ANNEX 6 - COMPANY S ENVIRONMENTAL TAG & BILGE VALVE SIGNAGE SYSTEM

Fleet Management India Pvt.Ltd. Revision: 2 ANNEX 6 - COMPANY S ENVIRONMENTAL TAG & BILGE VALVE SIGNAGE SYSTEM Preface This instruction has been prepared to provide Ship s Staff and Shore based personnel with a clear description and pictorial representation of the Company s Environmental Tag and Bilge valve signage system. Contents 1. Identification of sealing points and methods of sealing 1.1 General criteria 1.2 Review of Drawings 1.3 On-Site Survey 1.4 Types of seals provided 1.4.1 Managing wire seals 2. Methods of sealing flanges, compression fittings and valves 3. Specific systems & locations required to be sealed and marked. 4. Instructions for grouping sealing points, assigning location numbers, printing location & warning tags and preparing the Master list of seals. 4.1 Instructions for grouping of sealing points and numbering of sealed locations 4.2 Instructions for printing & fitting warning-cum-location tags. 4.3 Templates of Warning and Location tags. 4.4 Master List of Seals 5. Alternative methods of sealing 6. Discontinued methods of sealing Environmental Management System Annex 6 Page 1 of 47

Fleet Management India Pvt.Ltd. Revision: 1 1. Identification of sealing points & assigning of location numbers 1.1 General Criteria: The following components require sealing, to prevent them from being used to facilitate unauthorized discharge overboard of water that has accumulated in the Engine Room Bilges, oily water accumulated in other parts of the vessel, sludge oil or other marine pollutants. Seals must be uniquely numbered and attached in such a way that the component being sealed cannot be opened without breaking the seal. Seals may not be broken or removed without notifying the Chief Engineer. a) Oily Water Separator and Oil Content Meter piping. b) Emergency Bilge suction valves, Direct Bilge suction valves and cross-over valves between Engine room Bilge mains and suction piping of large capacity sea water pumps and Eductors. c) Bilge and Sludge piping suction and discharge. d) Flanges of readily removable sections of piping leading overboard sealing alternate flanges may be sufficient provided no section of piping can be removed without breaking the seals. Pipelines of large diameter (generally over 150 mm nominal dia.) need not be sealed; for example, sea water piping leading overboard which is over 150mm nominal dia need not to be sealed. e) Blind Flanges fitted to piping leading overboard. f) Access covers of sludge and bilge tanks i.e., those included in the IOPP certificate appendix A/B, sections 3.1 and 3.3. g) Access covers of cofferdams and void spaces in the engine room. h) Sea water piping of heat exchangers where nominal dia is 150 mm or less. i) Eductor piping. j) ODME piping. k) Pressure gauge and thermometer connections on piping leading overboard. l) Standard Discharge connections for Bilge, Sludge and Sewage. m) Anchor wash piping and eductor piping in forepeak store. n) Boiler Blow down line complete from Boiler up to overboard. o) High sea suction, low sea suction and emergency sea suction steam blow line and air vent lines. p) Suction strainers of sea water pumps vent and drain valves. q) Sewage discharge pump suction line and discharge line up to over board. r) Sewage piping leading overboard and to Sewage Plant; inspection / access manholes and covers of Sewage Plant. s) Standard discharge connections for Sludge, Bilge and Sewage. t) Bunker manifold blanks on deck. 1.2 Review of Drawings: Engine room piping drawings must be reviewed to establish the following: 1) The number, identity and location of Direct Bilge Suction valves that lead to the suction side of large capacity pumps such as the Fire and G/S pump. Environmental Management System Annex 6 Page 2 of 47

Revision: 1 2) The number, identity and location of Emergency Bilge suction valves leading to large capacity pumps such as the Main Cooling Sea Water pump. 3) The number, identity and location of Bilge crossover valves connecting the engine room bilge main to the suction piping of large capacity pumps such as the Bilge and Ballast pump or the Ballast / cargo hold eductors. 4) The identity and location of the suction valves of spaces such as the Duct Keel, Cofferdams, Void Spaces, Clean Drain tanks etc. so that the opening of these valves may be controlled. 5) The interconnection between cargo hold and engine-room bilge lines in order to determine the feasibility of removing this interconnection (without compromising the readiness in an emergency to connect the e/r bilge main or the cargo hold bilge line to the suction side of large capacity pumps and always under approval from Class). 1.3 On-Site survey: A survey of the engine room and other machinery spaces, from which there is a possibility of illegal discharges of oily water or oil or other polluting liquids, should be carried out. The purpose of this survey is to determine the components that must be sealed or otherwise controlled in order to ensure that discharges of pollutants or possible pollutants cannot be undertaken without breaking numbered seals or without obtaining authorization of the Chief Engineer or Master. During such survey, the systems and components that require to be sealed will be identified. 1.4 Types of seals Fig 1. Sticker seal Fig 2. Wire seal Fig 3. Plastic seal Environmental Management System Annex 6 Page 3 of 47

1.4.1 Managing wire seals When a packet of wire seals is received, Sort the seals into smaller, numbered packets of 10 seals each for ease of accounting, and record in EMS-03 (Running List of Seals). All seals must be kept only in the Master s custody, under lock and key. When issuing seals, open only the necessary numbers of these smaller packets and do not put the remaining seals back into an opened packet. Environmental Management System Annex 6 Page 4 of 47

2. Methods of sealing flanges, compression fittings and valves 2.1 Flanges 2.1.1 Sticker seals This is the preferred option for sealing of Flanges, except in an exposed location, such as the Main Deck 2.1.2 Wire seals Fig 4. Sealing of flanges by sticker seal Holes should be drilled in two bolts at opposite ends of the flange, the wire drawn tightly through both and then sealed. The photo depicts only one bolt the other cannot be seen. Fig 5. Environmental Management System Annex 6 Page 5 of 47

