IN THE MATTER OF: DOCKET NO. DCA-99-MM-021
X
INVOLVING THE AMPHIBIOUS
PASSENGER VESSEL SAFETY FORUM
VOLUME II OF II
 
 
 

PLACE: Memphis Marriott
Memphis, Tennessee
 

DATE: December 9, 1999
 
 
 

The above-entitled matter came on for hearing, pursuant to
notice, at 8:10 a.m.
 
 
 

APPEARANCES:

MR. JOHN HAMMERSCHMIDT
National Transportation Safety Board

MS. MARJORIE MURTAGH
Director, Office of Marine Safety
National Transportation Safety Board

MS. ELAINE WEINSTEIN
Deputy Director of Operations, OSRA
National Transportation Safety Board

MR. DONALD TYRRELL
Chief, Major Investigations Division
Office of Marine Safety
National Transportation Safety Board

NTSB PANEL:

MR. ROBERT HENRY
Chief, Technical Services Division
Office of Marine Safety

DR. PAULA SIND-PRUNIER
Senior Human Performance and Survival Factors Specialist
Office of Marine Safety

MR. ASH CHATTERJEE
Senior Naval Architect
Office of Marine Safety
 

TOPIC #4. MAINTENANCE AND INSPECTIONS

MAINTENANCE MANAGEMENT OVERSIGHT OF
VESSEL MAINTENANCE & REPAIRS
AVAILABILITY OF PARTS & MANUALS
HOUSING SEALS & HINGE ASSEMBLY
BILGE/DEWATERING PUMPS
ALARMS (HIGH-LEVEL BILGE/VAPOR)
TESTING OF REPAIRS
MECHANICS QUALIFICATIONS and TRAINING
 

Panel #4 Witness Panel Members of Maintenance:

MR. BOB MCDOWELL
President
Branson's Ride the Ducks

MR. ANDY WILSON
President
BOSTON DUCKS

MR. TONY CERULLE
Maintenance Manager
BOSTON DUCKS

MR. DAN GAVINSKI
President
Original Boston Ducks

MR. JOHN WAGNER
Maintenance Manager
Original Boston Ducks
 

VESSEL INSPECTIONS, POLICIES, CERTIFICATION

QUESTIONS: NTSB Panel Members:  Rob Henry
  Ash Chatterjee
  Dr. Paula Sind-Prunier
  Bill Gossard

Panel #5 Witness Panel Members of USCG Compliance

CAPT BRIAN BASEL
USCB Chief, Office of Compliance, G-MOC

CAPT GLEN ANDERSON
USCB Commanding Officer, MSO Port Arthur

LCDR JAMES WHITEHEAD
USCG Chief of Inspections, MSO Boston

LT DEAN FIRING
USCG Vessel Compliance Division, G-MOC-2

MR. ROBERT THOMPSON
Consultant

Panel #6 Witness Panel Members for State Issues & Compliance:

MR. BRIAN KEMPF
Acting Boating Law Administrator of New York
  Office of Parks, Recreation & Historic Preservation

COLONEL RICHARD A. MURRAY
  Director, Department of Fishreies, Wildlife &
  Environmental Law Enforcement,
  Commonwealth of Massachusetts

MR. WILLIAM G. ENGFER
  Director, Recreation, Enforcement, and
  Education Department of Natural Resources,
  State of Wisconsin

MR. PAUL DONHEFFNER
  President, National Association of State
  Boating Law Administrators

MR. TED WOOLLEY
  Boating Law Administrator, Division of Parks
 & Recreation, State of Utah
 

TOPIC # 5. OPERATIONAL SAFETY

SAFE OPERATING CONDITIONS

NIGHT, SEA, CURRENT, WEATHER ONDITIONS.
DISTANCE FROM SHORE/DEPTH OF WATER
MANAGEMENT OVERSIGHT
OPERATOR EXPERIENCE & TRAINING
CAPTAINS' PRE-TRIP INSPECTION
SITUATION AWARENESS

QUESTIONS: NTSB Panel Members: Rob Henry
 Dr. Paula Sind-Prunier
 Tony Murray

Panel #7 Witness Panel Members for USCG Compliance:

CAPTAIN BRIAN BASEL
USCG Chief, Office of Compliance, G-MOC

CAPTAIN GLEN ANDERSON
USCG Commanding Officer, MSO Port Aurthur

LCDR JAMES WHITEHEAD
USCG Chief of Inspections

LCDR ERIC P. CHRISTENSEN
LUSCG MSO Chicago

MR. ROBERT THOMPSON
Consultant

Panel #8 Witness Panel Members for Passenger Vessel Operators

MR. BOB MCDOWELL
President, Boston Ducks

MR. ANDY WILSON
President, Boston Ducks

MR. PHIL YOUNG
Director of Operations, Boston Ducks

MR. ROB PIERSON
Chief Operating Officer, Chicago Duck Tours
 
 

MR. DAN GAVINSKI
President, Original Wisconsin Ducks

OPERATOR CERTIFICATION

LICENSING
OCMI CONSISTENCY OF QUALIFICATIONS
25 TON MASTER/LAUNCH OPERATOR
ROUTE SPECIFIC/VESSEL SPECIFIC

QUESTIONS: NTSB Panel Members: Dr. Paula Sind-Prunier
 Tony Murray
 Rob Henry

Panel #9 Witness Panel Members of USCG Compliance:

LCDR DAVE DOLLOFF
USCG National Maritime Center

CLOSING STATEMENT
Member Hammerschmidt

LIST OF ATTENDEES:

CAPT. JOHN GRENIER
Chief Office of Investigation and Analysis, G-MOA

CAPT. BRIAN BASEL
Chief Office of Compliance, G-MOC

MR. ROBERT MARKLE
Chief Lifesaving and Fire Safety Standards Division
G-MSE-4

CAPT. JEFFERY LANTZ
Commanding Officer
Marine Safety Center

CAPT. GLEN ANDERSON
Commanding Officer
MSO Port Arthur

LCDR JAMES WHITEHEAD
Chief of Inspections
MSO Boston
 

LCDR DAVID DOLLOFF
Assistant Chief of Licensing
National Maritime Center

LCDR ERIC CHRISTENSEN
MSO Chicago

LCDR GENELLE VACHON
Office of Maritime and International Law
G-LMI

CWO ROBERT SORRELL
MSO Milwaukee
LT. DEAN FIRING
Vessel Compliance Division
G-MOC-2
 

