Ecology Prevention Recommendations on Bulk Oil Transfer Operations

1998-2005

The table below contains recommendations made by the Washington State Department of Ecology to ship operators, regulated facility operators, Classification Societies, industry associations, equipment manufacturers and government agencies following investigations of spills that occurred during ship bulk oil transfer operations. Some recommendations have been made in more than one case and no attempt was made to remove duplicate recommendations. Readers will note that some recommendations were broad, while others were very specific to the circumstances of the spill.
Recommendation Reference Number	Recommendation Text
2005-053	Consider prioritizing the pre-booming of single-hulled tank barges prior to loading operations. If pre-booming is not feasible due to safety or environmental conditions, make the completion of a visual inspection of all available external hull areas in the cargo block a condition of the transfer.
2005-052	Consider specifically requiring that all single-hulled tank barges be visually inspected over all available external hull areas in the cargo block before loading operations commence.
2005-051	Consider prioritizing the pre-booming of single-hulled tank barges prior to loading operations. If pre-booming is not feasible due to safety or environmental conditions, make the completion of a visual inspection of all available external hull areas in the cargo block a condition of the transfer.
2005-050	Consider specifically requiring that all single-hulled tank barges be visually inspected over all available external hull areas in the cargo block before loading operations commence.
2005-049	Emphasize the dangers of complacency during oil transfers to crews by publicizing lessons-learned from this spill throughout the company’s fleet.
2005-048	Develop a procedure under which your tug crews handling single-hull tank barges and the tankermen-PICs (Persons-in-Charge) of such barges work together to visually inspect all available external hull areas in the cargo block prior to loading cargo. Require that the result of the inspection be logged.
2005-047	Work with {tank barge company} to develop clear guidance for required communication between your tug crews and tank barge tankermen-PICs (Persons-in-Charge).
2005-046	Work with {tank barge company} to develop criteria and procedures for use when your tug crews are approaching a berth with a tank barge under less-than-ideal environmental conditions.
2005-045	Emphasize the dangers of complacency during oil transfers to crews by publicizing lessons-learned from this spill throughout the company’s fleet.
2005-044	Develop a procedure under which your tankermen-PICs (Persons-in-Charge) and the crews of the tugs handling single-hull tank barges work together to visually inspect all available external hull areas in the cargo block prior to loading cargo. Make this procedure a requirement of all companies contracted to handle your single-hull tank barges. Require that the result of the inspection be logged.
2005-043	Work with {tug boat operator} to develop clear guidance for required communication between their tug crews and barge tankermen-PICs (Persons-in-Charge).
2005-042	Work with {tug boat operator} to help them develop criteria and procedures for use when they are approaching a berth with tank barges under less-than-ideal environmental conditions.
2005-041	Consider prioritizing the pre-booming of single-hulled tank barges prior to loading operations. If pre-booming is not feasible due to safety or environmental conditions, make the completion of a visual inspection of all available external hull areas in the cargo block a condition of the transfer.
2005-040	Consider specifically requiring that all single-hulled tank barges be visually inspected over all available external hull areas in the cargo block before loading operations commence.
2005-039	Consider prioritizing the pre-booming of single-hulled tank barges prior to loading operations. If pre-booming is not feasible due to safety or environmental conditions, make the completion of a visual inspection of all available external hull areas in the cargo block a condition of the transfer.
2005-038	Consider specifically requiring that all single-hulled tank barges be visually inspected over all available external hull areas in the cargo block before loading operations commence.
2005-037	Assign two tankermen, or a tankerman and tankerman’s assistant, to a tank barge for loading operations at night to assist with topping off operations and inspecting the surrounding water for possible oil spills.
2005-036	Develop a procedure under which your tug crews handling single-hull tank barges and the tankermen-PICs (Persons-in-Charge) of such barges work together to visually inspect all available external hull areas in the cargo block prior to loading cargo. Require that the result of the inspection be logged.
2005-035	In order to maximize the potential for systematic improvement resulting from this spill, undertake a joint effort with {tank barge operator}, {regulated facility operator}, the U.S. Coast Guard, and Ecology to publicize lessons learned from this spill, with emphasis on the importance of properly installing, maintaining, servicing, inspecting, testing and using tank level alarm systems and indicators.
2005-034	Emphasize the dangers of complacency during oil transfers to member companies and their personnel by publicizing lessons-learned from this spill throughout the {industry association} membership.
