing operation reference must be made to maker advices.

Another majorinconvenient due to the accumulation of the soot inside the boiler chimneystack is presented from the

sparks comingout from the ship’s funnel. Those sparks are generated from the heat exhaust gases igniting the old soot

when in contact and the same is blow out, pushed from the same gases. This circumstance may develop in a dangerous

situation whenever such sparks reach the cargo area on a tanker vessel where flammable atmosphere can be present. A

similar situation can arise during the normal soot blow of the boiler tubes, for this reason particular precautions need to be

undertaken every time before carry out any soot blowing.

Reference has to be made to the Company’s poster PMR.46.01 Soot blowing, which should be posted in ECR AND

Bridge.

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The Company, making reference to QSE Manual Sec 46.6.12.1, with the intent to safeguard

the economical and safety of the ship during his normal operations establish following

procedures and conditions to be accomplished during any soot blowing operation:

Boiler tubes should be soot blown prior to arrival and after departure from a port. Boiler tubes

should not be soot blown when the ship is in port. At sea, the officer on bridge watch should be

consulted prior to the operation commencing and the vessel’s course altered if necessary. 6.13 MAINTENANCE OF AUXILIARY GENERATORS

Maintenance of the auxiliary generators is based on running hours according to the PMS. In addition, record of

running hours is kept by the Chief Engineer and reported to the technical department on monthly basis. Alarms and

safety devices must be tested on regular basis as recommended by the Company PMS.

For compliance with nitrogen emission limits of Reg 13 of Annex VI and IMO NOx technical file, reference has to

be made to QSE section 24.13.2.

6.21 INERT GAS PLANT

Inert gas can be very corrosive due to the high concentration of Sulphur Dioxide SO2 and Sulphur Trioxide,

especially in case of flue gas. To avoid corrosion, inert gas is washed in a scrubber. All components of the plant will

be subject to rapid deterioration if proper maintenance is not carried out. After each discharge, the IG fans shall be

carefully washed by fresh water to remove all traces of corrosive agents from the impeller and casings. Inspection

and maintenance of other parts shall be performed following the manufacturer’s instruction book as scheduled in the

PMS.

The Company has established a number of tests and checks to be carried out at intervals specified in AMOS and in

IGS Inspection Record Book and Cargo Systems Equipment Preliminary Test - Checks Before Use.

SOOT BLOWING FILING:::

FILE NR.-------

Issue 1 Issue Date 28/02/2013 Area . Sec . Form n°

PMR.46.01

Soot blowing must be carried out every time before and after port operations, at least 1,5 mile off-shore, same operation must be duly recorded in the ship’s engine log book.

Soot blowing cannot be carried out whilst the ship is within harbour limits.

Soot blowing cannot be carried out during any cargo, ballasting or tank cleaning

operations in progress, if so it must be stopped and all tank openings closed.

Always before carry out any soot blowing the officer on bridge must be informed in order to alter the ship’s course up to the wind, if necessary.

Deck spaces to be checked for potential flammable materials.

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TO BE FILLED UNDER THE RESPONSIBILITY OF THE CHIEF ENGINEER

INTRODUCTION This booklet has been developed by taking into account IMO and Manufacturer recommendations. The Chief Engineer is responsible for performing all checks and tests as required and to keep this record book updated.

How to record

INERT GAS SYSTEM MAINTENANCE AND INSPECTION RECORD BOOK

SHIP’S NAME

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INDEX

1 FLUE GAS ISOLATING VALVE

2 FLUE GAS SCRUBBER

3 OVERBOARD PIPES AND VALVE FROM FLUE GAS SCRUBBER

4 BLOWERS

5 DECK WATER SEAL

6 DECK MECHANICAL NON RETURN VALVE

7 PRESSURE VACUUM VALVES

8 DECK ISOLATING VALVES

9 LIQUID FILLED PESSURE / VACUUM BRAKER

10 AUDIBLE AND VISUAL ALARMS

MAINTENANCE PROGRAMME

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Inspection may be made through the manholes. Corrosion attacks, fouling,

anddamage to the followingstructures shouldbe checked:

.1 scrubber shell andbottom

.2 cooling water pipes and spray nozzles(fouling);

.3 float switches and temperature sensors;

.4 other internals such as trays and demister filters.

Checks shouldalso be made for damage to non-metallicparts such as:

.1 internal linings;

.2 demisters;

.3 packed beds.

VERY IMPORTANT: Internal examination of the IG Scrubber must not be performed without

following the recommendation for entering enclosed spaces

To a limiteddegree, internal visual inspection will reveal damage at an early stage.

