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Instruction Date : enter a date.

LOC Egypt for Consultancy Service]


Address Line 1
ABL Report No. : Report ref Address Line 2
City, Country
Report Date : enter a date.
T. +xx(0) xx xxxx xxxx

VESSEL NAME / VESSEL TYPE

DP VESSEL ASSURANCE REPORT

UNDERTAKEN ON BEHALF OF
CLIENT COMPANY
VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

REPORT AMENDMENT RECORD

Rev Description of Amendment Author Checked Approved Signed

0 Issue for Client use

DISTRIBUTION LIST

Name Title Company

Insert Name CLIENT COMPANY

Internal File LOC Egypt for Consultancy Service]

This report (including any enclosures and attachments) has been prepared for the exclusive use and benefit of the
addressee(s) and solely for the purpose for which it is provided. Save to the extent provided for in the Company’s Terms and
Conditions or such other contract between the Company (or its affiliate) and the Client (or its affiliate) governing the issuance
of this report, the Company assumes no liability to the addressee(s) for any claims, loss or damage whatsoever suffered by
the addressee(s) as a result of any act, omission or default on the part of the Company or any of its servants, whether due to
negligence or otherwise. No part of this report shall be reproduced, distributed or communicated to any third party without the
prior written consent of the Company. The Company does not assume any liability or owe any duty of care if this report is
used for a purpose other than that for which it is intended or where it is disclosed to or used by a third party.

Report No.: Report ref Page 2 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

SUMMARY

This document provides DP assurance report, which includes an assessment of all the DP and
associated systems of the DP equipment class 2 vessel xxx for the suitability of DP operation
under the environmental conditions as per meteorological data in the intended location.

1. DP assurance is performed by ABL to determine whether the DP and associated systems of


the vessel are in accordance with the requirements of the applicable class rules, industry
standards and industry guidelines such as IMCA and MTS.

Further analysis was carried out on the capability analysis of the vessel and the electrical load
analysis to determine whether the vessel is suitable to carry out offshore supply, crane and
gangway transfer operations on DP during intact and after the worst-case failure is experienced.

The DP Assurance was performed at place, on the date and based on the document review and
inspection of DP related systems on board the vessel. The DP and associated systems of the
vessel are considered in accordance with the requirements of the applicable xxx class rules,
industry standards and industry guidelines, and suitable for the intended operation once the A
findings in section 4.0 are satisfactorily closed-out.

It should also be noted that nothing in this report shall be deemed to be a general statement of
seaworthiness.

Report No.: Report ref Page 3 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

ABBREVIATIONS LIST
ABS American Bureau of Shipping AHV Anchor Handling Vessel
Activity Specific Operating
ASOG ATD Action Tracking Document
Guidelines
AVM Automatic Vessel Management BV Bureau Veritas
CAM Critical Activity Mode CCTV Closed Circuit Television
Differential Absolute & Relative
DARPS
Positioning System
Differential Global Navigation Satellite
DG Diesel Generator DGNSS
System
Differential Global Positioning
DGPS
System
DNV Det Norske Veritas DP Dynamic Positioning
DPO Dynamic Positioning Operator
DP specialist or ABS Classification
DPS ECR Engine Control Room
(DPS-1, 2 or 3)
Emergency Shutdown System /
ESD FMEA Failure Modes and Effects Analysis
Device
Failure Modes, Effects and Floating Production, Storage and
FMECA FPSO
Consequence Analysis Offloading
Flag State Verification and
FSVAD GPS Global positioning (Satellite) System
Acceptance Document
GL Germanischer Lloyd (Now DNV GL) HIL Hardware in the Loop
Heat, Ventilation and Air International Marine Contractors
HVAC IMCA
Conditioning Association
ICS Integrated Control System IT Information Technology
IMO International Maritime Organization LBL Long Base Line
KR Korean Registry MRU Motion Reference Unit
IMO Maritime Safety Committee
LR Lloyds Register MSC Circ.
Circular
MSC IMO Maritime Safety Committee
Norwegian Technology Standards
MTTR Mean Time To Repair NORSOK
Institution
NI Nautical Institute OLF Norwegian Oil Industry Association
OIM Offshore Installation Manager PMS Power Management system
OSV Offshore Supply Vessel PSV Platform Supply Vessel
PRS Position Reference System
SBL Short Base Line SIMOPS Simultaneous Operations
International Convention on
STCW Standards of Training Certification & TAM Task Appropriate Mode
Watchkeeping for Seafarers
Thruster and Generator Operating
TAGOS TTT Time To Terminate
Strategy
TLP Tension Leg Platform USCG United States Coast Guard
UK Offshore Operators Association
UKOOA VRU Vertical reference Unit
(Oil & Gas UK)
UMS Unmanned Machinery Spaces WCFDI Worst Case Failure Design Intent
WCF Worst Case Failure
WSOG Well Specific Operating Guidelines