Fleet Management India Pvt.Ltd. 2.2 Compression fittings and small valves Sticker seals are the preferred option. Fig 6. Fig 7. Fig 8. Fig 9. ODME line valve sealed in open position Fig 10. OCM inlet valve Fig 11. OCM line valve sealed in open position Environmental Management System Annex 6 Page 6 of 47

Fleet Management India Pvt.Ltd. 2.3 Sealing of valves As shown below, the valve wheel is sealed with two wire seals passing through holes in flange bolts and drawn tight before sealing. Although bonnet is also sealed, in this case, as the wire is tight enough to prevent the bonnet from being opened, it is not necessary. Fig 12 Fig 13 The aim is to seal the valve in such a way that neither the wheel nor the bonnet can be removed without breaking a seal. Fig 14. Angle valve flange sealed with wire and valve bonnet sealed with sticker. Fig 15. Globe valve sealed on the flange and bonnet. Environmental Management System Annex 6 Page 7 of 47

Fleet Management India Pvt.Ltd. 3. Specific systems and locations required to be sealed and marked : The list below is not exhaustive or typical and additional or lesser systems may require to be sealed depending on the specific layout of each vessel. 1) OILY WATER SEPARATOR & OIL CONTENT METER a) Adaptors at both ends of sample line from OWS to OCM and any adaptors in between must be sealed. b) The sample line from OWS to OCM must be painted a distinctive colour that will distinguish it from other similar-sized piping in the vicinity. c) Any valves fitted at either end of the sample line and any valves in between must be sealed in the open position. d) If any drain line is provided in sample line same to be sealed in closed position. e) Electric cabling for 3/way valve must be sealed at both ends so that it cannot be disconnected without breaking the seal. f) Adaptors of Pneumatic line to the 3-way valve must be sealed so that it cannot be disconnected from the valve without breaking the seal. g) If it is necessary to open the OCM box for testing purposes, cabling inside must be sealed to make it tamper-proof. If not necessary to open the OCM box for operational purposes, the cover should be sealed. h) All alternate flanges of Bilge piping from Bilge tank to Pump and from pump through OWS to overboard discharge at ship s side must be sealed in such a way that will ensure that no section of this piping can be disconnected without breaking a seal. i) Piping from the OWS to overboard discharge valve, including the 3-way valve and re-circulating line from 3-way valve must be painted with orange/red paint with arrows indicating flow direction marked. j) OWS overboard discharge valve at ship s side must be enclosed by a box that is locked with two padlocks one with key only with Master and the other with the C/E. k) All valves in the OWS piping from the OWS to the ship s side must also have their bonnets sealed using sticker seals. Photos showing examples of ows & ocm sealing and marking Fig 16. As shown above, the entire overboard piping must be marked with Hi-Visibility Orange / Red paint and must indicate the flow direction of the effluent. Environmental Management System Annex 6 Page 8 of 47

Fig 17. OWS overboard valve locking arrangement the keys of one lock are to be only with the Master, while the keys of the other lock are to be only with the Chief Engineer, so that consent of both persons is given before the OWS can be operated to pump out Bilge Water. Fig 18. Sealing of OCM sample line valve and adaptor Fig 19. Sealing of sample line, inlet to OCM Valve Bonnet sealed Environmental Management System Annex 6 Page 9 of 47 Fig 20. Sealing of OWS overboard valve flange with Bonnet also sealed

Fleet Management India Pvt.Ltd. Seal pasted across screw of plate covering PCB & other electronic Components. Seals pasted on plastic sheet covering OCM internal wiring. Fig 21. Sealing of OCM internal wiring (OCM needs to be opened for testing) OCM cover sealed. OCM sample inlet filter, adaptor sealed. OCM sensor tube drain valve sealed in closed position. Fig 21a. Sealing of OCM (box does not need to be opened for testing). Environmental Management System Annex 6 Page 10 of 47 Fig 22. Sealing of pneumatic line connections & electric cabling of 3-way valve

As shown in the OWS schematic diagram above: The OWS piping from the OWS to overboard via the 3-way valve must be painted with Hi- Visibility orange red paint. The direction of flow must be clearly marked. Alternate flanges on the OWS piping must be sealed with Marpol seals. The OWS effluent sample inlet piping must be sealed at both ends. In case there are any ferrules or connections on the sample line each and every ferrule/connection must be sealed to make the line tamper proof. The sample line must be painted a distinctive colour (ex. High-visibility orange / red paint) to distinguish it from similar sized piping in the vicinity. The OWS overboard valve must be placed in a box and locked with two padlocks. The fresh water inlet valve must be painted blue. 2) BILGE CROSS-OVER VALVES Bilge cross over valves refers to valves that connect the engine room bilge main to the suction side of Fire and GS pump and to Bilge and ballast pump. There may also be a separate cross-over valve between the cargo hold bilge line and the engine room bilge line. Environmental Management System Annex 6 Page 11 of 47

