S-9 Vessel Status Report.pdf

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USS LEWIS B. PULLER FORCE GENERATION RISK REDUCTION Federal contract opportunity
Solicitation number
N6817125R0001
Issued by
Department of the Navy Naval Supply Systems Command

About this file

This document is a Request for Proposal (RFP) for the USS LEWIS B. PULLER (ESB-3) Force Generation Risk Reduction (FGRR) requirement. The scope of work consists of repair and maintenance packages for three phases: a regular overhaul-drydock (ROH-DD), lay berth and industrial assistance (IA), and a mid-term availability (MTA) at the contractor's facility within the U.S. Navy's 6th Fleet Area of Responsibility. The Place of Performance is at the contractor's facility or facilities. The solicitation number is N6817125R0001 and it closes on 18 December 2024 at 1500 Central European Time. The contracting agency is the Department of the Navy Naval Supply Systems Command.

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Other files attached to USS LEWIS B. PULLER FORCE GENERATION RISK REDUCTION, newest first.
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Attachment S7 PPI Form Final v5.xlsx XLSX spreadsheet
N6817125R0001 amd 0004.pdf PDF
N6817125R0001 conformed.pdf PDF
N6817125R0001 Amend 0003.pdf PDF
N6817125R0001 Amend 0002.pdf PDF
Attachment S7 PPI Form Final v4.xlsx XLSX spreadsheet
N6817125R0001 USS LBP FGRR.pdf PDF
Attachment S7 PPI Form v4 Posted.xlsx XLSX spreadsheet
N6817125R0001-0002.docx DOCX document
J-1b Lay berth_IA.xlsx XLSX spreadsheet
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J-2b MSC Lay berth_IA WI.pdf PDF
J-2c FDRMC MTA WI.pdf PDF
J-4 GFP LIST.xlsx XLSX spreadsheet
S-3_Foreign ACP Questionnaire.pdf PDF
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J-5_MSC Facility Survey.pdf PDF
S-4_Foreign National Cert.pdf PDF
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S-7 Fire and Safety Plan Checklist.pdf PDF
S-10 LBP Planned Maintenance_Sample SAMM Tasks.xlsx XLSX spreadsheet
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J-1c MTA.xlsx XLSX spreadsheet
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Text version

3 May 2024

VESSEL STATUS REPORT (FOR OWNER) WITH ASSET LISTING

LEWIS B PULLER

Class Number: 15234826 IMO Number: 9656008

Description: General Cargo Vessel Port of Registry: NOT SPECIFIED Flag: United States of America

Call Sign: NPUL Official Number: CG1180362

REGISTERED OWNER: MILITARY SEALIFT COMMAND

WCN: 963232

ADDRESS: 471 EAST C STREET BUILDING SP-64 NAVAL STATION, NORFOLK,

VA 23511-2419 United States

THIS REPORT HAS BEEN PRODUCED FROM FREEDOM AND IS SUBJECT TO ERRORS AND CHANGES THAT MAY OCCUR OUTSIDE THE FREEDOM APPLICATION.

ABS ASSUMES NO RESPONSIBILITY FOR ERRORS OR ACTIONS TAKEN BASED ON THE INFORMATION HEREIN. ABS'S ENTIRE RESPONSIBILITY AND LIABILITY IS

GOVERNED BY THE LICENSE AGREEMENT FOR ABS SURVEY MANAGER

VESSEL STATUS REPORT (FOR OWNER) WITH

ASSET LISTING

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Table of Contents

1 General Information 4

2 Vessel Survey Summary 6

2.1 Class Survey 6

2.2 Statutory Survey 6

2.3 Special Service Survey 6

2.4 ISM Audits 6

2.5 Attendance - In Progress 7

3 Vessel Certificates 8

3.1 Class 8

3.2 Load Line 8

3.3 SOLAS 8

3.4 MARPOL 8

3.5 ISM 8

3.6 Cargo Gear 9

3.7 Other 9

4 Vessel Findings 10

4.1 Condition of Class 10

4.2 Statutory Condition 18

4.3 Class Additional Requirements 20

4.4 Open ISM Non-Conformities - Plan Accepted 21

5 Engineering Findings 24

6 Facility Comments 28

6.1 Class 28

7 Vessel Assets Listing 30

7.1 Compartments - Conditions 30

7.1.1 Tank 30

7.1.2 Void 31

7.2 Special Continuous Survey - Machinery 2 32

7.2.1 Machinery Structures 32

7.2.2 Machinery Assets 33

7.2.3 Outfitting Assets 50

7.3 Special Periodical Survey - Automation 2 51

7.3.1 Machinery Assets 51

7.4 Special Periodical Survey - Hull 2 54

7.4.1 Hull Assets - Compartments 54

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

7.4.2 Hull Assets - Structures 60

7.4.3 Hull Assets - Zones 61

7.4.4 Machinery Assets 61

7.4.5 Outfitting Assets 61

7.5 Annual Survey - Cargo Gear 3 63

7.5.1 Machinery Assets 63

7.6 Annual Survey - Cargo Gear 4 63

7.6.1 Machinery Assets 63

7.7 Annual Survey - Cargo Gear 1 63

7.7.1 Machinery Assets 64

7.8 Annual Survey - Cargo Gear 2 64

7.8.1 Machinery Assets 64

7.9 Retesting Survey - Cargo Gear 2 64

7.9.1 Machinery Assets 64

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

General Information Vessel Information Vessel Name: LEWIS B PULLER Class Number: 15234826 IMO Number: 9656008 Port of Registry: NOT SPECIFIED Flag State: United States of America Call Sign: NPUL Official Number: CG1180362

Description Vessel Description: General Cargo Vessel SOLAS Category: Cargo Ship MARPOL Category: Not an Oil Tanker IBC IGC Category: Not Applicable ISM Category: Other Cargo Ship

Class Information Class Notations: ✠A1, ✠AMS, ✠ACCU, ✠APS

Additional ABS Notations: CRC, MAN, NBLES +, NVIC 2-95 ACP, PMP, RW, UWILD Service Restrictions: Unrestricted Service Record Comments: - Class State: Classed Other State:

Lifecycle State: In Operation, Active Dual/Double/Triple Class: No Previous Class Society : NOT SPECIFIED

Principal Vessel Characteristics Length Overall: 239.33 m Length Between Perpendiculars: 233.22 m Depth (Molded): 15.47 m Breadth (Molded): 50 m Freeboard Assignment:

Freeboard Displacement (tonnes) Deadweight (tonnes) Calculated Freeboard (mm) State Conventional Freeboard from Ring 106664 71577.48 3517 Active

Design Deadweight: 71577.48 tonnes Equipment Number: U-53

Tonnage Information Regulation Gross Tonnage Net Tonnage

ITC 66870 20061

Suez 66654.47 57822.19

New Construction Information Shipyard: GENERAL DYNAMICS NASSCO Hull number: 543 Contract Date: 01-May-2011 Keel Laying Date: 27-Sep-2013 Delivery Date: 12-Jun-2015

Vessel Relations No Data Available

ISM Information

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

SMC Issuer American Bureau of Shipping DOC Issuer American Bureau of Shipping

Owner and Manager Information Registered Owner

Name: MILITARY SEALIFT COMMAND Address: 471 EAST C STREET BUILDING SP-64 NAVAL STATION, NORFOLK, VA 23511-2419 United States

WCN: 963232

ISM Vessel Manager Name: - Address: -

WCN: -

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Vessel Survey Summary

Class Survey

Survey Name Due Date Range Date Last Survey

Date Last Attending ABS Office

Extended/ Force Majeure

Status

Annual Automation Survey 4 11-Jun-2024 11-Mar-2024 - 11-Sep-2024 - - - Due Annual Hull Survey 4 11-Jun-2024 11-Mar-2024 - 11-Sep-2024 - - - Due Annual Machinery Survey 4 11-Jun-2024 11-Mar-2024 - 11-Sep-2024 - - - Due Annual Survey - NBLES 4 11-Jun-2024 11-Mar-2024 - 11-Sep-2024 - - - Due Annual Survey - Preventative Maintenance 4

11-Jun-2024 11-Mar-2024 - 11-Sep-2024 - - - Due

Drydocking Survey 11-Jun-2025 - - - - Not Due Special Continuous Survey - Machinery

11-Jun-2025 11-Mar-2025 - 11-Jun-2025 23-Mar-2024 Dubai Port - Not Due

Special Periodical Survey - Automation

11-Jun-2025 11-Mar-2024 - 11-Jun-2025 - - - Due

Special Periodical Survey - Hull 2 11-Jun-2025 11-Mar-2024 - 11-Jun-2025 - - - Due Tailshaft Survey - Port Tail Shaft 10-Jun-2025 - - - - Not Due Tailshaft Survey - STBD Tail Shaft 10-Jun-2025 - - - - Not Due

Statutory Survey

Survey Name Due Date Range Date Last Survey

Date Last Attending ABS Office

Extended/ Force Majeure

Status

Annual Ballast Water Management Survey 4

11-Jun-2024 11-Mar-2024 - 11-Sep-2024 - - - Due

Annual IAPP Annex VI Survey 4 11-Jun-2024 11-Mar-2024 - 11-Sep-2024 - - - Due Annual IOPP Annex I Survey 4 11-Jun-2024 11-Mar-2024 - 11-Sep-2024 - - - Due Annual Load Line Survey 4 11-Jun-2024 11-Mar-2024 - 11-Sep-2024 - - - Due Annual Safety Construction Survey 4 11-Jun-2024 11-Mar-2024 - 11-Sep-2024 - - - Due Annual Safety Equipment Survey 4 11-Jun-2024 11-Mar-2024 - 11-Sep-2024 - - - Due Periodical Safety Radio Survey 4 11-Jun-2024 11-Mar-2024 - 11-Sep-2024 - - - Due Renewal Ballast Water Management Survey 2

11-Jun-2025 11-Mar-2025 - 11-Jun-2025 - - - Not Due

Renewal IAPP Annex VI Survey 2 11-Jun-2025 11-Mar-2025 - 11-Jun-2025 - - - Not Due Renewal IOPP Annex I Survey 2 11-Jun-2025 11-Mar-2025 - 11-Jun-2025 - - - Not Due Renewal ISPP Annex IV Survey 2 11-Jun-2025 11-Mar-2025 - 11-Jun-2025 - - - Not Due Renewal Load Line Survey 2 11-Jun-2025 11-Mar-2025 - 11-Jun-2025 - - - Not Due Renewal Safety Construction Survey 2 11-Jun-2025 11-Mar-2025 - 11-Jun-2025 - - - Not Due Renewal Safety Equipment Survey 2 11-Jun-2025 11-Mar-2025 - 11-Jun-2025 - - - Not Due Renewal Safety Radio Survey 2 11-Jun-2025 11-Mar-2025 - 11-Jun-2025 - - - Not Due

Special Service Survey

Survey Name Due Date Range Date Last Survey

Date Last Attending ABS Office

Extended/ Force Majeure

Status

Annual Survey - Cargo Gear 4 01-Nov-2024 - - - - Not Due Retesting Survey - Cargo Gear 2 04-Jan-2026 - - - - Not Due

ISM Audits

Survey Name Due Date Range Date Last Survey

Date Last Attending ABS Office

Extended/ Force Majeure

Status

ISM Renewal Audit 2 13-Dec-2025 13-Sep-2025 - 13-Dec-2025 - - - Not Due

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Attendance - In Progress

Port Office Report Number Estimated Last Visit

Date Report Status Survey Tasks

Norfolk Port 6383241 - In Progress Other Survey (Class)

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Vessel Certificates

Class

Certificate Number Certificate Name Term Issue Date Expiry/

Extended Date

Last Certificate State

Last Certificate State Date

15234826-4449513-012 Class Certificate Full Term 04-Jan-2021 11-Jun-2025 Annual/ Intermediate Endorsement

15-Nov-2023

Load Line

Certificate Number Certificate Name Term Issue Date Expiry/

Extended Date

Last Certificate State

Last Certificate State Date

15234826-4449513-027 Deadweight: 71577.48 tonnes International Load Line Certificate