Report No.: Report ref Page 4 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

TABLE OF CONTENTS

ABBREVIATIONS LIST ................................................................................................................. 4

1 INTRODUCTION ....................................................................................................................... 6

2 DP ASSURANCE ...................................................................................................................... 7

3 CONCLUSIONS ...................................................................................................................... 10

4 FINDINGS ............................................................................................................................... 11

5 PARTICULARS OF THE VESSEL .......................................................................................... 12

6 VESSEL CERTIFICATES ........................................................................................................ 13

7 MAINTENANCE AND STATUS REPORTS............................................................................. 14

8 PROJECT PARTICULARS ..................................................................................................... 16

9 DP ASSURANCE DOCUMENTATION PARTICULARS.......................................................... 17

10 DP OPERATIONS MANUALS / PROCEDURES ..................................................................... 18

11 MANNING ............................................................................................................................... 19

12 DP CAPABILITY ANALYSIS .................................................................................................. 20

13 DP AND ASSOCIATED SYSTEMS CONFIGURATION .......................................................... 21

APPENDIX A VESSEL’S CERTIFICATES

APPENDIX B VESSEL’S CLASS STATUS REPORT

APPENDIX C VESSEL’S DP CAPABILITY PLOT

APPENDIX D IMO CREW LIST

APPENDIX E DP KEY PERSONS CERTIFICATES AND EXPERIENCE

APPENDIX F VESSEL FMEA PROVING TRIALS REPORT.

APPENDIX G ELECTRICAL LOAD ANALYSIS

Report No.: Report ref Page 5 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

1 INTRODUCTION
1.1 General
1.1.1 Instructions were received from xxxxxx to conduct the DP assurance of the DP 2 vessel xxxxxx.

1.2 Scope of Work


1.2.1 xxxxxxx has requested LOC Egypt for Consultancy Service] to carry out the DP assurance of
the DP 2 vessel xxxxx. The DP assurance was then performed by ABL to determine whether
the DP and the associated systems of the vessel are in accordance with the requirements of
the applicable class rules, industry standards and industry guidelines such as IMCA and MTS.

Report No.: Report ref Page 6 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

2 DP ASSURANCE
2.1 Objectives
2.1.1 The objective of the process of DP assurance is to assess whether the subject vessel is
adequately fault tolerant as per the assigned DP equipment class notation and that the vessel
can maintain its desired position and heading during intact and post worst-case failure as
defined in the FMEA of the vessel under the environmental conditions simulated in the
capability analysis.

2.1.2 The objective is also to determine whether electrical power system is adequately rated so that
it can supply demanded electrical power to thrusters as indicated in the capability analysis
during intact condition and after experiencing the defined worst-case failure of the vessel while
supplying electrical power to all the auxiliary systems that are needed to be operating during
DP.

2.1.3 Review of DP related certificates, crew certification and competences, and general condition of
the vessel is also part of the assessment.

2.1.4 Electrical load analysis will be further analysed to determine whether the vessel has sufficient
electrical power to supply the industrials equipment during intact condition and after the worst-
case failure is experienced.