 P  R  O  C  E  E  D  I  N  G  S
(8:00 a.m.)
MR. HAMMERSCHMIDT:   If everyone would please take their
seats, we'll get started.
Let me first welcome everyone back to the National
Transportation Safety Board's Amphibious Passenger Vessel
Safety Forum.
Here in Memphis, outside it's cool and foggy, but inside
it's very comfortable and bright.  And so we'll try to
continue to illuminate some of the safety issues that pertain
to amphibious vessels.
Today we have two topic areas to cover, which are
labeled Maintenance and Inspections, that's topic #4, and
then we will proceed and finish up with topic #5, Operational
Safety.  And may as well continue the process we had going
yesterday and we'll turn it over to Mr. Don Tyrrell.
  MR. TYRRELL:  Thank you, Mr. Hammerschmidt.
This panel consists of Mr. Bob McDowell, President of
Branson Ducks, Mr. Andy Wilson, President of Boston Ducks,
Mr. Tony Cerulle, Maintenance Manager for Boston Ducks, Mr.
Dan Gavinski, President of Original Wisconsin Ducks, and Mr.
John Wagner, Maintenance Manager for Original Wisconsin
Ducks.
Questioning of this panel will be led by Mr. Ash
Chatterjee from the NTSB Technical Panel.
MR. CHATTERJEE:  Good morning, gentlemen.
I'm going to start as usual as I did yesterday, starting
with Mr. McDowell, and moving on to my right, your left, and
I'm going to start with a question that follows on to
yesterday's discussion with the naval architect, Mr.
Ringelberg.  He presented installed costs of $1,000 for two
watertight bulkheads on a DUKW, and $1,000 for installing
foam, and about $10,000 -- these are all approximate numbers,
I understand -- $10,000 for up -front engineering costs.  Now
this question is addressed to any of you, in any order.  Who
would like to comment on these installations, that is, their
practicality, their costs, retrofitting versus new
construction, any other aspects that you would like to share
your views on.  Who wants to volunteer first?
  MR. MCDOWELL:  I can start, if that's appropriate. One
of the things that you have to take in consideration, as
you're looking at this, is to go through the fleet that
you're proposing the impact and find out what existing
operating systems are in those voids, and what it would take
to move them as well.
When you talk about putting in different supports and
members, we really need to look at the on-road aspect of it.
 These are life chassis which have a certain amount of give
and flex as you go down the road, and want to make sure we
don't create any hard spots that would create fatigue over
time and possibly create an additional issue.
As far as the costs go, I think we'd have to generate
the plan and look at the specifics of it, and to get with
people that are involved in installing foam, and to get a
hard bid to verify that. But I would assume that he's
probably not too far out of alignment.
MR. CHATTERJEE:  Thank you Mr. McDowell.
MR. WILSON:  I would like to respond.
First of all, I have to commend the Safety Board for
doing that.  I didn't think it was possible, and I really
walked away with a great deal of optimism that it is
possible.
Kind of going with what Mr. McDowell just said, it may
be a little bit more complex than it was represented. I
talked to Mr. Ringelberg afterwards, the forward bulk head
was at the fire wall, and underneath the fire wall is the
transmission, and at least on our DUKWs their located through
there.  So basically there's a large piece of machinery right
in that area where the bulkhead would go across.  And so
there would be a significant amount of engineering there to
make that watertight, although it may be able to be moved
back and realigned.
I think in our scenarios, we have vacuum braking systems
and so on many of those voids we'd have to completely re-
engineer our braking system to open up those voids, which all
of this is possible, but the re-engineering of the equipment
in those voids could be expensive.
And I think lastly, which you noted, was that if the
foam is not properly fastened into the DUKW itself, it really
will be ineffective.  And so I think the engineering of that
and the structural costs associated with engineering the foam
and attaching the foam to the DUKW could be more than what he
had represented. But definitely it's something that we are
going to explore immediately.
MR. CHATTERJEE:  Thank you, Mr. Wilson.
MR. GAVINSKI:  It's something that Wisconsin Ducks would
consider. The cost is minor from our point of view, but we
would have a concern about our maintenance program and how we
are able to get down into the bilge and move around and do
the things that we would have to do down there with the foam
in the bilge.
MR. CHATTERJEE:  Thank you.
We'll go on to the next question.  The next question is
a broad question, and I invite you to speak at some length,
because instead of asking a number of short questions, this
is an all encompassing one, if you would, describe for us the
company's management's oversight of its repair and
maintenance program.  For instance, how problems are first
detected, how corrective actions are taken, how the
accountability is assigned, and the maintenance repair
records, how they're kept, how it is insured that repairs are
properly done in a timely manner, and how recurring problems
are tracked and so forth.  The whole cycle, the feedback
loop.
Mr. McDowell?
MR. MCDOWELL:  Okay.  First of all, in the detection
process there are several ways to identify a problem with the
DUKW.  The driver, first and foremost, we try to keep them on
the same vehicle.  Each vehicle, although we build them the
same, it's just like cars, they have a little bit different
sounds and characteristics. So any deviation from that is
really identifiable by our operator.
At the start of the day he does -- the DOT has a
mandatory check-off list that we use, but we have embellished
it quite a bit to encompass the safety features that we want
to ensure are in place for the operation over the course of
that day.  And in the inspection he will check the propeller,
our V-strut and some other things:  life jackets, fire
extinguishers and some other items that aren't normally found
on the Department of Transportation's check-off list.
At the end of the day, we have our daily maintenance
program which is done immediately after the DUKW has
completed its duty, and we have a check-off list for our
maintenance people to identify any deviations in fluid
levels, or any things that they see in the corresponding
mechanical apparatus that could impede its ability to do a
good job the next day.
If any one of these people finds a particular item that
needs to be repaired, they write it up on a form that's in
triplicate; one copy goes to our dispatcher, which is what we
call a top at our primary facility, and then two copies go to
our maintenance staff.  Maintenance staff then tries to
identify, based on what's written on the form, what the
problem is and goes about the task of correcting it so the
DUKW will be prepared for the next day at work.
Once the repair work is done, then the dispatcher has
his copy identifying that there was a problem.  He comes down
the next morning to verify that the work has been completed.
 Depending on what kind of work was performed, the driver in
his DOT check-off, one of those copies goes into the DUKW and
part of his check-off is to check the log on the DUKW; and if
there is repair work that has been done, then he would know
what was done and drive the DUKW out that morning to make
sure that everything has been repaired properly.
And more than likely, depending on the kind of repair,
our maintenance supervisor would take the DUKW out that
evening, after the repair work was done, to verify that it
was completed properly.
MR. CHATTERJEE:  I had a follow-up question, Mr.
McDowell.  Did you say it was the Department of
Transportation check-off list?
MR. MCDOWELL:  Yes.
MR. CHATTERJEE:  Does it have marine aspects included in
that check-off?
MR. MCDOWELL:  No, it doesn't.  I'll be glad to share
with the group the form that we use and the things that we've
identified as items that we've added to the list that we
think that are prudent.
MR. CHATTERJEE:  Yes, please.
MR. MCDOWELL:  It will take a minute for me to find it.
 If you want to go ahead ...
MR. CHATTERJEE:  I'm sorry, did you want to -- do need
some time to...
MR. MCDOWELL:  Just let me see if I can find it real
quick here. [Pause]   All right, I have it in front of me.
Do you want me to go through the items we check?
Mr. CHATTERJEE:  Basically, I wanted to know when you do
in-water testing, when you it necessary to test it in the
water?
MR. MCDOWELL:  When we do our repairs, this may not
sound quite right, but the boot system from our prospective
is very easy.  We've done it so many years that there's not a
lot of problems that we find in association with it.  What we
do when we have repair work done in that area, there's an
additional maintenance supervisor technician that will take a
look at it and ensure that the inspection, or the
installation has been done correctly.  And then we put it
into service.
MR. CHATTERJEE:  And how would you test Higgins pumps
and the pumps?
MR. MCDOWELL:  Oh, I'm sorry.  That's primarily on our
daily maintenance program.  On more of an annualized basis,
we do have a periodic maintenance program that's done at
approximately 200 to 250 hours.  In that, there's thirty-some
pages of things that have been identified that we go through
and check off, and they're signed off by individual
inspectors through that process.  It's a pretty time
consuming process.
We also have an annualized inspection.   We call it our
Winter Rebuild Program, where we go through the equipment
thoroughly top to bottom, front to back.   We check wheel
bearings and everything on the equipment.  At the end of the
season, we do go out and strip out all the seats, the
floorboards, and do a water float test to verify that there's
not any water encroachment in any of the compartmental areas
that hasn't been identified through normal operation, and
make the appropriate repairs at that time.
Then we go through and do the entire Winter Rebuild
Program and have the equipment prepared for the next
operating season.
MR. CHATTERJEE:  How frequently are the Higgins pumps
tested?
MR. MCDOWELL:  Approximately every 200 to 250 hours.
And we do have a test at the start of the season that we run
for the Coast Guard as well.
We've designed a 35-gallon water tank that we have up on
a fork-lift truck next to the DUKW and we run a pipe into the
inlet.  We take the pick-up [strainer] off of the suction
side of the Higgins pump off and pipe the hose from our 35-
gallon test tank directly into the pump, and we activate the
system.
MR. CHATTERJEE:  Thank you.
You've addressed this question in some ways, so you do
have a preventative maintenance policy?
MR. MCDOWELL:  Oh, absolutely.  We're very proactive in
what we do.  We've run thousands and thousands of trips in
our operating environment, which is very demanding.  We go up
some steep hills off road and some other things that aren't
normally done.  So we've had the opportunity to discover the
weaknesses over the equipment over time, and it made the
proper improvements, and our maintenance program has been
designed to support that.
MR. CHATTERJEE:  Do you have a maintenance supervisor
who reviews that the work is done, that each person assigned
to their task are doing -- are in fact doing the enforcement,
to check on the enforcement of the policy?
MR. MCDOWELL:  Yes.  Jay Hyatt is in charge of our
maintenance staff, and that's his role and responsibility.
MR. CHATTERJEE:  I'll ask the same question of Mr. Andy
Wilson now. Your company's management's oversight of your
repair and maintenance program, please.
MR. WILSON:  First of all, similar -- a lot of what we
do is very similar to Ride the Ducks.  I think one of the
most critical things we do is, we do keep the same driver
with the same vehicle so they get to know that vehicle.
We also, which we can provide, have a DOT check-off list
that's performed daily as well as at the end of the day.  Any
issues that the drivers would have would be filled out and
taken care of that night.  So we have a daily review.
We also have a weekly inspection of all critical systems
that we have found that could be prone to failure, and so
those are inspected on a weekly basis.
And then similar to Ride the Ducks, Branson, every 250
hours we do a periodic maintenance or inspection, and then
annually, similar to Ride the Ducks, we strip out the seats.
 We inspect everything in each DUKW.  We have several
mechanics going through it annually for about a five-six day
period, rebuilding certain items, inspecting certain items.
In terms of the way we manage the shop before the
Arkansas incident, we had a total of seven maintenance
personnel for our seventeen DUKWs that we operate.  We
decided to go to a two-tier review standard after the
Arkansas incident.  So now we have increased our staff as a
result from seven to ten.  So we have ten maintenance
personnel for our seventeen vehicles.  Tony Cerulle is the
head of the -- director of vehicle maintenance and has been
in that position for five years.
We then have two assistance managers that work at night
and then the rest are mechanics.  So, as the work is
performed, after that work is done, it is now inspected. So
there's a two-tier review process that we have implemented
because of the Arkansas incident.
In terms of responsibility, anytime a driver writes
something up is that -- the response that -- needed a repair,
that response is then -- well, all repairs are written up.
We keep logs, repair orders in essence,  so there's an audit
trail as to all the work that's been done on each DUKW.  And
then on any daily maintenance that was done or daily repairs
is that that work order also goes back to the captain so they
know that the work was completed and what needed to be done.
I guess, lastly, we're in the process, which I think is
important, we're building a state-of-the-art facility that we
will be moving into in a couple of weeks.  That's significant
to that -- also helps the repair and maintenance of these
DUKWs.
MR. CHATTERJEE:  In addition to the DOT checklist, as
far as marine items, Howell fittings, and inspection of those
items are concerned, do you have an addendum check-off list
for those items?
MR. WILSON:  Yes.  Especially on the weekly, we inspect
the Higgins pump on a weekly basis to make sure it is
completely operational.  As I said, mainly the weekly
inspections that we go through that we have critical systems
that we believe need to be inspected on a ...
MR. CHATTERJEE:  Is the Higgins pump accessible for a
weekly inspection?
MR. WILSON:  Yes, it is.
MR. CHATTERJEE:  How do you access it?
MR. WILSON:  I'll let Tony answer that.
MR. CHATTERJEE:  Isn't it under the floorboards?
MR. CERULLE:  Yeah, you can remove a seat and remove the
floorboard and get right to it easily.
MR. CHATTERJEE:   And it's a visual inspection that you
do weekly?
MR. CERULLE:  Ah, you do a visual.  You also do a
mechanical, where you take the strainer off, check the
bearings, check the chain tension, chain alignment, sprocket
key-way, the sprocket itself.  Just basically check
everything.  You also grab the impeller end and the sprocket
to make sure the shaft isn't broken.  Just to make sure it's
completely functional, check all the hosing, piping.
MR. CHATTERJEE:  And the inspection results are
recorded?
MR. CERULLE:  Oh, yeah.
MR. CHATTERJEE:  Okay.  When you developed this addendum
checklist on marine items, on what basis do you establish
