DAVID J COOPER JR

Propulsion machinery must be maintained to ensure proper operation. Repair main engines to satisfaction of USCG or TPO.

Provision must be made to guard against liquids rising in the venting system to a height that would exceed the design head of a cargo tank or fuel-oil tank. It may be made by high-level alarms or overflow-control systems or other, equivalent means, together with gauging devices and procedures for filling cargo tanks While conducting refueling of day tank, the high level shutdown switch failed to secure the fuel pump upon reaching high level. The high level alarms were secured due to known malfunction with the alarm panel. Crew secured fuel pump upon discovery of fuel spill. 100 gallons of fuel spilled on deck and waterway. Duty Marine Inspector will accept a Towing Vessel Inspection Bureau report that satisfies the requirements of this deficiency. Upon satisfaction of repairs by Towing Vessel Inspection Bureau, any codes for Action that limit vessel operations may be removed, and the DMI is to be formally notified by Towing Vessel Inspection Bureau.

"This subpart sets forth the procedures by which an operator of a vessel must establish and maintain, for itself and for the owners and demise charterers of the vessel, evidence of financial responsibility required by Section 1016(a) of the Oil Pollution Act of 1990. This subpart applies to the operator as defined herein of any vessel using the navigable waters of the United States or any port or other place subject to the jurisdiction of the United States, including a vessel using an offshore facility subject to the jurisdiction of the United States." Upon the initial certification of the vessel, found the vessel is 380 GRT without an approved Certificate of Financial Responsibility (COFR) that is required for vessels over 300 GT. Provide all necessary documentation to the National Pollution Funds Center and obtain an approved COFR. 33 CFR 138.10 and 33 CFR 138.15

"Policies must be in place that cover the owner or managing operator’s approach for ensuring vessel compliance, including, but not limited to, policies on maintenance and survey, safety, the environment, security, and emergency preparedness." a) Since no Certificate of Financial Responsibility (COFR) was provided to the vessel, identify the gap in the company's towing safety management system (TSMS) that allowed the delay in COFR submission/possible confusion of applicability, and ensure this gap is written down and addressed to prevent future incidents. Provide this completed TSMS portion to both your TPO (TVIB) and our office for review within 14 days. b) Furthermore, conduct an evaluation of all Turn Services towing vessels over 300 GRT to assess if a COFR has been issued and provide results no later than 1200 on 11MAR2020. 46 CFR 138.220(c)

PROVIDE A U.S. COAST GUARD APPROVAL NUMBER FOR THE MARINE SANITATION DEVICE ON BOARD.