2.2 Conduct of Work


2.2.1 The DP assurance includes review of DP-related document and attendance to conduct the
audit of the vessel. Once both desktop review and attendance are completed, the assessment
will conclude to specify the status of the vessel.

2.2.2 Capability analysis of the vessel is analysed to understand the maximum environmental
conditions under which the vessel is capable of maintaining its demanded position and heading
during intact condition and after the defined worst-case failure of the vessel is experienced.

2.2.3 Further, required electrical power required by thrusters in both cases above in section 2.2.2 is
also assessed and compared with the available electrical power of the vessel as indicated in
the electrical load analysis to determine whether the vessel has sufficient electrical power to
feed thrusters while supplying electrical power to auxiliary systems that are needed to be
functioning during DP operation.

2.2.4 Electrical load analysis is further analysed to determine whether power plant is capable of
providing electric power thruster and auxiliary system in the condition stated within the
documents listed in section xxx while supplying electric power to mission equipment until the
industrial mission is safely terminated or completed.

Report No.: Report ref Page 7 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

2.2.5 Desktop analysis typically includes but not limited to the review of the following documents:

 Details of the intended operation including the limitations of the change of orientation of
the vessel

 Environmental conditions under which the vessel will be operated.

 DP FMEA including the class approval letter to see whether there are outstanding
comments from the applicable classification society

 DP proving trials including the class approval letter to see whether there are outstanding
comments from the applicable classification society.

 Latest DP annual trials report.

 Latest Vessel Specific DP Operation Manual.

 DP capability analysis (This should include intact and worst-case failure condition including
additional forces caused by the intended mission for example pipelay).

 Electrical load analysis for DP intact and worst-case failure condition.

 ASOG/WSOG and applicable DP checklists

2.2.6 Based on the outcome of the review, the surveyor may request additional documents and/or
additional DP related tests to be conducted to determine the suitability of the subject vessel for
the intended operation.

Report No.: Report ref Page 8 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

2.3 Acceptance Criteria


2.3.1 The acceptance criteria for this DP assurance are those that are defined in the applicable Rules
of Class (xx) rules and industry guidelines such as IMO, IMCA and MTS.

2.3.2 Applicable Guidelines:

 IMCA M103, The Design and Operation of Dynamically Positioned Vessels.


 IMCA M109 - A Guide to DP related Documentation for DP Vessels
 IMCA M117 - The Training and Experience of Key DP Personnel.
 IMCA C 002 – Competence Assurance and assessment.
 IMCA M125 - Safety Interface Document for a DP Vessel Working Near an Offshore
Platform.
 IMCA M206 - A Guide to DP Electrical Power and Control System.
 IMCA M140 - DP Capability Plots.
 IMCA M166 - Guidance on Failure Modes and Effect Analysis.
 IMCA M182 - The Safe Operation of Dynamically Positioned Offshore Supply Vessels.
 IMCA M252 - Position Reference Systems and Sensors for DP Operations.
 IMCA D010 - Diving Operations from Vessels Operating in Dynamically Positioned Mode.
 IMCA M04/04 - “Methods of Establishing the Safety and Reliability of DP Systems”,
including Annexes
 IMCA SEL016 - Guidance on the Investigation and Reporting of Incidents.

2.4 Schedule
2.4.1 xxx Marine/DP Consultant with ABL, attended the vessel xxx at xxhours on xx 2018 at Suez
anchorage area. The DP Assurance was commenced at xx hours on the xx 2018 and
completed at xx hours on the xxx 2018. The surveyor departed the vessel at xxx hours on the
xxx 2018. Desk top review of the DP documents was conducted prior to attendance of the
vessel.

