QUESTION: I have a regulatory interpretation question regarding generators.
A generator fails on a vessel equipped with 3 generators while the other two generators are fully operable. Only one generator is needed to carry the load for the vessel. Are we required to report this to the Coast Guard and TVIB?
RESPONSE: Short answer is yes, based on the following:
Guidance concerning reportable marine casualties was taken from NVIC 01-15 title 46, code of federal regulations (CFR), part 4 marine casualty reporting procedures guide with associated standard interpretations 46 CFR 4.05-1.
The loss of an online generator IS considered a reportable marine casualty no matter the duration. However, if you have the required 2 operational power supplies, you continue to meet the requirements under Subchapter M.
The benefit of this setup is that the vessel still has the required power supplies so you can schedule repairs to the affected generator later and continue operations without lost time.
Once reported, this may be handled differently from one Coast Guard unit to another since it does not affect operations. These would be the 2 most likely and agreed-upon options but they do not preclude an alternate path not discussed in this FAQ under the direction of the OCMI.
- CG-835V not issued, Notify TPO IAW companies TSMS for repairs. Continue operations
- CG-835V issued, Action Code A, Self-reported Worklist item, not fwd. facing. Notify TPO IAW Companies TSMS. Continue operations.
QUESTION: During an annual survey a question was raised on whether a vessel must have flame screens on vent pipes for fuel oil. I thought was a requirement for all Sub M vessels, where can I this requirement?
RESPONSE: 46 CFR 143.265
46 CFR 143.265 Additional fuel system requirements for towing vessels built after January 18, 2000.
(c) Vent pipes for integral fuel tanks. 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. Vents from two or more fuel tanks may combine in a system that discharges on a weather deck. The net cross-sectional area of the vent pipe for the tank must be not less than 312.3 square millimeters (0.484 square inches), for any tank filled by gravity. The cross-sectional area of the vent pipe, or the sum of the vent areas when multiple vents are used, must not be less than that of the fill pipe cross-sectional area for any tank filled by pump pressure.
QUESTION: Are potable water tanks required to have protection such as a screen on the vents for safety or to prevent bugs from getting in?
RESPONSE: Yes. Vent screens are one of the measures that might be used to prevent contamination of potable water.
46 CFR 140.510(b) – As far as practicable, the owner or managing operator must implement other types of safety control measures before relying on Personal Protective Equipment. These controls may include administrative, engineering, source modification, substitution, process change or controls, isolation, ventilation, or other controls.
Further, the regulations also state:
21 CFR 1250.82(c) – Each potable water tank shall be provided with a means of drainage and, if it is equipped with a manhole, overflow, vent, or a device for measuring depth of water, provision shall be made to prevent entrance into the tank of any contaminating substance. No deck or sanitary drain or pipe carrying any nonpotable water or liquid shall be permitted to pass through the tank.
