The Second Quarter of 2011 PSC Detention Trend Report

(For Owner)

2011. 08.

Survey Team

Regional Trend for Detention and Deficiency

. Paris MoU

*. Recent Trend - Inspection related to Sulphur oxides(Sox) emission(bunker notes, sampling log book, bunker change procedure) - VDR function and random alarm test and normal condition check after reset - Implementation of Fire and Abandon ship Drill and record (see attached Check point of Fire and Abandon ship Drill in UK) - Navigation plan(berth to berth) and up-to-date chart - Operation of emcy fire pump and leak check(If it can be run in 5 minutes Without any leakage, required minimum pressure of suction : -500mmHg, discharge : 3kg/c) - Black out test(simulation test) with familiarity of all crews - Operation of quick closing valve(including emcy generator DO tank) - Condition of structure(hatch cover cleat, air vent head)(hammering test) - Function and contact condition of E/R funnel damper - Installation of insulation for heat surface - Familiarity of operation of CO2 system for all crews - Control of garbage(garbage record, galley and toilet condition etc.) - Correspondence of SOLAS training manual and equipments on board - Function of water ingress system and de-watering system - Protection for crews(safety device and guard for work ship)

*. Detainable Deficiency - Ten(10) major detainable deficiencies and overall inspection - PSCO emphasizes implementation of ISM and checks real-time NIR database - Each Certificate and valid crews license - Crews working hour and resting hour record - Function of GMDSS(DC Power) and familiarity with GMDSS equipment - Condition of Firemans outfit - Corrosive condition of Gangway - Function of oily water separator and 15ppm alarm check(oil check inside discharge pipe and check for proper record of oil record book) - Check for engine room and S/G room clean condition (connections for piping system, oily insulation for piping, around D/G fuel pump, purifier room floor, S/G ram etc. Leakage is checked after actual operation during some time. Wipe out before entering port) - Extended inspection for bulk carrier more than 15 years - CIC(Concentrated Inspection Campaign) related Structural Safety and International Load Line will be carried out in 2011 which are not easy to rectify within short period time. Please implement close-up check

. USCG

*. Recent Trend - Function of Oily Water Separator(familiarity of crews) and confirmation of record book(ships keel laid after 2005.01.01, according to

Res.MEPC.107(49), the running time which was recorded in data logger of OWS should be corresponded with oil record book.) - Record of delivery note of bunker or lub. Oil should be corresponded with oil record book - The actual quantity of oily bilge tank and sludge tank should be corresponded with oil record book Check for illegal discharge of oily bilge and sludge from the

vessel(temporary discharge pipe or flexible hose) - The periodical maintenance record of fire fighting and life saving equipments(life boat operation test record (both side with picture), condition of weak link of life raft and the expiration date of fire fighting and life saving equipments) - Supply of emergency power source for navigation light panel, fire detection control panel, water ingress system and de-watering system)

*. Detainable Deficiency - Ten(10) major detainable deficiencies and overall inspection - Valid crew license check - Confirmation for running condition of aux. machinery and detention with SMS Failure when crews unfamiliarity - Check for person on duty record related to ships security, visitor list and education record for person in charge of security according to SSP - Emergency response(fire and abandon ship drill, operation of fire equipment, emergency steering etc) check, when unskilled operation and failure for drill, PSCO gives some time for re-education but re-failure after some period brings detention

- USCG asks to wear lifeline when fireman enters into fire during drill - Pressure check of self-breathing apparatus air cylinder of firemans outfit and spare bottle - Expiration date for life saving/fire fighting equipment (invalid equipment should be scraped or managed separately) - Fire detection system in engine room and galley - Check for engine room and S/G room clean condition (connections for piping system, oily insulation for piping, around D/G fuel pump, purifier room floor, S/G ram etc. Leakage is checked after actual operation during some time. Wipe out before entering port) - Emergency stop for Fan and fuel pump - Installation of weather-tight door and fire door in accommodation - Quick closing valve operation test(Control air reservoir pressure) - Record for ozone depleting substances - Record and procedure of low sulphur bunker change-over - Oily water separator, ODME, piping relating MARPOL ANNEX I - Western some area, Intensive inspection of Garbage (SMS deficiency when food waste is found in paper box) - Oil/Chemical Tanker had been considered as a well-maintained ship by oil major inspection. However crews unfamiliarity with below equipment and malfunction causes detention o ODME simulation test o Oil/water surface detector function test o Cargo tank high/overfill alarm test o Cargo pump emergency stop test from manifold o IGG safety test

