USNS BIG HORN

Fire-extinguishing appliances shall be kept in good order and be available for immediate use at all times. Vessel reported that two reserve Halon cylinders (01 for cargo pump room and 01 for paint locker) were low on nitrogen pressure. Additionally, vessel reported that six CO2 activation bottles for Halon system are overdue for hydrotest. Replace cylinders and provide report verifying satisfactory operation. 74 SOLAS 97 II-2/21

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure that the ship in all respects will remain fit to proceed to sea without danger to the ship or persons on board. Tank level indicator #3 is inoperable. Prove proper operation of TLI #3. 74 SOLAS 20 I/11(a)

Means shall be provided to close all openings which may admit air to or allow gas to escape from a protected space. Vent fire closure 06-104-4 does not have a gasket. Install gasket. SOLAS 97 II-2/5.1.4

Fire extinguishing appliances shall be kept in good order and be available for immediate use at all times. Vessel self-reported that multiple AFFF heads on the tank-top deck were blocked and inoperable. Clear AFFF heads. SOLAS 97 II-2/21

Where cables which are installed in hazardous areas introduce the risk of fire or explosion in the event of an electrical fault in such areas special precautions against such risks shall be taken. Attending MI noted that there were numerous electrical wires not properly terminated on the cargo deck. All wiring on the cargo deck shall ether be removed when not in service or by terminated in an appropriate junction box approved for use in cargo areas. Specific locations where this was noted Port aft deck near shore tie interface, and Centerline deck junction box in dead. SOLAS 97 II-1 45.5.4

In tankers, electrical equipment, cables and wiring shall not be installed in hazardous locations unless it conforms with standards not inferior to those acceptable to the Organization. Attending MI’s noted that there were two household/shop fans being utilized in the lower level of the Pump room. During the course of the inspection a third fan was added to the pump room. All equipment utilized in a hazardous locations shall be designated as such. Instructions and procedures to insure safe operation of ships and protection of the environment in compliance with relevant international and flag state legislation. Company shall develop, implement and maintain a safety management system that validates which equipment is safe for use within the cargo pump room and cargo deck. ABS shall verify implementation via limited scope internal audit.97 SOLAS II/1 45.11 / ISM Code 1.4.2

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure that the ship in all respects will remain fit to proceed to sea without danger to the ship or persons on board. The Emergency Bilge suction filter basket located within the engine room lower level was badly wasted. 97 SOLAS 1/11

Fire detection systems shall be kept in good order so as to ensure their required performance if a fire occurs. Fire detection panel is currently displaying an error and is unable to be reset.

Fixed fire extinguishing systems shall be installed having due regard to the fire growth potential of the protected spaces. During annual servicing and COI inspection of fixed firefighting of Halon system, Marine Inspectors and ABS identified multiple Halon bottles that are out of normal range. 74 SOLAS 1997 II-2/10.1.1

Where remote control of propulsion machinery from the navigation bridge is provided and the machinery spaces are intended to manned, the propulsion machinery orders from the navigation bridge shall be indicated in the main machinery control room or a the maneuvering platform as appropriate. During coordinated test of engine order telegraph (EOT) between bridge and engine control room (ECR), the port side bridge EOT alarm does not correspond to what the ECR indicator. 74 SOLAS 1997 II-1/31.2.4

Each tank vessel with a cargo capacity of 1,000 or more cubic meters of oil or residue must have an overfill device on each cargo tank that has independent high and overfill alarms. The high alarm on #10P cargo tank is in constant alarm and unable to reset. Effective repairs shall be made and satisfactory testing prior to carriage of cargo in the #10P cargo tank. 33 CFR 155.840(b)(1)

The Condition of the ship shall be maintained fit to proceed to sea without danger to the ship or persons on board. Port main engine automation failure for LO, rocker arm LO, and FO pressure are maxed out and not accurately reading. STDBY pumps and alarms will not activate, local gauges and engine safety shutdowns are still functional. Require manned engine room watch when port main engine is operational. 74 SOLAS (2020) I/11(a) 705 - full machinery manning

Incinerators onboard ships shall be provided with a manufacturer's operating manual and servicing provided by personnel responsible for its operation. Incinerator installed onboard was not operational, had an air leak from the sluice gate control line, had heat damage to cabling on the top of the sluice gate structure, and had 10+ active alarms in fault for the system. Satisfactory repairs and operation shall be witnessed by RO prior to use. 73/78 MARPOL (2017) 705 - prior to use

