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APPENDIX A DRAFT OF U.S. COAST GUARD CIRCULAR ON PASSENGER SUBMERSIBLES 47

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US Owns ~ Trar~ation ~ Ids /' Co - Gas !a NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. Commandant (GMTH) b.^ILl~G ADC,RESS. Ed Unites States Coast Guard 2100 2nd Street, SW Washington, DC 20593-0001 (202) 267-2997 COMDTPUB Pl6700.4 NVIC - Subj: Guidance for Certification of Passenger Carrying Submersibles 1. PURPOSE. This circular provides guidance for certification of passenger carrying submer~lblea under Title 46, Code of Federal Regulations, Subchapter T - Small Passenger Vessels thunder 100 Gross Tons) (46 FOR Parts 17S-187~. 2. DISCUSSIoN. a. Non military submersibles have been used for several decades in the industrial, experimental and research fields. Submersibles had not been used in any commercial service for which the existing inspection statutes and regulations would apply until 1987 when the first passenger carrying submersible to be certificated by the U.S. Coast Guard went luto operation in St. Thomas, U.S. Virgin Islands. Two other passenger submersibles had already been operating in the Cayman Islands and Barbados (outside U.S. Jurisdiction) beginning in 1986. b. For operations under O.S. Jurisdiction, the inspection statutes of U.S. Code Title 46 - Shipping (46 USC) and the regulations in 46 CFR Subchapter T - Small Passenger Vessels (46 CFR Parts 175-187) apply to any submersible less than 100 gross tons carrying more than sis passengers. Since the regulations were developed primarily with surface craft in mind, many of the requirements cannot be applied to or may otherwise be inappropriate for submersibles. Additionally, there are many measures not in the regulations which must be applied to attain an equivalent level of safety to that of surface craft and otherwise minimize any inherent hazards of underwater operation. 48 ILL. ~ 1 1 1 == __ == ..

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NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 2. c. There has also been much interest regarding the operation of smaller submersibles carrying Six or fewer passengers. To date, orly a few such operations exist. Such vessels are not subject to present inspection laws. Bowe~rer, they are subject to regulation as ur~inspected veseele under 46 CER Subchapter C - {Juinspected Vessels (46 CER Parts 24-26~. These submersibles must also be designed and constructed to a recognized industry Standard for safe underwater operation. Additionally, they wag be subject to special local operating restrictions as may be imposed by the Captain of the Port (COTP) relative to navigation Safety, port safety and security, and vessel traffic conalderations. d. Recreational submersibles must comply with 33 CFR, Subchapter S (Boating Safety). Undocumented submersibles (i.e., those not having federal documentation) with propulsion equipment, must be numbered in accordance with the federal numbering system or the numbering system of the state in which the submersible will be principal y operated. When a submersible is involved in a collision, accident, or casualty, the operator is required to report such occurrences to the appropriate OCMI or state authorities, and to render all possible assistance to others involved in such incidents. 33 CER 155 (Oil Pollution Preventlon Regulations for Vessels) and 33 CFR 159 (Marine Sanitation Devices) also apply to recreational submersibles. Voluntary reports of submersible operations in or-near U.S. waters may be made to the nearest Coast Guard Operations Center. Inquiries about the extent of such reports and other questions that cannot be recolored locally should be directed to Commandant (G-NRS) at (commercial/FTS) 202/~-267-1948. These reports are intended for informative use in search and rescue (SAR) activities only. . . Enclosure (1) to this circular provides general guidance relative to the inspection and certification requirements for submersibles, primarily those carrying more than sis passeDgere. This document does not stand alone, i.e., it makes reference to the applicable regulations and to the appropriate industry standards. Designers, builders and operators must also be familiar with and use the referenced arteries. Subaersible technology is not new, but its application in the passenger carrylog industry is still very much under study. Though we have established a safe baseline, as this industry grows we will see caner technological advances which w111 have to be carefully considered in view of safety. We have initiated a number of studies from which we are likely to gain some insights that may impact on these guidelines, the regulations and the referenced ladustry standards. Eventually, we plan to establish specific regulations for this class of vessels. In the meantime, enclosure (1) to considered to be the beat available approach to facilitating this ludustry while ensuring passenger safety. 49