Fleet Management India Pvt.Ltd. If removal of such cross-connections does not compromise SOLAS requirements of having at least two large capacity power pumps available for pumping out E/R bilges in case of emergency (this requirement is usually met by the Direct Bilge Suctions and Emergency Bilge Suctions) and similarly does not compromise the pumping out of Cargo Hold bilges by large capacity pumps, the cross-connection must be removed and both ends blanked and sealed after obtaining written approval from the vessel s Classification Society. Any modification should be shown and endorsed on the piping Drawings. Refer to Fig. 29. If it is not possible to remove such cross-over connections, then: a) Valve wheel and valve body must be painted a distinctive colour (suggest Red) b) A sign board should be posted near the valve with the words in lettering three inches in height stating BILGE CROSS-OVER, EMERGENCY USE ONLY, OR Lettering three inches in height should be painted on floor plates adjacent to the valve stating BILGE CROSS-OVER, EMERGENCY USE ONLY. c) The valve should be sealed in such a way that will prevent the valve wheel from being turned or lifted off the spindle or the bonnet of the valve from being removed without breaking the seal. To achieve this, it may be necessary to place additional sticker seals across the wheel nut at the top of the spindle and across the nut at the base of the spindle (in case of an extended spindle), near the Bonnet. 3) DIRECT BILGE SUCTION VALVES Direct bilge suction refers to valves that directly connect the engine room bilge wells or tanktop with the suction side of large capacity pumps such as the Fire & G/S pump and the Bilge & Ballast pump with no intervening valves. a) Valve wheel and valve body must be painted a distinctive colour (suggest Red) b) A sign board should be posted near the valve with the words in lettering three inches in height stating DIRECT BILGE SUCTION, EMERGENCY USE ONLY, OR Lettering three inches in height should be painted on floor plates adjacent to the valve stating DIRECT BILGE SUCTION, EMERGENCY USE ONLY. c) The valve should be sealed in such a way that will prevent the valve wheel from being turned or lifted off the spindle or the bonnet of the valve from being removed without breaking the seal. To achieve this, it may be necessary to place additional sticker seals across the wheel nut at the top of the spindle and across the nut at the base of the spindle (in case of an extended spindle), near the Bonnet. 4) EMERGENCY BILGE SUCTION VALVE a) Valve wheel and valve body must be painted a distinctive colour (suggest Red) Environmental Management System Annex 6 Page 12 of 47

b) A sign board should be posted near the valve with the words in lettering three inches in height stating EMERGENCY BILGE SUCTION, EMERGENCY USE ONLY, OR Lettering three inches in height should be painted on floor plates adjacent to the valve stating EMERGENCY BILGE SUCTION, EMERGENCY USE ONLY. c) The valve should be sealed in such a way that will prevent the valve wheel from being turned or lifted off the spindle or the bonnet of the valve from being removed without breaking the seal. To achieve this, it may be necessary to place additional sticker seals across the wheel nut at the top of the spindle and across the nut at the base of the spindle (in case of an extended spindle), near the Bonnet. PHOTOS SHOWING EXAMPLES OF CROSS-OVER, DIRECT AND EMERGENCY BILGE VALVES SEALING AND MARKING Lettering 3 high Fig 24. The photo shows direct bilge suction and cross over bilge suction valves. Fig 25. The valve wheel has been sealed by wire seal to the bonnet and sticker seal has been applied to bonnet flange. Environmental Management System Annex 6 Page 13 of 47

Lettering 3 high Fig 26. The stencil color should be contrast to floor plate color. Lettering 3 high Fig 27. Valve is below the floor Fig 28. Valve onnet sealed with sticker seal CARGO ENGINE ROOM INTERCONNECTION REMOVED Sticker seal should be used and welded nuts removed. Environmental Management System Annex 6 Page 14 of 47 Fig 29. Cargo-Engine Room Bilge interconnection removed (Class approval required)

5) BILGE PUMP SUCTION & DISCHARGE PIPING a) The manhole of the Bilge Holding tank must be sealed suggested method of sealing is to use 2 nos wire seals, each fitted to studs at opposite ends of the manhole cover, as sticker seals are liable to be damaged. b) The manhole / inspection cover of the primary bilge tank should be sealed, unless it is designed to remain open (to allow evaporation). c) Alternate flanges of Bilge suction piping from Bilge Holding Tank to OWS service pump and from OWS service pump through OWS to overboard discharge at ship s side must be sealed in such a way that will ensure that no section of this piping can be disconnected without breaking a seal. d) If a Bilge Daily pump is additionally provided for transferring Bilge water from Bilge wells to Bilge holding tank then the piping from the pump to the Bilge holding tank must be sealed. e) Alternate Flanges of Bilge piping from the discharge of the Bilge pump to the standard discharge connection on deck must be sealed in such a way that will ensure that no section of this piping can be disconnected without breaking a seal. f) Any blind flanges on Bilge pump suction or discharge valve manifolds must be sealed. 6) SLUDGE PUMP SUCTION & DISCHARGE PIPING a) The Manholes of all sludge tanks included in section 3.1 of the IOPP certificate Appendix A / B must be sealed. b) Alternate Flanges of Sludge piping from Sludge tanks to the Sludge pump and from Sludge pump to the various Sludge tanks must be sealed in such a way that will ensure that no section of this piping can be disconnected without breaking a seal. c) Alternate Flanges of Sludge piping from the discharge of the Sludge pump to the standard discharge connection on deck must be sealed in such a way that will ensure that no section of this piping can be disconnected without breaking a seal. d) Any blind flanges on sludge pump suction or discharge valve manifolds must be sealed. e) Alternate flanges of the line from the incinerator waste oil tank to the incinerator must be sealed. 7) INTERCONNECTION BETWEEN SLUDGE AND BILGE PIPING. a) Interconnection pipe line between sludge and bilge pump suction piping and discharge piping must be sealed and if any spectacle flange is provided to be sealed in blanked condition; if valve is provided same needs to be sealed in closed position. This is to prevent the transfer of bilge water to the incinerator waste oil tank for evaporation, which is not permitted. The blank is to be removed and/or valve to be opened only when discharging bilge water ashore. 8) CLEAN DRAIN TANK AND DISCHARGE PIPING a) The manhole of the clean drain tank must be sealed. b) Alternate Flanges of clean drain tank piping from the tank to the overboard valve must be sealed in such a way that will ensure that no section of this piping can be disconnected without breaking a seal. Environmental Management System Annex 6 Page 15 of 47

