BILL O'DONLEY

All owners or operators of towing vessels with a Towing Safety Management System (TSMS) may comply with the requirements of subpart B of this part by outfitting their vessels with appropriate alternate arrangements or equipment so long as these variations provide an equivalent level of safety and performance and are properly documented in the TSMS. Vessel modified starboard fuel tank to include a branch line that runs to the starboard weather deck. The branch line is tied into a transfer pump and hose reel that allows the vessel to dispense fuel to machinery associated with the tow. A fuel line isolation valve is installed in a suitable location on the branch line. The isolation valve does not have the ability to be closed remotely from the weather deck in the event of a fire. OCMI determined that in order to meet the fire safety and response provisions, the vessel will need to install equipment that allows for a remote closure of the valve outside the fuel tank from the weather deck. In addition the vessel must create TSMS procedures that cover the fueling operations, meet all requirements of 33CFR 156,and provide a nondestructive testing report of the tank.

All owners and operators of an existing towing vessel must have a valid COI prior to the specified phase-in period. This vessel is one of the associated fleet that has not obtained a valid COI. The vessel shall be made available for a Coast Guard COI inspection within 90 days. If an inspection is not completed prior to this date, the action for this deficiency shall be changed to a 60 (Rectify deficiencies prior to movement) and the vessel may no long be permitted to operate.