o O2 analyzer test o Condition of deck seal, PV breaker check o Fixed gas sampling system test o Portable gas detector function and calibration check o Cargo log book o Designation for smoking area - SMS relating detention is getting more and more - Western area(Hawaii, Alaska) also carries out inspections consistently. - Uncompleted repairs and matters during dock in China causes detention - When the equipment relating safety and pollution is out of order before entering port, take a step according to SMS procedure and record and report to USCG

. Tokyo MoU (Japan)

*. Recent Trend - Check for the special requirement for some Class A and C cargoes according to IMSBC Code - The welding should be applied throughout the suction or discharge pipe for emergency fire pump, which penetrates the machinery space, except for th e connection of flange of the sea inlet valve(ships after 2002.07.01 in 2000 SOLAS, (Korean flag ships after 2001.01.05)) - Check for the periodical maintenance record of fire fighting and life saving and radio equipments

*. Detainable Deficiency - Ten(10) major detainable deficiencies and overall inspection - Safety Navigation equipment check (Magnetic/Gyro Compass, Radar, MF/HF) - Newly revised Convention items - Newly revised Certificate (IAPP, IOPP, CDG, IMSBC) - Oil record book - Installation condition of fire integrity around engine room space(close-up check during survey for new ship building and after-construction survey) - ISM performance (fire and abandon ship drill record or actual simulation) - Normal check except CIC - Rectification inspection of deficiency for ships going within Korea-China-Japan - Ocean going vessels are excluded except first entering - Record for fire and abandon ship drill - Installation of compound on cable penetration part(close-up check during survey for new ship building) - Oily water separator filter approved by oil water separator maker should be onboard which kept on stressing for years

. Tokyo MoU (AMSA)

*. Recent Trend - Operation of E/R fan damper and check inside after open the cover of fan - Black out test(simulation test) with familiarity of all crews(it ship adopts test

switch, the sequence of emcy D/G start, insert of ACB, emcy fire pump with emcy source and 2 jets of fire line shooting test will be checked) - Implementation of ISM(record for duty and rest hour of crews, crews familiarity with equipments, revision of chart and corrective action of deficiencies etc.) - Operation of emcy fire pump and leak check(instant operation should be possible even under unloading and no ballast condition) - Operation of oily water separator and check for oil in discharge line from the sampling line(please clean out the discharge pipe and filter)

- Management of helicopter landing area(record for drill, publication and strength assessment for helicopter landing area) - Check for alarms of M/E and D/G(F.O leakage alarm, oil mist alarm etc)

*. Detainable Deficiency - Ten(10) major detainable deficiencies and overall inspection - Navigation plan and up-to-date chart (chart should be supplied before entering port, no permission for chart brought by pilot) - Newly revised oil record book

- Corrosion of lifeboat davit, maintenance, starting sequence - Hatch cover cleat clearance(3~4mm) and corrosion condition - Hatch cover seat condition and Gap check - Condition check for every gas sampling points cap on hatch cover - High pressure double-shield fuel pipe - Sewage treatment operation, circulation line, flexible hose between chambers - Leakage check in cargo hold from ballast tank - Air vent head of ballast, FW, FO, LO tank overhaul inspection - De-watering system operation test - Water ingress system operation test - Life boat lowing test with remote control line, brake test for full speed let-go - MF/HF operation test with DC power(BQ/RQ) - Crews working hour and resting hour, record in log book - Concentrated Inspection Campaign (Gangway, Pilot Ladder) (close-up check during survey for new ship building) - Condition of engine room cleanliness

. Tokyo MoU (China)

*. Recent Trend - Inspections related to oil pollutions became severer and more strengthened after recent oil pollution from drillship in Bohai Bay