c) The clean drain tank suction valve must be locked, with the key only in the C/E s possession. Before opening this valve and pumping out the contents of this tank, it must be ensured that there is no oil in the tank. This could be done by looking through an inspection port or manhole or using oil finding paste on a sounding tape through the sounding pipe. However, if a 15 ppm monitoring device is fitted on the discharge line that incorporates an automatic 3-way valve or stopping device that will not permit discharge unless the OCM is switched on and the effluent is below 15 ppm, the above precautions are not necessary. In all cases, the discharging of the Clean Drain tank must be recorded, with date and time of operation in the Engine Log Book. 9) TANK MANHOLE COVERS TO BE SEALED a) All tanks of IOPP Appendix A/B section 3.3(Bilge water tanks), All tanks of IOPP Appendix A/B section 3.1 (Oil residue tanks). b) Clean drain tank, Economizer soot collection tank, Void Spaces and Cofferdams in the engine room, cooling water tank, Steering gear rudder trunk, Sewage plant manhole door and Sewage holding tank manhole door. 10) EXHAUST GAS ECONOMIZER WASH WATER TANK AND PIPING Fig 30.Manhole door depicts on one side wire sealing and on other side sticker seal. a) Alternate Flanges of piping from the EGE wash water tank to the pump / eductor and onwards to the overboard discharge valve are to be sealed. b) The overboard discharge valve or the EGE wash water tank suction valve must additionally be locked, with the key under the C/E s sole control. Environmental Management System Annex 6 Page 16 of 47

Suction valve locked Fig 31.Sealing of soot tank Eductor piping Fig 32.Sealing of soot tank suction valve flange. 11) SEWAGE TREATMENT PLANT AND DISCHARGE PIPING a) Alternate Flanges of inlet piping accessible sections to the Sewage Treatment plant and from the plant to the pump must be sealed. b) Discharge piping from the sewage treatment plant to the overboard valve and to the holding tank (if fitted) and to the standard discharge valve on deck all alternate flanges must be sealed. c) Alternate Flanges of piping from the holding tank to the sewage discharge pump must also be sealed. d) The manholes / inspection ports of the sewage treatment plant and sewage holding tank are to be sealed. e) The valve of the Sewage holding tank must be locked when it is not being discharged (ensure that wheel cannot be removed without breaking a seal). Fig 33.Sealing of sewage treatment plant discharge piping. Environmental Management System Annex 6 Page 17 of 47

PHOTOS SHOWING EXAMPLES OF SEWAGE PLANT AND HOLDING TANK SEALING. If wire seal is used, wire must pass through two bolts at opposite ends of the flange. Fig 34.Seals on STP insp port & inlet Fig 35.Sealed STP ovbd valve flange Paste sticker seals across wheel nuts to prevent wheel from being opened and valve operated Do not seal flanges by welding nuts to flanges use sticker seals or pass wire through holes drilled in bolts. Fig 36. The photo depicts locked sewage holding tank suction. Ensure sticker seals are applied to the wheel nuts to prevent them from being opened and valve operated. Environmental Management System Annex 6 Page 18 of 47

12) SEA WATER PIPING : Pipes of heat exchangers (Including M/E & A/E L.O. Coolers, F.W. Coolers, FRAMO HYDRAULIC OIL Coolers, HYDRAULIC WINCH POWER PACK Coolers, REFRIGERATION PLANT Condensers, ECR Air con Condenser, WORKSHOP Air con Cooler, GALLEY Air con Condenser, MAC cooler. a) All sea water pipes that are of 150mm nominal dia. or below from the point of inception to overboard should have alternate flanges sealed. b) Blank flanges / blind flanges / stub pipes fitted to sea water piping of nom. dia. up to 150mm should be sealed. c) Pressure gauge and thermometer fittings on these pipe lines to be sealed. If sticker seal is used, wire seal is unnecessary. Fig 37. Refr. plant condenser cooling O/B. Fig 38. SW piping of MAC cooler Fig 39. S/W I&O pipe flanges of reefer condenser Fig 40. Winch cooler S/W I&O pipe flanges. Environmental Management System Annex 6 Page 19 of 47

13) BOILER BLOW-DOWN PIPING a) Boiler blow-down piping from the boiler outlet down to the overboard valve should be sealed. Sealing alternate flanges is acceptable. b) The blow-down overboard valves must be kept locked in Port. c) Overboard has two valves, the bonnet of the inboard valve must be sealed. Fig 41. Seal on boiler blow-down pipe flange Fig 42. Boiler blow-down valve flange sealed 14) BALLAST / HOLD BILGE EDUCTORS a) Alternate Flanges of suction piping leading to eductors must be sealed. b) Alternate Flanges of discharge piping from eductors leading overboard must be sealed. c) Suction pressure gauge connections to the educator must be sealed. Pressure gauge connection sealed. Fig 43. Environmental Management System Annex 6 Page 20 of 47

Fleet Management Indai Pvt. Ltd. 15) BALLAST PIPING a) Blank flanges and stub pieces on ballast piping must be sealed. b) Suction and discharge pressure gauge connections must be sealed. 16) FRESH WATER GENERATOR & EJECTOR PUMP Fig 43. Blank flange on Ballast pipe. a) Ejector pump suction line flanges alternate flanges is sufficient. b) Sea water piping from ejector pump to FWG and pipes leading overboard from FWG to be sealed. c) Pressure gauge and thermometer connections on sea water piping leading overboard from FWG. Fig 44. FWG Ejector pump sea suction Fig 45. Ejector pump overboard 17) SEA CHESTS a) Steam and air blow connections on sea chests. b) Flanges or adaptors on sea chest steam/air vent piping must be sealed along the entire length of the vent line. Environmental Management System Annex 6 Page 21 of 47