2005-033	In order to maximize the potential for systematic improvement resulting from this spill, undertake a joint effort with {tank barge operator}, {regulated facility operator}, the U.S. Coast Guard, and the {industry association} to publicize lessons learned from this spill, with emphasis on the importance of properly installing, maintaining, servicing, inspecting, testing and using tank level alarm systems and indicators.
2005-032	Review State contingency planning standards and clarify requirements for initial boom deployment timing (e.g. will having containment boom in the water during the first hour suffice, or will having the boom secured in a systematic manner to intercept oil be the standard for defining “deployment”).
2005-031	Develop procedures to ensure that all response vessels and equipment used by regulated oil facilities are regularly inspected, tested, and maintained.
2005-030	Undertake a review of the feasibility of conducting frequent inspections of bulk oil transfer operations to ensure compliance with vessel and facility procedures, as well as state and federal requirements. Identify potential sources of additional funding to allow the Program to undertake such inspections while maintaining the Program’s core activities at current levels.
2005-029	Undertake a review of oil transfers occurring in Washington State waters and give consideration to requiring a second tankerman during night time transfers (those occurring between 2100 and 0700) as a way of ensuring both personal safety and the safety of the oil transfer.
2005-028	Undertake a review of oil transfers occurring in Washington State waters and give consideration to requiring automatic shut-down devices at regulated oil facilities and to requiring that tank barges loading at those facilities be equipped to activate those devices.
2005-027	Undertake a review of oil transfers occurring in Washington State waters and give consideration to requiring pre-booming of regulated oil facilities where safe and feasible, and, if feasible, under what conditions.
2005-026	In order to maximize the potential for systematic improvement resulting from this spill, undertake a joint effort with {regulated facility operator}, {tank barge operator}, Ecology and the {industry association} to publicize lessons learned from this spill, with emphasis on the importance of properly installing, maintaining, servicing, inspecting, testing and using tank level alarm systems and indicators.
2005-025	Share the lessons-learned from this spill throughout the U.S. Coast Guard.
2005-024	Undertake a review of oil transfers occurring in Washington State waters and give consideration to requiring a second tankerman during night time transfers (those occurring between 2100 and 0700) as a way of ensuring both personal safety and the safety of the oil transfer.
2005-023	Undertake a review of oil transfers occurring in Washington State waters and give consideration to requiring automatic shut-down devices at regulated oil facilities and to requiring that tank barges loading at those facilities be equipped to activate those devices.
2005-022	Undertake a review of the training provided to inspectors tasked with inspecting the domestic tank vessel fleet to ensure they are provided with the knowledge-base to determine when safety-critical systems have been modified in a way that merits further examination by the U.S. Coast Guard.
2005-021	Undertake a review of inspection procedures for domestic tank barges to determine if adequate guidance regarding the scope and depth of pre-inspection preparation and review of vessel documents is in place. Specifically, ensure that procedures require a thorough review of vessel documentation prior to annual inspections and the reporting of any documentation discrepancies noted during such review.
2005-020	Ensure that the testing of the tank level indicators, automatic shut-down systems, and overfill alarm systems are adequately emphasized during inspections of tank barges. Give consideration to the adoption of additional procedures by which inspectors would more positively verify the critical set points of such systems.
2005-019	Undertake a review of the inspection history of the {tank barge} to determine how the original installation of the {manufacturer} tank level alarm system and how the alarm portable alarm unit (PAU) power supply modification were accomplished without the submission of plans. In addition, determine how the system was inspected annually for a period of seven and six years, respectively, without the lack of documentation being corrected.
2005-018	Review the {manufacturer} tank level alarm system as currently installed aboard the {tank barge}, with special attention to the potential for damage to the exposed, un-armored tank level alarm sensor unit cables located in hazardous zones, and to the potentially compromised intrinsic protection of the system resulting from the rewiring of the alarm system portable alarm unit (PAU) to an external power source.
2005-017	In order to maximize the potential for systematic improvement resulting from this spill, undertake a joint effort with {tank barg operator}, the U.S. Coast Guard, Ecology and the {industry association} to publicize lessons learned from this spill, with emphasis on the importance of properly installing, maintaining, servicing, inspecting, testing and using tank level alarm systems and indicators.
2005-016	Share the lessons-learned as a result of this spill at oil terminals operated by {regulated facility operator}.
2005-015	Revise facility Declaration of Inspections to cover testing tank level indicators, automatic shut-down systems, and overfill alarm systems, if installed.
2005-014	Undertake a review of {regulated facility operator}oil terminals to determine at which facilities pre-booming of transfers is safe and feasible, and, if feasible, under what conditions.