*. Detainable Deficiency - Ten(10) major detainable deficiencies and overall inspection - ISM, ISPS relating matter (Minimum manning certificate, resting hour for crews, fire and abandon ship drill record) - ISM relating detention with many deficiencies - Structural safety on Load Line Convention(air pipe, ventilator, weather-tight door etc) - Escape trunk inside size(800mmX800mm) (close-up check during survey for new ship building) - Installation condition of fire detector and call point (close-up check during survey for new ship building) - Em'cy fire pump suction pipe penetrating engine room and insulation for it - Insulation condition(escape trunk, between Bridge and small space, between spaces around engine room, comparison with fire control plan/ fire protection plan) - Gyro repeater information can be seen from emergency steering position (close-up check during survey for new ship building) - Installation and condition of weather-tight door (E/R door, Windlass room door, Lifeboat door & skylight) - Removal of safety pin of CO2 fire extinguisher bottle according to makers Recommendation (close-up check during survey for new ship building) - Installation condition of CO2 system pilot cabinet and alarm test - Operation of 3 way valve of oil water separator, 15ppm alarm and crews familiarity - High pressure double-shield fuel pipe - Operation of quick closing valve (air reservoir pressure and leak check for

control line) - Designated company for repair of PSC deficiency - Tianjin PSCO takes note of sewage treatment system (operation of Air blowing, shipside valve) - PSCO makes use of Ningbo area as a educational field for newcomer, Carrying out inspection with 5~6 company - Crews familiarity of job and system - Low quality of small & medium-size company - Ningbo PSCO carries out intensive inspection of Korean flag vessels after Korean vessel crashed with bridge - Shandong PSCO carries general and intensive inspection from stability to drills * The number of China PSCO is getting more and inspection is getting more intensive, more detail preparation should be implemented by people onboard.

. Indian MoU (India, Iran)

*. Recent Trend and detainable Deficiency - Ten(10) major detainable deficiencies and overall inspection - 5 Major Check Points in India 1. Oil water separator function test(check for by-pass discharge line) 2. Function of emcy fire pump(check for pressure and leakage) 3. Maintenance of lifeboat and drill record 4. ISM related matters(crews familiarity, Certificate, resting hour for crews, crews license)

5. Check for engine room and S/G room clean condition - Safety navigation equipment and GMDSS equipment - up-do-date chart - PSCO does not require any rectification or corrective action of Class.

. Vina Del Mar MoU (South America)

*. Recent Trend - Since 2011.06.20 requirement concerning air cleanness and acclimatization has been stated on Brazilian Health regulation for calling in Brazil. Related maintenance record or Certificate from sanitary authority can be requested by PSCO.

*. Detainable Deficiency - Ten(10) major detainable deficiencies and overall inspection - Clean condition and oil leak check for engine room and below D/G, aroud hatch cover cylinder and steering gear floor) (Brazil requires dry condition for above spaces. No exception) - Load line mark condition - Operation test for emcy fire pump and emcy generator engine (PSCO gives second chance. Success of 2nd start after 1st failure leads to Code. 17) - Maintenance of crews license and manning check comparing to Minimum Manning Certificate - Brazil assigns ISM Code 30 with more than 5 Code 17s

- Brazil indicates many deficiencies relating Load Line Convention - At Brazil, the attitude of Captain is critical during inspection - Argentine PSCO implements rational inspection, but requires main propulsion system to stand-by due to low depth of water of ports (Main engine overhaul is prohibited in should be acquired from Authority ) - Water speed is fast at narrow channels, so both Port and Starboard side anchors should be used at anchorage. And related machinery(anchor chain, hydro motor for windlass) should be properly functioned. (when one side anchor is out of order, 2 tug boats should tug the vessel for 24 hours) Argentine coast, and permission

. Taiwan

*. Recent Trend and detainable Deficiency - Taiwan does not belong to Tokyo MoU. But PSCO uses Tokyo MoU CIC Checklist and inspects Structural safety and International Convention on Load Lines) - Ten(10) major detainable deficiencies and overall inspection - Taiwan dispatched PSCO to major port and has been reinforced inspection - Korean ship managing companies consider Taiwan as a PSC Free Zone and send old ships. And inspection rate is getting higher after 2010. As a result PSC detention rate is getting higher.