Fig 46. Sea chest steam blow valve sealing Fig 47. Sea chest air vent line flange sealing Fig 48. Steam blow line flanges and adaptors sealed and tagged. 18) DECK SCUPPER PIPES LEADING OVERBOARD a) Drains of funnel top and Drains from main decks passing through engine room/steering gear room or other machinery spaces and leading overboard must have their (alternate) flanges sealed. This deck scupper line passing through steering gear room shows no flanges, but if flanges are provided same need to be sealed. Environmental Management System Annex 6 Page 22 of 47

19) O.D.M.E. a) All adaptors on sample piping from discharge line to ODME must be sealed so that no section can be opened without breaking the seal. Fig 49. ODME sample line sealing Fig 50. ODME sample line sealing 20) STANDARD DISCHARGE CONNECTIONS FOR BILGE, SLUDGE AND SEWAGE, PORT / STBD. a) Either the valve wheels or the blanks at the ends of the connections must be sealed. If the valve wheels are sealed it must be ensured that the wheels or the valve bonnets cannot be removed without breaking the seals. b) Valve flanges and any pipe flanges on the standard discharge connection piping must also be sealed. Wire Seal passed through wheel and both flanges of valve and sealed. Fig 51. Sealing of Standard discharge connections Environmental Management System Annex 6 Page 23 of 47

21) F.O. / D.O BUNKER MANIFOLDS PORT / STBD a) Blanks Flanges at F.O. and D.O. bunker manifolds to be sealed. Only wire seal to be used (as stickers will not last in exterior locations). Fig 52. 22) FORE PEAK STORE & CHAIN LOCKER EDUCTOR a) Alternate Flanges of suction and discharge piping of the forepeak and chain locker eductor must be sealed. b) Pressure gauge fittings on the eductor must be sealed. c) Alternate pipe flanges from port and stbd bilges up to overboard to be sealed. Fig 53. Fpk. Eductor I&O pipe flanges sealed. Environmental Management System Annex 6 Page 24 of 47

23) ANCHOR WASH PORT / STBD Alternate Flanges of anchor wash piping in forepeak store must be sealed. 24) VARIOUS OVERBOARD VALVES a) All overboard valves in the engine room and machinery spaces must be clearly marked with name. b) Flanges of valves are to sealed on opposite sides by wire seal passed through bolts. (or) c) Flanges may be sealed using one sticker seal. d) Find attached photos of various overboard valves PHOTOS SHOWING EXAMPLES OF SEALING OF VARIOUS OVERBOARD VALVES Fig 54. Atm. Cond. & Ref. Cond. O/B pipe flanges sealed Valve Bonnet sealed with sticker seal. Fig 55. Fig. Provision reefer overboard valve 2 nos bolts sealed by wire seal, only one seal can be seen in the photo Valve flange sealed with wire seal. Fig 56. Boiler blow down valve sealing Environmental Management System Annex 6 Page 25 of 47

Fig 57. Grey water overboard valve with bypass to grey water tank alternate flanges sealed by sticker seals Fig 58. Intermediate shaft bearing overboard seal. Fig 59. Sewage overboard Environmental Management System Annex 6 Page 26 of 47

4. Instructions for grouping sealing points, assigning location numbers, printing location & warning tags & preparing the Master list of seals. 4.1 Instructions for grouping of sealing points and numbering of sealed locations: a. Each System described in section 2 of this Annex, such as Oily Water Separator and Oil Content Meter, Bilge cross-over valve, Boiler Blow-down piping etc. is to be assigned a unique Location number. b. Each seal within each such system to be assigned a sub-location alphabet. c. Hence, all seal locations will be identified by a location number and a sub-location alphabet, for example 1a, 1b, 1c. 4.2 Instructions for printing Warning-cum- location tags (see templates below), when shore-supplied tags are not available on board. a. Print out Warning-cum- location tags with location numbers and sub-location alphabets typed above the Warning in as shown in fig 100a. The warning and location numbers should preferably be printed on both sides. Colored (Yellow) paper may be used for this purpose to prevent depleting the ship s stock of color printer cartridges. b. Laminate the tags and cut them out. c. Punch a hole into each tag after laminating it and attach the tag with a cable tie or seizing wire close to the sealed location. d. Where there are many seals fitted in close proximity to each other such as on the OWS, attaching warning-cum- location tags to each seal location may give a cluttered appearance. In such cases, only a location number and alphabet (Fig 100b) will suffice at each seal point, with one or two Warning signs (Fig 100c) posted nearby. 4.3 Templates of warning and location tags ETS SEAL POINT 1a Fig 60a. WARNING It is against Company Policy to remove or damage ETS seals without notifying the Master or Chief Engineer. If seal is to be removed, Company ETS procedures must be followed. If a seal is found damaged or missing, this must be reported to the Master or Chief Engineer immediately. Failure to comply with above could result in termination of employment. Fig 60b. Environmental Management System Annex 6 Page 27 of 47 ETS SEAL POINT 1a WARNING It is against Company Policy to remove or damage ETS seals without notifying the Master or Chief Engineer. If seal is to be removed, Company ETS procedures must be followed. If a seal is found damaged or missing, this must be reported to the Master or Chief Engineer immediately. Failure to comply with above could result in termination of employment. Fig 60c.