that checklist?
For instance, the DOT checklist is predetermined and
given to you.  As far as the marine checklist on seals, on
hull, two-hull fittings, and things like that, on what basis
have you selected the items and their frequency?
Have you consulted with the Coast Guard or with your
peers or with other companies that operate DUKWs?
MR. WILSON:  Mainly, you know, part of it is just logic
order of the critical systems, and the other thing is that
the systems are -- any systems that are really critical to
safety or reliability.  We believe that reliability equals
safety, and so anything that has to do with reliability and
safety that's a critical system, we decide to inspect on a
weekly basis to make sure it was intact and functioning.  And
we have certainly reviewed this with the Coast Guard.  I
don't recall if they've had direct input, more than we've
given them our check-off list for review.
MR. CHATTERJEE:  Thank you.  You've just touched on my
next question.  What do you consider to be the critical
safety items that need maintenance inspection on your part?
MR. WILSON:  On a daily basis, weekly basis?
MR. CHATTERJEE:  All of them.
MR. WILSON: I'll turn that over to Tony, because that's
his job.
MR. CERULLE: Thanks.  Anything safety related: bilge
pumps, steering systems, braking systems, hull integrity,
anything that involves safety is a critical item.
In a CFR reg, they even have a classification of what
are vital systems, which include the bilge system, anything,
basically anything water related, that's safety.
MR. CHATTERJEE:  And how often do you test the Higgins
pump operation in the water?
MR. CERULLE:  The Higgins pump is tested every year with
the Coast Guard in our annual inspection.  The weekly
inspection bears up the mechanical end of it.  It's not
actually water tested on a weekly basis.  But if there's any
question of its working, it can be tested very quickly in the
shop or take it out to the water and flood the hull or
whatever you need to do.
MR. CHATTERJEE:  But annually you test it in the water,
annually?
MR. CERULLE: With the Coast Guard, yes.
MR. CHATTERJEE:  We're going to move on to Mr. Dan
Gavinski and ask the same question of you?
MR. GAVINSKI:  Wisconsin Ducks has an extensive marine
maintenance and repair program. I guess what I'd like to do
is just run through, starting in our fall season, when we're
starting to wind down, as that is when we start our
preparations for the following year, and just run through our
checklist on what we do in the fall.
First of all, the seats are taken up, the floorboards
are removed, the hull is washed, then we take the DUKW to the
lake for an inspection of the hull.  We check the bilge and
electric pump.  They go over the discharge hoses.  Then we
start preparing the DUKWs for the wintertime.  Obviously in
Wisconsin it does get cold.  We do an oil change.  We put
anti-freeze in the motor.  We drain the differential, and we
put oil in the differential for the wintertime.  We check the
fume and water alarm, the outside of the DUKW is washed.  And
then, when our shop supervisor takes the vehicle to the lake,
he is making note of any -- if there is any leaks in the
vehicle or any repairs  that he is going to have to be doing
during the wintertime and/or welding repairs on the vehicle.
 We have a welding repair checklist that he goes over.
Then we have a winter maintenance program, which starts
with the hull is scraped of any loose paint and then it's
repainted.  The braking system is gone over, emergency brake
is checked, the wheel bearings, transmission, transfer case,
prop transfer, seals, bearings, u-joints, rear ends, bogie
axle, stabilizer, torque rod.  The springs, the rudder and
the prop are re-packed.  They do an inspection of the
steering column to make sure that the blowers are operating.
 Then, as we get closer to springtime, the floorboards are
repainted.  And if any repairs of the canopies are needed,
it's done during our winter season.
Then, in the springtime, in preparation to opening, we
start to reverse what we just did. The battery is put in. We
spray paint the bilge with a second layer of paint. The
floorboards are painted, the plugs are put back in, the
antifreeze is drained from the vehicle, oil is taken out of
the differential, grease is put back into the differential,
and we do an overall greasing of the vehicle.  The brakes are
bled, our supervisor will check the fuel shutoff valves and
the hand-turned shutoff valve at the back of the DUKW.
They go through the lights, the PA, put the radios back
in.  They check the blower, the hand held bilge pump is
tested.  Then, the vehicle is taken back to the lake for our
spring inspection of the hull.  They also check the bilge
pumps at that time to make sure that they are operating
properly, make sure that the discharge hose is in place.
They check the water alarms, the fume and fire alarm is
tested on the vehicle, go thru the tiller line, and then we
have an outside inspection of the fire extinguishers.
And then, Wisconsin Department of Natural Resources
comes in and does an inspection of our life saving equipment
which is the ring buoys, the life preservers.  We have a
checklist to make sure the fire buckets are put back in,
flashlights, tiller line tools, our first aid kit.
And then, our drivers start coming back to start
working.  When they come back, they're going to be taking
their assigned vehicle out for a practice trip.  They may
take one, they may take two, depending on how many years they
have worked for us, and then the vehicle is ready to go with
passengers.
At the end of that first day, the vehicle is greased,
the prop and the rudder is greased, and the short shaft is
greased.  And when the mechanics are underneath the vehicle,
they are doing a daily inspection of the under-hull of the
vehicle.
And then on a weekly basis, we have a weekly greasing
done of all of our vehicles.   We have a trap door that
enables our mechanics to get down into the bilge to do the
greasing of all the zerts that have to be done.  There is a
list of eighteen items that they are checking in the hull.
There's a list of seventeen things that are being checked
underneath the hull, and then there are also seven or eight
items that are checked off in the engine compartment.  Those
mechanics will sign those sheets that those things were done,
and then, if there's any maintenance that is required, it is
taken to our shop supervisor or shop foremen.
Our drivers will have a DUKW checklist sheet that they
fill out.  If there are any maintenance repairs that they
have discovered, they'll write that up at the end of our day
or when it happens.  If it's during the middle of the day,
they take the vehicle up to our shop.  They fill out the
report, and then our shop supervisor will review that.
For instance, first thing in the morning, when we start
our operation, they're going through the sheets that were
filled out the previous evening, and then our assistance
manager, one of our assistant managers is always at our shop
during our morning shift, and he is reviewing with our shop
supervisor or shop foreman what vehicles are down, how long
they will be down, and then the assistant manager will be
assigning a spare DUKW for the day.
MR. CHATTERJEE:  Thank you very much Mr. Gavinski.
I have one question on pumps, on bilge pumps and de-
watering pumps.  Do you have a Higgins pump?
MR. GAVINSKI:  Yes, we do. And an electric pump and the
hand-held pump.
MR. CHATTERJEE:  Okay.  And how often are those, the
Higgins pumps and the other pumps tested in the water?
MR. GAVINSKI:  Spring and the Fall, then they're checked
weekly.
MR. CHATTERJEE:  So it's tested twice a year in the
water?
MR. GAVINSKI:  That is correct.
MR. CHATTERJEE:  Okay.  Thank you.
Going back to Mr. McDowell.  Mr. -- you're with the same
company, Mr. Wagner, right, as Mr. Gavinski?  Okay.
Going back to Mr. McDowell, on the DOT. inspection
checklist, do you know, does the DOT or highway or state or
federal inspector come in to review your maintenance logs on
the -- do they review the DOT checklist?
MR. MCDOWELL:  They have, but it's not a frequent
occurrence.  It's generally as -- when we get a new DUKW
ready to go and on the road, they do come in and do the
oversight on the serial numbers, on the motors, and some
things like that.  We do take them through and keep them
abreast of what we're doing.
MR. CHATTERJEE:  And the review of your maintenance logs
on the DOT checklist?
MR. MCDOWELL:  Not to my knowledge.
But, Ron, have they?  Ron's our safety officer and helps
in oversight of regs.
           [Ron's answer is inaudible]
MR. CHATTERJEE:  Mr. McDowell, please repeat the answer
for us.
MR. MCDOWELL:  Not generally.
MR. CHATTERJEE:  And how often do they come into your
shop?  Is it annually or approximately or ...
MR. MCDOWELL:  When we have a new DUKW that's getting
ready to go on the road, they are part of the licensing
process, but beyond that it's an infrequent occurrence.
MR. CHATTERJEE: Mr. Wilson, is your experience the same
with the DOT inspectors?
MR. WILSON:  We're not subject to the jurisdiction of
the DOT but the Department of Public Utilities, the
Massachusetts Department of Public Utilities, Transportation
Division, and we do receive licensing from them, and they do
come in on an annual basis and inspect it as a bus vehicle.
As to the details of their inspection, I know they do brake
tests and ...
MR. CERULLE:  Checks everything, basically, and inside
and out for, you know, safety, sharp edges, that kind of
stuff.
MR. MCDOWELL:  If I can make a comment there, too.
Prior to Andy getting up and started, I wanted to commend
them for taking the time out of their schedule to come to
Branson to study and understand the DUKW completely from
front to back.  They had two individuals at our shop over the
course of two days that went through the equipment quite
extensively before they're allowed to come into the market.
MR. CHATTERJEE:  Mr. Cerulle,  do they express an
interest in reviewing your maintenance logs?
MR. CERULLE:  I think they've viewed them before.  It's
not a constant thing, but they're certainly available if they
want to see them, sure.
MR. CHATTERJEE:  Okay.  Thank you.
Going back to Mr. McDowell again.  What are your sources
for obtaining spare parts for DUKWs?  Do you use commercial
manufacturers to supply new parts, or is there any
difficulties with surplus army parts?
 MR. MCDOWELL:  Part of our vision as a company to grow
this business, we had to identify that those parts are not
readily available, there is a limited supply, and what kind
of impact it would have on us as we try to grow the business.
 And so, as we're looking at the new generation DUKW that
we're developing, we did a lot of analysis out in the
marketplace, in terms of whether it's already been proven for
this weight and class and size of vehicle.  That part
availability would be there, and what kind of parts would we
have to take upon ourselves in the manufacturing process.
And through that process, we've eliminated almost
all of the items that are not readily available so we will
not get in trouble on down the road in terms of reliability
and part availability.
MR. CHATTERJEE:  And, as far as maintenance manuals,
what do your mechanics use?  Do they have access to the old
army manuals?  Or do you have your own?
MR. MCDOWELL:  We do have a have a complete set of the
old military manuals.  They're very specific to the original
configuration, of course, and, in some instances, they're
helpful.
But, generally speaking, what we have chose to do and
are in the process of doing, is to develop our own
maintenance manuals as it pertains to our particular
configuration of the equipment that we're developing.
MR. CHATTERJEE:  Thank you.
Same question for Mr. Wilson:  Your sources for spare
parts and manuals.
MR. WILSON:  Similar to Mr. McDowell, much of the DUKW
that we operate uses new parts, readily available parts.  The
main parts are obviously the hull, which has been, you know,
much of that has been replaced.  We need the steering box,
transfer case, prop box, prop shaft and propeller.  And, most
of those things are -- we do have spares, but -- and those
are the main, original DUKW parts that we continue to use.
Otherwise, everything else are off-the-shelf parts that are
readily available today.  So, yeah, there is a limited supply
of the original DUKW parts that we do utilize, but do have
stock on hand.
MR. CHATTERJEE:  I'll address the same question to Mr.
Gavinski.
MR. GAVINSKI:  We have both commercial suppliers and
military suppliers.
MR. CHATTERJEE:  And do you experience any difficulties
with shortage in those areas of parts?
MR. GAVINSKI:  Over the last several years, we're
starting to get down on our supply of brake parts, brake
drums, and two years ago we switched over to a disc brake
system to handle that situation.
MR. CHATTERJEE:  As far as manuals availability for your
mechanics to work with?
MR. GAVINSKI:  We have original military manuals put out
by General Motors and the Army.
MR. CHATTERJEE:  Okay.
This question is for Mr. Andy Wilson and then, Mr.
Cerulle, as you see fit.  If you would, give us an idea, if
you like, on your modified design that you've developed for
the drive shaft seal.  And, if you would, explain to us the
reasons why the design was developed and compare it with the
traditional seal housing arrangement for the boot, if you
want to go into it.
    MR. WILSON:  I'll just give a brief overview.  We
did realize that when and if there was a boot failure that
there was a chance for a large volume of water coming through
that boot, and this was before the Arkansas incident.  So Mr.
Cerulle developed a device that basically eliminated the
need, although we are going to put the modified boot system
back on this winter to provide redundancy.  And basically the
original design of the boot system -- the reason that the
boot system was developed is because the axle is moving and
the drive shaft needed to have flexibility.  That was the
original need for the design of the boot.  And, that
flexibility was occurring with the universal joint internal
to the hull.  And so, what this device does, it brings the
drive line external to the hull so the flexing of the drive
line is occurring external to the hull.  And that's done via
this device which bolts up where the boot would traditionally
bolt up, and it's just is an extended drive shaft that brings
that universal joint external.  So all that flexing that's
occurring is basically a carrier bearing.  And the design is
significantly better.  When and if there was a failure of a
carrier bearing that there would be nominal leakage.  And
with the putting the boot system back on, it would provide,
again, redundancy.  So we put the original boot system on,
and if that should fail, then this would be the back-up
system.
MR. CHATTERJEE:   I have a follow-up.  Mr. Wilson, does
this new arrangement restrict the motion of the drive shaft
when it comes to going down ramps in any way?
MR. WILSON:  No.
MR. CHATTERJEE:  So it does not impose any limitations
on how steep of a ramp the DUKW can handle?
MR. WILSON:  No.
MR. CHATTERJEE:  Okay.  Is any others among you that
would like to share ideas on any other ...
MR. WILSON:  Can I have a follow through on that?
MR. CHATTERJEE:  Yes.  Sure.
MR. WILSON:  One of the things that we also have found -
- one of the things that is very difficult to find is the
boots.  That was the other thing that concerned us, that the
supply of boots was very limited.
And the other thing that also concerned me was that it
