Page 103: of Maritime Reporter Magazine (June 1999)

tions under certain limited conditions.

The conclusion was that they could, and

Policy Letter 3-98 was the result.

Now, owners of all types of passenger vessels (not just casino vessels) operat- ing in "benign, low-risk" environments may conduct a series of underwater sur- veys and internal examinations in accor- dance with the Policy Letter and receive a 30-month extension of the drydock requirement. Each vessel must be oper- ating in "benign, low-risk environments, defined as which are operated in "...fresh water, (less corrosion risk), near-shore and/or shallow water, mud- bottom rivers, limited routes and limited time underway."

In the past year, more than a dozen casino vessels have completed Special

Drydock Extension Surveys and have been granted 30-month extensions.

Since the underwater surveys have been recently completed, it is difficult to make a definitive statement as to long- term reliability of the results compared to actual drydock examinations. There have been no safety problems or techni- cal issues which might cause USCG to reconsider allowing this alternative pro- cedure. Underwater survey reports have documented hull conditions in detail, sometimes in more quantitative terms than is normally done at a traditional drydock examination. Undeniably, the video and ultrasonic gauging records are much more extensive than those normal- ly made during a traditional drydock examination. In fact, confidence in the program is strong enough that the exist- ing policy is being refined and incorpo- rated into a Notice of Proposed Rule- making which will eventually result in new regulations.

For the gaming vessel owners who have opted to conduct Special Drydock

Extension Surveys, the impact has been extremely positive. In every case, both

USCG and the cognizant state gaming agency have allowed gaming to continue while the vessel was examined at the dock, except for brief periods when the hull was opened for valve, shaft or rud- der removals, passenger operations were not interrupted.

In order for the Special Drydock

Extension Survey program to be reliable and successful, all involved parties must know their roles and perform them cor- rectly. The vessel owner must first decide whether the Special Drydock

Extension (underwater) Survey is the right choice for his operation. Currently, for vessels operating more than six months of the year in fresh water, the drydock and tailshaft inspection interval is five years. To determine whether actu- al drydocking or underwater survey makes the most economic sense, he should consider all costs (direct and indirect) of each drydocking versus underwater survey. For the underwater survey program, a commitment must also be made to perform the Hull Main-

June, 1999 tenance and Assessment Program speci- fied in the policy letter. For casino ves- sels, the underwater survey is the hands down winner because of the ability to continue dockside gaming throughout the process. Owners of non-casino pas- senger vessels may conclude that the rel- atively higher expense, in most cases, of an underwater survey (especially if in- water hull repairs or shaft replacements are required) makes the traditional dry- dock examination more advantageous.

The owner should become familiar with

Policy Letter 3-98 and the applicable references, such as the Navigation and

Vessel Inspection Circular (NVIC) for underwater surveys. Next, proposals should be solicited from qualified diving

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