4.4 Seal management Fleet Management India Pvt.Ltd Date: 31 - Dec - 2014 Revision: 1 Environmental seals fitted are to be logged in the Electronic Seal Management program available on PARIS. This can be accessed by clicking Environmental Reports Seal Management from the PARIS Home Page. The following pages give instructions on how the Electronic Seal Management program is to be populated with data and used for recording the affixing and replacement of environmental seals. 4.4.1 Setting up Electronic Seal Management on an existing vessel where seals have already been affixed (and recorded in the ETS Log). Step 1. If Data has not yet been entered in the Electronic Seal Management program in PARIS but seals are already affixed on board (and logged in an ETS Log), it is first necessary to group seals as outlined in section 4.1 of this Annex and then enter information about each seal in an excel sheet as shown in the Table below - this excel sheet is referred to as the Master List of Seals. SEAL LOCATION No SEAL SUB- LOCATION Seal No SYSTEM DECRIPTION OF SEAL LOCATION ON SYSTEM COMPONENT COMPONENT SIZE E/R LOCATION (VERTICAL) E/R LOCATION - OTHER DESCRIPTION Seal type 1 2 a A019355 Clean Bilge tank manhole, inspection cover inspection cover E/R bottom platform aft, port sticker b A019382 Clean Bilge tank manhole manhole E/R bottom platform aft, port sticker A05632 Sludge p/p discharge to shore, v/v Stop check valve E/R bottom platform port wire a ND65 b A05602 Sludge p/p discharge connection flange line ND65 E/R bottom platform Port, sludge p/p wire c A019430 Sludge p/p disch. to shore, flange flange line ND65 E/R bottom platform port sticker d A019354 Sludge p/p disch. to shore, line flange line ND65 E/R bottom platform port sticker e A019337 Sludge p/p disch. to shore, line flange line ND65 E/R bottom platform port sticker 3 A019356 Bilge tank manhole manhole E/R bottom platform port sticker 4 A019389 Waste oil tank manhole manhole E/R bottom platform port sticker 5 A05685 Bilge cross-over suc. v/v v/v Butterfly v/v ND200 E/R bottom platform port wire 6 a b A019353 OWS Bilge pump, disch. valve, flange Stop check valve ND32 A019352 OWS Bilge pump, disch. valve, flange Stop check valve ND32 E/R bottom platform port sticker E/R bottom platform port sticker Environmental Management System Annex 6 Page 28 of 47

Fleet Management India Pvt.Ltd. Date: 31 - Dec - 2014 Revision: 1 The completed Master List of seals should be sent to the office in order for the seals that are already affixed to be uploaded to PARIS. Step 2. Once the seals that are already affixed are uploaded by office, they will appear on the Master s screen after the next data exchange. Status will read In Transit. The Master should confirm receipt of these seals by clicking Confirm receipt next to each Row of seals. The screen shots below are taken from a DEMO site. Step 3. When the Master clicks Confirm receipt, the screen shown below will appear. The Master should click Confirm, without selecting any seal numbers, because it is assumed that these seals are already affixed on board and it is not necessary to label any of them as Missing or Damaged. Environmental Management System Annex 6 Page 29 of 47

Date: 31 - Dec - 2014 Revision: 1 Step 4. After clicking Confirm, the following screen will appear. The Master should now click Hand to C/E to transfer the seals to the C/E. Step 5. In the screen that appears after clicking Hand to C/E, select all the seals on the left and click the double-right arrow. Then click Submit. Step 6. The C/E now needs to confirm receipt of these seals after logging on using his Password, by clicking Confirm Receipt. The following will be the information displayed on C/E and Master s screens respectively after the C/E confirms receipt. C/E SCREEN Environmental Management System Annex 6 Page 30 of 47

Fleet Management India Pvt.Ltd. Date: 31 - Dec - 2014 Revision: 1 MASTER SCREEN Step 7. Setting up seal locations (this can be done at any time by the C/E or Master, without waiting for seals to be uploaded by the office or transferred to him by the Master). From the information in the Master list of seals, details of each location that has a seal need to be set up. THIS MUST BE DONE BEFORE SEAL NUMBERS CAN BE AFFIXED. To add a location, the C/E must click the Location Setup Tab (see figure above) and click Add. Step 8. Feed in location details in the box that opens up when Add is clicked (refer to Step 6), then click Submit. In the example below, details given in the sample of the Master List of Seals shown in Step 1 have been entered. Repeat this process until all locations in the Master List of Seals have been added. Once Submit is clicked, the location will appear in the List of Seal Locations for Vessel as shown below. Environmental Management System Annex 6 Page 31 of 47

Date: 31 - Dec - 2014 Revision: 1 600 X 400 mm Step 9. Affixing seals to locations. Click Seal Management encircled in the screen shot above. In the screen that will appear, click Affix seal as shown below. Step 10. In the screen below, select the seal location from the drop-down menu, then the seal number from the next drop-down menu. Choose Reason from the options given (in the example below, Initial sealing is selected). If Others is selected, it is necessary to fill-in the field entitled Other Reason. When setting up the electronic system for the first time, select Initial sealing. It is in order to select the current date when initially setting up the system instead of entering the date when the seal was actually affixed. Note that if the seal location states sticker as Environmental Management System Annex 6 Page 32 of 47

Date: 31 - Jul - 2014 Revision: 1 seal type, only the sticker seals that have been transferred to the C/E will appear in the seal # menu. In the example shown below, location number 1a and seal number A152000 are selected. Click Submit when all information is entered. After clicking Submit, the Affixed History Tab on C/E s screen will show Waiting for Approval in the column entitled Approved by Master ; in the Master s screen, two buttons will appear, entitled Confirm Affixed and Reject. It is necessary for Master to confirm that the correct seal number is fitted to this location and click Confirm Affixed. If there has been a mistake, he can click Reject instead. C/E s SCREEN MASTER S SCREEN Environmental Management System Annex 6 Page 33 of 47