only had a single clamp on it, which is not traditional.  I
consider the boot system a through hull fitting.  And
traditionally, you'd always double clamp that and the
original boot did not have the room to put two clamps on it.
 So when we retrofit this new boot system that we're
developing, we found a brand new design of boots, and it has
the space to double clamp it as well.  So, I just wanted to
also interject that in redesigning an entire system that
there are new boots that are available that allow for double
clamping, but does require significant modification to the
receptacles where the clamping would occur to allow for the
double clamping to occur.
MR. CHATTERJEE:  Thank you.
I was going to invite any of the other panelists to
share any ideas on design modifications that they are
considering or have implemented to make a DUKW safer.  Any
volunteers?
MR. MCDOWELL:  We are actually reviewing that, but we
don't have anything to submit at this time.  There's some
issues  -- we rubber mount our transfer case for vibration
noise reduction, and so there's a certain amount of range of
motion that needs to be accommodated for when we're going up
our steep mountains and things.  Our class vehicle with our
additional capacity is a little higher to gross vehicle
weight, so we're reviewing what Andy has and, hopefully,
we'll be able to incorporate it into our system.  But in lieu
of that, we'll continue to try to find a reasonable
alternative for us and others.
MR. CHATTERJEE:  Okay.  Thank you.
Earlier this year we found that some DUKWs were operated
without their drive shaft housing tube-hinge assemblies, as
they were originally designed by the Army.  What is the
purpose of the housing hinge assemblies that are at the
forward end of the shaft housing?  And do you believe that
the DUKW should be operated without their housings or without
the hinge assemblies or should they  -- do they serve any
useful purpose and should be retained?
Mr. McDowell?
MR. MCDOWELL:  It's been our experience that we believe
that that is a necessary component of the DUKW.  It holds the
drive tube in the correct relative proximity as it relates to
the differential and allows the boots to function properly.
Conceivably, the drive tube could get out of position without
the hanger being in place.
MR. CHATTERJEE:  Thank you.
That's all the questions I have.  I'm going to pass the
questions on to Dr. Sind-Prunier.
DR. SIND-PRUNIER:  I have one follow-up question on Mr.
Chatterjee's question.   I'd like to first direct this to the
gentleman from Wisconsin.  You've been in operation for how
many years now?
MR. GAVINSKI:  Fifty-four.
DR. SIND-PRUNIER:  Fifty-fours years.
Now, Mr. Chatterjee had asked you some questions about
the inspection procedures for maintenance that you follow and
you went into an elaborate discussion on your annual protocol
for maintenance.  I was wondering, how has that changed over
the years or have -- has that been a very consistent and
regular procedure from going back how far?
MR. GAVINSKI:  It's been consistent, as far as our
records go back, to the early fifties.
DR. SIND-PRUNIER:  Okay.  And have you changed the
procedures or do you still follow the same ...
MR. GAVINSKI:  Basically follow the same procedures,
unless there was some Coast Guard new requirements through
the years, and then those were added to the list.
DR. SIND-PRUNIER:  Okay.  Are your vessels under Coast
Guard inspection?
MR. GAVINSKI:  We are not at the present time.
DR. SIND-PRUNIER:  Mr. McDowell, similarly, you also
have, I believe they are written procedures, checklists that
are followed?
MR. MCDOWELL:  Yes.
DR. SIND-PRUNIER:  And how are those -- have those
changed over the years?
MR. MCDOWELL:  Yes, they've evolved over time.  We've
invited outside consultants and resources to come in and
provide oversight on what we've been doing.
We've been working with the Coast Guard quite
extensively on the development of our new equipment and
implemented procedures, as it makes sense with the new
equipment.
We have a consultant, Fred Seaman.  What's the title,
Ron?  Seaman Safety Services.  He comes in and helps do an
overview.
We've invited the State of Missouri in to do an overview
on our entire operation, manufacturing and so forth and
received input from them through our safety committee that
meets monthly with all the disciplines of our company.  We
receive input from them, so we take a very proactive approach
to the sensitivity of the safety issues in regard to our
customers, our employees, and the people we come in
interaction with.
DR. SIND-PRUNIER:  Okay.  Just for sake of completeness,
Mr. Cerulle, I understand you have a daily, a monthly, as
well as an annual inspection checklist?
MR. CERULLE:  The daily is the driver DOT type
checklist.
DR. SIND-PRUNIER:  Is the driver?  Right.
MR. CERULLE:  There's the weekly mechanic checklist, and
it's a periodic 200-hour inspection which ends up being every
month in the summertime.
DR. SIND-PRUNIER:  Okay.  Now recognizing yours as
probably the youngest of the companies, they have been in
operation about five, roughly five years, but....
MR. CERULLE:  Yes.
DR. SIND-PRUNIER:  ... how have those checklists
changed over that time?
MR. CERULLE:  Initially, we probably followed the
leader, Ride the Ducks, where they have been in business so
long.  It's evolved due to lack of conditions for us.  You
know, the DUKWs are on different terrain than their in, items
we've identified as being close to scrutiny than may be the
case somewhere else.  It's just evolved over the years of
usage of the DUKWs, things we find pertinent to be monitored
closely.
DR. SIND-PRUNIER:  What would cause you to monitor
something more closely?
MR. CERULLE:  For instance, if you're on a smooth road
surface as your toll route, you probably wouldn't have any
problem with say, you know, suspension bushings, or what have
you, you know.  If you were on a rough terrain, you might go
through suspension bushings or leaf springs more frequently,
in that case you'd say, you know, "I have to monitor these
closely, where someone else might not have to."  On that I
do.
DR. SIND-PRUNIER:  Okay.  Would you, like I say, maybe
characterize your checklist as being risk based in some sense
that, when you identify a problem, you scrutinize it more
closely and incorporate it into your procedures to ensure
that that is consistently done?
MR. CERULLE:  I guess you could say that, yeah.  A lot
of it, too, is just like Andy said earlier, common sense,
things that you know are a high safety factor that you have
to monitor closely.
MR. MCDOWELL:  Can I interject there, please?
DR. SIND-PRUNIER:    Sure.
MR. MCDOWELL:  In the instance of the suspension system,
the Boston roads are more of a patchwork-type road system
because of all the utility work that's ongoing, and with the
central artery project going on it's a little bit more than
that, so it's a little bit of a challenge to keep that in
place.  So, not only do we monitor it closely, once we
identify our problem then part of our role and responsibility
is to help come up with a solution to the problem, so as we
go into the next season, yes, we'll monitor the improvements
closely and see what kind of progress we've made, and if it's
not what we would term acceptable because of it's frequency
of maintenance.  And we would continue to work and monitor on
that particular problem.
DR. SIND-PRUNIER:  Okay.  Thank you.
From listening to, and the fact that it sounds like the
companies, at least that are represented up there, seem to
have some well-developed procedures based on your experience.
 And it would seem that there is a considerable body of
knowledge about maintenance practices and safety procedures.
 Do you feel these are things that all operators need to be
aware of if they are going to operate in this industry?
Are there certain things in particular that you feel
just are not unique to your operations but are essential to
safety throughout the industry?
MR. MCDOWELL:  Would you like me to address that?
DR. SIND-PRUNIER:  Yeah, we'll go from ...
MR. MCDOWELL:  Well, as I think about this, you have to
think about the sizes of the companies, and their experience,
 and how they're getting started up, you know.  When I
started in business, I was driving, mechanizing, and
managing, and doing all the skill sets.  So to develop forms
to hand to myself, probably wouldn't make a whole lot of
sense, but I understand the necessity for documentation for
overview, and I think that's an important role and
responsibility that we all need to accept.
But as I think about the evolution of this business, the
responsibility of the ownership, I would say that it's
probably as important for the culture of the company to be
developed to support the safety and the ongoing
responsibility that they have as hauling passengers for hire.
 It doesn't do a lot of good for management to develop forms
and systems and processes if inevitably the front line staff
doesn't implement them, so that's part of why we brought Fred
Seaman on, to further that within our company to deeply
ingrain that into our culture.  It's been incorporated in our
core value statement, and we're working hard to achieve a
status level from the State of Missouri that really requires
that to be a part of our culture.  If that's done, then a lot
of these things will be done automatically, which is really
the intent, I think, of why we're here -- not to develop a
form to make sure that it's done as much as getting the right
culture in place to allow this to happen naturally and have a
self placing organization as it relates to safety issues.
DR. SIND-PRUNIER:  Okay.
Mr. Wilson, do you have any different thoughts on that?
MR. WILSON:  I have some very strong thoughts on that.
Again, I mentioned yesterday that the regulatory community in
Boston, which included federal, state and local regulators,
literally would not take me seriously, because they asked the
question, "What experience do you have to operate this
business?"
And even though I was a very accomplished businessman, I
was in investment banking, which really had nothing to do
with the DUKW business.  And, it was not until I brought an
experienced operator to the table, like Mr. McDowell, that
they would begin to even consider permitting me, and that
included the Coast Guard in Boston.  And, that made a huge
difference.  And I do look back and I think, you know, some
of the terms that were used yesterday, novelty vehicle,
novelty vessel, this is a very unique business.
You know, given my business experience, I really do not
know of a business that requires so many business skill sets
to be successful.  And that has been my concern as this
business is emerging is to, you know, what level of
experience and knowledge new operators are required to have
to be successful.
And, I will continue to stress that I think I would have
failed if I had not brought Mr. McDowell's twenty-plus years
experience to the table, both from an equipment standpoint
and a maintenance standpoint, because again, I think somebody
mentioned yesterday, there is real DUKW science that exists
and that DUKW science only comes through experience and
knowledge and entering this business cold.  I'm not too sure
that that could be easily accumulated.  So I feel very
strongly that experience, the checklists -- you know,
checklists don't -- they're just checklists.  It doesn't mean
that they train somebody exactly what they're looking for.
Tony and my mechanics started off by being trained in Branson
and this made a huge difference in our success.  So I feel
very strongly that this whole area needs to be examined.
And again, I'll just throw a concept on the table, that
the Department of Public Utilities put us through, which was
a concept -- and we had to have a public hearing on this ----
- concept being fit, willing and able.  And I think the
fitness standard came because I was able to affiliate myself
with Mr. McDowell and his experience.
DR. SIND-PRUNIER:  Mr. Gavinski, any different thoughts
on that?
MR. GAVINSKI:  I think it's very important that all DUKW
operators share information with other operators, especially
new people that are getting started in the business.
Wisconsin Ducks has never had a problem answering any
questions to any operators who were first thinking about
getting in business.  I always made myself available to
answer questions to them, and our shop personnel were also
made available.
We've had quite a few people through the years who have
come to our operation and reviewed it, and we've always
welcomed them to come.
DR. SIND-PRUNIER:  I'd like to go back to something that
I believe it was Mr. Cerulle had said earlier, about your
inspection procedures.  And I think he specifically mentioned
the V-Strut, and some specific maintenance checks that are
done, or the daily checks by the operators that addressed the
V-Strut.  What was the genesis of that requirement?
MR. WILSON:  Actually, that was...... if you don't mind,
I'd like to answer that.
DR. SIND-PRUNIER:  Okay.  That's fine.
MR. WILSON:  It's my understanding that there was a
casualty in the Washington D.C. operation, and which I had
heard by the grapevine that there was some casualty.  And I
had not heard about it.  And the V-Strut is -- the prop shaft
comes out, the V-Strut holds it, and there's a bearing cap on
the end with two bolts that hold the bearing cap on, and
apparently the nuts -- and then there's seizing wire that
goes through the nuts that keep the nuts from backing out.
And apparently the nuts had backed out.  This is what I was
told. The prop shaft came loose and then that tunnel kind of
chopped up the back end of the tunnel.  So, I had heard about
that by word of mouth.
Went back to the Coast Guard, found out -- tried to get
as much details as I could.  Realized it was a very easy
thing to do on a daily and weekly basis to inspect to make
sure just that that seizing wire was in place.
And with Mr. McDowell's help this year, we're also
adding a redundant V-Strut.
DR. SIND-PRUNIER:  Okay.  So...
MR. MCDOWELL:  I've got a picture of that, too, if it
would be appropriate to share with the group. It's a very
simple apparatus that would basically negate that exposure.
DR. SIND-PRUNIER:  Okay.  So, in addition to your own
experiences with maintenance problems, etc. that cause you
to, you know, adjust your procedures for what you check, in
addition learning from the experience of others, in
particular casualties involving DUKWs has proven helpful,
prior to the recent attention on DUKWs because of the sinking
in Hot Springs, were you aware of any problems with the
sealing systems or the sealing system on the DUKW?
I'll start with Mr. Wilson, since...
MR. WILSON:  We had had problems with the bands on the
boots in a few instances and that had concerned me, yes.
DR. SIND-PRUNIER:  Okay.  You had had problems with the
bands on the boots.  Were these reportable casualties?
MR. WILSON:  Looking back, the answer is yes.  At the
time when they were issues, they were -- I did not consider
it a casualty because all of our safety systems worked, but
it concerned me enough to redesign our system.
DR. SIND-PRUNIER: Okay.
Mr. McDowell?
MR. MCDOWELL:  We have completely redesigned the entire
rear portion of our DUKW to minimize that exposure with our
overload fixed leaf spring system.  We've increased the
length of the drive shaft to limit the range of motion with
the primary drive shaft, and as it relates to the boot
system.  I've not had a single problem since we've re-
modified that system.