Condition of the ship and its equipment shall be maintained so as to remain fit for the ship to proceed to sea without danger to the ship or persons onboard. Noted alarms on navigational light panel for both stern lights and one of the two forward mast head lights. Light operation and alarms shall be cleared to satisfaction of RO, ship limited to daylight ops. 74 SOLAS (2020) I/11(a) 705 - daylight ops only

Purpose of this regulation is to contain a fire in the space of Origin. The fire integrity of the division shall be maintained at Openings and penetrations. Identified improper bulk head penetrations from ECR to main machinery space, MCT firestop was pulled out to allow new cable passage, additionally five new holes were drilled for cable penetrations without fire resistant insulation. Bulkhead and penetrations are required to be “A”60. 74 SOLAS(1997) II-2/9.1.3

Means shall be provided to control leaks of flammable liquids. Oil leaking from #1 & 3 SSDG turbo charger oil level gauge, STBD Main fuel return line IWO oil purification room. 74 SOLAS(1997) II-2/4.1.1

The Condition of the ship shall be maintained fit to proceed to sea without danger to the ship or persons on board. Active Air leak from FO-PV015 IWO oil purification room. 74 SOLAS (2020) I-11(a)

Hydraulic power operated steering gear shall be provided with a low-level alarm for each hydraulic reservoir. STBD steering gear low lube alarm inoperable. Reservoir oil level to be checked on engineering rounds until repaired and operational. 74 SOLAS(1997) II-2/9.1.3

The company should establish procedures to ensure the ship is maintained in conformity with the relevant rules and regulations. Company should ensure that inspections are held at appropriate intervals, any non-conformity is reported, and appropriate corrective action is taken. TANO alarm system is two years past scheduled maintenance and grooming , observed active alarms for incinerator smoke, aux boiler # 2 smoke, incinerator malfunction, feed and condensate sys dissolved solids high, refrigeration system #1 malfunction. Alarm grooming & servicing shall be completed within 60 days to the satisfaction of the RO. Required manned engine room watch until deficiency is cleared. 74 SOLAS(2020) IX/5 ISM CODE 10A

Lifeboats onboard shall be provided with a first aid kit in a waterproof case. The first aid kits currently onboard are expired. A new first aid kit shall be provided for each lifeboat onboard. 74 SOLAS (1997) III/41.8.20

The Condition of the ship shall be maintained fit to proceed to sea without danger to the ship or persons on board. Noted two (02) corroded LP air pipes on cargo deck area leaking air. 1. IVO #4P WBT (U joint) 2. IVO Starboard Rescue Boat (Aft structure, deck fitting) Corroded pipes shall be replaced to satisfaction of RO. 74 SOLAS (2020) I/11(a)

Fire~fighting systems and appliances shall be kept in good working order and readily available for immediate use. Found EDG halon time delay disconnected. Reconnected by servicing provider during inspection. 74 SOLAS (1997) 11-2/14.2.l.2

No less than 4 line throwing projectiles and 4 lines shall be provided on the ship for line-throwing appliances. Found only three (03) line-throwing appliances on board during inspection. An additional four (04) line-throwing appliances were supplied onboard during the inspection. 74 SOLAS (1997) III/49

A minimum of two (02) two-way portable radiotelephone apparatus shall be provided for each fire party for fire-fighter's communication. These devices shall be of an explosion-proof type or intrinsically safe. Ships constructed before 01JUL2014 shall comply with this no later than the first survey after 01JUL2018. Noted only 1 portable radiotelephone for fire team, and device was not intrinsically safe/explosion proof type. A minimum of 2 devices, in compliance with the requirements above, shall be provided at each fire locker within 30 days to the satisfaction of the RO.