Full Term 04-Jan-2021 11-Jun-2025 Annual Endorsement

15-Nov-2023

YY234826-2283194-001 Survey of Load Lines 12-Jun-2015 - Issued 12-Jun-2015

SOLAS

Certificate Number Certificate Name Term Issue Date Expiry/

Extended Date Last Certificate State

Last Certificate State Date

15234826-5212860-267 ABS Record of Approved GMDSS Radio Installation

10-Jun-2022 - Amended 15-Nov-2023

15234826-5212860-447 ABS Record of Ship Safety Equipment for SLE 10-Jun-2022 - Issued 10-Jun-2022

15234826-4449513-259 Record of Equipment for Statement of Voluntary Compliance for Cargo Ship Radio (Form R)

04-Jan-2021 - Renewed 04-Jan-2021

15234826-5212860-638 Record of Equipment for the Statement of Voluntary Compliance for Cargo Ship Equipment (Form E)

10-Jun-2022 - Re-Issued 10-Jun-2022

15234826-4449513-196 Statement of Voluntary Compliance for Cargo Ship Construction

Full Term 04-Jan-2021 11-Jun-2025 Drydocking/ Bottom Endorsement

15-Nov-2023

15234826-5212860-226 Statement of Voluntary Compliance for Cargo Ship Equipment

Full Term 10-Jun-2022 11-Jun-2025 Periodical Endorsement

15-Nov-2023

15234826-5212860-233 Statement of Voluntary Compliance for Cargo Ship Radio

Full Term 10-Jun-2022 11-Jun-2025 Periodical Endorsement

15-Nov-2023

MARPOL

Certificate Number Certificate Name Term Issue Date Expiry/

Extended Date Last Certificate State

Last Certificate State Date

15234826-3299168-012 Statement of Voluntary Compliance for Energy Efficiency

Full Term 19-May-2017 - Issued 19-May-2017

15234826-3299168-013 Statement of Voluntary Compliance for Energy Efficiency Supplement

19-May-2017 - Issued 19-May-2017

15234826-5450784-241 Statement of Voluntary Compliance for Oil Pollution Prevention

Full Term 18-Sep-2022 11-Jun-2025 Intermediate Endorsement

15-Nov-2023

15234826-5450784-268 Statement of Voluntary Compliance for Oil Pollution Prevention - Supplement Form A

18-Sep-2022 - Re-Issued 18-Sep-2022

15234826-4449513-591 Statement of Voluntary Compliance for Sewage Pollution Prevention

Full Term 04-Jan-2021 11-Jun-2025 Issued 04-Jan-2021

ISM

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Vessel Certificates

ISM

Certificate Number Certificate Name Term Issue Date Expiry/

Extended Date Last Certificate State

Last Certificate State Date

15234826-4556877-005 Safety Management Certificate Full Term 09-Dec-2020 13-Dec-2025 Intermediate Endorsement

15-Nov-2023

Cargo Gear

Certificate Number Certificate Name Term Issue Date Expiry/

Extended Date Last Certificate State

Last Certificate State Date

15234826-5982627-001 Cargo Gear Annual Certificate-5982627-001 Full Term 15-Nov-2023 - Issued 15-Nov-2023 15234826-4449513-007 Cargo Gear Re-testing Certificate-4449513-007 Full Term 04-Jan-2021 - Issued 04-Jan-2021

15234826-2931380-001 Register of Lifting Appliances-2931380-001 12-Jun-2015 - Annual Endorsement

15-Nov-2023

Other

Certificate Number Certificate Name Term Issue Date Expiry/

Extended Date Last Certificate State

Last Certificate State Date

YY234826-2283194-022 Narrative Report - Statement of Fact Full Term 12-Jun-2015 - Issued 12-Jun-2015 YY234826-2283194-023 Narrative Report - Statement of Fact Full Term 12-Jun-2015 - Issued 12-Jun-2015 YY234826-2283194-024 Narrative Report - Statement of Fact Full Term 12-Jun-2015 - Issued 12-Jun-2015 YY234826-2283194-025 Narrative Report - Statement of Fact Full Term 12-Jun-2015 - Issued 12-Jun-2015 YY234826-2283194-026 Narrative Report - Statement of Fact Full Term 12-Jun-2015 - Issued 12-Jun-2015

15234826-5982627-511 Narrative Report - Statement of Fact - Statutory-5982627-511

15-Nov-2023 - Issued 15-Nov-2023

15234826-4449513-298 Record of Anti-Fouling Systems 04-Jan-2021 - Issued 04-Jan-2021

15234826-4449513-219 Statement of Voluntary Compliance for Anti- Fouling System

Full Term 04-Jan-2021 - Issued 04-Jan-2021

15234826-4449513-378 Statement of Voluntary Compliance for Ballast Water Management

Full Term 04-Jan-2021 11-Jun-2025 Intermediate Endorsement

15-Nov-2023

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Vessel Findings Condition of Class Condition No. Status Asset Survey Task Due Survey Task Finding Type/Criticality Date Created Due Date

501.3 Open

Due in 90 days

Main Power Distribution System

Annual Machinery Survey 2 WO# 5212860 attended at NOT SPECIFIED

Outstanding/ Recommendation

10-Jun-2022 11-Jun-2024

Found Condition of Class number 500 was examined and closed during this survey attendance. A potential was cascade failure of the high voltage switchboards was identified for certain situations as documented in the “ESB/ESD Class Notice No 3” dated 31 May 2022 and CoC number 500. A possible modification to resolve the issue was under investigation by the client and

OEM

at the time of the survey last visit date.

The Class Notice No 3 was issued by the client to provide operational guidance to the chief engineer to mitigate chance of recurrence in case of future DAU failure and recovery steps.

Recommended: It is recommended that the final analysis and any proposed modifications to computer-based controls software or hardware be submitted to ABS Engineering for review and tested to the satisfaction of the surveyor.

No Rectification: At the request of the owner the finding due date has been extended in line with the next Annual Machinery Survey due11 September 2023.

An analysis and corrective action under ongoing development by the

OEM

and

MSC.