DR. SIND-PRUNIER:  Okay.  What prompted those
modifications?
MR. MCDOWELL:  Well, as I went through yesterday and
showed you some of the areas of concern there, basically you
have to be very critical in terms of measuring all those
components and making sure they are all correct, the exact
correct length for all those systems to work properly.  And
rather than have to worry about those kinds of issues, we
said, "What's the better way to do this?".  And so, we spent
quite a bit of time in the development of that.  Like the
gentleman with the Aqua Terror [Hyrda-Terra?], we basically
had the disposition, that, if -- based on all the trips that
we've run -- and we've run over a hundred thousand trips over
the course of the years -- what would we do to design this
DUKW to eliminate those exposures that we look at as a
potential incident, you know, creating incident in the
future.  So we tried to eliminate all the areas that we feel
like those risks may exist.
DR. SIND-PRUNIER:  Okay.  The gentleman from Wisconsin,
prior to the recent events, were you aware of any specific
problems or specific incidents involving sealing systems
failures?
MR. GAVINSKI:  No, I was not.
We consider it, as Bob had also said earlier, it is
routine maintenance for us.  It's not something that we dwell
over a lot.  We've been operating for so long everything has
become pretty routine now.  We're maintaining about sixty
amphibious vehicles.
DR. SIND-PRUNIER: Okay.  Thank you.  Finally, one
final question.  And, given -- well, actually I guess it's
already been asked so I won't trouble you with it.
Mr. Henry, do you have any additional questions?
MR. HENRY:  Yes.  Yes, I do.
Mr. McDowell. Large amphibious passenger vessel
operations have the critical mass to devote resources to an
effective maintenance program.  What should our expectations
be for the effectiveness of maintenance programs for the
small amphibious passenger vessel operators?
MR. MCDOWELL:  Well, I believe there's a real
opportunity for management to take advantage of what I would
call mentorship.  The drivers obviously have roles and
responsibilities.  What we're working on right now, which a
small company can do quite effectively, is to ask one of the
drivers to take on the responsibility of being the expert on
procedures of going in the water.  Another driver can take on
the responsibility of the DOT check-off list and be actually
a trainer for new people that come on board, and it
significantly increases the breadth and depth of your
organization, and is a wonderful management tool.  People
will look at the safety items from a more objective
standpoint instead of being resistant to change, if they have
the opportunity to take pride of ownership.  So even a small
company, there are some things that they can do to create
some significant change in both the culture and the practical
application of these safety features.
MR. HENRY:  And, Mr. Wilson, can you talk for Boston
Ducks?
MR. WILSON:  Can you re-ask the question, please?
MR. HENRY:  Basically, large operations, you know, have
the critical mass that can be devoted to an effective
maintenance program.  What should our expectations be for the
small operator, who maybe runs just a couple boats and
doesn't have the resources to, you know, specifically devote
to maintenance?
MR. WILSON:  Well, I guess my opinion on that is that I
was a small operator five years ago.  We opened up with four
vehicles, which I consider to be small, and moved ten
thousand people in our first season.
I can only speak to my own experience.  When I opened
up, immediately what I did is, I acknowledged the various
areas of the critical parts of this operation.  So I hired a
director of vehicle maintenance immediately, a director of
operations immediately and a director of marketing, which I
know isn't critical here.
I think unlike most others that have opened up after me,
we were very well capitalized.  I mentioned yesterday that we
opened up with 1.6 million dollars worth of debt in equity
for a small company operating four DUKWs carrying ten
thousand people our first operating season, it was
significant.  So I opened up with a mind that I wanted to be
safe out of the gate.  That was my first concern.  So, again
I held myself and again, the regulatory community, I think,
held my company to a standard to make sure that we were going
to be successful and safe, and that's how we did it.
MR. HENRY:  And, Mr. Gavinski, for Wisconsin Ducks.
MR. GAVINSKI:  I think that if there are new operators
getting into the business, they have to expect to spend money
so that they can maintain the same safety standards as a
large organization does.  Anything that goes wrong in a small
organization, it's going to affect the larger ones also. So
from a larger standpoint looking at the smaller operators, I
would hope that they do not compromise on any safety issues.
MR. HENRY:  Following up on that statement, an accident
by any DUKW operator is going to reflect on all DUKW
operators.  Can you gentlemen suggest any approaches, as a
collective group, to pass on your experience and knowledge,
especially if you've operated a lot of DUKWs and seen a lot
of different types of damage incidents to the smaller
operators who may not have that experience level?
Mr. McDowell?
MR. MCDOWELL:  It is a significant challenge.  You know,
as I think back of how the DUKWs were first released out of
military service, they were complete and pretty well ready to
go.  You put the flame arrester on it, the vents and put
seats in it, life jackets, fire extinguishers, so forth and
they were safe equipment.
What concerns me today is that a lot of the DUKW hulls
that have been stripped out are now being purchased and
retrofitted and put into service.  And it's because of the
year that they were built, it's becoming more difficult for a
new operator to understand what are the critical components.
We are hoping to get together as a group after this
session to work at identifying, you know, some of those
issues that help everybody understand the responsibility and
the opportunities that we have to work together as a group to
deal with this very issue.
MR. HENRY:  Mr. Wilson?
MR. WILSON:  Again, I concur with Bob.  Bob, for a long
time, has been pushing for some sort of association.  But,
again, I'm not trying to harp on this, but I was held a very
difficult standard in my own regulatory community, and I
think I run a much better business today because of
government.  And I will go back -- I don't know the answer to
this question, but I'm sure that people that go into the
airline industry or whatever also have some sort of base
qualification to get into certain, into that industry.  I
assume so.  I hope so. And, I was held to that standard in my
own regulatory community, and so I still have to ask that
question, "Should that standard be applied not only to me but
to any potential operator?"  And, I kind of answer it with a
question.
MR. HENRY:  Okay.  And Mr. Gavinski?
MR. GAVINSKI:  I agree with what Mr. McDowell said.
MR. HENRY:  Okay.  Mr. McDowell, what type of vehicle
deficiencies, damage, repairs and modifications would prompt
you to notify the Coast Guard?
MR. MCDOWELL:  Well, I guess if there's a significant
breach of the hull, welding repairs, so forth.  What we are
doing with our particular office, because of its geographical
proximity to our location -- it's about a five hour drive --
we're reviewing and updating our notification procedures.
We're generating a check-off list basically on all of the
modifications that we're making.  They're aware of the
modifications that we have that we are in the process,
through our winter rebuilds, to upgrade some of the equipment
to have a little bit more of a consistent product.
We, through the e-mail process, are able to send
pictures and things like that so they can visually review.
 They're welcome to come through our facility at any
time.  We have several DUKWs in process concurrently so they
can review all stages and development of the DUKW.
But, from a maintenance standpoint, they review our
maintenance records.  The Coast Guard has a regulatory person
that's dedicated just to that.  He comes in and inspects our
records as it pertains to our drug testing program and
everything else. So, we'll do anything that is requested of
us by our local MSO, and look forward to working with them on
those issues.
MR. HENRY:  Okay.  And, Mr. Wilson, for Boston Ducks.
And what I'm really trying to get at is the non-routine need
to have the Coast Guard notified of damage or modifications
or repairs.
MR. WILSON:  Over time, our understanding of what should
be reported, and has developed over time -- and, basically,
if there's been anything that's compromised the seaworthiness
of the DUKW at this point, we contact the Coast Guard and
consult them.  And if they choose to come in, then they
choose to come in and review what occurred and any corrective
action that we've taken.
MR. HENRY:  Okay.  Now, Mr. Gavinski, you don't have
Coast Guard oversight, but I have the same question.  Is
there a regulatory oversight within Wisconsin that you would
notify in case you were making modifications to your DUKWs or
had significant damage or repair work?
MR. GAVINSKI:  There is no one that we would notify.
If we found a failure in something at Wisconsin Ducks,
we have an excellent relationship with the Coast Guard office
in Milwaukee.  Even though we are not under their
jurisdiction, we follow their regulations.  And we would
readily, openly communicate with that office anything that
has happened at Wisconsin Ducks.
MR. HENRY:   Okay.  I'm just a little curious in
following up to some questions that Mr. Chatterjee had on the
Higgins pump. I'll start with Mr. McDowell.  Could you
explain exactly how the Higgins pump is tested in water?
MR. MCDOWELL:  We did a water test once with Alan
Gavinski, which was one of our inspecting officers.   We just
simply pulled the large plugs out and went out in the water.
 And it automatically activates the system.  But now we --
that why we built the tank.  Our water location is over ten
miles away, I believe, so it's not practical to drive all the
DUKWs out there, so we do it right on sight, on property,
with that thirty-five gallon tank, and you can tell in short
order, I mean it is immediately discharged.  It's amazing how
quickly it pumps the water out.
MR. HENRY:  And you say this is a test you perform
annually on each DUKW?
MR. MCDOWELL:  No.  More than annually.  At the start of
the season we do it, but it's a part of our periodic
maintenance program as well,  So 200 to 250 hours,
approximately in that hour framework.
MR. HENRY:  Is there an effective way to test the
performance of the Higgins pump without putting it in the
water or a tank?
MR. MCDOWELL:  Yes.  The inlet pipe will only allow so
much water to come in to the Higgins pump.  And as long as
you don't, through your testing process, impede the water's
ability or the feed rate to the pump, you know, I would say
that it would simulate, you know, the same kind of scenario
out there in the water.
One of the things that we did do as of a result of the
incident, is the discharge hose has a couple -- the discharge
outlet pipe rather has two hoses on it that are clamped in
position.  We've designed a contiguous pipe with mandrill
bends all the way to the exterior of the DUKW, so there's no
way that anybody could misinstall it.  It's a permanent
fixture in our DUKWs now.
MR. HENRY:  Okay.  And Mr. Wilson, whoever would like to
speak for Boston DUKWs, on the same question?
MR. WILSON:  It is tested annually, and I believe it's
tested by filling the hull right now with water.
MR. CERULLE:  That or you could also remove the strainer
and tip it upside down and fill the strainer and pump up with
water from a hose or a container like Bob uses, what have
you.
MR. WILSON:  And I'm also of the belief that our weekly
inspections to making sure that the pump is mechanically
intact and all hosing, and what have you, you know, the
weekly inspection of the system to make sure it's all intact
also is an important feature.
MR. HENRY:  And Mr. Gavinski for Wisconsin Ducks?
MR. GAVINSKI:  In the spring and the fall our shop
supervisor checks the Higgins pump.  He looks down to see if
the impellers are working properly.  If there is a problem
with it, we have a one-inch belly plug that we can pull on
the vehicle and put water into the bilge and then it will
work.  And he would check it.  If there is a bearing out,
then the drivers know it because it makes a loud noise.
MR. HENRY:  Okay.  But there's no routine to actually do
a performance test of it on a regular basis?
MR. GAVINSKI: We check it ...
MR. HENRY:  Actually pump the water?
MR. GAVINSKI: We check -- no.  No, we don't.
MR. HENRY:  One last question.  Prior to the Arkansas
incident, my understanding of seals probably didn't go any
further than what you would find on a front wheel drive, CV
joint, which is sort of a weather cover, dust cover.  And I
suspect you can purchase similar covers in the same
configuration that we would find on the boot seal of a DUKW.
And I'll start with Mr. McDowell.  What properties do you
look for in ordering replacement boot seals?
MR. MCDOWELL:  They're not readily available.  That's
one of the topics of discussion I hope to address with the
group at large.
We were looking at re-manufacturing that particular
component, but we're holding off until we had a good feel on
what the findings may or may not be as a result of this
hearing.  I'm sure there will be some discussion on it as we
meet afterwards.
MR. HENRY:  And Mr. Wilson?
MR. WILSON: Well, we did develop -- if I understand your
question, we did redevelop this system before the Arkansas
incident,  and we did research to -- have decided to also
retrofit, as I mentioned earlier, in addition to this system,
a modified boot system.  And, we basically did research and
testing on new boots that were available in the marketplace.
MR. HENRY:  Okay.  And Mr. Gavinski?
MR. GAVINSKI:  Based on our past usage of the boots, we
have about a five-year supply of the boots.  But in
anticipation of that, we are in the process of having a new
one made and it should be available within a month.
MR. HENRY:  I have three cards from the audience.  Two
of them are related, and I'll read the first one. "How many
patches can a DUKW's hull accept?"   And in parenthesis is,
"The assumption is that the hull becomes weaker the more it
is patched."
And there is a similar question. "How frequently is
welding and hull repairs required?"
Mr. McDowell?
MR. MCDOWELL:  Well, you do need to be sensitive to the,
 I guess, heat affected zone.  If you end up putting a quilt,
so to speak, together versus putting in new material.
The relative condition of the DUKW when you start, I
guess, is really the predeterminates of what you ultimately
do to it.  But basically if some of the ribs, where they
attach, were spot welded, and there's a lamination area there
that is susceptible to corrosion, it's generally easier to
remove the entire side and replace it as opposed to going
through and doing a lot of patchwork. So, my recommendation
would be to, you know, do a good overall repair.
A lot of the DUKWs in the past that we've acquired
through private individuals have been patched with Bond-Do or
fiberglass and other materials that we certainly don't
recommend, and that's why we sandblast the entire vessel to
make sure there's no areas that have been patched over that
aren't readily, visibly, identifiable to the normal
inspection process.
MR. HENRY:  Mr. Wilson for Boston Ducks.