Report No.: Report ref Page 9 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

3 CONCLUSIONS
3.1.1 On the basis of the desktop review of the DP-related documents and the outcome of the DP
survey conducted on board, the IMO DP Equipment Class 2 vessel xxx, the DP and associated
systems of the vessel are considered in accordance with the requirements of the applicable
xxx class rules, industry standards and industry guidelines (IMCA) (as specified in section 2.3)
when the DP system is configured as per the FMEA and DP operation manual once the
category A finding(s) described in section 4.2 of this report are closed-out to the satisfaction of
ABL.

Report No.: Report ref Page 10 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

4 FINDINGS
4.1 Explanation
4.1.1 Findings are grouped into three categories:

 Category A – Violation of international regulations and/or audit criteria/guidelines


(specified in section 2.3) which leads to the DP system being no longer fully fault-tolerant,
in addition to, any safety failure that poses a threat to the personnel or vessel or operations
for immediate action or proposed plan of action before engagement to the proposed scope
of work.

 Category B – Failure/violation which is identified as per “Category-A”, but the redundancy


concept may be fully fault-tolerant at reduced environmental limits, and/or safety failure
which does not pose an immediate threat to personnel or vessel or operation. To be
completed within three months, with the exception of items that require major overhaul
period e.g., dry-docking.

 Category C - The redundancy concept is fully fault tolerant, but an element of non-critical
redundancy is unavailable. Finding is placed as a constructive suggestion for improvement

4.2 Findings – Category A


4.2.1 There are xxx (xxx) findings under this category:

1. xxx

2. Xx

3. xx

4.3 Findings – Category B


4.3.1 There are xx (xx) findings under this category:

1. xxx

2. Xxx

3. xxx

4.4 Findings – Category C


4.4.1 There are xx (xx) findings under this category:

1. Xxx

2. Xxx

3. xx

Report No.: Report ref Page 11 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

5 PARTICULARS OF THE VESSEL

Ref Item Remarks

1.1 Name of Vessel:

1.2 Type of Vessel:

1.3 Owners of the vessel

1.4 Operator of the vessel

1.5 Port of Registry

1.6 Place of Build

1.7 Date of Build

1.8 Length Overall

1.9 Breadth Moulded

1.10 Depth

1.11 Designed Draft

1.12 Gross Tonnage

1.13 Net Tonnage

1.14 Classification Society

1.15 Class Notations

1.16 Fuel Oil Capacity

1.17 Fresh Water Capacity

1.18 Ballast/Drill water

1.19 Liquid Mud/Brine

1.20 Dry Bulk

1.21 Methanol

1.22 Main Generators

1.23 Shaft Generators

1.24 Emergency Generator

1.25 Bow/Aft Thrusters

1.26 Azimuth Thrusters

1.27 DP System Overview

DP Class notation:

DP Equipment Class:
IMO Number:

Report No.: Report ref Page 12 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

Ref Item Remarks


DP control system:
Generators:

PMS/IAS:
Thrusters:
Safety systems:

Other information:

6 VESSEL CERTIFICATES
Certificate Issued Expires Comments
Certificate of Registry
Minimum Safe Manning
International Tonnage Certificate
International Ship Security Certificate
Ships Radio Station Licence
Continuous Synopsis Report
Certificate of Class
International Load line Certificate
Cargo Ship Safety Equipment Certificate
Cargo Ship Safety Construction Certificate
Cargo Ship Safety Radio Certificate
ISPP Certificate (Int. Sewage Pollution
Prevention Certificate)
IAPP Certificate (Int. Air Pollution Prevention
Certificate)
IOPP Certificate (Int. Oil Pollution Prevention
Certificate)
International Anti Fouling System
GMDSS Shore Based Maintenance Contract
Ships Sanitation Certificate
Document of Compliance
Safety Management Certificate
Document of Compliance for Ships Carrying
Dangerous Goods
P&I Certificate
H&M Insurance Certificate
Employers Liability Insurance Certificate
Blue Card
Main Crane Certificate of Test
Rescue Davit Certificate of Test

Report No.: Report ref Page 13 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