Fleet Management India Pvt.Ltd. Date: 31 - Dec - 2014 Revision: 1 Step 11. Master should click Confirm Affixed after confirming that the correct seal number is affixed to the location. After this, the seal will appear in the Present Status and the process for logging this seal number in the electronic seal management program is complete. These steps will have to be repeated for each seal. After all seals are entered, by clicking Print Present Status, a list of all sealing locations and seal numbers, very similar to the Master List of Seals, can be generated. Step 12. Once all the seals that were already affixed on board have been entered into PARIS as described in the steps above, the Master should send to the office a list of all unused seal numbers (spares) and seal types (Sticker or Wire) that are in his custody (it is to be noted that unused seals must always remain in the Master s safe custody, except when they are issued for affixing). Office will then upload these seal numbers into PARIS after which the Master should confirm receipt as shown above in Step 2. Setting up of electronic seal management is now completed and henceforth the vessel may discontinue the use of the ETS log (EMS-01). However, a note should be made after the last entry in the ETS log stating that its use is henceforth discontinued in favour of electronic seal management on PARIS. 4.4.2 Setting up Electronic Seal Management on a new vessel Step 1. Unused seal numbers and seal types in the Master s custody should be communicated to the office in a spreadsheet. These will then be uploaded to PARIS by office and the Master should confirm receipt as shown in 4.4.1 steps 2-3. Environmental Management System Annex 6 Page 34 of 47

Date: 31 - Dec - 2014 Revision: 1 Step 2. The required numbers of seals should be issued to the C/E for affixing similar procedures as in 4.4.1 steps 4-6. To determine how many and where seals are to be affixed, the Master and C/E must read through section 3 of this Annex 6 carefully. Step 3. Locations should be set up on PARIS as shown in 4.4.1 steps 7-8. Location number tags supplied by office (or fabricated on board as shown in 4.2 & 4.3 above) should be fitted at each sealing point. It is useful to use a Blank copy of the Master List of Seals to note down location details and seal numbers by hand, before entering in PARIS. This will avoid errors while inputting data. SEAL LOCATIO N No SEAL SUB- LOCATIO N Seal No SYSTEM DECRIPTION OF SEAL LOCATION ON SYSTEM COMPONENT COMPONENT SIZE E/R LOCATION (VERTICAL) E/R LOCATION - OTHER DESCRIPTION Seal type Step 4. The seals issued by the Master should be affixed to the locations set up in PARIS as shown in 4.4.1 steps 9-11. Once all seals physically affixed are entered into the electronic seal management, the process of setting up will be completed. Environmental Management System Annex 6 Page 35 of 47

Date: 31 - Dec - 2014 4.4.3 Further instructions, frequently-asked questions and trouble-shooting. 1) The Confirm Affixed or Reject buttons (Master s screen Affixed History Tab) / Hand to C/E or Edit buttons (Master s screen Await Confirmation / Unused Tab) / Edit button (Master s screen Damaged / Missing Tab) / Print Unused List Tab (Master s screen) / Edit or Return to Master buttons (C/E screen Await Confirmation / Unused Tab) / Del or Edit buttons ( Location setup Tab) cannot be seen. A1) This could be happening because all columns are not visible on the screen. Zoom out by holding down the Ctrl key on the keyboard and pressing the - key until all columns are visible. 2) Some seals that are already in PARIS cannot be found on board. A2) Even after conducting a thorough search, if some seals that were supposed to be in the Master s custody ( Master store ) or with the C/E ( C/E store ) cannot be found, they can be declared as Missing (or Damaged in case they are damaged) by both Master as well as C/E, by following steps below: Environmental Management System Annex 6 Page 36 of 47

Fleet Management India Pvt.Ltd. Date: 31 - Dec - 2014 MASTER S SCREEN In Tab Awaiting Confirmation / Unused click Edit button on the row containing the seal that is Missing / Damaged. In the screen that will open on clicking Edit, select the Missing / Damaged seal number, then select either Missing or Damaged from the drop-down menu and click Save. To revert to the Seal Management screen, click Seal Management. The seal number selected as Missing / Damaged will now appear in the Damaged / Missing Tab of the Seal Management screen (below). The Master can reverse the Missing / Damaged label for any seal by clicking Edit, selecting In good condition from the drop-down menu and clicking Save. Environmental Management System Annex 6 Page 37 of 47

Fleet Management India Pvt.Ltd. Date: 31 - Dec - 2014 C/E SCREEN The C/E can also label a seal number in his possession as either Missing or Damaged. In the Tab Awaiting confirmation / Unused, of the Seal Management screen, clicking Edit opens the same screen as shown above, where he can select the Missing / Damaged seal number and choose between Missing and Damaged before clicking Save. However, only the Master can restore a Missing or Damaged seal. After clicking Save the seal number will appear in the Await Confirmation / Unused screen (C/E screen) with Status shown as Missing. 3) The C/E is to sign off but his Account of Wages cannot be generated. A3) There is an interlock built in to the seal management program which will not allow the C/E (or the Master) s account of wages to be generated unless all seals that are in C/E Store are returned to Master. All unused seals must be in Master s custody before the C/E s or Master s account of wages can be generated. To return seals to Master, on C/E s screen, under Await Confirmation / Unused Tab, click the button Return to Master. The Master now has to click the button Confirm receipt from the C/E in the Await Confirmation / Unused Tab. This will change the status of the seal from C/E Return (Await Confirmation) to In good condition and location from C/E Store to Master Store. Environmental Management System Annex 6 Page 38 of 47