MR. WILSON:  The first time we had to do a hull repair,
the Coast Guard came in and it was a fairly small repair.
And they pretty much defined standards as to hull repair in
general, and so we learned a lot through the Coast Guard.
I'll let Tony finish.
MR. CERULLE:  I can't speak for the other MSO's, but our
MSO holds us to a standard of, I believe, is three inches
from the hull breach.  You have to crop out the steel to good
steel, no pitting and all corners have to be rounded, too.
They would prefer, if you have an area of repairing that
already has previous patches, if it's possible to crop out a
larger section to ensure the stability and integrity of it.
MR. WILSON:  So, in other words, you won't have multiple
patches.
MR. CERULLE:  No.
MR. WILSON:  If you're patching an area that's already
been patched, they've instructed us to cut out the whole area
of patches and just put one patch in instead of a patchwork
quilt.
MR. HENRY:  Okay.  And Mr. Gavinski for Wisconsin Ducks?
MR. GAVINSKI:  If we do have any holes, we try and cut
out a whole section.
We've been maintaining our vehicles for fifty-four years
with the intention that we're going to be operating for
another fifty years and obviously we don't run in salt water.
 They are extensively maintained and we try not to get in a
position where we are patching it.
MR. HENRY:  And one last question I'll ask of each of
you.  Is there a feasible way to inspect or test for water
saturation of closed cell foam if this were to occur?
And I guess if you feel like you can respond to that,
fine, if you want to pass on it.  Mr. MCDOWELL?
MR. MCDOWELL:  Well, I'm not as knowledgeable as I need
to be on this subject, but we did do some preliminary review
on that.  My comment regarding the saturation came from an
article that I read in Boat Builders publication.  And they
talked about the foam.  Once the exterior edge of the foam
has been damaged, which can happen very easily just from
people bumping up against it, then there is a possibility to
get encroachment of moisture over time.
Now, maybe some of the closed cell foams are quite a bit
more sophisticated since this article was written or maybe
some of that information was inaccurate.  But in that article
they talked about the difficulty of removing foam and
identifying the saturation point over time.  How much has the
additional flotation been damaged over time?  So, even though
you feel like you may not have water in the boat, if you have
saturation on one side, then the DUKW, of course, would start
listing, as if you did have a breach in the hull on that
side.
So, I'd say, that just in terms of practical
application, once the foam has been installed, that you could
go out and do a float test and draw the water line, or
actually we could weld it in place so it couldn't be removed
easily, and then do that on an annual inspection process to
determine how much degradation of the foam has taken place
over time.
MR. HENRY:  Mr. Wilson?
MR. WILSON:  Obviously I have no experience at this
point.  I would concur somewhat with what Mr. MCDOWELL just
said.  I would also think that it would appear that these
cells would be able to be removed, and just by weighing them
or feeling their weight you would know whether or not they
were saturated or not.  Obviously, that would be a concern if
we go with this type of system.
MR. HENRY:  Mr. Cerulle?
MR. CERULLE:  I concur with Mr. Wilson.
MR. HENRY:  And Mr. Gavinski?
MR. GAVINSKI:  We have not done any research on the
matter.
MR. MCDOWELL:  Can I have a further comment on that?
MR. HENRY:  Yes, Sir.
MR. MCDOWELL:  Most of the applications that I am
familiar with, they inject the foam in rather than have a
removable body.  We went to Tracker Marine just to study the
process.  They do that on their seventeen and a half foot
fishing boats.
To get the density of foam in there consistently in the
void sizes that we're talking about, it's a little bit more
of a challenge than probably the average boat builder would
want to deal with as a new type installation.  The expansion
area needs to be calculated quite accurately, and the jigging
needs to be in place properly so it doesn't bow out the side
of the DUKW during the installation process, and things like
that.  So there's a lot of considerations that need to come
into play through the installation process.
And if it were to become saturated, it would be quite a
job to remove that product out of the cavity.
MR. HENRY:  Thank you, Sir.
One of the questions from the audience included some
operational questions on licensing, manning, and we'll defer
those to a later panel and turn it over to the executive
panel.
MR. JOHN HAMMERSCHMIDT:  Very good.  Any questions from
this end of the table?  Ms. Murtagh?
MS. MURTAGH:  Thank you.  Actually, I had one question
that I think could -- the information could really just be
submitted for the record, and that goes to Mr. Gavinski and
his maintenance expert.  One of the questions that was asked
was, you know, "How often you do particular maintenance on
the pump and on the vessel?" and you indicated that you do
things, you know, weekly, monthly, but you didn't give the
details of that.  I would appreciate it if you would provide
that to us for the record.  You don't have to do it right at
this moment, but, if you would, it would help us quite a bit
so we can take a look at all of the other information as
well.
I did have some additional questions for you, sir, and
that is, the other operators, at least the ones that are
here, have Coast Guard oversight and you indicated that you
are not under Coast Guard inspection.  Do you have oversight
from an independent organization?
MR. GAVINSKI:  No, we do not. Other than our life saving
equipment.  We were under the jurisdiction of the Coast Guard
 until, or through 1990.
MS. MURTAGH:  And then that was changed. So, since then,
you don't have any regulatory organization, as I understand
the answer to the question.  Do you have any independent
organization that you yourselves use, outside organization
that you have come in and do an independent review of the
hull, the equipment on your vessels, other than the life
saving equipment?
MR. GAVINSKI:  No, we do not.
MS. MURTAGH:  And who looks at the -- is it the life
preservers? Or do you have additional life saving ...
MR. GAVINSKI:  The Department of Natural Resources looks
at them. They check them every spring.
MS. MURTAGH:  Okay.  The concept that I have heard from
all of you is to share the information as owners and
operators, which is very promising, but you are only a
portion of the industry.  Do you have anticipation of
expanding this organization, this owner-operator-builder
organization to all of the operators?
You had indicated that you were going to meet after this
meeting so that is why I was curious. If you would answer,
please.
MR. MCDOWELL:  I'm not sure what the future holds.   I
know we want to be a part of maturing this product and
elevating its status in the sightseeing industry. I think it
is a viable venue for entertainment and sightseeing that can
be utilized in many different locations safely, and it's our
hope to be a part of that.
MS. MURTAGH:  I guess I'm looking more from a safety
standpoint, because that's ...
MR. MCDOWELL:  That is a critical component of it and
can't be done without it.  Obviously, we've spent quite a bit
of time developing those systems and processes to support
that, in addition to modifying the equipment, so, yes.
Absolutely.
MS. MURTAGH:  Mr. Wilson?
MR. WILSON:  I guess I'm not clear on the nature of your
question you're asking.  As an organization, are we looking
to expand other markets or are we looking to help the
industry become safer?  I'm not really ...
MS. MURTAGH:  Yes, I'm sorry.  The latter was the intent
of my question.  I understood from the answers you all had
given before, you intended meeting as a group after this
forum to potentially share information regarding maintenance
safety features, that kind of thing.
MR. WILSON:  The answer is ideally has been mentioned,
you know, after the Arkansas incident, you know,  any --we're
all kind of affected by one another's operation.  So it is my
number one concern to make sure, not only we are doing what's
necessary but what other operators are doing.  I would much
rather work together as an industry and hopefully develop
either our own standards, our own regulations.  But if that's
not the case because people won't come to the table, then,
quite honestly, I feel I have no other choice but to turn to
government to step in and do that.
MS. MURTAGH:  Thank you.  Mr. Gavinski?
MR. GAVINSKI:  Bob has suggested that he would like to
get together with the other operators .  I would hope that
everyone would attend the meeting after this session has
ended.
MS. MURTAGH:  Thank you.  Mr. Gavinski, if I could do a
follow-up on the question I'd asked you before.  You don't
have Coast Guard oversight.  Do you have any oversight from
the highway side for the operation of the DUKWs?
MR. GAVINSKI:  No, we do not.
MS. MURTAGH:  Okay.  Thank you.  That's all I have.
MR. HAMMERSCHMIDT:  Before going to Mr. Tyrrell, let me
ask a follow-up question that Ms. Murtagh got into.  In terms
of how much of the industry that this panel represents, you
represent three of the twenty operators that we've
identified, at least in our preparation for this forum.  Mr.
MCDOWELL, how many DUKWs do you operate?  How many vehicles?
MR. MCDOWELL:  Approximately twenty units.
MR. HAMMERSCHMIDT:  Twenty?
MR. MCDOWELL:  Yes.
MR. HAMMERSCHMIDT:  And, Mr. Wilson, how many?
MR. WILSON:  Seventeen.
And I would like to interject that I think that the
three companies represented up here probably represent about
99 percent of the carrying capacity of this industry.
MR. HAMMERSCHMIDT:  Could you repeat that?
MR. WILSON:  I would have to say that the three
companies up here represent, I don't know, ninety-some odd
percent of the entire industry in terms of passengers carried
is represented at this table right now.
MR. HAMMERSCHMIDT:  Well, that's what I was going to get
to.  That's what I was leading into by getting some
preliminary statistics, but -- very good. I just wanted to --
that was my thinking, that you probably represented a very
high percentage of the number of passengers carried each
year, but wasn't clear on the exact statistics on that.
 Mr. Gavinski?
MR. GAVINSKI:  I don't know if it is that high.  I
haven't done a survey of the other people in the industry.  I
know what we carry, but I don't believe it's 90 percent.
MR. HAMMERSCHMIDT:  And, Mr. Gavinski, did you say
earlier that you have sixty DUKWs in operation?  Is that the
figure?
MR. GAVINSKI:  We own ninety-two but we have forty-five
tour DUKWs.  We have some vehicles that we use as shuttles
from our ticket booths in the outlying area.  It's about
fifty-eight to sixty that are operational.
MR. HAMMERSCHMIDT:  Okay.  At any rate the point I was
trying to make is, although you are only three operators, you
do represent a significant segment of the amphibious vessel
tourist industry in terms of the number of people you carry
year in and year out.  And, I think in this section that ran
in this forum on maintenance, it's apparent that the
approaches you all have been taking are quite comprehensive
in the maintenance area.
Mr. MCDOWELL?
MR. MCDOWELL:  Mr. Hammerschmidt, they've prepared a
slide.  We were talking earlier about this prop shaft
protector.  Before we close with our session, I'd like the
opportunity to put it on the overview so people can further
understand the comments regarding Andy's proposal or
presentation on this.
MR. HAMMERSCHMIDT:  Very good.  Let me ask one other
quick question of Mr. Gavinski.   In your fifty-fours years
of operation, or your company's operation, do you know of any
accidents that your company has experienced in all those
years?
MR. GAVINSKI:  Through fifty-four years, we have had
some minor incidents.  There has never been an incident that
was related to mechanical failure.
MR. HAMMERSCHMIDT:  Okay.  Just while we have you here,
can you recollect any evacuations that have occurred in your
operation?
MR. GAVINSKI:  Zero.
MR. HAMMERSCHMIDT:  Zero. Okay.  Thank you.
And before we go to this slide let's go to Mr. Tyrrell
for a question.
MR. TYRRELL:  Yes.  Mr. Gavinski, could you tell us what
happened in 1990 to remove your company from Coast Guard
inspection jurisdiction?
MR. GAVINSKI:  The Wisconsin River was declared non-
navigatable, so the Coast Guard did not have jurisdiction
after that.
MR. TYRRELL:  I see.  Even though the Coast Guard has no
inspection jurisdiction, do they have any other jurisdiction
over any aspect of your operation?
MR. GAVINSKI:  No, they don't, other than the fact that
we do follow the regulations that they impose.  We have open
dialogue with them.  They are willing to come up and look at
our operation any time that we ask them to come up.
MR. TYRRELL:  Does the State of Wisconsin place any
operational restrictions on your business?
MR. GAVINSKI:  No, they do not.  Other than our shuttles
--  there is an inspection by the Department of
Transportation of our shuttles because they are licensed as
buses.
MR. TYRRELL: I see.  If you were to, God forbid, have
an accident, would you be required to report that accident to
any state or federal agency?
MR. GAVINSKI:  I'm sure that we are.  We'd have to
report it to the Department of , I think it's Safety and
Building Inspections.  I think that's what category it falls
under.
MR. TYRRELL:  I'm sorry, I didn't hear.
MR. GAVINSKI:  I believe that's the category that we
would fall under as far as if anyone is injured.
MR. TYRRELL:  Would the local sheriff or police or law
enforcement, state police or anybody like that have any sort
of role if there was some sort of accident?
MR. GAVINSKI:  Technically, no.  We operate our land
portion of our tours all on our own property.  We cross a
county highway at three locations.  When it has happened in
the past, we have had them come in though, yes, and do a
report.  It's basically for our insurance company.
MR. TYRRELL:  Thank you very much.  That's all I have.
MR. HAMMERSCHMIDT:  Then let's proceed with the slide
that Mr. MCDOWELL would like to describe for us.
MR. MCDOWELL:  Just for clarification for the audience.
 It's a little difficult to see.  I'll do my best.
[Showing slide]
Right here you can see the wire tie and the bolts that
secure the cab to the bottom to the V-strut that Andy was
referencing.  If this particular component was to come apart,
we've designed a retention ring.  There's clearance in
between the shaft and this tube stock here that allows for
the removal and maintenance of the babbitt bearing that's in
the rear.  It's just secured by these three supports here.
They're easy to install and it just eliminates that exposure.
  Is there any comments you want to make, Andy?
MR. WILSON: No.
MR. HAMMERSCHMIDT:  We thank you for that added
information.
MR. MCDOWELL:  Thank you.
MR. HAMMERSCHMIDT:  Seeing that there's no further
questions for this particular panel, let me thank you very
much for your participation this morning and for your
responsiveness to all the questions.  It's been very
informative, and you may stand down.
We will take a ten minute break before proceeding to our
next panel.
[Whereas, a break was taken from 9:45 a.m. to 9:52 a.m.]
MR. HAMMERSCHMIDT:  The next panel will be addressing
issues concerning vessel inspections, policies and
certification.
MR. TYRRELL: We don't seem to have all of the panel
members here.
MR. HAMMERSCHMIDT:   And, we'll wait until all of the