Diagnostic monitoring system shouldbe used as they greatly assist in

maintainingtheeffectiveness of the equipment.

An inspection of the blowers should include:

.1 internal inspection of the blowers casing for soot deposits or signs of corrosive attack;

.2 examination offixed orportable washing system;

.3 inspection of the functioning ofthe fresh water flushing arrangement, where fitted;

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.4 inspection of the drain linesfrom the blower casing to ensure that they are clear and operative;

.5 observation of the blower under runningconditionsfor signs of excessive vibration,

indicatingtoo large an imbalance.

This unitperforms an important function and must be maintainedin good condition. Corroded inlet pipes and damage to float-controlled valves are not uncommon. The overboard drain lineand connection are also possible sources of trouble.

An inspection of the deck water seal should include:

.1 Openingfor internal inspection to check for:

.2 Blockage of the venture linesin semi-dry type water seals;

.3 corrosion of inletpipes andhousing;

.4 corrosion of heating coils;

.5 corroded or stickingfloats for water drain and supply valves and level

monitoring. Testing forfunction:

automatic fillinganddraining: checkwith a local level gauge ifpossible;

presence of water carry-over (open drain cocks on inert gas main gas main line)during operation.

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MAINTENANCE PROGRAMME

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===========unquote==========

8.LANGUAGE:

The working language on-board is English, & all the crew is proficient in English language.

9.HEALTH AND FATIGUE

Available records and statements have confirmed that personnel on watch were adequately rested and that none

of them has suffered health problems since they have joined the vessel.

The company Drug & Alcohol Policy has banned alcohol from all its managed vessels, implementing an alcohol

free policy.

10.SECURITY PROCEDURES

On board vessel and at Terminal we were maintaining security level 1, proper gangway watch were maintained through-out

the port stay and rounds were made on full vessel by watch keepers to check all restricted areas are properly Locked/

Sealed.

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11.DEVIATION FROM RULES

A continuous sparks emission has been blown out from vessel’s funnel for about 15 minutes .

Black stack emission anddischarge at sea of carbon soots from I.G. scrubber occurred before and after the sparks emission.

The unsafe situation createdby the ship and her breaching of the Terminal’s environmental policy (REF.ch.4.4.8 of the

“S.I.O.T. Terminal Information and Port Regulations”)

12.IMMEDIATE ACTION AND CORRECTIVE ACTION

As immediate action the Discharginghasbeen suddenly stoppedas required by the Terminal, who demand to stop the cargo

transfer without giving any reason.

In the meantimeCoast Guardpatrol boat and Port Skimming Barge service reach the Vessel to monitor any sea and air

dangerous emission, patrolling surrounding area during all cargo operation, in order to identify uncontrolled emission,

however no breach or pollution have been take over.

1. Once Chief Engineer has been advised regarding the spark emission, he checked the DD/GG status from remote panel in

ECR, all found in order.

Accordingly Chief Engineer and Engine staff immediately went to check locally and found at D/G#3 the line #6 with high

temperature.

At this time, Chief Engineer, stopped immediately D/G # 3.

Having removed the cylinder cover #6 of the D/G#3, it has been found the fuel injector seized in open position, which

caused incorrect combustion.

The unburned fuel particles have originated the sparks emission.

The Fuel Injector replaced with new one and D/G#3 has been tried out with satisfactorily result.

2. Apart from event 1), Boiler abnormal smoke density alarm and IG O2 analyser Low O2 content alarm were

activated and Chief Engineer was informed that black stack emission and carbon soot discharged at sea

from I.G. Scrubber was in progress. Due to the fact that theonly Aux Boiler #1 was dedicated to IG production they checked the combustion and found black

stack emission.

The excessive density smoke is sign of incorrect combustion and lack of air, therefore Engine Staff has found the levers for

the controlling of the air combustion air flap, seized in semi-open position leading to a lack of air. Immediately greased and

restored the proper working condition, the Scrubber Over board effluent checked and found clear.

13.ROOT CAUSES ANALYSIS

The investigation team after having deeply examined all parameters and statement of fact, reached to the following

conclusion regarding the root cause of this incident:

1)The D/G#3 is under PlannedMaintenance with CBP AMOSand at the time of event therewas no overdue job or any

outstanding.

The primary cause of sparks emission was that Injector of line #6 was seized and the high deviation alarm line#6 did not

work due to inhibition of electrical amplifier of the thermocouple, that gave fake temperature input in the General Alarm

System in ECR remote panel.

Lack of Company procedures to compare the DD/GG temperature of the local thermometer against the remote General

Alarm System panel always before Manoeuvre (Arrive and Departure), before Cargo Transfer operation take place and

whenever Chief Engineer deems necessary, keeping record in the Engine Log Book.