Fleet Management India Pvt.Ltd. Date: 31 - Dec - 2014 MASTER S SCREEN 4) Replacing a seal with another one A4) This can be initiated only by the C/E. On the Seal management screen, click the Affix seal Tab, as shown below. Then follow the steps explained in section 4.4.1 steps 9-11, of this Annex. Remember that the Master has to confirm affixing of the seal, otherwise the seal will not be recorded as affixed in PARIS. 5) When I try to affix a seal in a location, I get the message Previous seal at this location has not been approved by Master yet. Referring to the example above, the previous seal fitted in location 3-f had not yet been approved by the Master because the button Confirm Affixed could not be seen on the Master s screen. Holding down the Ctrl key while pressing the - resulted in the screen zooming out and the button could then be seen (refer to Q1 of this FAQ). Environmental Management System Annex 6 Page 39 of 47

Date: 31 - Dec - 2014 6) How can I print-out a list of seals and locations that are presently affixed on board? A6) The Present Status of the seals affixed on board can be printed out by clicking the Tab Present Status and then the button Print Present Status in the Seal Management screen. Clicking Print Present Status generates a PDF file that can be saved or printed. This can be done by Master as well as C/E. 7) How can I print-out a list of unused seals? A7) The list of unused seals can be printed out by the Master only, by clicking the button Print Unused List. This button is available in all Tabs of the screen Seal Management. This will generate a PDF list of seals that are located in Master store or C/E Store. The PDF list is in the same format as Form EMS-03. The last page of this list has spaces for the outgoing and incoming Masters to append their signatures after verifying the list, when command is changed. A copy of this signed list must be attached to the Master s handing over checklist D-20A. 8) How can I generate an excel list of seals from PARIS? A8) The Excel button provided may not work due to errors in the program. Instead, data in the various seal management screens may be selected, copied and pasted (Copy-Paste) on to an excel sheet. 9) How can I change the seal type for a location that already has a seal affixed on PARIS? A9) Once a seal is affixed on PARIS the seal type for that location cannot presently be changed by the vessel. A new location identity will have to be created for the new type of seal and the old seal retained. A future amendment to the program to incorporate this feature is planned. However, if the seal has not been affixed on PARIS, the seal type can be changed in Location Setup. Click Edit, then change the seal type, as shown below. Environmental Management System Annex 6 Page 40 of 47

Fleet Management India Pvt.Ltd. Date: 31 - Dec - 2014 10) I want to delete a seal location that is not required to be sealed as per Company guidelines. However, the seal is already affixed on PARIS. How can I do this? A10) At present, the facility to delete a sealing location that already has a seal affixed on PARIS does not exist Ship Service Desk ashore needs to be contacted. An amendment to incorporate this feature is planned. However, if a seal is not affixed, the sealing location can be deleted by clicking Del in the Location setup screen. Environmental Management System Annex 6 Page 41 of 47

Fleet Management India Pvt.Ltd. Date: 31 - Dec - 2014 5. Alternative methods of sealing (only to be used if sticker seals are not available) Welded nuts should be removed and replaced by wire seal passing through holes in bolts (minimum two at opposite ends of flange). Valve must be sealed in open position or removed. Fig 61. In this Illustration, an external sleeve has been placed on the piping and this sleeve is connected with Marpol seals (plastic seals are shown but wire seals may be used instead). In case the piping needs to be dismantled the Marpol seals will have to be broken. Fig 62. In this Illustration, a metal pipe section is put on the oil sample inlet of the OWS oil content meter and attached to a Marpol seal. This Pipe section protects the ferrule and the OWS drain piping. Fig 63. A metal pipe section is put on the 3 way valve and the piping to protect all the ferules. This arrangement will ensure that the Fresh water line and the sampling line to the OWS cannot be dismantled. Environmental Management System Annex 6 Page 42 of 47

Fleet Management India Pvt.Ltd. Date: 31 - Dec - 2014 Fig 64. The Final layout of the oil content meter with all the Marpol seals in place Valve must be sealed in open position or removed. Contd.. Alternative methods of sealing the oil content meter and associated piping (only to be used if sticker seals are not available) Stage 1: Stage 2: Cutting and marking of metal plates to fit various pipe junctions Bending of the various plates to snugly fit the piping Environmental Management System Annex 6 Page 43 of 47

Date: 31 - Dec - 2014 Contd.. Alternative methods of sealing the oil content meter and associated piping (only to be used if sticker seals are not available) Side view Elevation Complete View As can be seen from the diagrammatic description above: Locking plates have been placed on the three-way piping along with 4 Marpol seals to secure the opening up of three way piping. If valve cannot be sealed in open position, it must be removed. Fig 65. A locking plate arrangement to secure the OWS oil sample inlet Environmental Management System Annex 6 Page 44 of 47

Fleet Management India Pvt Ltd. Date: 31 - Dec - 2014 contd.. Alternative methods of sealing the oil content meter and associated piping (only to be used if sticker seals are not available) Sealing arrangement for the inlet piping of a Oil content meter Drain valve must be sealed in closed position Valve must be sealed in open position or removed. Similarly, any ferrules on the piping, pipe joints must also be sealed Environmental Management System Annex 6 Page 45 of 47

Fleet Management India Pvt Ltd. Date: 31 - Dec - 2014 6. Methods of sealing that should NOT be used (discontinued) The practice of using shim to seal valves to be discontinued. OWS sample line sealing done by copper/brass shims and lashed by wire not acceptable. Environmental Management System Annex 6 Page 46 of 47

Date: 31 - Dec - 2014 Flanges are no longer to be sealed by welding nuts and passing seals through them. This is due to the possibility of burning off the nuts and later re-welding them with the seals intact (particularly if they are made of wire). Instead, sealing of flanges should be done by applying sticker-type seals across or along the flanges, as shown in other photographs in this document, Alternatively, flanges may be sealed by passing the stainless-steel wire provided through holes in two bolts at opposite ends of the flange and applying the orange coloured, plastic, numbered seal provided. Existing nuts that have been welded to flanges for the purpose of applying seals must be removed and replaced with sticker or wire seals. Environmental Management System Annex 6 Page 47 of 47