2005-013	Develop procedures to exercise oil spill response vessels, in water, for a period of time that maintains drive train functionality; and which complies with any manufacturers’ recommendations regarding periodic operation.
2005-012	Extend the lessons-learned as a result of post-spill examination of the response to the spill at the {regulated facility operator} facility at Point Wells, as outlined above, to other oil terminals operated by {regulated facility operator}. Specifically, apply the improvements to the response boat inspection, testing, and maintenance program to all facilities operated by {regulated facility operator}.
2005-011	In order to maximize the potential for systematic improvement resulting from this spill, undertake a joint effort with {regulated facility operator}, the U.S. Coast Guard, Ecology and the {industry association} to publicize lessons learned from this spill, with emphasis on the importance of properly installing, maintaining, servicing, inspecting, testing and using tank level alarm systems and indicators.
2005-010	Emphasize the dangers of complacency during oil transfers to crews by publicizing lessons-learned from this spill throughout the company’s fleet.
2005-009	Undertake a thorough review of response boat placement aboard tank barges operated by {tank barge operator} to ensure that deployment in time to meet State contingency planning standards is assured under foreseeable oil spill scenarios.
2005-008	Revise the company’s Oil Transfer Procedures to emphasize the requirement that the {tank barge operator} Declaration of Inspection be filled out, in lieu of or in addition to, the facility-supplied Declaration of Inspection, in cases where the facility-supplied Declaration of Inspection does not include a line item requiring testing of the tank level indicators, automatic shut-down systems, and overfill alarm systems aboard the barge.
2005-007	In developing the risk-based tank barge manning procedure (see U.S. Coast Guard Recommendation #4 {in the full report}), ensure that the potential for reduced alertness in tankermen conducting night time oil transfers is given adequate weight. Specifically, consider utilizing two tankermen for all night time transfers (those occurring between 2100 and 0700) as a way of ensuring both personal safety and the safety of the oil transfer.
2005-006	If one is not currently in place or under development, develop a Crew Endurance Management System for {tank barge operator} personnel that takes into consideration the impact of travel time and varying scheduled work hours on {tank barge operator} personnel (specifically, tankermen).
2005-005	Provide protection from physical damage to the exposed, un-armored tank level alarm sensor unit cables located in hazardous zones aboard the {tank barge} and other {tank barge operator} tank barges fitted with similar equipment.
2005-004	If not already accomplished, prepare and submit plans for the {manufacturer} tank level alarm system as currently installed aboard the {tank barge} to the U.S. Coast Guard for review, with special attention given to the rewiring of the alarm system portable alarm unit (PAU) to an external power source.
2005-003	Develop procedures that ensure that all proposed safety system modifications made aboard vessels operated by {tank barge operator} are fully reviewed and documented, and are submitted to the U.S. Coast Guard for review in accordance with federal requirements.
2005-002	Develop procedures that ensure that plans for all required systems installed aboard vessels operated by {tank barge operator} are prepared and provided to the U.S. Coast Guard for review in accordance with federal requirements.
2005-001	Ensure that employees responsible for maintenance and calibration of tank level indicators, automatic shut-down systems, and overfill alarm systems aboard barges operated by {tank barge operator}are fully familiar with the systems and have received training from the manufacturer on how to properly undertake those tasks; or, have a certified manufacturer’s technician conduct all maintenance and calibration operations on the tank level indicators, automatic shut-down systems, and overfill alarm systems aboard barges operated by {tank barge operator}.
2004-013	Develop company policy that directs Tankermen to avoid topping off two different products simultaneously.
2004-012	Update company’s pre-load planning form to include the following items to ensure {tank barge operator} tankermen have a clear understanding of the planned load sequence and planned finish ullages: 1.Tank Fill Sequence 2.Total tank capacity 3.Starting sounding or ullage 4.Planned final sounding or ullage
2003-027	Communicate details of this incident and its causes to personnel throughout the {regulated facility operator} facility.
2003-026	Through training, ensure that all appropriate company personnel view the dock/barge or dock/ship transfer process as a single operational system that requires good communication between all personnel with a stake in a safe and spill-free transfer process.
2003-025	Ensure that company policies and procedures contain standards for investigating and analyzing each spill occurrence that occurs at the facility, with an eye toward lessons-learned that can be used to prevent future spills.
2003-024	Modify {regulated facility operator} written policies and procedures and the standard company Declaration of Inspection (DOI) to ensure the method for line clearing is part of the standard communication checklist used by the Persons-in-Charge (PICs) during the pre-transfer conference.
