COMPARTMENT MONITORING AND MAINTENANCE

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1 SQEMS OPERATING PROCEDURE OP-TEC-02 1 of 8 References: 1. SCOPE This Procedure scope is to establish criteria and modalities for the planning of hull compartments, status constant monitoring and reporting, implementation of maintenance of Company vessels, structure and protective coatings, in order to assure a safe and efficient performance of the vessels during their full life extension. 2. RESPONSIBILITY Fleet Director To establish the hull structure monitoring and evaluation, and coating management policy. To propose the same to Company Management and get the approval for the vessels maintenance budget. Technical Dept. Mgr. To instruct and overview the hull compartments continuous monitoring in accordance with the policy and the directives of the Fleet Mgr.; To establish eventual prompt or scheduled repairs on hull structures and coatings after evaluation of costs involved to be proposed to Fleet Manager in accordance with the Company policy.; To give directives and support to the Superintendents in performing their duties; To review the status and performance data of the managed vessels; To manage the budget approved by Management; To provide specialized technicians (Nace/Frosio certified coating surveyors/gauging and NDT engineers) if requested, for inspecting/assessing Company compartments conditions. Superintendent To instruct and overview ship s Staff monitoring and reporting; To make periodical inspection on the assigned vessels in order to verify the implementation of the monitoring, correct reporting, any eventual matter highlighted, and any possible overhaul maintenance and repair; To collect all the defects or notes collected in the monitoring, personal inspections, specialized survey reports in order to discuss with Technical Manager and prepare the repair technical spec; To follow any major repair, overhaul and maintenance work related to the hull ; To require extra works if deemed necessary by any prompt issue and to check their completion; To check and approve the purchase requirements of the assigned vessels for the task; To prepare budget to be proposed to the Technical Department Manager. Master and Chief Mate To implement and perform the scheduled hull compartments monitoring, planning the job within the Company required frame time; To assure all Safety measures according to Company and International rules requirements are complied with; To report all the inspection done through AMOS PMS system or manually if system not yet implemented; To provide for the due reports related to: - the STRUCTURE condition - the ANODES (if any) condition - the compartment CLEANING condition - the COATING (if any) condition Prepared by: Reviewed by: Approved by: TECH Dept. Fleet Director General Manager Distribution: to all managed vessels

2 2 of 8 3. PROCEDURE 3.1 Company policy The Company identified as critical issues the following tasks: The monitoring of hull compartments in terms of coating condition and structure integrity; The continuous effort to keep the vessel structure and coating at best condition as defined by Company policy through constant maintenance as deemed necessary; The prompt repair in case of any major outstanding; The study of the cause and possible corrective action for any vessel defect caused by fatigue, or any defect noted. The above in order to safely maintain vessel condition during the whole management life of the vessel allowing a safe and reliable performance for the safety of the vessel Staff and for the interest of any third party. 4. STRUCTURE As any kind of structure vessel steel hull is subject to wear and possible wastage along vessel life,company policy is aimed to get the objective to keep the vessel structure at best condition possible and for sure well within the Technical and Market indicators. We are highlighting a difference between the two aspects by trying to identify first the limits in both the two aspects. As Technical limit we are making reference to the Class limits and conditions. On Market side for tankers the limit is imposed by Condition Assessment Program (CAP) and CAP rating objective fixed as Company target. For bulk carrier considering last IACS requirements and new Common Structural Rules (CSR) the limit is imposed by the target to keep any thickness reduction out of any substantial corrosion limit. In order to attain these requirements Company is requesting a continuous monitoring and reporting in accordance with WIN TEC 06 and 07 and a chain of responsibility in following tasks: reporting said visits in the most precise and correct way (enclosing pictures and drawing abstract) over-viewing of said reports Strictly following ESP program with correct Hull Survey Program preparation, allowing a smooth inspection plan preparation, including staging plan, and definition of technical spec for repairing and dry-docking. In the enclosed tables we sumarize the definition of the Tmin. = minimum thickness acceptable by Class, in reference to a T original or as built (fig. 2.1 on page 3), and the CAP commercial aspects/rating objectives, plus hull rating methodology (pages 6 and 7). In these lines are highlighted following main targets: Premuda steel reduction acceptability criteria for tankers and bulkers (page 3-Fig. 2.1 in red) General Class minimum thickness acceptability for longitudinal and transversal strength members (page 4 and 5). It is here recommended that for any new vessel or new incoming vessel under management a dedicated request to Class that followed the construction must be issued for getting the full list of allowable thickness reduction acceptability (wastage table). Premuda CAP rating objectives (page 6 highlighted in yellow) CAP hull rating methodology, with consideration on good and very good condition, explaining both the Company rating objective and the Company steel reduction acceptability criteria for tanker vessels (page 7 highlighted in yellow). Naturally any major steel job needed during the vessel life management should be organized/scheduled and performed with vessel in repair condition, off hire, better if along dry-docking periods, followed and controlled by qualified people and certified by Class. The above for safety reasons and for reducing at minimum any vessel off hire time with unscheduled activities.