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NAVIGATION AND JESSE INS]?BCTION CIRCUITS NO. I~?L~NTATIGN. Coast Guard plan Eerier, icepection, and certification will be based on the guidance contained tn thee circular. Owners, operators, designers ant bulldere of passenger carrying su~erelbles oust tee come familiar with the applicable regulations and sta~derde. To facilitate a timely inspection for certification, they are also urged to follow the guidelines of enclosure (~) closely. (~) Saall Passenger Submersible Guidance (2) Guidelines for Stability of Saall Passenger Submersibles* (3) References (4) Addresses (5) Urban Hass Transportation Admisstration (OMTA) Recoa~ended Fire Safety Practices for Rail Transit ~teriale Sciection (deleted) Non-Sta~ard" Distributlon: C:e New Orioa" (90~; Baltimore (45~; San FrancIsco (40~; Port Arthur, Honolulu, Puget Sound (351; Miami, Mobile, I~ong Beach, Morgan City (25~; Hampton Roads, Jacksonville, Portland OR (20~; Boston, Portland He, Charleston, Anchorage (151; Cleveland (123; Loule^Ile, Heephis, Paducah, Pittsburgh, St. Louis, Se~ra~h, San Juan, Tampa, Galveston, Buffalo, Chicago, Detroit, Duluth, Hil~ulcee, San Diego, Juneau, Valtes (101; Providence, Buntlag ton, V~ington, Corpus Cnristi,.Toledo (S). C:e New Tork (70~; P2~1adelp~a (3S); Houston (2S); St. Ace (S); Sturgeon War (4 ~ . D:1 CG Idason Officer I~SE"IFICOND (Code HEN), CG Liaison Officer RSPA (DHM-22), CG liaison Officer HARAD (t~R-720.1), CG laid eon Officer JUS~PHU (1~. *Sample spreadsheet calculations (Figure 4) have been deleted from Enclosure 2. 50

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Encl. (1) to NVIC GUIDANCE FOR CEtTIFICATION OF PASSENGER CARRYING SUBMERSIBLES TABLE OF CONNECTS Chapter 1. - General Background 1. Introduc~cion 2. The Underwater Safety Project 3. US Navy 4. American Bureau of Shipping 5. Passenger Submersible History 8. Applicability 1. Subchapter T- Small Passenger Vessels 2. Subchapter C - Uninspected Vessels 3. Subchapter H - Passenger Vessels 4. Recreatlo~1 Submersibles 5. Foreign Flag Submersibles C. Equivalency D. Regulation Development Chapter 2 . - Inspection and Certif ication A. Concept Review B. Application for Inspection C. Plan Review D . Inspection for Initial Certif ication E . Inspection for Cert if ication F. Certif icate of Inspection G. Reinspection H. Drydockir~g or Hauling Out I. Notification of Repairs and Alterations Chapter 3 - Construction and Arrangement A. General Design B. HuD Structure C. Subdivision and Stability D. Means of Escape E. Interior Construction F. Raile and Guards Chapter 4 - Lifesaving Equipment A. Life Preservers B. Primary Lifesaving Equipment C. Ring Buoys D. Distress SignAle E. F. G. Emergency Position Indicating (EPIRB) First Aid Kit Individual Emergency Breathing Apparatus 51 Page 2 2 2 3 3 3 4 4 4 4 4 6 7 7 8 8 9 9 10 10 10 12 13 13 13 13 13 13 13

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Enc.=. (1) to NVIC Chapter 5 - Fire Protection Equipment B. C. mu rare ~t~nsutaner~ D. E. General Fire Ampa/Pire Main System lo. __ an. ~ Portable Plre E~titlgut8her8 Plre Detection System Chapter 6 - Machinery Installation A. General B. Lifeaupport Sgetems C. Bilge Sgatems Chapter 7 - Electrical Installation A. General B. Cable C. Emergency Power D. Batteries and Battery Charging Chapter ~ - Vessel Control A. Ballast Systems B. Emergency Ballast Systems C. Auto-pilot D. Communications E. Alarms F. Remotely Controlled Valves Chapter 9 - Operation A. General B. Deere Slice C. Operations Manual/Safety Plan D. Rescue E. Maintenance Chapter 10 - Manning and licensing A. General B. Submersibles not subject to inspection C. Submersibles sub Sect to inspection Chapter 11 - Foreign Passenger Submersibles Operating in the U.S. A. Coastwise Trade B. Inspection Standards C. Inspectlon and Certification D. Operations Manual 14 14 14 14 14 15 IS 15 16 16 16 16 17 17 17 17 17 17 18 18 18 19 20 21 21 21 22 22 23 23 Encl: (2) Guidelines for Stability of Small Passenger Submersibles (3) References (4) Addresses (5) Urban Mass Transportation Adminstration (UMTA) Recommended Fire Safety Practices for Rail Transit Materials Selection 52