ACS office authorization provided by email dated 12 September 2022.

Recommended: It is recommended that the final analysis and any proposed modifications to computer-based controls software or hardware be submitted to ABS Engineering for review and tested to the satisfaction of the surveyor.

No Rectification: At the request of the owner the finding due date has been extended for three (3) months until 14 February 2024. An analysis and corrective action under ongoing development by the

OEM

and

MSC.

ACS office authorization provided by email dated 16 November 2023 pending USCG approval, as applicable.

Recommended: It is recommended that the final analysis and any proposed modifications to computer-based controls software or hardware be submitted to ABS Engineering for review and tested to the satisfaction of the surveyor.

No Rectification: It was advised by the Owner representative that subject modification is planned to be completed June-July 2024 by OEM. Owner representative requested to extend subject finding till 11 June 2024, due to unrest in the middle east region and vessels constant urgent mission tasking causing shifts of required maintenance periods and ABS attendance windows of opportunity.

Acceptance on extension of subject due date till 11 June 2024 was received from ACS and Flag Administration.

Recommended: It is recommended that the final analysis and any proposed modifications to computer-based controls software or hardware be submitted to ABS Engineering for review and completed modification as per approved drawings tested to the satisfaction of the Surveyor.

Condition No. Status Asset Survey Task Due Survey Task Finding Type/Criticality Date Created Due Date

503.5 Open

Due in 90 days

Fire Main Charging Pump

Modification Survey (Class)

WO# 5212860

attended at NOT

SPECIFIED

Outstanding/ Recommendation

10-Jun-2022 11-Jun-2024

Found Fire Main Charging Pump Commissioning

The fire main charging pump installation and piping modification was carried out at this time as detailed in this report.

The installation was considered satisfactory, though operational testing and integration to MCCS automation was not completed at the time of vessel departure.

Recommended: Operational testing of the pump is to be carried out to the satisfaction of the surveyor.

Following the installation of MCCS software updates, testing is to be carred out of the fire main charging pump remote control and automatic operation to the satisfaction of the surveyor per the Test Notes and Special Note of the approved installation drawing 8613980 Rev - approved on ABS Houston letter T1913612 dated 09-Oct-2019.

No Rectification: At the request of the owner the finding due date has been extended by 60 days. The owner advised that the installation and testing is scheduled to be completed in the October

VR

period.

testing of the pump is to be carried out to the satisfaction of

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Vessel Findings Condition of Class

Following the installation of MCCS software updates, testing is to be carred out of the fire main charging pump remote control and automatic operation to the satisfaction of the surveyor per the Test Notes and Special Note of the approved installation drawing 8613980 Rev - approved on ABS Houston letter T1913612 dated 09-Oct-2019.

No Rectification: At the request of the owner the finding due date has been extended until 23 December 2022. The owner advised that the installation and testing is scheduled to be completed in the December

ACS office authorization provided by email dated 14 October 2022.

testing of the pump is to be carried out to the satisfaction of

Following the installation of MCCS software updates, testing is to be carred out of the fire main charging pump remote control and automatic operation to the satisfaction of the surveyor per the Test Notes and Special Note of the approved installation drawing 8613980 Rev - approved on ABS Houston letter T1913612 dated 09-Oct-2019.

Partial Rectification: The fire main charging pump was found to be working with local controls and was operationally tested with local control to the satisfaction of

MCCS software remains to be updated to integrate fire main charging pump remote controls and automation.

Recommended: Following the installation of MCCS software updates, testing is to be carred out of the fire main charging pump remote control and automatic operation to the satisfaction of the surveyor per the Test Notes and Special Note of the approved installation drawing 8613980 Rev - approved on ABS Houston letter T1913612 dated 09-Oct-2019.

No Rectification: At the request of the owner the finding due date has been extended for three (3) months until February 2024.

Following the installation of MCCS software updates, testing is to be carried out of the fire main charging pump remote control and automatic operation to the satisfaction of the Surveyor per the Test Notes and Special Note of the approved installation drawing 8613980 Rev approved on

ABS

Houston letter T1913612 dated 09-Oct-2019.

ACS office authorization provided by email dated 16 November 2023 pending USCG approval, as applicable.

Recommended: Following the installation of MCCS software updates, testing is to be carred out of the fire main charging pump remote control and automatic operation to the satisfaction of the surveyor per the Test Notes and Special Note of the approved installation drawing 8613980 Rev - approved on ABS Houston letter T1913612 dated 09-Oct-2019.

No Rectification: Owner representative requested to extend subject finding till 11 June 2024, due to unrest in the middle east region and vessels constant urgent mission tasking causing shifts of required maintenance periods and ABS attendance windows of opportunity.

Owner representative advised that following the installation of MCCS software updates, testing on the fire main charging pump remote control and automatic operation will be completed and presented to the satisfaction of the Surveyor in accordance with the approved installation drawing 8613980 Rev - approved on ABS Houston letter T1913612 while vessel at port on June 2024.

ACS office authorization for extension of the finding was provided by email dated 1 February 2024 and with USCG approval confirmationemail dated 8 February 2024.

Recommended: Following the installation of MCCS software updates, testing is to be carred out of the fire main charging pump remote control and automatic operation to the satisfaction of the surveyor per the Test Notes and Special Note of the approved installation drawing 8613980 Rev - approved on ABS Houston letter T1913612 dated 09-Oct-2019.

Condition No. Status Asset Survey Task Due Survey Task Finding Type/Criticality Date Created Due Date

504.5 Open

Due in 90 days

ACCU Control & Monitoring System

Modification Survey (Class)

WO# 5212860

attended at NOT

SPECIFIED

Outstanding/ Recommendation

10-Jun-2022 11-Jun-2024

Found MCCS Software Updates

The machinery control and monitoring system computer-based controls software was not updated yet at the time of attendance to reflect the following modifications which have been completed on board:

1.

Watertight Door Number open/close status indication (ref to O2E surveyor comment 4715473-E-001).

2.

Removal of water ballast pump number and addition of fire main charging pump.

