The tops of the baffle plates installed to limit water from entering holds 3 and 2A through the fire dampers, which were about 25 to 26 feet above the accident voyage still waterline, were found after loss of propulsion to submerge at heeling angles of 26° to 29°, with only hold 3 flooded to 20 percent at 0.7 permeability. No damage control plan or emergency plan was found that might recommend securing the fire dampers in extremely high seas to prevent potential downflooding through ventilation openings into cargo holds.