The starboard rescue boat is inoperable due to a failed transmission and has been out of commission for 6+ months. Obtain proper replacement parts, repair rescue boat, and prove ability to make 6 knots. 74 SOLAS (14) III/20.2

The starboard rescue boat is unable to be launched or recovered due to improper stowage arrangements and missing rigging. Replace improper length pendant, remove cargo straps securing boat to davit, and replace rigging and brake lines. Demonstrate launching and recovery of rescue boat. 74 SOLAS (14) III/20.2

Overhead lighting in the EDG room is not secured and galley overhead lighting is missing shielding covers. 74 SOLAS (14) II-I/45.1.3

Lagging in missing in areas within the cargo pump rooms and machinery space. 74 SOLAS (14) II-I/26.1

Life boat No. 4 has an inoperable limit switch. 74 SOLAS (14) III/4.2.2

The paint locker had spilt lineseed oil and haphazard stowage inside. 74 SOLAS (14) II-2/4.1.1

Laundry room had bedding sheets and towels scattered throughout the space, creating a fire and tripping hazard. 74 SOLAS (14) 1/11(a)

Stbd CPP hydraulic remote pitch control failed.

Salt water pipe to all three salt water service pumps currently has a crack and is leaking saltwater. If crack becomes worse there is potential to lose propulsion plant. Vessel is required to have tug escort from sea buoy to mooring. Tug escort shall be two tugs with an aggregate total horsepower of 9,000 or 90 ton bollard pull. Make repairs to satisfaction of classification society.

Port Main Engine air start distributor failed.

Make permanent repairs to the damage IWO Frame 31-35 port side, Port side accommodation ladder, and frames 113–131 by the Helo Flight deck, 01 level. 23Jan09 recieved email from [name withheld] advising repairs have been completed and approved by an ABS Surveyor. Due date extended to next annual exam for confirmation.

Conduct repairs to Starboard Shaft Control Pitch Propeller leakage.

Demonstrate proper operation of #2 PTO generator in all modes.

Provide proof of 3rd mates STCW endorcement for GMDSS, prior to 3rd mate standing Navigation watch.

Provide proof of repair to Fire Alarm system.

Replace expired line throwing device.

Prove proper operation of the emergency generator auto bus transfer.

Prove proper operation of #2 PTO generator in modes 2 and 3 and demonstrate reverse power relay trip

Correct all faulty manual pull stations identified by Hiller service report.

Prove proper lift of the #1 & #2 Ship's Service Air and Start Air receiver relief valves as marked on the valve placard, not to exceed the MAWP of the receives NLT 30 days.

Repair exhaust leak on the #3 SSDG turbo charger.

Prove the audible alarm in the machinery spaces can be heard throughout the engine spaces.

Prove proper operation of automation test procedure 2-18, #5 to the satisfaction of the attending marine inspector NLT 30 days.

Prove proper operation of the EDG start accumulator bottles.

Renew the flex couplings on both reefer units.

Make proper repairs to the leaking sprinkler piping in the overhead behind the console in the #3 lifeboat.

Prove proper operation of number one starting air receiver relief valve.

Prove proper operation of ship's whistle relief valve.

Prove proper operation of watertight doors.

Ensure spanner wrenches are located at each machinery space fire station.

Remove excess fuel, oil, and water from around Ship's Service Diesel Generators.

Demonstrate proper operation and calibration of the cargo discharge oil content meter.

Replace burnt-out bulbs in all flashing lights in machinery spaces.

Install/prove operation of P.T.O. (port)(pony generator).

make repairs to port inflatable pontoon that has pulled free of inner fiberglass hul.

Renew all failed battery E-lights prior to sailing

Re strap overhead cable runs in and around machinery spaces

Low L/O shutdown on #4 generator failed

PROVIDE DOCUMENTATION OF C.G. OR ABS APPROVED WELDERS QUALIFICATIONS I.A.W. 46 CFR PART 57 & ASME CODE SECTION IX.

PROVIDE APPROVED C.G. OR ABS PLANS (UNDER NVIC 10-82) TO INDICATE REPAIRS & MODIFICATIONS TO NO.6 & 7 KING POSTS. LEGACY COMPONENT DESC: APPROVED REPAIR PLANS

PROVIDE APPROVED WELDING PROCEDURES FOR THE AREAS BEING REPAIRED/MODIFIED TO NO.6 & 7 KING POSTS. LEGACY COMPONENT DESC: APPROVED WELDING PROCEDURES

PROVIDE WRITTEN DOCUMENTATION OF WELDERS PERFORMING REPAIRS/MODIFICATIONS TO NO.6 & 7 KING POSTS TO INDICATE WHICH WELDERS CONDUCTED WELDING TO NO.6 & NO.7 KING POSTS AND THE SPECIFIC LOCATION OF THE AREA WELDED. LEGACY COMPONENT DESC: WRITTEN STATEMENT OF FACT