Recommended: The MCCS software update is to be submitted to ABS Engineering for review and is to be examined and tested to the satisfaction of

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Vessel Findings Condition of Class

The O2E surveyor comment 4715473-E-001 has been closed at this time and converted to condition of class as the modification is completed (Note that stand-alone watertight door remote controls and position indicator panels are isntalled on the vessel.

The

MCCS

has only position indicators does not have remote control of doors.):

As the modifications are part of the MCCS, the development procedures, software quality plan, evidence of software testing, and software version record are to be maintained such that these could be made available to the Surveyor when requested as per 4-9-3/9 and 4-9-3/Table 2 of the SVR. See also 4-9-3/Appendix 1, 7.5 modification of program contents/data in accordance with a procedure. Tests after modifications are to be specifically witnessed by an ABS Surveyor in accordance with 4-9-3/Table item 5.4.

No Rectification: At the request of the owner the finding due date has been extended by 60 days. The owner advised that the installation and testing is scheduled to be completed in the October

Recommended: The MCCS software update is to be submitted to ABS Engineering for review and is to be examined and tested to the satisfaction of

The O2E surveyor comment 4715473-E-001 has been closed at this time and converted to condition of class as the modification is completed (Note that stand-alone watertight door remote controls and position indicator panels are isntalled on the vessel.

The

MCCS

has only position indicators does not have remote control of

As the modifications are part of the MCCS, the development procedures, software quality plan, evidence of software testing, and software version record are to be maintained such that these could be made available to the Surveyor when requested as per 4-9-3/9 and 4-9-3/Table 2 of the SVR. See also 4-9-3/Appendix 1, 7.5 modification of program contents/data in accordance with a procedure. Tests after modifications are to be specifically witnessed by an ABS Surveyor in accordance with 4-9-3/Table

No Rectification: At the request of the owner the finding due date has been extended until 23 December 2022. The owner advised that installation and verification is scheduled to be completed in the December

Recommended: The MCCS software update is to be submitted to ABS Engineering for review and is to be examined and tested to the satisfaction of

The O2E surveyor comment 4715473-E-001 has been closed at this time and converted to condition of class as the modification is completed (Note that stand-alone watertight door remote controls and position indicator panels are isntalled on the vessel.

The

MCCS

has only position indicators does not have remote control of

As the modifications are part of the MCCS, the development procedures, software quality plan, evidence of software testing, and software version record are to be maintained such that these could be made available to the Surveyor when requested as per 4-9-3/9 and 4-9-3/Table 2 of the SVR. See also 4-9-3/Appendix 1, 7.5 modification of program contents/data in accordance with a procedure. Tests after modifications are to be specifically witnessed by an ABS Surveyor in accordance with 4-9-3/Table

No Rectification: At the request of the owner the finding due date has been extended in line with the annual machinery survey due to scheduling delays by the vessel automation vendor for attendance by their technician.

Recommended: The MCCS software update is to be submitted to ABS Engineering for review and is to be examined and tested to the satisfaction of

The O2E surveyor comment 4715473-E-001 has been closed at this time and converted to condition of class as the modification is completed (Note that stand-alone watertight door remote controls and position indicator panels are isntalled on the vessel.

The

MCCS

has only position indicators does not have remote control of

As the modifications are part of the MCCS, the development procedures, software quality plan, evidence of software testing, and software version record are to be maintained such that these could be made available to the Surveyor when requested as per 4-9-3/9 and 4-9-3/Table 2 of the SVR. See also 4-9-3/Appendix 1, 7.5 modification of program contents/data in accordance with a procedure. Tests after modifications are to be specifically witnessed by an ABS Surveyor in accordance with 4-9-3/Table

No Rectification: At the request of the owner the finding due date has been extended for three (3) months until 14 February 2024 due

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Vessel Findings Condition of Class to scheduling delays by the vessel automation vendor for attendance by their technician.

ACS office authorization provided by email dated 16 November 2023 pending USCG approval, as applicable.

Recommended: The MCCS software update is to be submitted to ABS Engineering for review and is to be examined and tested to the satisfaction of

The O2E surveyor comment 4715473-E-001 has been closed at this time and converted to condition of class as the modification is completed (Note that stand-alone watertight door remote controls and position indicator panels are isntalled on the vessel.

The

MCCS

has only position indicators does not have remote control of

As the modifications are part of the MCCS, the development procedures, software quality plan, evidence of software testing, and software version record are to be maintained such that these could be made available to the Surveyor when requested as per 4-9-3/9 and 4-9-3/Table 2 of the SVR. See also 4-9-3/Appendix 1, 7.5 modification of program contents/data in accordance with a procedure. Tests after modifications are to be specifically witnessed by an ABS Surveyor in accordance with 4-9-3/Table

No Rectification: Owner representative requested to extend subject finding till 11 June 2024, due to unrest in the middle east region and vessels constant urgent mission tasking causing shifts of required maintenance periods and ABS attendance windows of opportunity.

As advised by the Owner representative, automation and controls OEM, General Electric Power Conversion, has completed software modifications, worked through with ABS Engineering approval, and is scheduled to be install during 2 June – 17 July 2024 shipyard availability. Software modifications will address at that time Watertight Door indication as well as remove Ballast Pump from machinery controls and monitoring system. Watertight Door interface cable is scheduled for March shipyard availability.

Acceptance from ACS and from USCG was received for above accordingly by emails dated 1st and 8th February 2024.

Recommended: The MCCS software update is to be submitted to ABS Engineering for review and is to be examined and tested to the satisfaction of

The O2E surveyor comment 4715473-E-001 has been closed at this time and converted to condition of class as the modification is completed (Note that stand-alone watertight door remote controls and position indicator panels are isntalled on the vessel.