3 3 of Thickness Measurement Guide - Acronyms and definitions Conditions: conditions are issued to ship owners by class, in order to impose improvements, additional surveys or other actions to ensure compliance with rule requirements. CA: a condition on behalf of a flag state that will be issued if the condition is related to statutory surveys where DNV has been authorized. (Pt. 1 Ch. 1 Sec. 3 B803 of the DNV Rules) CAP: condition assessment program. Voluntary hull condition survey, where a ship s hull, machinery or piping system is given one of the following ratings; 1- very good condition, 2- good condition, 3- satisfactory condition or 4- poor condition (below acceptable class standard). CC: a condition of Class will be issued if a condition is related to requirements set by the rules. A CC is subject to specified rectification (e.g. repairs) or operation (e.g. survey) and shall be carried out within a given time limit, in order that the ship retain class. (Pt. Ch. 1 Sec. 3 B802 of DNV Rules) C.N.72.1: classification notes no. 721 Allowable Thickness Diminution for Hull Structure. ESP: Enhanced Survey Program. Requirements for planning, execution and reporting for hull survey of oil/chemical tankers, obo and bulk carriers. Excessive corrosion: an extent of corrosion that exceed the allowable limit, so that steel must be replaced. Ref. Fig. 2.1 Extensive corrosion: an extent of corrosion consisting of hard and/or loose scale, including pitting, over 70% or more of the area under consideration, accompanied by evidence of thickness diminution. IACS: international Association of Classification Societies. DNV is one of 12 member classification societies, which all have to abide by common IACS rules. The other member societies are American Bureau of Shipping, Bureau Veritas, China Classification Society, Germanisher Lloyd, Lloyd s Register of Shipping, Nippon Kaiji Kyokai, Korean Register, Polski Rejester Statkow, Registro Italiano Navale, Rinave Portuguesa and Register of Shipping of the U.S.S.R. Minumum thickness list: List of minimum acceptable thickness values for the structural parts of a ship. An individual list will be made by DNV for each and every ship which is to be measured. MTP: Maritime Technology and Production (DNV centre at Hovik, Norway). Substantial corrosion: where less that 25% of the corrosion margin is left, yet thickness is higher that for excessive corrosion, Limits are stated in the minimum thickness list. Tmin: minumum allowable thickness. Calculated by class and entered into a minimum thickness list. If a steel plate or profile corrodes to a thickness less than this value, it will normally have to be replaced. Tmin list: see minimum thickness list. Tsubst: see Substantial corrosion UTM: Ultrasonic Thickness Measurements, used to determine the thickness of steel plates and profiles. 4.2 Premuda steel reduction criteria

4 4 of Allowable material diminution for general corrosion General Following criteria for allowable diminution on original scantling are given as general class indication. The corrosion margins may however vary in size depending on the decive strenght criteria (yeld strenght, beickling). It should be noted that due to varying stress levels and different stiffemming arrangements this simple criteria may not always be generally applied and following consideration might be applied: Class dedicated wasting table specified for Vessel; Class direct control at Special/Intermediate docking in close up and remote control by Structure Dpt Vessel with length, L >100m, structure within 0.4 L amidships The allowable material diminution is based or requirements for net scantlings at renewal Survey Hull. The method includes criteria to local strength, buckling strength and requirement to hull girder section modulus. The maximum allowable diminution will be determined by the requirement that gives the least reduction. It may be relevant to carry out more detailed calculations in order to get more exact and differentiated results Local strength Control The minimum thickness of plates, stiffener/girder webs or flanges at renewal survey may be determined from the following: General corrosion criteria: tmin= K* t org T org= original as built thickness (documented owner s addition will be subtracted) K = diminution coefficient from tables 3.1 or 3.2 as following.

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8 8 of 8 5 COATING It is well known to everyone the importance that any coating system has got during the last years in consideration of the possibility to prevent any steel structure from corrosion and thickness reduction and in reference to new SOLAS emendaments, specially in way of water ballast tanks and cargo oil tanks/cargo holds.recently 07/2008 also our WIN-TEC 06 has been modified in consideration of IACS Guidelines for Coating Maintenance and repairs that stated the final judgement of tank coating condition not anymore on total tank coating wastage per cent, but on the worst judgement given to any part of tank examined. Company policy on this issue is stating the following: Company is identyfing the needing to have a constant monitoring of coating condition that highlights any coating condition decrease in order to promptly activate a corrective action and plan for next repair time. Company is normally authorizing, in addition to Ship Staff/Office Superintendent routine inspections and in case of any doubt on coating condition judgment, the use of certified NACE/FROSIO coating inspectors, in order to better judge the existing situation and to better plan what needed for the repair. 6 ANODES At the rule development stage anodes could be fitted in water ballast tanks as an addition to coating system in order to prevent starting of corrosion on any coating defect or fitting not protected. Company is underlining that no anodes should be fitted on board of any vessel unless a proper plan has been prepared by competent firm and approved by Company Management. If on any vessel an anode plan has been approved from construction time as additional protection to original coating, the same has to be monitored according to WIN-TEC 06 and reported accordingly. Wastage status must be recorded and eventual replacement scheduled for next docking. 7 CLEANING In reference to this issue Company is stating that any vessel must be maintained in the best cleaning status as possible. Condition must be monitored according to WIN-TEC 06 and 07 in order to be evaluated from Ship Superintendent/Vessel Captain. Special cleaning tasks to be organized in case of particular condition highlighted by tank monitoring. Special attention must be always given to COT during normal tanker operation and mainly before vessel docking. 8 SYSTEMS INSIDE COMPARTMENTS Any system fitted inside any compartments must be briefly inspected and monitored once the compartment is inspected according to WIN TEC 06 and 07. Any defect or consideration regarding their status must be reported in the dedicated spaces or in the notes. 9 SAFETY ALERT The Master shall always report to Technical Department notifying on urgent basis any problem/defect detected out of a supposed routine inspection, reporting it in the most detailed way (eventually sending pictures and structural drawing abstract highlighting the members involved). In case of any issue related to vessel safety and structural integrity immediate notice must be given to the concerned DPA (see OP-SAF-06) in order to provide follow up actions as per Company procedures en force. References: OP-TEC-04 Maintenance and inspection on board WIN-TEC-06 Ballast Tanks and Void Spaces Monitoring WIN-TEC-08 Tanks Washing and Tank Cleaning Equipment