2003-023	Communicate details of this incident and its causes to personnel throughout the {regulated facility operator} fleet.
2003-022	Modify {tank barge operator} written policies and procedures and any standard company Declaration of Inspection (DOI) to ensure the method for line clearing is part of the standard communication checklist used by the Persons-in-Charge (PICs) during the pre-transfer conference.
2002-047	Review the {marine loading arm (MLA) manufacturer} ISO 9001 quality control system to ascertain how the {MLA coupler manufacturer}QCDC (quick connect/disconnect) couplers were installed without the over-center lock indicators, why replacement indicators were not subsequently ordered and installed, and why the opening of {regulated facility operator's} No. 4 MLA coupler during an installation and commissioning hydrotest under {MLA manufacturer} supervision was not documented.
2002-046	Review the prevention measures undertaken on the {marine loading arm (MLA) coupler manufacturer} QCDC (quick connect/disconnect}couplers installed at {regulated facility operator} for potential application to similar {MLA coupler manufacturer} QCDC (quick connect/disconnect) couplers installed at other facilities.
2002-045	Investigate the {regulated facility manufacturer}conclusion that the locking washers on the four bolts holding the clamp cylinder bracket to the coupler “had lost much of their spring.” Should the conclusion show merit, ensure that other facilities with similar QCDC (quick connect/disconnect) couplers are properly notified to inspect and/or replace those locking washers.
2002-044	Review the {marine loading arm (MLA) coupler manufacturer}QCDC (quick connect/disconnect) coupler manuals supplied to facilities utilizing these couplers and ensure that all inspection and preventive maintenance items are clearly stated. Include torque values for all bolts that require periodic inspection for tightness.
2002-043	Investigate the {marine loading arm (MLA) coupler manufacturer} coupler release of March 1, 1990 at the {refinery/terminal} in New Jersey to determine if there are similarities to the {regulated facility operator} coupler release that require notification of other facilities utilizing {marine loading arm (MLA) coupler manufacturer} hydraulically-actuated QCDC (quick connect/disconnect) couplers of similar design.
2002-042	Ensure that all the appropriate marine terminal procedures sufficiently emphasize that the design of the {marine loading arm (MLA) coupler manufacturer} QCDC (quick connect/disconnect) couplers requires full rotation of the actuator collar to ensure proper (and continuous) seal.
2002-041	Ensure that all the appropriate marine terminal procedures are modified to reference the use of the new positive hydraulic shut-off valves and E-clips located on the couplers.
2002-040	Ensure that {marine loading arm (MLA) coupler manufacturer}provides a comprehensive list of inspection and preventive maintenance items for the Nos. 3 and 4 MLA couplers as well as the Nos. 1 and 2 couplers provided by {MLA coupler manufacturer} The list should include the appropriate torque values for all bolts that require periodic inspection for tightness.
2002-026	Field modifications of equipment should not be made. The covers on the emergency disconnect were duct-taped closed.
2002-025	Consider providing vessels docking at facility handouts on potential wind/sea state effects peculiar to the dock.
2002-024	Consider installing equipment to provide weather, current and wave observations at the dock to the National Weather Service on a real-time basis.
2002-023	Ensure dock operators are trained to understand the importance of their role in communicating information that may have bearing on safety decisions made by vessel personnel.
2002-022	Review company policy/procedures for monitoring weather forecasts and conditions at the dock and ensure adequate emphasis is placed on taking early steps to prepare for high winds and seas.
2002-021	Consider installing mooring load measurement devices on your docks. This equipment is available and has been installed at a number of large tanker berths. Should the loads become high or the lines become slack, the terminal operator can advise the ship.
2002-020	Take an active role to ensure adequate vessel mooring security at their dock. The {regulated facility operator} facility is located in an area vulnerable to wind and wave action at their docks and the potential for associated dynamic loading should be fully accounted for in any mooring analysis. Mooring analyses submitted by vessel operators should be carefully reviewed by facility engineers and marine terminal personnel before they are approved.
2002-019	Ensure that all company vessels have an up-to-date mooring analysis for the berths they frequent, and that such analyses contain the best information obtainable regarding currents, winds and seas.
2002-018	Review company policy/procedures for tending mooring lines during inclement weather.
2002-017	Ensure Masters effectively utilize night orders to address special precautions that may be necessary in light of anticipated environmental conditions.