The

MCCS

has only position indicators does not have remote control of

As the modifications are part of the MCCS, the development procedures, software quality plan, evidence of software testing, and software version record are to be maintained such that these could be made available to the Surveyor when requested as per 4-9-3/9 and 4-9-3/Table 2 of the SVR. See also 4-9-3/Appendix 1, 7.5 modification of program contents/data in accordance with a procedure. Tests after modifications are to be specifically witnessed by an ABS Surveyor in accordance with 4-9-3/Table

Condition No. Status Asset Survey Task Due Survey Task Finding Type/Criticality Date Created Due Date

505.5 Open

Due in 90 days

JP5 Pump Room Fixed CO2 System

Annual Machinery Survey 2 WO# 5212860 attended at NOT SPECIFIED

Outstanding/ Recommendation

10-Jun-2022 11-Jun-2024

Found Modification

JP5

Room

CO2

Fixed Fire Fighting System

A CO2 fixed fire fighting system was found installed in the forward JP5 room. The system was reportedly connected in service until disconnected at the current maintenance period for the annual fire fighting system inspection.

The following items were noted:

1. The modification related to installation of the JP5 Room CO2 Fixed Fire Fighting System was reported to be incomplete/in-progress according to the client’s records though the system had actually been placed in service evidently some time in or 2021.

2. An installation and commissioning report was not available at the time of the survey and no record was available that the system was presented for surveyor examination following installation.

3. Operation instructions were not posted at the CO2 bottles or the remote release station. Operation manual was not available on board and a description had not been included in the vessel SOLAS / fire fighting training manual.

Maintenance tasks are to be added to vessel preventative maintenance system per SOLAS requirements. It was noted that the

JP5

Room system is unique from the existing vessel

CO2

systems in that it has an automatic release function.

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Vessel Findings Condition of Class

4. The system installation differed from the approved drawing in that one of two remote release stations were cancelled.

Engineering comments P-012, P-013, P-014 of project 3928343 were verified and closed at this time.

Recommended: Prior to placing the JP5 Room CO2 Fixed Fire Fighting System in service the system is to be examined against the approved drawings and commissioning testing carried out to the satisfaction of

The system installation in the JP5 Pump Room is optional and not mandatory, so the system was locked-out at this time until commissioning will be completed.

No Rectification: At the request of the owner the finding due date has been extended by 60 days. The owner advised that the installation and testing is scheduled to be completed in the October

Recommended: Prior to placing the JP5 Room CO2 Fixed Fire Fighting System in service the system is to be examined against the approved drawings and commissioning testing carried out to the satisfaction of

The system installation in the JP5 Pump Room is optional and not mandatory, so the system was locked-out at this until commissioning will

No Rectification: At the request of the owner the finding due date has been extended until 23 December 2022. The owner advised that installation and testing is scheduled to be completed in the December

Recommended: Prior to placing the JP5 Room CO2 Fixed Fire Fighting System in service the system is to be examined against the approved drawings and commissioning testing carried out to the satisfaction of

The system installation in the JP5 Pump Room is optional and not mandatory, so the system was locked-out at this until commissioning will

No Rectification: At the request of the owner the finding due date has been extended in line with the annual machinery survey due to scheduling delays by the CO2 system manufacturer for vessel attendance by their technician.

Recommended: Prior to placing the JP5 Room CO2 Fixed Fire Fighting System in service the system is to be examined against the approved drawings and commissioning testing carried out to the satisfaction of

The system installation in the JP5 Pump Room is optional and not mandatory, so the system was locked-out at this until commissioning will

No Rectification: At the request of the owner the finding due date has been extended for three (3) months due to scheduling delays by

CO2

system manufacturer for vessel attendance by their technician.

ACS office authorization provided by email dated 16 November 2023 pending USCG approval, as applicable.

Recommended: Prior to placing the JP5 Room CO2 Fixed Fire Fighting System in service the system is to be examined against the approved drawings and commissioning testing carried out to the satisfaction of

The system installation in the JP5 Pump Room is optional and not mandatory, so the system was locked-out at this until commissioning will

No Rectification: Owner representative requested to extend subject finding till 11 June 2024, due to unrest in the middle east region and vessels constant urgent mission tasking causing shifts of required maintenance periods and ABS attendance windows of opportunity.

It was reported by the Owner Representative that ship was delivered and approved without JP5 Room CO2 fire suppression system. Military Sealift Command (MSC) decided to upgrade and install system. Final ventilation, pump shutdown wiring requires installation and OEM, Hiller Systems, needs to attend for final commissioning. Plan is to complete wiring during March 2024 shipyard availability and have OEM, commission during 2 June – 17 July 2024 shipyard availability.

Acceptance from

ACS

and from

USCG

was received for above accordingly by emails dated 1st and 8th February 2024.

Recommended: Prior to placing the JP5 Room CO2 Fixed Fire Fighting System in service the system is to be examined against the approved drawings and commissioning testing carried out to the satisfaction of

The system installation in the JP5 Pump Room is optional and not mandatory, so the system was locked-out at this until commissioning will

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Vessel Findings Condition of Class Condition No.

Status Asset Survey Task Due Survey Task Finding Type/Criticality Date Created Due Date

508.3 Open

Due in 90 days

Indicator

Modification Survey (Class)

WO# 5212860

attended at NOT

SPECIFIED

Outstanding/ Recommendation

10-Jun-2022 11-Jun-2024

Found Modifications

MILCREW

TEU

Reefer Locked-in Alarms

Reefer modules related to the following engineering comments have been installed on board. The comment has been closed at this time and converted to condition of class.

T1877268|T1883837|T1926473;

MILCREW

Reefer TEUs Locked-in Alarm;

436-8614086 (E-002)

Recommended: The alarms are to be installed and tested to the satisfaction of

Reefer TEUs Locked-in Alarm;

We received the revised drawing submitted with TEU Lock-in Alarm Panel added at the command center. We also note that the DAU connection has been removed. Please note that the refrigerated space alarm is to be annunciated at the normally manned control station upon activation of lock-in alarm pushbutton at the TEUs (10-12, 14, 15, 16, 17). Surveyor to verify that the alarm is annunciated at the normally manned location as per Steel Vessel Rules 4-8-2/11.7.3.

No Rectification: At the request of the owner the finding due date has been extended in line with the next Annual Machinery Survey due11 September 2023.

At the last on board survey attendance the refrigerated container was examined and noted to not have self-closing doors and did not have automatic closing latch. Therefore the risk of an individual being accidently locked in was considered low and supports the due date extension to allow time for the owner to arrange the modification and installation of lock-in alarms.