panel members are in their positions.  [Pause]  Ready for
action?
MR. TYRRELL:  This panel is composed of Captain Brian
Basel, U.S. Coast Guard, Chief of the Office of Compliance,
U.S. Coast Guard Headquarters; Lt. Commander Eric
Christensen, U.S. Coast Guard, from the Marine Safety Office
in Chicago, Illinois; Lt. Commander James Whitehead, U.S.
Coast Guard, Chief of Inspections at MSO Boston; Lt. Dean
Firing, U.S. Coast Guard.  He's with the Vessel Compliance
Division at U.S. Coast Guard Headquarters; and Mr. Robert
Thompson, who is a consultant that the NTSB has arranged to
participate in this proceeding.
I would like each one of you, if you wouldn't mind,
starting with Captain Basel and moving down the table, give
us a brief description of your duties and responsibilities,
and if Mr. Thompson would give us a brief description of his
background and experience.
Following the self introductions, Captain Basel will
give a short presentation of an overview of the Coast Guard
inspection process.
CAPT BASEL:  Thank you Mr. Tyrrell.
Just in a nutshell, the Office of Compliance for Marine
Safety is the office that is charged with promulgation,
promulgating the guidelines necessary for the field to
conduct their inspections.
One thing I would like to add though, is that we are
also the third and the final level in an appeal process.
After the OCMI and after the District, should anybody feel
aggrieved by a decision in the field that it is unwarranted
or unreasonable in your specific operation.  And we encourage
people to use that process. It's not used enough.  Thank you.
  I might also add, if I could, I have been the officer in
 charge of Marine Inspection in Tampa which had a DUKW, also
in Cleveland, and my background is in quite a few field tours
in Baltimore, overseas in Rotterdam, in Louisiana, and
District Tours in New York, as well as being Chief of the
Coast Guard's Traveling Inspection Staff for four years in
Washington, D.C., as well as a tour in Washington on the
promulgation of the Coast Guard's Marine Safety Manual.
 Thank you.
MR. TYRRELL:  Thank you.  Commander Christensen.
COMMANDER CHRISTENSEN:  Yeah, and as I stated yesterday,
I'm Chief of the Inspections Department at Marine Safety
Office, Chicago; twelve years experience within the Coast
Guard.  My entire career has been spent in marine inspection.
MR. TYRRELL:  Thank you.
COMMANDER WHITEHEAD:  I hold a similar title to Lt.
Commander Christensen.  I'm Chief of Inspections and
Investigations at MSO, Boston, basically overseeing all
inspections of vessels ranging from liquified natural gas
ships, fishing vessels, small passenger boats, including
DUKWs; and investigations relating to those also.
MR. TYRRELL: Thank you.
LIEUTENANT FIRING:  I'm Lieutenant Dean Firing with the
Vessel Compliance Division.  My main duties there at this
time are the Program Manager for the Ultimate Compliance
Program; the Program Manager for the Streamline Inspection
Program.  Also compliance issues relating to sub-chapter T
vessels, small passenger vessels.  I have twelve years in the
marine safety field in inspections and investigations.
MR. TYRRELL:   Thank you very much.  Mr. Thompson.
MR. THOMPSON: Yes, sir.  I've recently retired after
twenty-two years in the Coast Guard;  starting inspecting
DUKWs when they arrived at the Chicago location.
Went to MCDOWELL's, when he was down in Branson, to get some
early experience so I could get familiar with what I was
looking at; reviewed the policies from St. Louis, authored
the '98 DUKW policy, submitted it for review and
authorization.
I've been working with DUKWs, looking at different DUKWs
for quite a few years. I was part of the investigation on
Miss Majestic sinking just before retirement, and have stuck
with several companies after that to assist them in complying
with the Coast Guard regulations.
MR. TYRRELL:  All right.  Thank you very much.  Captain
Basel, you have a short presentation?
CAPT BASEL: Thank you.  What I'd like to do is just
lay out a quick -- do a quick rundown of what the Coast Guard
procedures, inspection procedures are and what their
guidelines are.  And I think that may allay some of the
questions that may come up.
On a small passenger vessel, once the initial
construction and outfitting is completed, as we heard
yesterday, very detailed initial inspection of the hull, the
fittings, the machinery and all the equipment is conducted.
And the inspector is satisfied that applicable regulations
have been met.  At that time a certificate of inspection,
which is valid for three years, is issued.  Annual re-
inspections will be done of a similar scope but to a lesser
degree.
Sub-chapter T, that we've heard so much about, is a
special set of regulations specifically designed for small
passenger vessels.  It recognizes that there are many
different designs and applications, and that the application
of what is known as sub-chapter H for the larger passenger
vessels would be both difficult and highly inappropriate.  It
is specifically intended to provide the flexibility, where
it's appropriate, to both the vessels and to the OCMI.
That's exactly why that sub-chapter was written.
There is other guidance on inspections available to
inspectors in the form of our marine safety manual, which
will clarify issues or provide additional guidance on unusual
vessels.  For example, the authorization to allow radiator
cooled engines on the DUKWs has been in this manual now for
more than twenty years.  The NAVIC is another form of
guidance, published particularly when we desire information
to be disseminated to industry.  And you've heard a lot about
the NAVIC being the Navigation and Vessel Inspection
Circular.
Several times yesterday, you heard of a possible NAVIC
on DUKWs. Several weeks ago, I met with some of the DUKW
industry leaders, prior to being aware of this forum, and
discussed a working meeting; sit down and really roll up our
sleeves and lay out the issues and concerns and all of the
best practices.  So many of which we have heard this morning
and yesterday.  We're looking for national consistency.  And
as we heard, this industry has grown very rapidly and is
expected to keep growing.  Many of the unique features of the
amphibians are expanding.  It is readily apparent that there
are many initiatives and combinations of initiatives that can
appear capable of providing the level of safety desired by
everyone.  The time has obviously come to consolidate all of
the local initiatives into a national policy, be they from
the industry or be they from some of the various Coast Guard
and Marine Safety offices that have promulgated their own
unit and instructions.
As you may have seen in the report of the Miss Majestic,
the Coast Guard has made quite a few recommendations to our
own procedures to improve these processes.  And we will deal
with them most expeditiously.  I would like to remind
everybody the barring the need to revisit a vessel, due to
deficiencies that might be noted in the inspection, the Coast
Guard may only visit a vessel once in a year.
There is a tremendous responsibility placed on the
owner, on the operator and on the master, as we've heard this
morning, to maintain his vessel and equipment in a seaworthy
state.  Meaning, meeting or exceeding the existing
regulations.
Amphibious vessels are unique in that they are
essentially dry docked after each trip, providing the
responsible party the opportunity to continuously examine the
exterior of that vessel.  This factor alone is a significant
consideration of any OCMI where special consideration is
given as opposed to strict application of sub-chapter T,
where it may not be practical.
On the other hand, this unique operation provides
opportunities to conduct modifications that might not be
readily apparent to an inspector.  On this note,  I caution
that the regulations require that the Coast Guard be
notified, and we've heard it here this morning, when any
repairs that affect the safety of the vessel are conducted.
Obviously we've seen the need to elaborate exactly what is
meant by that statement, particularly in regards to boots.  I
would, however, strongly suggest that in the next working
group that was mentioned, that we carefully define this and
any other penetrations, boots and any other penetrations that
are unique to amphibians.
In the recommendations of the report or discussions of
the Traveling Inspection Staff.  This is a team of five very
experienced and senior officers that are available to assist
the OCMI or the Chief of Inspection Department or Inspectors.
 In any case, where they feel they may have something unique
and different that they would like a second opinion on, or it
may exceed the unique expectations or the training of the
people in that port.  To this point they have never been
called, that I'm aware of, on a DUKW which tends to tell me
that there is a fairly good level of field confidence in the
inspection of the DUKWs.
In closing, I believe we need to make mention of just
the human factors.  We've touched on that earlier, in
particular in the Miss Majestic case.  We can always say,
"What would have happened?" the what if scenarios. " What if
the clamp had been a little tighter?"  "What if the hinge
assembly had been in place?", "What if a deficiency report
with a brief time frame had been written?", "What if the
Higgins pump was operational?" "What if the operator had
noticed the bilge discharged sooner."  "What if there had
been an in the water check of the boots?"  And I could go on.
 I think a lot of these are listed in the report as
contributing factors.
What I am saying is that every weak link in this chain
involves a human factor.  The safety net involves not only
the owner and the master but also the mechanic and the
inspector.  The importance of maintenance, training, drilling
 can't be over emphasized, and we've heard that here.
I thank you, and I think the panel will be pleased to
attempt to answer any questions that you might have.
MR. TYRRELL:  Thank you very much, Captain.
Mr. Ash Chatterjee will lead off questioning this panel.
MR. CHATTERJEE:   Thank you Mr. Tyrrell.  Good Morning
gentlemen.
My first question is directed at Captain Basel, and then
I'll ask the same question of the others.  In May 1999, the
Coast Guard issued an internal bulletin called an AIG, titled
-- quote -- "Inspection Safety Awareness of DUKWs" --unquote,
which required the MSO's to inspect the watertight integrity
and safety aspects of DUKWs and their zones.  Please give us
an update on what was checked and what was found.
CAPT BASEL:  Okay.  In fact, there were two safety
alerts that were issued, to use that term. The AIG is just an
addressee of who it goes to.  But essentially, it was
immediately after the incident a safety alert was put out.
It basically just said "Get it, take a look at every one of
these things. We don't know what happened yet, but get a look
at the underwater body, take a look at all of the through
hull fittings, anywhere where water intrusion might come in."
I say approximately two weeks later, obviously the
report was not out, but at that time there was a reminder to
make sure everybody had been out on each of the DUKWs that
were in existence or inspected at the time.  And now, it was
additional guidance, as far as flooding areas, to get out and
take a look at specifically hinge assemblies, bilge systems,
bilge alarms and that notifications of escape is being given
in the briefings.  Again, these were just notifications,
reminders to stay on top of this and obviously that
recommendations would be coming from the report.
MR. CHATTERJEE:  Could you clarify the notifications and
the findings were sent out to the field?
CAPT BASEL:  Yes, these were sent out to every Marine
Safety Office.  It may have been limited to each one that had
a DUKW, but perhaps I think Lieutenant Firing, who was in
Washington at the time, was probably the drafter of those.
LIEUTENANT FIRING:  The address that you have there went
out to all Marine Safety Offices, including all district
offices.  So, The address is a general address to get
information to basically any Marine Safety personnel in the
Coast Guard.
MR. CHATTERJEE:   Yes, my question has to do with what
was found and what was checked.
CAPT BASEL:  At that time, we did not ask for the
findings to be returned.  We were sending out notices of what
to look for specifically.
MR. CHATTERJEE:   Can you give us an update now, at this
point as to what was found.
CAPT BASEL:   As I said, we did not ask for the
information to come back, so we have not compiled that in
headquarters.  Again, it was a notification and obviously
we're waiting for the exact findings of the report.
MR. CHATTERJEE: Lt. Commander Christensen, what have you
found in your MSO?
LCDR CHRISTENSEN:  When those safety alerts came out,
actually we had already gone out and conducted an inspection
following -- in fact, I believe it was the next day following
the casualty, we sent out our duty inspector to take a look
at, I believe. it was three DUKWs, and that duty inspector
was the not yet retired Mr. Thompson.  Although I remember
most of the conversation that Bob and I had regarding what
was found, I would like to ask that he, since he was the
inspector that went out there and looked at that, perhaps he
could share his more detailed account.
MR. CHATTERJEE:  Mr. Thompson, please.
MR. THOMPSON:  Yes, I went out the next day and looked
at the DUKWs that were operating in Chicago, namely Chicago
Duck Tours, made some recommendations of what I found to be
less than perfect boots, anything that looked questionable.
Spoke with them about -- immediately they went into the
repair replacement operation.
Upon getting down there to Hot Springs, I made a
courtesy check of the other DUKW operation that was down
there, the National Park Service DUKWs.  Took a look at their
DUKWs, crawled under them.  Spoke with Don about those parts
that were underneath there, whether they were good, bad or
ugly.  Took at look at the rest of the DUKWs that belonged to
Yellow and White.  Made recommendations as I found them.
MR. CHATTERJEE: Any general findings, any general areas
of weakness?
MR. THOMPSON: Yeah, in some instances we found where
the brackets were missing or maybe missing a bolt or two.
Some boots were less than what I would use or certificate
with.
MR. CHATTERJEE:  Okay.  Thank you.
MR. THOMPSON:   That was it.
CAPT BASEL:  If I might also add that that safety alert
was also put out on the web for everybody, for anybody to see
also.
MR. CHATTERJEE:  Okay.  Thank you.
CAPT BASEL:  With the guidelines of what we were looking
for.
MR. CHATTERJEE:  Thank you.  Lt. Commander Whitehead?
LCDR WHITEHEAD:  Yes.  the day after the Arkansas
casualty, myself and our senior investigating officer,  who's
a qualified inspector, went to the Boston DUKW facility, went
through each of those DUKWs, both internally, externally,
checking all the hull, the through  hull penetrations.
I think within two days, two or three days had another
inspector who is very familiar with the DUKWs, probably our
most senior inspector on the DUKWs, go and check the three
DUKWs in Plymouth. I believe on one of the DUKWs, it was
found one of the retaining wire on the strut for the
shaft, the propeller shaft was found missing and those were
replaced.
On the Boston DUKWs, we found two things that later I
brought those up verbally to Boston DUKWs, and we followed up
with a letter to them, and it's since been corrected.  Those
two things were the life jacket stowage.  While you could
take the life jacket out, I found them to be kind of tight