PROVIDE REPAIR DATA PLATE TO NO.1 AUXILIARY BOILER I.A.W. NATIONAL BOARD INSPECTION CODE. LEGACY COMPONENT DESC: DATA REPAIR PLATE

CONDUCT HYDROSTATIC TEST TO 1.25 X MAWP TO NO.1 AUXILIARY BOILER. LEGACY COMPONENT DESC: HYDROSTATIC TESTING

CONDUCT REPAIRS TO THE NO.1 AUXILIARY BOILER (S/N N-22631) TO FRONT CASING AREA WHERE WASTAGE & CRACKS ARE EVIDENT I.A.W. 46 CFR 59.10 & ASME CODE STANDARDS. LEGACY COMPONENT DESC: Combustion Chamber

PROVIDE REPAIR PROPOSAL & WELDING QUALIFICATIONS FOR C.G. REVIEW & APPROVAL TO REPAIR NO.1 AUXILIARY BOILER CASING.

NO. 1 AUXILIARY BOILER TO BE KEPT OUT OF SERVICE UNTIL FINAL REPAIRS ARE COMPLETED AND A FUNCTION TEST IS COMPLETED TO THE SATISFACTION OF ATTENDING COAST GUARD MARINE INSPECTOR.

CONDUCT REPAIRS TO THE FOLLOWING GENERAL ALARM BELLS: 1. LOWER LEVEL ENGINE ROOM FORWARD OF MAIN DIESEL ENGINES. 2. ELECTRICIAN SHOP ATOP OF BOOK SHELF. 3. GENERAL ALARM BELL BETWEEN STATEROOMS 04-90-3 & 04-94-3. LEGACY COMPONENT DESC: General Alarm

PROVE PROPER OPERATION OF STEERING ROOM PORT SIDE WATER TIGHT DOOR TO CLOSEBETWEEN 20-40 SECONDS.

PROVE PROPER OPERATION OF ALL LIFEBOAT BILGE PUMPS.

COMPLETE VENTILATION MODS FOR INCINERATOR ROOM TO ALLOW FOR THE FIRE DOOR CLOSURE TO CLOSE DOOR. A LIVE WATCH MUST BE MAINTAINED WHILE INCINERATOR IS IN OPERATION.

RENEW LIGHTS ON LIFEJACKETS AND EMERSION SUITS WITH COAST GUARD/SOLAS APPROVED LIGHTS.

REPAIR RIGID OIL LINES TO OVERHEAD CAM VALVE COVERS TO NO. 4 SSDG TO B2 ANDB5 COVERS.

REPAIR EMERGENCY DIESEL GENERATOR MONITORING PANEL TO PRE-LUBE SYSTEM.

REPAIR EYE WASH STATION IN FRONT NO. 3 SSDG.

REPAIR OILY WATER SEPARATOR REMOTE CONTROL IN MCR CONSOLE.

PROVIDE PROPER STCW ENDORSEMENTS FOR ALL ABS PRIOR TO ASSIGNING TO WATCHSTANDING DUTIES.

DEMONSTRATE LIFEBOAT NUMBER 3, 2, 4 SPRAY WASHDOWN SYSTEM.

PROPERLY HARDWIRE OR REMOVE AMA-OIL INJECTION PUMP AFT OF NO.1 EVAPORATOR.

PROPERLY LABEL C.B. PANEL "ENG. ROOM MOV POWER PANEL" WITH DIRECTORY LIST OF C.B. SWITCHES POSITIONS.

REPAIR STIFF OPERATION OF EMERGENCY SHUTDOWN CABLE TO NO.3 SSDG.

REPAIR NO. 1 SALT WATER CIRCULATING PUMP SEAL. LEGACY COMPONENT DESC: Pump

MAKE REPAIRS TO GENERAL ALARM BELLS THROUGH OUT THE SHIP.

RENEW ALL FOUR LINE THROWING DEVICES WHICH HAVE EXPIRED.

REPAIR SEARCH LIGHT OUTLET FOR NO.1 LIFEBOAT.

PROPERLY LABLE EMERGENCY LIGHTS THROUGHOUT THE VESSEL.

