CAPT BRENNAN

Each vessel with a capacity of 250 or more barrels (10,500 gal) of oil shall provide transfer procedures for transferring (a) To or from the vessel; and (b) From tank to tank within the vessel. Vessel carries more that 250 barrels of fuel and does not have transfer procedures.

Pressure vessels over 5 cubic feet in volume and over 15 pounds per square inch maximum allowable working pressure (MAWP) must be equipped with an indicating pressure gauge (in a readily visible location) and with one or more spring-loaded relief valves. The total relieving capacity of such relief valves must prevent pressure from exceeding the MAWP, as established by the manufacturer, by more than 10 percent. Vessel's port and starboard air compressor vessels have a MAWP of 150 PSI with both relief valves at 200 PSI. Vessel to install relief valves to not exceed the MAWP by to the satisfaction of Coast Guard Marine Inspector. 46 CFR 143.300 (a)

Crewmembers must meet the requirements in §§ 15.405 and 15.1105 of this chapter, as appropriate. Crewmembers were unfamiliar with life raft operations and did not have certified Lifeboatmen. A Crewmember is to be certified Lifeboatmen and provide certification to the satisfaction of Coast Guard Marine Inspector. 46 CFR 140.405 (a)

Users must always maintain their Automatic Identification System in an effective operating condition and ensure the accuracy of all broadcasted dynamic, static and voyage information in accordance with 33 CFR 164.46(d). This vessel is currently transmitting an incorrect value for their IMO number and a zero value for the vessel’s draft. Correct all incorrect values being transmitted through the AIS to the satisfaction of an attending Coast Guard Marine Inspector prior to August 13, 2020.

A Marine Employer must provide an EAP education program for for the employer's crew members and supervisory personnel. The training program must include at least the following elements: the effects and consequences of drug and alcohol use on personal health, safety, and work environment; the manifestations and behavioral cues that may indicate drug and alcohol use and abuse; and documentation of training given to crew members and the employer's supervisory personnel. Supervisory personnel must receive at least 60 minutes of training. Provide EAP supervisory and employee training and provide training records to the satisfaction of an attending Coast Guard Marine Inspector prior to August 13, 2020.

Marine Employers must ensure that they and their crew members have met the requirements of a Chemical Testing Program as required in 46 CFR 16.203(a). Provide documentary proof of pre-employment tests and random drug tests for the last 12 months through Medical Review Officer letter for each drug test. The paperwork must be submitted to the satisfaction of an attending Coast Guard Marine Inspector prior to August 13, 2020.

Personnel dispatched from the vessel or that are working in an area on the exterior of the vessel without rails and guards must wear a work vest approved by the Commandant under 46 CFR subpart 160.053. The crew is currently utilizing Type III PFD's under CG Approval 160.064. Owner must either provide the appropriate work vests in accordance with 46 CFR 140.430(a) or request a Special Consideration from the local OCMI in accordance with CVC Work Instruction (CVC-WI-010(1) prior to August 13, 2020

Pressure vessels over 5 cubic feet in volume and over 15 pounds per square inch maximum allowable working pressure (MAWP) must have a indicating pressure gauge visible to the crew in accordance with 46 CFR 143.300(a). There was an indicating pressure gauge affixed to each tank but the locations was such a way that it was not visible by the crew. Move of provide another means for the crew to clearly see the pressure of both air receivers to the satisfaction of an attending Coast Guard Marine Inspector prior to August 13, 2020

Each towing vessel fitted with an installed bilge pump and piping system must have a check/foot valve installed on the suction side that prevents unintended back flooding through the bilge piping in accordance with 46 CFR 143.275. During a test of the vessel bilge dewatering system, there was no foot/check valve installed. Properly install a foot/check valve on the suction side of the each bilge piping to the satisfaction of an attending Coast Guard Marine Inspector no later than August 13, 2020.

Fuel systems for towing vessel main engines and generators must have a documented maintenance plan to ensure proper operation of the system. Vessel unable to provide proof of documented maintenance and documentation they are following the maintenance for fuel system. Provide documented maintenance plan for the fuel systems in way of the main engines and generators to the satisfaction of an attending Coast Guard Marine Inspector prior to August 13, 2020.

Emergency lighting must be provided for all internal crew working and living areas. Emergency lighting sources must provide for sufficient illumination under emergency conditions to facilitate egress from each space and may be automatic, battery-operated with a duration of no less than 2 hours or Non-electric, phosphorescent adhesive lighting strips that are installed along escape routes and sufficiently visible to enable egress with no power. The stairwell on the upper deck in way of the crew stateroom was not sufficiently illuminated in the event of power loss. Install an acceptable form of emergency lighting in this location to the satisfaction of an attending Coast Guard Marine Inspector prior to August 13, 2020.