STEVE DUNAVANT

The owner or managing operator of the towing vessel must make a request for an amended COI to the cognizant OCMI any time there is a change in the character of the vessel, its operation, or similar factors specified in its current COI. AS of this date this office has not received a request for an amended COI when certain factors, as stated on the COI, are no longer current. Specifically, the vessel is no longer operated by Mardi Gras Marine and the vessel is no longer covered by TSMS Certificate ITOW-MGM-20240306. The vessel must satisfy all requirements to receive an amended COI, which may include an OCMI inspection, prior to conducting commercial towing operations.

A towing vessel that is certified for rivers must be equipped with either an approved 160-B semi-portable fire extinguisher OR a fixed fire-extinguishing system installed to protect the engine room. The vessel is not currently equipped with either the required semi-portable fire extinguisher or an approved fixed fire extinguishing system. The vessel must have the full complement of fire fighting equipment prior to conducting commercial towing operations.

An external audit must be conducted prior to the issuance of the initial COI for vessels subject to an owner or managing operator's TSMS that have been owned or operated for 6 or more months prior to receiving the initial COI. Provide objective evidence of a satisfactory external audit conducted by a cognizant third-party organization within 6 months (05March2025) of issuance of the initial COI. Failure to complete and provide evidence of this audit will result in the vessel being reverted to the Coast Guard inspection option, suspension of the vessel operations, or COI revocation, as determined by the OCMI.

A towing vessel may not be operated without having on-board a valid COI issued by the Coast Guard as required by 46 136.202. Vessel's Temp COI expired on 26 Aug 2024. Vessel can not operate in a commercial status until new COI has been issued by the Coast Guard.

Machinery and electrical systems must be designed and maintained to provide for safe operation of the towing vessel and safety of persons on board under normal and emergency conditions. Fitting to main air supply tank failed resulting in the loss of throttle control at the operating station. Prove proper operation of air tank prior to getting underway and commercially operating.

A towing vessel may not be operated without having on-board a valid COI issued by the Coast Guard as required by 46 136.202. Vessel missed 90 day window for annual inspection. Vessel can not operate in a commercial status until new COI has been issued by the Coast Guard.

Fixed fire pump installed must be capable of delivering water simultaneously from the two highest hydrants at a pressure of 50 psi and a flow rate of atleast 80 gpm. During inspection MI noted that the PSI coming off the fixed fire pump was 30 PSI. Boat received a portable fire pump to meet regs boat shall fix installed fire pump within 30 days.

Each towing vessel must have a reliable means to provide notification when an emergency condition exists or an essential system develops problems that require attention. Vessel does not have a means of conducting an operational test of the alarm set points for: 1. Main Engine Low Lubricating Oil Pressure, 2. Main Engine High Cooling Water Temperature, 3. Auxiliary Generator Engine Low Lubricating Oil Pressure, 4. Auxiliary Generator Engine High Cooling Water Temperature Alarms must be visible and audible at each operating station. Provide a reliable means to test alarm set points to the satisfaction of the attending Marine Inspector.

Period of Validity: For a towing vessel utilizing the TSMS option, the COI is invalid upon the expiration or revocation of the owner or managing operator TSMS certificate. Prior to conducting commercial vessel operations, vessel must have a valid COI on board.

Period of validity: For a towing vessel utilizing the TSMS option, the COI is invalid upon the expiration or revocation of the owner or managing operator TSMS certificate. Prior to conducting commercial operations, vessel must have a valid COI on board.

The owner and managing operator must ensure that the towing vessel is in compliance with this subchapter and other applicable laws and regulations at all times. The hull suffered damage to the bottom plating near the keel approximately 20 feet aft of the bow in the space forward of the engine room resulting in water ingress to the space. The vessel is authorized to proceed from its current location to Wepfer Marine, Memphis TN to complete permanent repair. Transit will be conducted in accordance with vessel's TSMS and Vessel and Barge Sinking Response Plan. Transit has been approved by TPO (TVIB). Contact the Coast Guard as soon as it is safe to do so if the situation onboard the vessel deteriorates or anything changes. Please work with your TPO (TVIB) to clear the deficiency IAW CG-CVC Policy Letter 17-10.