PROVIDE SOLAS APPROVED WEIGHTED LIFE RINGS FOR BRIDGE WING QUICK RELEASE.

REPAIR/REPLACE AIR SUPPLY HOSES IN ALL LIFEBOATS DUE TO AIR LEAKS.

PROPERLY MAKE THE OPERATION HANDLE FOR STEERING GEAR ROOM STARBOARD WTD TO OPERATE IN THE DIRECTION OF THE DOOR MOVEMENT.

PROPERLY LABLE ALL WATERTIGHT DOOR ACTUATORS WITH THE DIRECTION OF_x001C_ OPERATION.

REPAIR HYDRAULIC LEAK ON ENGINE CONTROL ROOM WATERTIGHT DOOR.

PROVE PROPER OPERATION OF THE 5-10 SECOND DELAY ALARMS FOR SLIDING WATERTIGHT DOORS AS REQUIRED BY ASTM 1197.

CLEAN CARPENTER SHOP TO COMPLY WITH GENERAL HOUSE KEEPING STANDARDS.

CONDUCT TEST OF PITCH FAILURE ALARM AS PER PG 2-20 AT LECS OF APPROVED AUTOMATION PROCEDURES.

HYDRO STATIC TEST TO BE CONDUCTED TO OXYGEN BOTTLES IN HOSPITAL SPACE.

REPAIR RIGID OIL LINES TO OVERHEAD CAM VALVE COVERS TO NO. 3 SSDG TO A3 COVER.

PROVIDE AUXILIARY LINE (1500 FEET) FOR LINE THROWING GUN.

PROVIDE CONDITION REPORT OF REPAIRS/STATUS OF PORT MAIN ENGINE STARBOARD AIR HORN HOUSING CRACKS. EXTENSION GRANTED.

CONDUCT REPAIRS TO NO.2 PTO GENERATOR REVERSE POWER RELAY AND TEST TO SATISFACTION OF C.G. INSPECTOR.

PROVE PROPER OPERATION OF PTO GENERATOR IN GENERATOR MODE NO. 2 VERIFY GENERATOR RPM SUSTAIN FULL LOAD OVER FULL RANGE OF THROTTLE LEVER POSITION I.A.W. PG 2-7 OF APPROVED AUTOMATION PROCEDURES. PROVIDE WRITTEN DOCUMENTATION FROM CHIEF ENGINEER.

PROVE PROPER OPERATION OF PTO GENERATORS TO INDICATE THROTTLE LEVER AHEAD AND ASTERN TO SHOW ENGINE SPEED INCREASE AND PITCH MOVEMENT I.A.W. PG 2-6 OF APPROVED AUTOMATION PROCEDURES. PROVIDE WRITTEN DOCUMENTATION FROM CHIEFENGINEER WITH COPY OF MARINERS LICENSE.

DEMONSTRATE SPRINKLER SYSTEM FOR JUNGLE DECK.

CONDUCT REPAIRS TO NO.2 PTO SYNCRO-COMPENSATOR MOTOR AND CONDUCT FULL FUNCTION TEST OF SYSTEM I.A.W. APPROVED PROCEDURES IN THE PRESCENCE OF A C.G. MARINE INSPECTOR.

[withheld — contains personal information; the deficiency system, dates, and resolution status are shown above]

REPAIR LEAKS TO FIRE HYDRANT VALVES STEMS TO F/S 100, F/S 27, F/S 18, F/S 7.

PROVIDE COPY OF SAFETY RELIEF VALVE TESTING REPORT.

REPLACE THE FOLLOWING SAFETY RELIEF VALVES: FAS NO.8, FAS NO.6, FAS NO.2, RAS NO.3, FAS NO.8, NO.1 MOISTURE SEPARATOR AND RESERVE AIR FLASK. LEGACY COMPONENT DESC: Valve

PROVIDE DOCUMENTATION THAT ALL FAS SAFETY RELIEF VALVES MEET MIL SPEC REQUIREMENTS.

PROVE PROPER INSTALLATION AND OPERATION OF RADARS TO THE SATISFACTION OF ATTENDING MARINE INSPECTOR PRIOR TO GETTING UNDERWAY.

PROVIDE COPY OF FUEL OIL TRANSFER PROCEDURES IAW 33 CFR 155.