. Turkey

*. Recent Trend and detainable Deficiency - Ten(10) major detainable deficiencies and overall inspection - Intensive check for pollution - Valid Certificate and record(ESP File etc.) - Check for general hull condition - Up-to-date SOPEP(list of national operational contact points) - GMDSS equipment function test and familiarity of crews

. Vietnam

*. Recent Trend and detainable Deficiency - Ten(10) major detainable deficiencies and overall inspection - ISM related matters(crews familiarity, Certificate, resting hour for crews, crews license) - High pressure double-shield fuel pipe

Deficiency which should be checked for new ship building

- The welding should be applied throughout the suction or discharge pipe for emergency fire pump, which penetrates the machinery space, except for th e connection of flange of the sea inlet valve(ships after 2002.07.01 in 2000 SOLAS, (Korean flag ships after 2001.01.05))

- Escape trunk inside size(800mmX800mm)(2002.07.01 Keel Laying) after installation of inside Insulation and Structural support shold be sure confirmed - Interference Pilot ladder with overboard scupper - Fire integrity(boundary around engine room, escape route and under-side of bridge etc.) - Installation, distance of fire detector(Ro-Ro ship(2012.07.01 K/L)s movable deck should be applied) - Installation of hatch cover(clearance, weather-tight) check and installation condition of small hatch(interference with support, pipe and weather-tight) - Removal of safety pin of CO2 fire extinguisher bottle according to makers Recommendation (close-up check during survey for new ship building) - Installation of Navigation light - Installation of handrail for escape route in accommodation - Manual call points for CO2 room, emcy generator room are recommended to install. (still discussing in IMO) - Certificate state and endorsement for approved manual - Approved Certificate, publication and manuals should be supplied to ship before ships delivery

Attachment 1 : Check points and guidance for fire fighting drill in UK Attachment 2 : Ireland PSCO Checklist Attachment 3 : USCG Document Checklist(Freight Vessel) Attachment 4 : USCG Document Checklist (Tanker) Attachment 5 : SMC Audit/Periodical survey Document General Checklist

Attachment 1

Check points and guidance for fire fighting drill in UK

Progress for fire fighting drill

o Don t run(panic) when fie-signal for drill coming o Close all doors in accom. on way to muster station o Just carry and don t wear life jacket(it should be used for abandon ship drill) o All crews should be gather at muster station including person on duty confirmation for injured and missing crew. o All crews carry their equipments(fireman s outfit, fire hose etc.) - crews should be informed where equipments store in advance o Don t enter into the accom. area after run out of there because the area is filled with fire and smoke. o Fire hose has proper length to reach to the E/R floor o Fire line for cooling for area around fire should be supplied until end of drill o A jet of fire line for cooling should be held by 2 persons as 1 team - The second officer controls crews on scene - The length of hose should be consisted with 2 or 1 hose according to ship s condition - Duty should be granted in advance o Em cy fire pump should be used for fire in E/R and main fire pump should be used for fire in area of em cy fire pump. o Don t reach to em cy fire via E/R filled with fire and smoke o Fire hose should be carried by at least 2 persons as 1 team who wear BA and fireman s outfit. o The fire team should start to wear fireman s outfit at muster station.

(Fire team is consist of at least 5 persons and the first officer is leader. 2 persons wear fireman s outfit and other 2 persons assist to wear.) o Pressure check for BA and tight test for mast. o Fire team enters into fire zone according to the instruction of first officer. o Feel the surface heat with his hand o The second person of fire team helps not to disturb another person with fire hose entering. o Other people without fireman s outfit must not enter into the fire zone. o Mission of the first fire team is to rescue the injury. o After rescue of the injury, another fire team of at least 2 persons with fireman s outfit enters into the fire zone. o The first officer reports entering and coming out time, name of fire team and pressure of air bottle to the bridge and records on the bulletin board. o At bridge the progress of distress call, report to shore etc. should be carried out. o At bridge condition from on scene report should be recorded on the copied fire control plan. (the fire zone, entrance, situation of fire team etc.) o The third officer records all report on log book o Rescue team is consist of 2 persons - The second officer controls - Stay not far from the fire zone without strong wind (Preparation: stretcher, first aid kit, blanket, basket with water in a half, oxygen respirator, cooking vinyl foil for burn damage etc.) - Move the injury to the safe place and give treatment - Rescue team should know how to use oxygen respirator and wash the burn damage and wrap with cooking foil.