2002-016	Review company policy/procedures for monitoring weather forecasts and environmental conditions while at berth, ensure that forecasts, predictions and conditions are monitored regularly, and that adequate emphasis is placed on taking early steps to prepare the ship for high winds, seas and current.
2002-015	Consider the mooring systems on their vessels to be critical safety systems as defined in International Safety Management (ISM) Code Section 7 “The Company should establish procedures for the preparation of plans and instructions for key shipboard operations concerning the safety of the ship and the prevention of pollution. The various tasks involved should be defined and assigned to qualified personnel.” ATC’s policy/procedures should cover the entire mooring system - including the maintenance, inspection, and replacement of the mooring lines, in line with industry standards for their specific equipment.
2002-014	If there were special circumstances that apparently contributed to the failure of the tank coating and subsequent corrosion pitting aboard {ship}, share the findings of the investigation with other tank vessel operators classed by {Classification Society}, and if appropriate, with other International Association of Classification Societies (IACS) members.
2002-013	Work with Sheridan to determine a cause for the tank coating failure in the port slop tank aboard the {ship} and ensure that other {ships} in {ship operator’s} fleet, classed by {Classification Society}, are not experiencing similar failure and associated deep corrosion pitting.
2002-012	Ensure that each of the required checks of segregated ballast tanks for oil contamination (on initial discharge and before stripping per the Chief Mate’s cargo orders) is logged distinctly and for each individual tank.
2002-011	Modify the procedures for checking segregated ballast tanks for oil contamination to ensure that such checks do not result in personnel making confined space entry without the appropriate confined space entry precautions.
2002-010	Consider modifying company cargo tank inspections to require more specific documentation of the observations made by personnel (generally Chief Mates) that conduct such inspections.
2002-009	Ensure that personnel conducting cargo tank inspections (generally Chief Mates) are properly trained to recognize the signs and symptoms (including early signs) of tank coating failure. Consider working closely with {Classification Society}to accomplish such training.
2002-008	Consider modifying company procedures to require regular checks of slop tanks to determine the location of the oil water interface (and thus the volume of oil versus water in the tanks). Ensure that the results of such checks are recorded.
2002-007	Ensure that the {ship's} cathodic protection system is functioning correctly and adequately.
2002-006	Work with {classification society} to determine a cause for the tank coating failure in the port slop tank and ensure that other {ships} in {ship operator's} fleet are not experiencing similar failure and associated deep corrosion pitting.
2002-005	Ensure that Chief Mates regularly monitor compliance with standing orders and cargo orders and take prompt corrective action when deviations are noted.
2002-004	Ensure that mates standing cargo watches implement standing orders and cargo orders from the Chief Mate, and understand the importance of monitoring the levels in all tanks, even those that are supposed to be static.
2001-034	Require that facility Persons-in-Charge (PICs) learn what the watch rotation is aboard the vessel during the pre-transfer conference with the vessel PIC, and actively request that each vessel watchstander meet with the facility PIC to review and sign the Declaration of Inspection (DOI) at scheduled shift changes.
2001-033	Incorporate International Safety Guide for Oil Tankers & Terminals (ISGOTT) guidelines for communicating to and coordinating with the vessel with regard to ballast operations into your procedures, and require an explicit exchange of information with vessel Persons-in-Charge (PICs) with regard to facility policy requiring that sea suction and overboard discharge valves be secured (and sealed as appropriate) while at the facility dock (thus prohibiting the loading of ballast water via the ship’s cargo system while at the dock).
2001-032	Ensure that all Persons-in-Charge (PICs) complete the Declaration of Inspection (DOI), not as a matter of routine, but as an important check on transfer readiness (thus ensuring compliance with 33 CFR 156.130 [Code of Federal Regulations]).
2001-031	Ensure, to the maximum extent possible, that all transfers across the dock at your facility happen in full compliance with your operating requirements (a requirement of Washington State law and regulation)
2001-030	Incorporate International Safety Guide for Oil Tankers & Terminals (ISGOTT) guidelines for communicating to and coordinating with the facility with regard to ballast operations into your procedures.
2001-029	Ensure compliance with your procedures for oil transfers aboard your fleet by conducting regular spot-checks.
2001-028	Ensure that oncoming watchstanders during transfer operations read and sign the Declaration of Inspection (DOI) and meet with the facility Person-in-Charge (PIC) before assuming the watch.
2001-027	Ensure that all Persons-in-Charge (PICs) complete the Declaration of Inspection (DOI), not as a matter of routine, but as an important check on transfer readiness (thus ensuring compliance with 33 CFR 156.130 [Code of Federal Regulations]).