PROVE PROPER OPERATION OF MDES' AUTOMATION ALARMS AND SHUTDOWNS.

DEMOSTRATE WEIGHT TEST OF #1 AND #4 LIFEBOAT DAVITS PRIOR TO GETTING UNDERWAY.

RENEW ALL FUEL OIL AND LUBE OIL FLEXIBLE HOSES ON EMERGENCY GENERATOR _x001C_ WITH APPROVED FIRE RESISTENT MARINE HOSES.

INSTALL USCG APPROVED "FIRE STOP" IN ELECTRICAL CABLE RUN ABOVE WATERTIGHT DOOR STBD SIDE STEERING FLAT.

REPAIR CHEMICAL TREATMENT TANK FOR MSD.

REPAIR WRONG DIRECTIONAL ALARM ON EOT LOCATED IN MAIN CONTROL.

REPLACE EXISTING LIFTING PENDANTS AND ASSOCIATED HARDWARE AS ORIGINAL ON BOTH PORT AND STARBOARD RESCUE BOATS; CONDUCT WEIGHT TEST IN PRESENCE OF COAST GUARD MARINE INSPECTOR.

UPDATE FIRE CONTROL PLAN TO INDICATE PROPER TYPE, AMOUNT AND LOCATION OF FIREFIGHTING EQUIPMENT.

PROVIDE PROPER OPERATION OF OIL DISCHARGE MONITOR PRIOR TO DEPARTURE FROM THE PORT OF HAMPTON ROADS.

PRIOR TO LOADING CARGO PROVE PROPER OPERATION OF SPRINKLER SYSTEM ON LIFEBOAT NO. 3.

MAKE PROPER REPAIRS AND DEMONSTRATE PROPER OPERATION OF PORT MAIN DIESEL ENGINE.

MAKE PROPER REPAIRS TO PORT MAIN DIESEL ENGINE CRANKSHAFT PRIOR TO DEPARTURE PORT OF HAMPTON ROADS.

CONNECTING ROD FOR PISTON BROKE. THIS CAUSED DAMAGE TO SURROUNDING PARTS.

Demonstrate proper operation of both starting air receiver relief valves.

Provide properly rated pressure gauge in way of #2 auxiliary boiler with a mid-range deflection of 200 psi.

Make permanent repairs to minor interior leak in way of #4 lifeboat sprinkler system.

REPAIR STBD REDUCTION GEAR AFT PINION BEARING TEMPERATURE SENSOR. MAINTAIN A LIVE WATCH ON BEARING UNTIL SENSOR IS OPERATIONAL.

RENEW THE HYDROSTATIC RELEASE ON THE EPIRB.

PERFORM SATISFACTORY OPERATIONAL TEST OF CARGO DECK SPRINKLER SYSTEM.

PROVIDE COPY OF FOAM ANALYSIS.

INSTALL DOOR KNOB IN FIRE SCREEN DOOR AT 05 LEVEL OF STAIRWELL.

REPAIR STBD CARGO DOOR AND CONDUCT A SATISFACTORY HOSE TEST

REPAIR STBD ACCESS DOOR GASKET FOR #4 LIFEBOAT

REPAIR CABLE STUFFING TUBE IN ENGINE COMPARTMENT FOR #4 LIFEBOAT

INSTALL PRESSURE RELIEF VALVE AFTER FIREPUMP AND BEFORE THE DISCHARGE VALVEAS PER 46 CFR 34.10-5(d)

REPAIR/REPLACE SHIP SERVICE AIR RELIEF VALVE AND TEST FOR PORPER OPERATION

REPAIR/REPLACE EMERGENCY LIGHTING AS NECESSARY AND CONDUCT A SATISFACTORY TEST.

INSTALL INSULATION AROUND GALVANIZED EXHAUST PIPE AS PER MANUFACTURES REP FOR ALL LIFEBOATS

PROVIDE APPROVED PLANS FOR HIGH PRESSURE AIR SYSTEM (3000 PSIG) (ASI#C8-27549-01-10) WITH SPECIFIC ACCEPTANCE FOR USE OF THE 6 CU. FT. HP AIR RECEIVERIN HPAC RM MANUFACTURED IAW MIL-F-22606B AS NOTED IN ABS LTR P-321183, L-O-40641 DTD 23APR90.