THERESA ECHOLS

Verification of compliance with design standards, when required by § 144.135, must be performed by an individual or entity who meets the requirements of § 144.140. The vessel underwent extensive modifications at Southwest Shipyard, Brady Island, Houston, TX. The vessel has completed an inclining examination as required by the OCMI, but the completed design verification, including stability analysis and the stability letter have not been submitted to the OCMI. The Owner shall submit the stability calculations and proposed stability letter to the Marine Safety Center within 60 days. The vessel is authorized to operate during this time.

Vessel is undergoing substantial repairs and modifications at Southwest Shipyard, Brady Island, Houston, TX with the intent of returning to service as an Inspected Towing Vessel. Following review of submitted scope of work, Sector Houston Galveston has determined modifications substantially prolong the life of the vessel and may be considered a Major Conversion as defined in 46 CFR 136.110 and 46 USC 2101(18). Owner/operator is required to submit documentation to the USCG Marine Safety Center (MSC) for a Major Conversion Determination. 46 CFR 136.110 46 USC 2101(18)

Verification of compliance with design standards, when required by § 144.135, must be performed by an individual or entity who meets the requirements of § 144.140. The vessel is undergoing extensive modifications at Southwest Shipyard, Brady Island, Houston, TX. Upon request by the Coast Guard MI, verification of design standards has not been provided IAW 46CFR144.145 including but not limited to 46CFR144.145(b). Upon request by Coast Guard MI, the Owner failed to provide the required documentation. The company shall provide documentation to the satisfaction of the TPO and Coast Guard prior to the vessel being placed back in service.

Verification of compliance with design standards must include review and analyses of sufficient plans, drawings, schematics, calculations, and other documents to ensure the vessel complies with the standards used. The plans must be stamped with the seal authorized for use by the individual or entity performing the verification of compliance, or otherwise indicate that they have been reviewed and determined to meet the applicable standards by an individual or entity who meets the requirements of § 144.140. Upon request by Coast Guard MI, the Owner failed to provide the requested documentation. The company shall provide documentation to the satisfaction of the TPO and local OCMI. The required documentation shall include but is not limited to the requirements of 46CFR144.145(g) prior to the vessel being placed back in service.

A copy of the verified plan must be provided to the cognizant Officer in Charge, Marine Inspection (OCMI) and the third-party organization (TPO) conducting the surveys, if applicable, except as provided in paragraph (e) of this section. Upon request by Coast Guard MI, the Owner failed to provide the requested documentation. The company shall provide the associated plans and documentation to the satisfaction of the TPO and local OCMI prior to the vessel being placed back in service. The owner or managing operator of a towing vessel that chooses the TSMS option for a towing vessel must document compliance with this subpart as follows: Provide objective evidence of an internal survey program.