7 MAINTENANCE AND STATUS REPORTS


7.1 Propulsion and Thrusters
Ref BT1 BT2 Port ZP Stbd ZP

1.1 Maintenance Records


Checked

1.2 Outstanding Maintenance

1.3 Last Oil Analysis (Date)

1.4 Last Oil Analysis Ok

1.5 Running Hours at Present

1.6 Last Major Overhaul

1.7 Next Major Overhaul

7.2 Diesel Generators


Ref DG1 DG2 DG3 EMG SG1 SG2

1.1 Maintenance Records


Checked

1.2 Outstanding Maintenance

1.3 Last Oil Analysis (Date)

1.4 Last Oil Analysis Ok

1.5 Running Hours At Present

1.6 Last Major Overhaul

1.7 Next Major Overhaul

7.3 Switchboard Maintenance


Ref Contractors Report 415 V 220 V

1.1 Name of the Contractor

1.2 Report No

1.3 Date

1.4 Remarks:

7.4 DP Sensors
Records Maintenance Records
Ref Sensor
Checked

1.1 Gyro 1:

1.2 Gyro 2 :

1.3 Gyro 3:

Report No.: Report ref Page 14 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

Records Maintenance Records


Ref Sensor
Checked
MRU 1:
1.4

1.5 MRU 2:

1.6 MRU 3:

1.7 MRU 4:

1.8 Wind Sensor 1

1.9 Wind Sensor 2

1.10 Wind Sensor 3

1.11 DGPS 1

1.12 DGPS 2

1.13 HiPAP 1:

1.14 Cyscan

Report No.: Report ref Page 15 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

8 PROJECT PARTICULARS

Ref Item Remarks

1.1 Project particulars:

1.2 ATD reference:

1.3 Project operation scope of


work:

1.4 Operating location:

1.5 Environmental conditions for


the area during the period of
operations:

1.6 Minimum water depth


required at location:

1.7 Operating within the 500m


zone:

1.8 If yes, provide specific


requirements of operating
within the 500m zone:

1.9 Industrial mission specific


maximum forces expected
on the vessel:

1.10 Does the operation permit


the change of vessel
orientation?

1.11 Details of any additional


equipment added to the
vessel for this project:

1.12 PRS Viability:

1.13 DP Sensor viability:

Report No.: Report ref Page 16 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

9 DP ASSURANCE DOCUMENTATION PARTICULARS

Ref Item Particulars

1.1 DP equipment class:

1.2 DP Class certification particulars:

1.3 FMEA particulars:

1.4 Is the FMEA class approved?


Is the Class approval letter available?

1.5 Are there outstanding comments from


Class?

1.6 Has the FMEA been reviewed within


the past 5 years:

1.7 Outstanding
recommendations/findings/ concerns
from FMEA:

1.8 FMEA proving trials particulars:

1.9 Is the FMEA proving trials class


approved?
Is the Class approval letter available?

1.10 Outstanding
recommendations/findings/ concerns
from FMEA proving trials:

1.11 Annual DP trials particulars:

1.12 Have DP annual trials been conducted


within the +/- 3 months anniversary
window?

1.13 Outstanding
recommendations/findings/ concerns
from DP annual trials:

1.14 DP control systems:

1.15 DP sensor particulars:

1.16 Independent joystick:

1.17 Position reference systems particulars:

DGPS 1:

DGPS 2:

CyScan:

HiPAP 1:

Report No.: Report ref Page 17 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

10 DP OPERATIONS MANUALS / PROCEDURES


Ref Item Remarks Report/Doc No.