Recommended: The alarms are to be installed and tested to the satisfaction of

Reefer TEUs Locked-in Alarm;

We received the revised drawing submitted with TEU Lock-in Alarm Panel added at the command center. We also note that the DAU connection has been removed. Please note that the refrigerated space alarm is to be annunciated at the normally manned control station upon activation of lock-in alarm pushbutton at the TEUs (10-12, 14, 15, 16, 17). Surveyor to verify that the alarm is annunciated at the normally manned location as per Steel Vessel Rules 4-8-2/11.7.3.

No Rectification: At the request of the owner the finding due date has been extended for three (3) months until February 2024.

At the last on board survey attendance the refrigerated container was examined and noted to not have self-closing doors and did not have automatic closing latch. Therefore the risk of an individual being accidently locked in was considered low and supports the due date extension to allow time for the owner to arrange the modification and installation of lock-in alarms.

ACS office authorization provided by email dated 16 November 2023 pending USCG approval, as applicable.

Recommended: The alarms are to be installed and tested to the satisfaction of

Reefer TEUs Locked-in Alarm;

We received the revised drawing submitted with TEU Lock-in Alarm Panel added at the command center. We also note that the DAU connection has been removed. Please note that the refrigerated space alarm is to be annunciated at the normally manned control station upon activation of lock-in alarm pushbutton at the TEUs (10-12, 14, 15, 16, 17). Surveyor to verify that the alarm is annunciated at the normally manned location as per Steel Vessel Rules 4-8-2/11.7.3.

No Rectification: Owner representative requested to extend subject finding till 11 June 2024, due to unrest in the middle east region and vessels constant urgent mission tasking causing shifts of required maintenance periods and ABS attendance windows opportunity.

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Vessel Findings Condition of Class

It was reported by the Owner representative that complete alarm systems are to be installed in mobile refrigerated containers installed on Mission Deck. Final installation will be presented to attending Surveyor while vessel approaches shipyardat June 2024.

Acceptance from ACS and from USCG was received for above accordingly by emails dated 1st and 8th February 2024.

Recommended: The alarms are to be installed and tested to the satisfaction of

Reefer TEUs Locked-in Alarm;

We received the revised drawing submitted with TEU Lock-in Alarm Panel added at the command center. We also note that the DAU connection has been removed. Please note that the refrigerated space alarm is to be annunciated at the normally manned control station upon activation of lock-in alarm pushbutton at the TEUs (10-12, 14, 15, 16, 17). Surveyor to verify that the alarm is annunciated at the normally manned location as per Steel Vessel Rules 4-8-2/11.7.3.

Condition No. Status Asset Survey Task Due Survey Task Finding Type/Criticality Date Created Due Date

520.3 Open

Due in 90 days

Potable Water System - Ship Service

Repair Survey (Class) WO# 5593580 attended at NOT SPECIFIED

Outstanding/ Recommendation

17-Jan-2023 11-Jun-2024

Found The owner reported that the Mission Reverse Osmosis unit (forward potable water unit) had developed piping and valve leaks due to corrosion. The brine overboard back pressure regulating valve and RO unit HP inlet relief valve were found with corroded and leaking fittings along with piping pinholes.

Recommended: The RO unit was examined and considered acceptable for continued temporary use until permanent repairs are carried out within 3 months. The RO unit is to be repaired and tested to the satisfaction of the surveyor.

No Rectification: At the requestof the Owners the due date for the finding was extended until annual machinery survey #3.

Recommended: The RO unit was examined and considered acceptable for continued temporary use until permanent repairs are carried out prior annual machinery survey #3. The RO unit is to be repaired and tested to the satisfaction of the surveyor.

No Rectification: At the request of the owner the finding due date has been extended for three (3) months until February 2024.

ACS office authorization provided by email dated 16 November 2023 pending USCG approval, as applicable.

Recommended: The RO unit was examined and considered acceptable for continued temporary use until permanent repairs are carried out prior annual machinery survey #3. The RO unit is to be repaired and tested to the satisfaction of the surveyor.

No Rectification: Owner representative requested to extend subject finding till 11 June 2024, due to unrest in the middle east region and vessels constant urgent mission tasking causing shifts of required maintenance periods and ABS attendance windows of opportunity.

It was reported by the Owner Representative that Reverse Osmosis Unit was tested by current Chief Engineer but vessel was not able to show to local Surveyor prior to last port/shipyard availability due to time restraints and urgent mission tasking.

Acceptance from ACS and from USCG was received for above accordingly by emails dated 1st and 8th February 2024.

Recommended: The RO unit was examined and considered acceptable for continued temporary use until permanent repairs are carried out prior annual machinery survey #3. The RO unit is to be repaired and tested to the satisfaction of the surveyor.

Condition No. Status Asset Survey Task Due Survey Task Finding Type/Criticality Date Created Due Date

543.1 Open

Due in 90 days

14" Butterfly Valve Ovbd No.14

Drydocking Survey

WO# 5982627

attended at NOT

SPECIFIED

Outstanding/ Recommendation

14-Nov-2023 11-Jun-2024

Found IT WAS REPORTED by the vessel management that port side high sea chest inlet valve was not able to be closed.

Owners arranged diving team to carry out repair using a cofferdam on the exterior hull. Due to shallow water depth at

ASRY

berth, owners proposed to move the vessel to

KBSP

Bahrain to carry out the permanent repairs.

Flag administration concurrence obtained vide email dated 08- Nov-2023. The diving company cofferdam design was going through an approval process per MSC procedures but the review has not been completed and the approval process was holding up the repair work.

A second diving company was contracted to closely work with the MSC review board to design and fabricate an

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Vessel Findings Condition of Class approved cofferdam suitable for this application.

Per latest schedule a short window 28 November to 02 December vessel availability could be utilized pending MSC approval of a cofferdam.

The second vessel availability is scheduled from January to January 2024.

The owner has issued a calculated risk assessment with mitigating actions, as follows:

Crew notified of the open ship side valve.

Develop a dewatering plan since progressive down-floodingis concern.

Daily verification the bilge suction in way of the high sea chest is operational.