2001-026	Ensure that all transfers at facilities happen in full compliance with the facility’s operating requirements (a requirement of Washington State law and regulation).
2001-025	Ensure that all valves along potential discharge routes involving the loading of dirty ballast and line flushing using the stripping pump are examined aboard the {ship}, found to be operating properly, and providing a tight seal when seated.
2001-024	Ensure that the guidance contained in the publication “Prevention of Oil Spillages Through Cargo Pumproom Sea Valves” is fully incorporated into company operating and maintenance procedures.
2000-024	Work with {regulated facility operator}, {regulated facility operator}, {tank ship operator} and National Oceanic and Atmospheric Administration (NOAA) to develop tidal current prediction factors for the Cherry Point and Ferndale facilities.
2000-023	Work with NOAA, {regulated facility operator}, {tank ship operator} and Ecology to develop tidal current prediction factors for the Cherry Point and Ferndale facilities.
2000-022	Work with {regulated facility operator}, {regulated facility operator}, {tank ship operator} and Ecology to develop tidal current prediction factors for the Cherry Point and Ferndale facilities.
2000-021	Review the company’s process for accepting tanker mooring arrangements, ensure that the process adequately reviews the mooring arrangements in light of environmental conditions likely to occur at {regulated facility operator's} facilities.
2000-020	Consider the installation of permanent tidal current monitoring equipment at the pier. Should such an installation be undertaken, work with the National Oceanic and Atmospheric Administration (NOAA) to provide the agency real-time access to the data.
2000-019	Cooperate with the Seattle Office of the National Weather Service by regularly providing weather observations (automated or manual) to forecasters on duty.
2000-018	Review the work hours of the pollution control representative in light of their role. Consider the use of more than one pollution control representative during transfers exceeding 12 hours, so that a continuous oversight presence is maintained on deck.
2000-017	Review the role of the pollution control representative. Ensure the pollution control representative is given adequate authority (and management support) to require a transfer shut-down should he/she detect an unsafe condition.
2000-016	Work with {regulated facility operator}, National Oceanic and Atmospheric Administration (NOAA), {tank ship operator} and Ecology to develop tidal current prediction factors for the Cherry Point and Ferndale facilities.
2000-015	Ensure that the revised mooring studies for {tank ship operator's} tankers at the Ferndale pier incorporate current speeds (in excess of 1 knot) and directions that were recorded by {environmental consultant} in May 1999 under contract with {regulated facility operators}. If necessary, undertake additional current monitoring study, in cooperation with {tank ship operator}, to determine the maximum probable current that will be experienced at the {regulated facility operator's} Ferndale pier and to determine the frequency and intensity of tideline passages at the pier.
2000-014	Ensure that the company’s Safety Management System (SMS) fully complies with Section 10.2.4 of the International Safety Management (ISM) Code.
2000-013	Revise company procedures to ensure that any permanent modifications to safety-critical systems, including mooring winches and brakes, are carefully considered and reviewed by company management prior to implementation. Ensure that any such modifications are documented in accordance with the company’s Safety Management System (SMS).
2000-012	Ensure that results of annual brake testing are readily available to those responsible for tending the ship’s moorings.
2000-011	Review the mooring winch maintenance system for the company, ensure that maintenance is occurring in accordance with the established schedule. Regularly audit maintenance logs to ensure continued adherence to the schedule.
2000-010	Revise company procedures to ensure that there are at least two qualified persons on duty on deck specifically dedicated to tending the ship’s mooring during transfer operations. These two persons should work together to ensure that the safety-critical mooring system is properly adjusted for the prevailing conditions.
2000-009	Revise company maintenance procedures to require inspections of the winch brakes prior to each mooring operation, and include checks derived from the {manufacturer's} winch manual. Ensure that these checks are documented and that any problems noted are addressed quickly.
2000-008	Work with {regulated facility operator}, {regulated facility operator}, National Oceanic and Atmospheric Administration (NOAA) and Ecology to develop tidal current prediction factors for the Cherry Point and Ferndale facilities.
2000-007	Ensure that the revised mooring studies for {tank ship operator's} tankers at the {regulated facility operator's} Ferndale pier incorporate current speeds (in excess of 1 knot) and directions that were recorded by {environmental consultant} in May 1999 under contract with {regulated facility operators}. If necessary, undertake additional current monitoring study, in cooperation with Tosco, to determine the maximum probable current that will be experienced at the {regulated facility operator's} Ferndale pier and to determine the frequency and intensity of tideline passages at the pier.