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Encl. (1) to NVIC CHAPTER 1. GENERA: A. Background. 1. Introduc Lion. Considerable research and development has been conducted relative to the safe design, construction, and operation of small manned submersibles. Participation in such efforts has included the Na", the Coast Guard, the submersible industry, the American Bureau of Shippln8 (ABS), and technical societies such as the Marine Technology Society (MTS) and the Society of Naval Architects and Marine Engineers ~ SNAME) . the safety Of ludustrial and research submersible operations has been the primary concern of most work accomplished until recently. The advent of the presenter carrying submersible has created the need to look at manned submersibles in a different light. Since 1986 the Coast Guard has worked closely with the developers of this new industry to establish a sound safety policy for the design. construction, and operation of these new submersibles. The Underwater Safety Project (USP). a. The Coast Guard Headquarters USP was established in 1968 in reaction to what appeared at the time to be a strong near-term need for Coast Guard regulation of underwater vehicles and stations. At the time there were about 50 civilian submersibles in existence in the U.S. In a decade of submersible operations there had only been three major accidents, resulting in the loss of one life. Nevertheless, to ensure at least a minimum standard of safety was maintained, the Coast Guard proposed legislation to obtain authorization for regulation of non-military submersibles regardless of size, service, or number of paseengere. b. Research and development efforts were initiated to determine the basic requirements for submersible regulations. Lialson with industry and Standards organizations was established in order to develop policy, codes , and guidelines for submersibles. MTS conducted three studies and published three sets of guidelines for submersible safety during the period from 1968 to 1979. These guidelines address design, operations, personae!, maintenance, procedures, and equipment. The Coast Guard actively participated in the development of the MTS guidelines and assisted with funding. Not logy after the USE was formed, the priority of the project was in question. The proposed legislation attempts regarding the regulation of nonmilitary submersibles had been unsuccessful. Also, the anticipated demand for submersibles and interest in the activity had not materialized. Although there had been steady advancement of submeralble technology, the maritime industry had experienced an economic recession. The use of submeralbles for other than limited industrial, experimental, or research applications did not appear likely. Coast Guard regulatory efforts on this subject ended with the termination of the USP in the late seventies. 53

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Encl. (1) to NVIC 7. 3. U.S. Navy. The Navy has always been concerned with the safety of military submersibles. The loss of THRESHER in 1963 caused Navy efforts to intensify and resulted in special safety programs. With the advent of the deep research vehicles such as TRIESTE and ALVIN, the Nary took action to ensure the safety of Naval personnel when embarked on manned noncombatant submersibles. Military certification requirements were applied as appropclate, and additional safety requirements were dictated by the aubmeraible's specialized design and use. ALVIN was the first such submersible certificated by the Navy. The Nawy's certification requirements are now published in "Systems Certification Procedures and Criteria Manual for Deep Submergence Systems, NAVMAT P-9290 . ~ 4. American Bureau of Shipping (ABS). a. During the mid-sistie~, ABS was approached by industry representatives and by the U.S. Nary regarding the practicality of preparing standards for the design and construction of commercial submersibles. Becaune of the limited information and experience available in the area of commercial submersibles, ABS began a lengthy effort of collecting, evaluating and developing technical data, safety criteria, operational aspects, etc. which led to the 1968 publication of the "Guide for the Classification of Manned Submeraibles.- b. During the seventies, builders, operators, and ABS (the Nary and Coast Guard as well) gained extensive experience relative to small submersibles, primarily those for research, industrial, and experimental service. Consequently, ABS published "Rules for Underwater Systems and Vehicles. in 1979 (ABS Rules). The Coast Guard participated in the development of these Rules. ~ ile not originally intended to encompass passenger submersibles, these Rules have served as a foundation for ABS to class a number of tourist submersibles to date. 5. Passenger Submersible History. a. In 1964 and 1965, the AUGUSTE PICCARD, a forty passenger carrying submersible, took some 32,000 tourists on over 1100 dives to 1000 feet in Lake Geneva at the Sales National Espositlon. Operation of the AUGUSTE PICCARD in the Unit et States in passenger carrying service was proposed; however, the Coast Guard would not accept the vessel because it was not built under Coast Guard inspection. The AUGUSTE PICCARD was then converted and operated as a research and industrial submersible. In 1984, a Canadian commercial submersible operating firm, Sub Aquatlce Development Corporation, built two passenger carryl~g submersiblea. The vessels, ATLANTIS I and II, were designed to carry 28 passe~gere and two crewmen on short voyages to a depth of 150 feet. These two vessels are now operating in the Cay~an Islands and Barbados. With the success of these vessels, Sub Aquatics approached the Coast Guard with a proposal for a 47 passenger submersible to be operated within U.S jurisdiction in the U.S. Virgin Islands (USVI). The Coast Guard worked closely 54