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Lack of Company Procedures to check every hours the DD/GG temperature from local thermometer in order to make cross

check with remote General Alarm System panel during Manoeuvre, Cargo Transfer operation, and whenever Chief

Engineer deems necessary, keeping record in the Engine Log Book.

2) The Aux Boiler #1 andI.G. Scrubber are under PlannedMaintenance with CBP AMOSand at the time of event there was no overdue job nor outstanding, furthermore both Boilers and I.G. Scrubber are tested either before arrive

andcommence cargo transferoperation.

The primary cause of black stack emission and discharge at sea of carbon soots from I.G. Scrubber were due to the levers for the controlling of the air combustionair flap of the Aux Boiler #1, seizedin semi-open

position leadingto a lack of air.

Shortage of Planned Maintenance in the CBP AMOS, “Forced draft fun control” that doesn’t reflect Maker’s manual

instruction and frequency of the checks to be carried out

14.LESSONS LEARNED / PREVENTIVE MEASURES

Notwithstandingthe maintenance of DD/GG and AuxBoilers are under control of Computerised Basic Program

“AMOS”, it has been noted that some additional checks and tests carried out according the

professionalism and good seaman practices must systematically perform as scheduled maintenance and including in

the PMS.

The PMSCBP must reflect the required maintenance as per Maker’s instruction

Once the checks and tests required would be carried out as routine operation under estimating the risk and hazardous

related to operationmagnitude of any occurrences increase thepossibility that might be happen.

The DPA Communication 06-2015 has been issued amending Company’ QSE Procedures Manual, in the Section 45

chapter 5.0 Engine watch :

----------- qte------------- 5.0 Engine watch

In case the engine room cannot be operated in unmanned mode, the watch shall be performed

by a qualified officer and an engine rating/petty officer holding valid watch keeper license.

The engineer on duty shall record all activities performed during the watch, such as checks and

soundings, in the engine log book.

Before any manoeuvre, when is required Engine Room manned, before any cargo transfer operations

and at any time Chief Engineer deems necessary, Officer in charge has to compare the DD/GG

temperature of the local thermometer against the remote General Alarm Systempanel and every hours

the local and remote temperature must be cross checked and recorded into the Engine log book

------------- Unqte———-

Furthermore we have identified lack of maintenance procedures in PMS Computerised Based Programme AMOS and we

deem necessary upgrade AMOS System basis Vessel’ specific “Auxiliary Boiler Forced Draft Fan” planned maintenance

and DPA Communication 07/2015 has been issued stating as follow:

Job:

CH384 FORCED DRAFT FAN CONTROL– 2W

Job Description:

AUX. BOILER FORCED DRAFT FAN:

Systemcontrol tobe done every 2 weeks

Check operational condition of Forced Draft Fan Electro-Pneumatic System who runs the capacity of the Fuel-Air

Ratio This Incident investigation will be part ofour safety “toolbox” to avoid same to occur again and it has been shared amongst

all Fleet Vessels.

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15. SUMMARY

The safety of the human life, the vessel itself, the cargo & the protection of the environment is the

foremost objective of the Company, & after incident investigation this is of paramount importance for

the Company to avoid reoccurrence of such kind of event with all resource available like Company’s seminaries, on

board training highlighting the importance of strictly following company policy all time.

To be highlighted that since the beginning the cooperation, proactive and total aim to collaborate has

been received by Master and all the Crew .

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Near Collision and attendance on board - IMTT Bayonne, New Jersey, Pier A By: Herbert N Wood

ECM Maritime Services, LLC

Houston, TX 77034, USA

Table of Contents

1. Preamble

2. Response Summary

3. Conclusions

4. Pictures of the Spill and Damage to the Facility

1. Preamble At approximately 0100 EDT on August 2nd, 2015, ECM Duty QI, Brian Lincoln received a call from the Master of

vessel, that his vessel was moored to the IMTT facility in Bayonne, New Jersey when a tug and barge narrowly missed

colliding with them and then allided with the mooring pier.

Apparently, the tug had lost power and was unable to go astern and lost control.

The allision of the tug and barge with the dock facility to which the vessel, was moored caused 4 mooring lines to part.

This dock, loading and transfer structure contained loading arms and piping for transfers and it was reported that one or two

of the pipelines were ruptured and approximately 50 bbls of #6 oil was released into the water.

The Master had advised that he requested tug assistance from the local agent until the vessel could be safely moored again.

He also stated that the USCG was on scene, although they had not yet boarded his vessel. He requested ECM assistance in

case the USCG did so.