Redundancy present with ability to cross-connect.

Ability to take suction from the low sea chest.

Recommended: Repair and test to the satisfaction of attending Surveyor.

No Rectification: Owner representative requested to extend subject finding till 11 June 2024,due to unrest in the middle east region and vessels constant urgent mission tasking causing shifts of required maintenance periods and ABS attendance windows of opportunity.

It was reported by the Owner representative that the Risk assessment was completed by ship’s Master/Chief Engineer and shared with local surveyor prior to departure from shipyard in November 2023. Replacement valves are on board.

Cofferdam design requires final MSC Engineering approval. ASRY shipyard is on contract to fabricate cofferdam, organize dive company and supply labor to change out both strainer isolation valves.

Acceptance from ACS and from USCG was received for above accordingly by emails dated 1st and 8th February 2024.

Recommended: Repair and test to the satisfaction of attending Surveyor.

Condition No. Status Asset Survey Task Due Survey Task Finding Type/Criticality Date Created Due Date

545.1 Open

Due in 90 days

Ballast Piping

Annual Machinery Survey 3 WO# 5982627 attended at NOT SPECIFIED

Outstanding/ Recommendation

15-Nov-2023 11-Jun-2024

Found IT WAS REPORTED that the ballast suction piping connected to port aft sea chest and serving General Services, Fire Pump, port side was found holed. The hole is located approximately 1.5 meter before the pump at 18:00 position looking forward. The crew installed a temporary repair patch using fiberglass. The repair was tested to MAWP and found satisfactory. The damaged section of pipe spool can be isolated on both sides of the holed section by closing two (2) ballast valves leaving the pipe spool dry. The pipe spool serves the emergency sea suction, so if not in use then blank off the damaged section of pipe to avoid further pipe deterioration. Risk assessment from the Master only verbal due to Master's workload. Mitigating action is to keep the pipe spool dry and isolated as much as possible. If schedule permits a new spool will replace the holed spool in the January 07-21 2024 VR-period.

Recommended: IT IS RECOMMENDED that the pipe spool is replaced and tested to the satisfaction of the attending Surveyor.

No Rectification: Owner representative requested to extend subject finding till 11 June 2024, due to unrest in the middle east region and vessels constant urgent mission tasking causing shifts of required maintenance periods and ABS attendance windows of opportunity.

It was reported by the Owner representative that temporary repairs in means of placed patch on the pipe holds/stays in tact. Photo was provided to undersigned Surveyor for review. Permanent repairs are planned to be carried out on June as planned by the owner representatives.

Acceptance from ACS and from USCG for extension till 11 June 2024 was received for above accordingly by emails dated 1st and 8th February 2024.

Recommended: IT IS RECOMMENDED that the pipe spool is replaced and tested to the satisfaction of the attending Surveyor.

Condition No. Status Asset Survey Task Due Survey Task Finding Type/Criticality Date Created Due Date

548.1 Open

Due in 90 days

Ship's Plans/Designs

Modification Survey (Class)

WO# 5982627

attended at NOT

SPECIFIED

Outstanding/ Recommendation

15-Nov-2023 11-Jun-2024

Found Modification Structural and Outfitting Mods Forward Decontamination Station

Structural modifications in accordance with drawing number 8497773 Rev -, was carried out at this time. The drawing was approved vide

ABS

Engineering Task reference T1671757.

The modification was visually examined, welds were surface NDE, weathertight vent opening was hose tested and

LEWIS B PULLER

CLASS NUMBER: 15234826

IMO Number: 9656008

In Operation, Active, Classed Date of Report: 3 May 2024

Vessel Findings Condition of Class found satisfactory.

Pending:

Weathertight door leading into the first room was leaking during the hose test.

The two (2) interior doors have a lap frame configuration but the lap joint is only tagged in place. The space is required to be gastight, which it is not.

Electrical cables have not been run and the bulkhead penetrations have not been sealed gastight.

The overhead electrical penetrations are not gastight.

Recommended: IT IS RECOMMENDED that the decontamination space be completed and re-inspected to the satisfaction of the attending Surveyor.

No Rectification: Owner representative requested to extend subject finding till 11 June 2024, due to unrest in the middle east region and vessels constant urgent mission tasking causing shifts of required maintenance periods and ABS attendance windows of opportunity.

It was reported by the Owner representative that no changes were done since condition of class issued. It was stated that this is a small room in the forward house that is being converted to a decontamination station. Approved modifications were not complete prior to departure from shipyard availability in November 2023. Plan is to complete during the June shipyard availability.

Acceptance from ACS and from USCG for extension till 11 June 2024 was received for above accordingly by emails dated 1st and 8th February 2024.

Recommended: IT IS RECOMMENDED that the decontamination space be completed and re-inspected to the satisfaction of the attending Surveyor.

Statutory Condition Condition No. Status Asset Survey Task Due Survey Task Finding Type/Criticality Date Created Due Date

546.1 Open

Due in 90 days

Embarkation Ladder

Periodical Safety Equipment Survey

2 WO# 5982627

attended at NOT

SPECIFIED

15-Nov-2023 11-Jun-2024

Found IT WAS REPORTED by the vessel management that the two (2) aft most embarkation ladders were worn out and needed to be replaced. Two (2) ladder covers were delivered to the vessel but an error had occurred so no embarkation ladders were delivered to the vessel.

A temporary solution has been incorporated onboard for the two (2) aft-most located embarkation ladders utilizing shackles to avoid using the deteriorated manila rope ends of the ladders making them useable in an emergency.

Lead time on new embarkation ladders makes it a possibility they can be installed onboard in the VR period 07-21 January 2024.

Recommended: IT IS RECOMMENDED that the aft most two (2) embarkation ladders be replaced at earliest opportunity.

No Rectification: Owner representative requested to extend subject finding till 11 June 2024, due to unrest in the middle east region and vessels constant urgent mission tasking causing shifts of required maintenance periods and ABS attendance windows of opportunity.

It was reported by the Owner representative that embarkation ladders work fine. They are long enough to omit/bypass the degraded section at the top and move the shackles to lower attachment points on the ladders, effectively…

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