Each towing vessel must have either self-priming, power driven, fixed fire pump, a fire main, and hoses, nozzles IAW paragraphs (a) through (d) or a portable pump. Fixed fire pump was found inoperable upon inspection. No portable pump available to meet requirement. Vessel must make corrections to existing pump or provide portable pump to meet requirements and demonstrate operational test to the satisfaction of the attending MI. 46 cfr 142.325

All bilges and void spaces are kept free from accumulation of combustible and flammable materials and liquids insofar as practicable. Bilges contained excessive Lube and Fuel Oil. Vessel is required to rectify condition to the satisfaction of the attending MI. 46CFR 142.220(a)

The vessel is currently under a code 60C CG-835V for failing to meet the minimum 75% COI fleet status. The vessel can not move until the a COI has been issued to the vessel or Company has acquired 75% COI fleet status.

Where installed, all watertight doors in watertight bulkhead must be closed during the operation of the vessel, unless they are being used for transit between compartments and bulkheads designed to be watertight must be maintained in that condition. Upon inspection watertight doors in E/R leading to rudder room and Generator rooms where found out of adjustment and unable to be secured. Bulkhead had been cut to provide access for newly installed MSD. Penetrations provide free flow of water between spaces designed to be watertight. Vessel is to rectify inoperable doors and bulkhead penetrations to meet watertight requirements to the satisfaction of the attending MI. 46 CFR 140.610 (d)(f)

Electrical systems and equipment must function properly and minimize system failures,fire and shock hazards. Multiple breaker panels, breakers and switches are broken, open, or inoperable. Wiring under MDE turbos melted and exposed. Systems must function as designed. Vessel is required to rectify systems to the satisfaction of the attending 46 CFR 143.400(a)

All crewmembers must be familiar with their fire-fighting duties, and, specifically how to: Fight a fire in the engine room and elsewhere onboard the towing vessel, including how to: Operate the fuel shut-off(s) for the engine room. When conducting test of fuel valves, crew was unable to conduct test due to lack of knowledge. Crew must demonstrate working knowledge and complete fire drill to the satisfaction of the attending MI. 46 CFR 142.245(a)(1)(iii)

At least one lifebuoy must have a lifeline, secured around the body of the lifebuoy. If more than one lifebuoy is carried, at least one must not have a lifeline attached. Upon inspection no line was found attached to life buoy. Vessel is required to rectify lifesaving appliances to the satisfaction of the attending MI. 46CFR 141. 360 (c)(1)

Each lifebuoy with a floating electric water light must have a lanyard of at least 910 millimeters (3 feet) in length, but not more than 1,830 millimeters (6 feet), securing the water light around the body of the lifebuoy. Floating Electric light found not attached to lifebuoy. And incorrectly installed.(No existing line present at all and Light actuating lanyard/Bracket not mounted). Vessel is required to rectify lifesaving appliances to the satisfaction of the attending MI. 46CFR 141.360(c)2

Each lifebuoy on a towing vessel must be approved and meet carriage requirements under approval 160.050 and 160.150. Lifebuoys found with missing and damaged Retroflection tape. Lifebuoy condition is required to be rectified to the satisfaction of the attending MI.46CFR 141.360(b)1

Propulsion machinery ' including main engines, reduction gears, shafting, bearings, and electrical equipment and systems, must be maintained to ensure proper operation. Both MDE and Ship Generators displayed multiple exhaust leaks, exposed wiring/connections and inoperable gauge panels. Vessel is required to rectify systems to the satisfaction of the attending MI. 46 cfr 143.205 (c)

Each heat detector is installed, tested and maintained in accordance with the manufacturers design manual. Heat detectors throughout vessel were found painted over, not maintained and inoperable. System to be maintained and tested operable to the satisfaction of the attending MI. 46 CFR 142.330(a)2

Each integral fuel tank must have a vent that connects to the highest point of the tank, discharges on a weather deck through a bend of 180 degrees, and is fitted with a 30-by-30-mesh corrosion-resistant flame screen. Flame screen on all vents does not meet the 30 by 30 mesh requirements. Required to rectify condition to the satisfaction of the attending MI. 46 CFR 143.265(c)

Equipment, cargo, and industrial components on board the vessel are properly secured and made ready for transit. Engine room tool box was found unsecured/unable to properly secure. Ensure Tool box is properly secured and made ready for transit to the satisfaction of the attending MI. 46 CFR 140.805(b)

The owner or managing operator must provide satisfactory evidence of the required servicing to the marine inspector. Inspection tags and markings were inconsistent and not available for reconciliation. Tags/Records made available to verify servicing is being conducted in accordance with manufacturers specifications to the satisfaction of the attending MI. 46 CFR 142.240(a)(1)(iv)