ECM contacted the local agent, Brian Bost with Moran Shipping Agencies, Inc (732-602-1551) who stated that he was en

route to the vessel and could provide updates throughout the night. After his arrival, he stated that the USCG had no

intention of boarding the vessel, as the vessel was not subject to the incident.

However, due to the cleanup operations that would ensue the vessel would not be able to leave in order to prevent

further spreading of the oil.

ECM then contacted Captain Sabia, the DPA for the vessel, to discuss the matter further and was told that it was very

unlikely that the USCG would be boarding the vessel.

Captain Sabia requested ECM assistance to assist the Master since boom had been placed around the vessel and wanted a

liaison between the Master and the USCG to ensure that the vessel’s interests were made known to the OSRO and the

USCG in allowing them to move or depart as needed. ECM then contacted our Herb Wood who proceeded to the

vessel.

At 1015 CDT, ECM contacted the USCG, LCDR Art Hudman, for an update on the USCG’s response to the incident.

LCDR Hudman stated that he had personnel en route to the scene to assess the situation to see if the vessel can or should be

moved and to what extent the vessel and surrounding areas had been impacted.

I informed him that our representative will be on scene shortly and will liaise with his investigators for cleaning of the

vessel’s hull or moving the vessel if needed. No COTP order had been issued to the vessel, restricting her movement, but

that was a possibility upon completion of the USCG’s assessment of the impacted area. However, because the vessel was

voluntarily cooperating with the operations, no COTP order had been issued.

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2. Response Summary ECM’s Herb Wood attended the vessel at IMTT, Bayonne on August 2,2015 following a report of a spill resulting from the

Van Line Bunkering Barge DOUBLE SKIN 501 striking and damaging Pier A at IMTT Bayonne.

ECM was requested to attend as Owners Representative, until the Master of the vessel was satisfied

that the situation was under control.

Mr. Wood arrived at IMTT Bayonne at 1130 hours on August 2, 2015 and was informed that no one was permitted to

board the vessel until it moved to Pier 9C. Mr. Wood was escorted to the Spill Command Center inside IMTT Bayonne

Facility and met with Coast Guard Representative Mark Sennick (207-491-6599) and Members of the Spill

Management Team from Gallagher Marine Systems, acting on behalf of the tug and barge incident.

After meeting with the Terminal Manager, ECM was permitted to board the ship.

In the process of boarding the ship, ECM also met with a USCG team and walked to the side of the ship and observed the

ship had been boomed and the majority of sheen from the spill was outside the boom surrounding the ship. This

observation negated the need to clean the side of the vessel.

Mr. Wood boarded the ship at about 1345 hours and met with the Chief Officer and Captain. During our attendance aboard

the ship, ECM acted as liaison between ship, agent, Coast Guard ashore and the Spill Management Team

ashore.

Specifics of the incident came to light and found that the incident occurred at 2148 hours on August 1, 2015. The ship was

discharging Ultra Low Sulfur Diesel.

The discharging operation was stopped by the ship immediately following the allision between the Barge DS 501 and the

dock. The only damage to the ship was that four (4) mooring lines parted as they had been secured to the shore mooring

bitts on the dock that was severely damaged as a result of the event.

At 1410 CDT, ECM was contacted by the vessel’s P&I representative stating that he had been to the facility but was not

allowed on board the vessel due to the damage to the catwalk connecting the shore to the mooring and loading part of the

dock (see photographs below). ECM put him in contact with Mr. Wood who directed him on how to get to the vessel

through another part of the facility.

The ship intended to move at 1500 hours depending on approval from the Coast Guard.

The vessel experienced delays due to waiting USCG approval. The only other problem was removal of two (2) spring lines

that were secured to sections of the pier no longer having personnel access. The ship received final approval to move the

ship to Pier 9C at about 1645. The docking pilot was ordered immediately by the agent and the move was scheduled for

1830. The move commenced on time and the ship was all secure at Pier 9C at 2010. Mr. Wood departed the ship at 2020.

3. Conclusions ECM wishes to thank the Master and crew for their cooperation and support during this incident and for their outstanding

hospitality during our time on board. ECM is grateful for the opportunity to assist the Master in this incident and ensure

that the best interests of the vessel were taken into consideration by the USCG and OSRO in their response.

This report has been prepared in good faith and without prejudice to any and all parties concerned. It is based on surveys

undertaken, investigations carried out and information submitted and made available at the time of writing. In the event that

further information or documentation is made available at a later date, we reserve the right to amend this report, and

our statements.

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PICTURES OF THE SPILL AND DAMAGE

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