Instruction for fire fighting drill

o Before fire fighting drill, PSCO instructs to crews below and start drill. - According to SOLAS Chapter III Reg.19.3.1, drill should carried out just like actual situation at sea. o All lights can be off to make up the situation but em cy lights can be on for the unforeseeable circumstance. o PSCO gives some information such as assumption of fire in E/R which is filled with fire and smoke. o When the fire zone are designated, report the fire to captain at bridge(personally not with phone). - In many cases, fire report can be omitted. o Don t enter into E/R with big fire and smoke just with a portable fire extinguisher. In that case PSCO considers person without wearing fireman s outfit and coming into the fire zone as a dead person and isolates person from drill. o All persons carrying fire hose and entering into fire zone should wear fireman s outfit. o Arrange for the hose for cooling around fire zone o At bridge all report from the scene should be submitted and properly recorded on log book. o In many cases the rescue team is not familiar with oxygen respirator and treatment of burning damage.

Attachment 2

Ireland PSCO Checklist

Attachment 3

USCG Document Checklist(Freight Vessel)

Attachment 4

USCG Document Checklist (Tanker)

Attachment 5

SMC Audit/Periodical survey Document General Checklist

- DOC - SMS Document, related Master List, NC record of previous audit, corrective action - Crew List, ITC, Ships Registry - Record for internal audit - Officers license, Seamans book - Crew Members Medical Certificate - ISPS (Certificate for SSO Security education, Internal audit record, Record for security education, Test report for security equipment) - PSC record - Emcy towing procedure(new ship:2011.01.01, existing ship:2012.01.01) - Stability booklet, Grain Loading Manual - Loading Instrument Certificate and approved manual - Cargo Securing Manual - ESP survey report file - Maritime information and maintenance - Deck log book record for limited view navigation - Record for self safety management before departure - Publication master list(including IMASAR Manual) - Approved SOPEP - Oil record book(Oil record book II for oil tanker) - ODMC Manual - COW Manual - 15ppm bilge alarm calibration certificate - Garbage management plan - Garbage record book - Garbage placard - IAPP (Oil delivery note file, record of bunker change-over, Inventory for ozone depleting substances, EIAPP certificate, Final technical file) - ISPP (Approved discharge rate for sewage holding tank) - VGP (Vessel General Permit) US EPA issues Permit Coverage - Maneuvering booklet and maneuvering information(W/H) - Cargo operation records, Stowage plan, Cargo manifest, Loading/Discharging plan, MSDS(Material Safety Data Sheets)

- Safety Equipment maintenance record (LRIT, VDR, EPIRB, AIS, SSAS,

Liferaft, Lifeboat & Davit, Immersion suits air test report, CO2 cylinder hydro test record(according to flag), CO2 cylinder weighing, Firemans outfit self breathing apparatus air cylinder hydro test, Safety equipment air cylinder hydro test, EEBD hydro test, Portable fire extinguisher hydro test, Portable fire extinguisher annual test report) SOLAS training manual , fire fighting training manual, fire safety operational booklets Safety radio annual inspection report Radio log Chart list and Chart correction log CSR(Continuous synopsis record) VRP(Vessel response plan) with USCG approval letter Ballast water management plan(BWMP) and Ballast water management record Medical log and Medicine inventory Plan of emcy drill and exercise and their records Emcy drill fire and abandon ship drill (Muster list, scenario) Embarkation ladder load test(first periodical survey after 2010.01.01, can be postponed to next docking survey) VOC management plan(crude oil tanker, 2010.07.01) EU directive 2005/33/EC(Low sulphur 0.1%)