1.1 DP operations manual:

1.2 Do the procedures and


checklists contained
within the DP
operations manual
fulfil the requirements
for the operations
specified in section 8:

1.3 DPO Familiarization


Requirement

1.4 Swing DP Crew


Document verified

1.5 DP Field arrival


checklists:

1.6 DP 500m zone entry


checks:

1.7 DP engine room set-


up checklist:

1.8 Engine room handover


check list

1.9 Mobilization Trials

1.10 Location Checklists

1.11 DP hand-over / 6
hourly checklists:

1.12 Diving checklists if


applicable:

1.13 ROV checklists if


applicable:

1.14 Is the IMCA guidelines


as specified under
Section 2.3.2 of this
report is implemented

Report No.: Report ref Page 18 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

11 MANNING

Ref Name Position STCW ’95 DP Cert. DP DP Experience


License No No/Type Experience on this VSL

1.1

1.2

1.3

1.4

1.5

1.6

1.7

1.8

Report No.: Report ref Page 19 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

12 DP CAPABILITY ANALYSIS

Ref Item Remarks

1.1 DP capability plot particulars:

1.2 What are the failure conditions


simulated in the capability analysis

1.3 Does the capability plot include all


thrusters, except the most effective
thruster? and indicate the most
effective thruster and the
environmental condition under this
situation

1.4 What is the Worst-Case Failure


Design Intent as per the FMEA

1.5 What is the actual worst-case failure


as per the DP proving trials and
conclusion in the FMEA?

1.6 Is worst case failure simulated in the


capability analysis is identical to actual
worst-case failure as stated in the
conclusion of the FMEA?

1.7 Do DP capability plots include analysis


for any expected external forces acting
on the vessel during DP station
keeping:

1.8 What are the maximum environmental


conditions under which the vessel can
maintain position and heading while
engaged in intended industrial mission
during intact condition of the vessel?

1.9 What are the maximum environmental


conditions under which the vessel can
maintain position and heading while
engaged in intended industrial mission
during worst case failure condition of
the vessel?

1.10 Is the vessel able to hold the position


and heading during intact condition
under the expected environmental
condition during the project?

1.11 Is the vessel able to hold the position


and heading during post worst case
failure condition under the expected
environmental condition during the
project?

1.12 Does the vessel crew take regular DP


footprints; Are these compared to the
Vessel DP capability:

Report No.: Report ref Page 20 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

13 DP AND ASSOCIATED SYSTEMS CONFIGURATION

Ref Item Remarks

1.1 State how many DP Control centres are


available; and their locations?

1.2 How is the main power distribution to be


configured for this industrial mission?

1.3 Indicate the minimum number of


generators connected to each bus.

1.4 If the mode of operation from the FMEA


(analysis) is CLOSED bus configuration,
have the below protection features been
analysed and confirmed within the initial
DP FMEA proving trials:

Over / Under excitation

Over / Under frequency

Voltage dip ride through capacity of all


consumers

Crash synchronisation

Functionality of PMS in relation to black-


out prevention

Segregation of power plant strategy

1.5 Does a high-level review of the FMEA


and FMEA Proving trials indicate that
sufficient analysis has been carried out
with reference to the below mentioned?

Redundancy

WCFDI

Worst Case Single Failure

Post WCF equipment capacity

Separation design intent

Category ‘A’ concerns

Configuration

FMEA has been carried out to industry


standards

1.6 Does the vessel have sufficient


electrical power to feed the thrusters,
auxiliary systems and the power
needed for consumers of the project?

1.7 Does the vessel have sufficient


electrical power to feed surviving
thrusters, auxiliary systems and the
power needed for consumers of the

Report No.: Report ref Page 21 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

Ref Item Remarks


project after the WCF is experienced?

1.8 Are there additional project equipment


powered by the ships power plant?

1.9 Has the approval been taken from the


applicable classification society to install
additional equipment?

1.10 Do the additional equipment influence


the DP system integrity?

1.11 Have any changes been carried out to


the DP systems since the original
FMEA, if so are the changes sufficiently
analysed and the FMEA updated:

1.12 Have IMCA standards been followed for


subsequent DP annual trials testing:

1.13 Has adequate testing within the DP


annual trials been conducted to prove
that the redundancy and fault tolerance
established within the original proving
trials are still intact:

Report No.: Report ref Page 22 of 23


VESSEL NAME / VESSEL TYPE : DP VESSEL ASSURANCE REPORT

Report No.: Report ref Page 23 of 23

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