and needed some strength to pull them out.  So, I recommended
that they change that arrangement a little bit so that they
could more easily come out, which they did.
The other thing was, I just had a concern on the side
curtains.  They were -- to prevent them -- they have to go on
the highway when they go to their location in Boston, and so
they had a bungee cord arrangement to keep the curtains in
place so they didn't flap in the wind, which could be
dangerous.  They've since, as Mr. Wilson, I think, stated
yesterday, they've since changed that to where they can just
pull a lever and those would immediately release.
  MR. CHATTERJEE:  Thank you.  Lieutenant Firing, would
you like to add anything to that?
LIEUTENANT FIRING: I believe I would, yes.  The first
message that we sent out was immediately after the casualty.
 We had received calls at headquarters from the field asking
if there were problems with DUKWs.  We immediately ran a
casualty database out of our computer database to find out if
there were class problems that we could identify, if we knew
of any particular problems. The results of that were
immediately published out in the first message, which stated
that we did not seem to have any problem that we knew of.
But here are the casualties and here is what has occurred on
DUKWs.  And it encouraged the OCMI's to go out and look.
The second message was sent out after the Miss Majectic
had been raised.  There appear to have been suspect areas.
The shaft housing connections, and also egress.  The second
message directed the district commanders to ensure that the
OCMI's pay particular attention to the shaft housing areas on
future inspections.  And also to require the operators to
give specific instruction during the safety orientation on
means of egress from the vessel.
MR. CHATTERJEE:  Thank you.  Captain Basel, could you
provide details of any changes in inspection policies for
DUKWs since May of 1999?
CAPT BASEL:  Again, the Coast Guard has not put out any
changes.  What we've heard here now is what we anticipated
once the report was completed.  We would be doing a forum to
look at all of the best practices, pull together some of the
best policies and practices that are out there, sit down, as
I said, roll up our sleeves with the industry and really put
together some sound guidelines that really address the
industry as it expanded.  And we still look forward to doing
that.  I think today's forum has just been outstanding. It's
given us a leg up on where we wanted to go, probably early
next year now that the report is out.
But to answer your question directly, we have not made
any specific changes.  There's been a lot of lessons learned
right now, but we have not changed any national policy.
MR. CHATTERJEE:  Okay.  Just for clarification, the
Coast Guard Industry group that's going to be addressing
DUKWs and amphibious vessels, is the intent of that to
develop policies for industry practices or is it to develop
your inspection policies?
CAPT BASEL:  I would say it could be both.
Where it goes, I really don't want to say just yet.  If
the regulations are needed, perhaps we'll have regulations.
If certain guidelines are needed, we'll have guidelines. I
think we've heard a lot of things here as far as maintenance.
 I think we a question was presented yesterday regarding the
SIP, or Streamline Inspection Program. I think the DUKW
industry is an absolute perfect candidate for that type of
program.  But I would still envision that the NAVIC would
have quite a few guidelines because there is a need, I think
as we have seen, for individual offices to have some unique
conditions for their specific area.  I think we've seen some
of them as we've talked about distances offshore, lengths of
run, things that haven't been mentioned, some have, some do
not have anchors.  And there are reasons for that -- whether
you are on running rivers or calm lakes, and so forth.
There's a whole lot of practices that will be specific,
but I think everybody has seen a tremendous need to bring all
of these together into one instruction to give the OCMI a
chance to look at all of the best practices that are out
there.  Perhaps there will be other ones that that unit had
not thought of that others had thought of, and then they can
put together the best possible policy for his specific
operation.  So we're not setting any limitations on where
we're going with this, with our working group.  We're going
to leave it wide open, whatever's necessary that's what we're
going to do.
MR. CHATTERJEE:  Captain Basel, why do you feel that the
Streamline Inspection Program is appropriate for DUKWs?
CAPT BASEL:  Well, as I said in my opening statement,
the Coast Guard may only get down to a vessel once a year.
That probably doesn't happen very often.  The inspectors are
out in the field.  They know what's going on in most of their
areas.  They probably will stop in when they're in those
 areas.  Those are the reality of what goes on.
But the Streamline Inspection Program is a program where
we step back a little bit more, and we have more of an
oversight role, where we stress on the owners -- and they lay
out very detailed programs on how an inspection should be
done to a level that at least meets, if not exceeds, our
regulations.
You do not have the Coast Guard coming down saying do
this, do this, do this.  The responsibility is on the master
and the owner and the operator to know exactly what is
required.  And in that regard, the boat is not made ready for
an inspection on an annual basis.  It's much easier for the
owner to maintain it to the regulations at all times.
Everybody in the process knows what's required and everybody
plays a role.
There's an ownership role in there and what we've found
in that process is that, as the individual masters and owners
start taking that responsibility on, they wind up doing and
meeting the regs much, much more.  They're more aware of
things and not waiting for people to tell them what to do.
They're aware of exactly what is required.
MR. CHATTERJEE:  In the Streamline Inspection Program,
how does the Coast Guard insure that all owners fulfill and
discharge their responsibilities in an equitable manner, big
operators and small?
CAPT BASEL:  We still come down and do our annual
inspection.  Much of it more would be on the record keeping,
on the drills, and a quick review of what is going on
operationally on the boat.  We do not walk away from it.  We
still do our inspections.  But again, it's on the recording
and on the capabilities of the owner and of the master to
maintain the vessel.
MR. CHATTERJEE:  Does the Coast Guard require DUKW
operating companies or amphibious vessel operating companies
to maintain records, maintenance records for review during
inspections?
CAPT BASEL:  No, we do not.
MR. CHATTERJEE:  Do you recommend that they do so?
CAPT BASEL:  Well, I think we're going to get into that
in our working group, but I think the panel before us laid
that out pretty well.
MR. CHATTERJEE:  Where do you draw the line between
maintenance and inspection, given that we've heard that DOT
has certain maintenance checklists?  What is the philosophy
where -- do you not feel that review of maintenance records
would help your inspectors in doing their inspections?
CAPT BASEL:  There's no question they might be of some
help.  But right now, the regulations do not require that
owners maintain records for us.  Certainly those that are
maintaining records and the Coast Guard is asking certain
questions -- it's nice that in order to go to a maintenance
record and say, "Here's what we've done.  Here's how often
we've replaced a boot." for an example and so forth.  But,
again, I say that right now that is not required in the
regulations.
MR. CHATTERJEE:  Okay. Thank you.
CAPT BASEL:  Is it a best practice?  I would say,
certainly, it might be.  And it's something that we can look
at in that working group.
MR. CHATTERJEE:  Okay.  Something worth looking at?
CAPT BASEL:  Absolutely.
MR. CHATTERJEE:  Sure.  Thank you.  A basic background
question, more for the audience.  What are the inspection
intervals for DUKWs and what are the areas of focus for COI
[Certificate of Inspection] inspection and re-inspections?
What are the different areas of focus?
CAPT BASEL:  Sure.  Essentially, they are the same.  The
annual re-inspection, same equipment just to a lesser degree.
 During a COI inspection, essentially, the hull, all the
equipment that's the internal structure and external
structure that's readily available, the pertinence, all the
machinery, life saving, fire fighting, essentially everything
that you see on the DUKW.
MR. CHATTERJEE:  Okay.
CAPT BASEL:  Just again, as I led off with, to the
annual inspection, same scope just to a lessor degree.  It's
a check.  It's normally done between the tenth and the
fourteenth month of the annual anniversary.
MR. CHATTERJEE:  Okay.  I'd like to know some more
details about the Coast Guard policy for inspection of de-
watering pumps.  What was your policy before May '99 and has
that changed since?  And are operational checks in the water
or is actual pumping required to test those pumps?
CAPT BASEL:  Okay.  As we said yesterday, the Coast
Guard has no requirements for de-watering.  We have bilge
requirements which is designed -- if you'll look in the
regulations, I think Captain Lance mentioned the capacity of
the pumps, it is designed to handle the routine leakage that
you get in normal operations, be it from some seals or glands
or normal leakage or rain and so forth that might go into the
bilges.  That is what our bilge requirements are.
Some units of, as we heard yesterday from Lt.
Commander Christensen in Chicago, require the Higgins pump to
be maintained on the vessel as a piece of original equipment.
 Again, we need to take a look at that as a working group, if
that is something that should be required.  But right now
that is not a Coast Guard requirement, unless that pump is
the pump that is used in a certain area for the ten gallon
per minute capacity.  There's nothing to say it can't be a
250 gallons per minute. But again, our requirements are for
bilge systems, not for de-watering systems. I think you had
another part to that question.
MR. CHATTERJEE:  Yeah, I was going to ask, isn't the
Higgins pump considered in the bilge pump category?  I use
the word de-watering, but if you would like to call it a
bilge pump, is that what it is called by the Coast Guard?
CAPT BASEL:  We would call it a bilge pump, yes.
MR. CHATTERJEE:  Okay.  And what is the Coast Guard
policy for checking our operational checks in the water made
on that pump by the inspector?
CAPT BASEL:  The Coast Guard requirements during an
inspection require an operational check of the bilge pumps.
It doesn't go any further than that.
We've heard some inspectors may require a water, a test
with water, some may not.  Again, I'll look at a working
group to make sure we have a consistent policy on what is an
operational check.
Again, the amphibs are unique in that they're out of the
water. Normal small passenger vessels in the water, you
hesitate to pump your bilges because you may have a pollution
incident.  So an inspector may or may not actually test with
water.
I found it gratifying this morning to see that most of
them are testing with water.  And in some cases there are
quite a few additional pumps that are there, if one pump
should fail.  I heard one owner say he was putting in six
pumps.  That's fantastic.  Again, that is exceeding the
regulations, but it may be necessary and it probably will be
considered one of our best practices.  Some inspectors do;
some inspectors may not.  Operational check is all that is
defined.
MR. CHATTERJEE:  If you test the Higgins pump without
water, would you construe that as an operational check?
CAPT BASEL:  I would tend to think it could be, yes.
MR. CHATTERJEE:  Of pumping air?
CAPT BASEL:  That is operational, yes.
MR. CHATTERJEE:  Okay.
CAPT BASEL:  Ideally, you would check with water.  I
think most people do check with water.
MR. CHATTERJEE:  Okay.  Thank you.
CAPT BASEL:  There's a lot of ways of doing that as we
heard today.  Taking it out, putting water in the hull.  I
have never -- I have been on DUKWs. I have never specifically
conducted an inspection on a DUKW.  I was not aware of
exactly what might happen if you put five or six or seven
inches of water in the bottom of a DUKW, whether that would
be a practical way of testing it, but I think I heard this
morning that that is a practical way, either in or out of the
water.
MR. THOMPSON:  Actually, I believe you would find that
that would cause that hull to stretch, begin splitting seams
with the thin material.  I believe you might cause more
damage than it's worth when it comes to filling the hull up
with five or six inches of water.
MR. CHATTERJEE:  Could you clarify that again?  Did you
say testing with a few inches of water in the hull?
MR. THOMPSON:  If you filled the hull up with water, as
was suggested, you're probably going to stretch that hull and
cause damage to it.  The hull was designed to keep water out,
not keep water in.
MR. CHATTERJEE:  So, residual water remaining in the
hull could be a problem, is that what you're saying?
MR. THOMPSON:  If you put six, eight, ten inches of
water inside the hull, you might cause damage to the hull.
MR. CHATTERJEE:  So, an alternative means would need,
you'd need to find an alternative way of testing the
operation of the pumps?
MR. THOMPSON:  The idea of piping a water tank of water,
a tank of water into the Higgins pump, right over the side
and bringing it in that way, that was excellent.
MR. CHATTERJEE:  Yes.
MR. THOMPSON:  I think that's a good test.
MR. CHATTERJEE:  Yes.
MR. THOMPSON:  I would advise against dumping a bunch of
water into the hull.
MR. CHATTERJEE:  Okay.  Thank you.
What was the Coast Guard policy for inspections of seals
and boots, for boots and band clamps before May of '99; and
has there been any changes in that inspection procedures
since?   Captain Basel or anybody else who wishes to answer
that.
CAPT BASEL:  No, there have not been any changes.  Right
now, the procedure is just looked at as another external hull
fitting or pertinence.  Inspector would look at the boots,
look at the condition of them, look at the assembly and so
forth, as he would in a normal through hull fitting, noting
that that is a fairly unique arrangement but it would be a
visual examination of the system.
MR. CHATTERJEE:  Mr. Thompson, the seals can be looked
at as a through hull fitting, as CAPT Basel said, but are
there any differences that you look for when you look at
seals and boots versus a regular through hull fitting?  What
are the things you might want to be aware of when you do this
unique inspection?
MR. THOMPSON:  On the initial construction, of course,
you'd pull the seals apart, look at them and make sure
they're in good condition, and they're the right type for the
installation that was intended.  Make sure that somebody is
not installing something of a lighter weight or something
that was not intended to be a water seal into the vessel.
In the original policy which we implemented in '98, it
did not involve the re-inspection of the boot seals.  In the
later policy, which was written and implemented, we realized
there was a deficiency.  And we included in what would
normally be a five year dry docking of the vessel, we
included the re-inspection of the boot seal, for that boot
seal to be removed at that time so you could get a good look
at it, because the upper seal on the aft