Machinery systems must be designed and maintained to provide for safe operation of the towing vessel and safety of persons on board under normal conditions. Propulsion and Generator system valves were found closed but in unsecured condition and not plugged allowing for mechanical or personal contact to open and provide free transfer of system fluids to engineering space. Secure lines and plug valves to the satisfaction of the attending MI. 46 CFR 143.205(a)

To stop the flow of fuel in the event of a fire or break in the fuel line, remote fuel shut off valve must be fitted on any fuel line that supplies fuel directly to a propulsion engine or generator prime mover. The valve must be operable from a safe place outside the space where the valve is installed. While conducting operational test of system crewmembers were unable to demonstrate operation due to lack of knowledge and training. Valve indicator also showed system in closed position while allowing fuel transfer. Must demonstrate correct operation of valve indicator and valve operation as well crews ability to use system as designed to the satisfaction of the attending MI. 46 CFR 143.260(b)

The following list of items must be recorded in the TVR, official logbook, or in accordance with the TSMS applicable to the vessel:Personnel records, in accordance with §140.400; Safety orientation, in accordance with §140.410;Record of drills and instruction, in accordance with §140.420;Examinations and tests, in accordance with §140.615;Operative navigational safety equipment, in accordance with §140.620; Navigation assessment, in accordance with §140.635; Navigation safety training, in accordance with §140.645; Oil residue discharges and disposals, in accordance with §140.655; Record of inspection of towing gear, in accordance with §140.820; and Fire-detection and fixed fire-extinguishing, in accordance with §142.240. Vessel could not provide nor did they have active system in place to meet record keeping requirements. Vessel is required to rectify program to the satisfaction of the attending MI.

The cognizant OCMI may require additional examinations of the vessel whenever he or she discovers or suspects damage or deterioration to hull plating or structural members that may affect the seaworthiness or fitness for the route or service of a vessel. These examinations may include a dry-dock examination, including: (1) An internal structural examination of any affected space of a vessel, including its fuel tanks; While conducting walk around of vessel during haulout Marine Inspector identified a number of cracked inserts, washed out welds, corroded and damaged STBD Prop shaft bearing housing, Report of hole in Stbd Fuel Tank and E/R slop. Insets and pitting were identified in numerous locations as well. Dry Dock and ISE to be conducted by surveyor with Coast Marine Inspector present to identify areas requiring repair. Report to be provided to Coast Guard and NDT conducted on all repairs to the satisfaction of the attending Marine Inspector. 46 CFR 137.300(a)(1)

Vessel was issued a CG-835V from CVC-1 allowing 90 days to obtain a COI. Vessel did not meet the 90 day requirement. A code 60 Prior to Movement has been issued. 46 CFR 136.202 Certificate of Inspection phase in period.

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.

FAILED TO RECORD TESTS & INSPECTIONS PRIOR TO A 24 HRS VOYAGE OR MASTER/OPERATOR CHANGE. [33 CFR 164.78 (b)]

NEED TO UPDATE NOTICE TO MARINERS (LAST DATE 1999). [33 CFR 164.72 (b)(3)(i)(B)

FAILED TO HAVE OIL TRANSFER PROCEDURES ON BOARD. [33 CFR 155.720]

POST PLACARD ON MARINE SANITATION DEVICE WITH OPERATION INSTRUCTIONS, SAFETY PRECAUTIONS, AND WARNINGS PERTINENT TO THE DEVICE. [33 CFR 159.59]

FAILED TO MAINTAIN ALL PORTABLE FIRE FIGHTING EXTINGUISHER ON BOARD. THE LAST INSPECTION DATE WAS IN APRIL 1999. [46 CFR 25.30-20 (b)(1)&(2)(i)]

VESSEL'S BELL WAS NOT ON BOARD AT THE TIME OF THE BOARDING.

FIXED FIRE FIGHTING SYSTEM IN ENGINE ROOM NEEDS TO BE INSPECTED.

THE VESSEL HAD 06 POB. THERE WERE 06 TYPE 1 PFD'S ON BOARD. THREE OF THE PFD'S WERE UNSERVICABLE DUE TO RIPS IN OUTER COVERING AND CUT STRAPS.

MARPOL PROHIBITED DISCHARGE PLACARD WAS NOT ON BOARD.