Fueling towing vessel question - follow on question

  1. Getting ready to load 60k gallons MDO from trucks to a berthed uninspected towing vessel - do I have to have a designated PIC? Please provide a cite if you know the answer.

  2. Must I submit a notice of transfer to local CG Sector?

[QUOTE=Fathom Marititime;146645]1. Getting ready to load 60k gallons MDO from trucks to a berthed uninspected towing vessel - do I have to have a designated PIC? Please provide a cite if you know the answer.

  1. Must I submit a notice of transfer to local CG Sector?[/QUOTE]

No, you do not need a Tankerman PIC. However you should have a Declaration of Inspection that designates the truck drivers as the “facility” PIC, and someone, probably the engineer, must be the tug’s PIC on the Declaration of Inspection. If each truck is under a certain number of gallons, then technically, you do not need to do a DOI, but why not do one anyway. Truck drivers are not usually as careful about spill prevention as mariners.

I do not recall ever notifying the USCG about taking fuel from trucks, but there might be some local requirement. Also, some states and cities may have local notice or permit requirements. Your marine ops manager should know, and handle it.

Are you a licensed engineer?
Does your company have a Bunkering Policy in the SMS?
Absent that I assume 33 CFR would apply in any case.
You can bet there will be a “person in charge” of that operation whatever their documents say, just see what happens when something goes wrong.
I agree with tugsailor, absent unambiguous company requirements (based on national/local laws of course), there seems to be little downside to documenting the precautions taken on DOI, being properly staffed up and monitoring the transfer.

Captain of the UTV can serve as The PIC.

[QUOTE=0rion;146653]Captain of the UTV can serve as The PIC.[/QUOTE]

As far as I know, anyone can serve as PIC to fuel a UTV. Some companies do specify in their company policies that it must be someone with a license or a tankerman endorsement. I try to avoid being that person, but sometimes I have to. In practice, the engineer actually receives the fuel.

Anyone as long as they have been trained in house by the Port Engineer or a person assigned by the company to train personnel in this matter.

And this is if your TSMS permitts it or the company standing orders( yes, still some outfits dont have a TSMS running) specifies it.

The only time I ever fueled a tug from trucks was down in San Juan back in the mid 80s. Can’t recall if I filled out the transfer check list (all that was required back then). I might have. We had four tractor/tank trailers on rotation and a couple of guys with a pump that stayed there. Did it at the San Juan Yacht Club dock.

San Juan Fuel by cmakin, on Flickr

[QUOTE=tugsailor;146655]As far as I know, anyone can serve as PIC to fuel a UTV… [/QUOTE]

See [U]33 CFR 155.710(e)(2)[/U] and the other regulations it incorporates by reference.

[QUOTE=jdcavo;146662]See [U]33 CFR 155.710(e)(2)[/U] and the other regulations it incorporates by reference.[/QUOTE]

That clearly requires someone with a license or tankerman ticket to fuel a UTV, But Only IF a DOI is required.

Since I routinely do a DOI, I do not remember the threshold for requiring a DOI.

No, thats not correct.

[QUOTE=cmakin;146658]The only time I ever fueled a tug from trucks was down in San Juan back in the mid 80s. Can’t recall if I filled out the transfer check list (all that was required back then). I might have. We had four tractor/tank trailers on rotation and a couple of guys with a pump that stayed there. Did it at the San Juan Yacht Club dock.

San Juan Fuel by cmakin, on Flickr[/QUOTE]
And they always tried to skim a little fuel off. The pumper and drivers got pissed when I made them strip one compartment at a time.

Are you taking on Fuel, or are you taking on Cargo? The requirements for each are a bit different.

[QUOTE=injunear;146666]And they always tried to skim a little fuel off. The pumper and drivers got pissed when I made them strip one compartment at a time.[/QUOTE]

Hey, up in LC, we were using Channel Fueling. We all know how much they were skimming, now. With purpose built barges for the scam, too. . . . I had a shortage every time, but not enough to be suspicious and the PE bought off on it. . . . I never got any of the goodies, other than one of their pennants. . . .

See 33 CFR 155.710(e)(2), as cited above. “. . . any transfer of fuel requiring a Declaration of Inspection . . .”

§156.100 Applicability.

This subpart applies to the transfer of oil or hazardous material on the navigable waters or contiguous zone of the United States to, from, or within each vessel with a capacity of 250 barrels or more; except that, this subpart does not apply to transfer operations within a public vessel.

§156.150 Declaration of inspection.

(a) No person may transfer oil or hazardous material to or from a vessel unless each person in charge, designated under §§154.710 and 155.700 of this chapter, has filled out and signed the declaration of inspection form described in paragraph © of this section.

Sometime the department of ecology locally will require a fueling manifest (sequence of fill and amount per tank) be filled out they do here in Washington state.

I know there aren’t PIC’s on 99 ton ferries loading 10,000+ at a time (facility). Why should you need one on a tug then? Just for arguments sake. That link to 33 cfr seems to be in regards to cargo, not bunkers. We have company designated PIC’s to perform transfers of fuel/lube between the tug and facility, trucks, or other vessels. The CG is notified whenever done at a facility, not sure about a truck.

Edit: 46 part 156 has more of the info. Found this interesting: § 156.118 Advance notice of transfer. (a) The COTP may require a facility operator to notify the COTP of the time and place of each transfer oper- ation at least 4 hours before it begins for facilities that: (1) Are mobile; (TRUCK?) (2) Are in a remote location; (3) Have a prior history of oil or haz- ardous material spills; or (4) Conduct infrequent transfer oper- ations. (b) In the case of a vessel to vessel transfer, the COTP may require a ves- sel operator of a lightering or fueling vessel to notify the COTP of the time and place of each transfer operation, as specified by the COTP, at least 4 hours before it begins. © No person may conduct such transfer operations until advance no- tice has been given as specified by the COTP. NOTE: The notification may be accom- plished by submitting a written schedule, pe- riodically updated to be current.

Don’t confuse PIC (Person-In-Charge) with a Tankermen-Engineer’s Endorsement.

Perfect - Thanks!