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Encl. (1) to NVIC (cont'd) with Sub Aquatice to define basic safety requirements. Acceptable design and operational features were established to ensure the safety of passengers and crew at a level equivalent to that of a small passenger vessel of similar capacity. This submersible, ATLANTIS III, was certificated in July 1987 and has been operating successfully in St. Thomas, USVI. In June 198B, another company successfully certificated a similar sized submersible, LOOPING GLASS, in St. Thomas. ATLANTIS IV aM ATLANTIS V have been certificated for operations in Rona, Hawaii and Guam, respectively. HARIEA I, a Panamardan flag submersible, operates in Saipan under control verification. B. Applicability. 1. Subchapter T - Small Passenger Vessels (Under 100 Gross Tone). a. Vessels less than lOO gross tons which carry more than sis passengers are subject to the applicable sections of Title 46 of the Code of Federal Regulations (CFR), Subchapter T (Parts 175 through 187) - Small Passenger Vessels. It is this group of submersibles on which this NVIC focuses. Compliance with applicable sections of 46 CFR Subchapter S - Subdivision and Stability, 46 CFR Subchapter Subchapter B - Merchant Marine Officers and Seaman, 33 CFR Part 155 - Oil Pollution Prevention Regulations for Vessels, and 33 CFR Part 159 - Marine Sanitation Devices is also required. b. In addition, due to the hazardous nature of operating a submersible vessel, the Captain of the Port (COTP) may impose special operational requirements under authority of Title 33, U.S. Code (33 USC), Chapter 25 (Sections 1221 through 1226) - Ports and Waterways Safety Program, and 33 CFR Part 160 - Ports and Waterways Safety - General. Special concerns for the COTP would include navigation safety, port safety and security, available rescue resources, and vessel traffic safety. The cognizant COTP must be contacted well in advance of any intended operations. 2. Subchapter C - Uninsoected Vessels. a. Submersibles carrying sis or less passengers, are peered veasela. as defined by 46 USC 2101~42~. Although not subject to inspection, these vessels must meet the requirements of 46 CFR Subchapter C - Uninspected Vessels. They must also meet the applicable requirements of 33 CFR Part 155 - Oil Pollution Prevention Regulations for Vessels, 33 CPR Part 159 - Marine Sanitation Devices, 33 CFR Subchapter S - Boating Safety, and 46 CPR Part 15 - Manning Requirements. Because of the unique design and operating characteristics, as well as the inherent hazards of underwater operation, an uninspected submersible may be permitted in U.S. passenger operations only if it is designed and constructed to a recognized industry standard. Additionally, the COTP may establish special local operating restrictions under the authority of 33 USC Chapter 25 - Ports and Waterways Safety Program, and 33 CFR Part 160 - 55

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Encl. (1) to NVIC B.2.b. (cont'd) Ports and Waterways Safety, General. These restrictions rlll address local navigation safety, port safety and 8ecurltg, and vessel traffic conalteratlons. To avoid delayed operations due to safety concerns that 'cay be raised about the design and conotructlon of the vessel or its intended operating area, an operator should contact the cognizant COTP well in advance of any intended operations. 3. Subchapter lI - Passenger Vessels. AnY passemer carrYin. submersible that ts lUU gross tone or more would be subject to inspection under 46 CFR Subchapter H. Although submersibles of this size are not envisioned for the near future, the guidelines of this circular could be used subject to application of Subchapter ~ instead of Subchapter T. Recreational Submersibles. Recreational vessels, as defined in 46 USC 2101~25), are vessels manufactured or operated primarily for pleasure, or leased, rented, or chartered to another for the latter's pleasure. Submersibles within this category are subject to the requirements of 33 CER Subchapter S - Boating Safety, Parts 173-183. The guidelines in this circular generally do not apply; however, depending on the area of operation, COTP operating restrictions may be appropriate. This will be evaluated on a case by case basle. These guidelines may be of assistance to a manufacturer or owner of a recreational submersible. 4. 5. Foreign Flag Submersibles. See Chapter ll. C. Equivalency. This NVIC is intended to outline a basis for determining equivalency or passenger carrying submeralbles to conventional small passenger vessels. Since the applicable regulations Ampere developed primarily with surface craft in mind, many specific features cannot be applied to or may otherwise be inappropriate for a submersible. The Coast Guard's approach to the novel design and unique operational hazards of passenger submersibles is to require a level of safety equivalent to that required for a Surface craft of similar size and service. This is established in part through a combination of design requirements and operational restrictions. ~ written operations manual and safety plan detailing normal and emergency operational procedures should be prepared early in the plan"~pg stage for concept review and submitted to Commandant (G-MTH-4), see Appendix C for addresses. It will be evaluated in conjunction with the proposed design to ensure the project addresses crew training, operational wrametere. surface vessel control. and safety features. _, ~ , ~ , D. Regulation Development. As more experience is gained with passenger carrying submersibles, regulations Specific to them and to their operations will be promulgated. Therefore comments to improve this NVIC are solicited. Comments should be submitted to Commandant (G-MTH-4~. 56

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Encl. (1) to NVIC CHAPTER 2. INSPECTION AND CERTIPICATION. A. Concept Review. Passenger carrying submersibles are novel vessels sad as such require special consideration. All new submersible vessel designs and all operations must be conceptually approved by Commandant. For concept review, an owner or builder should submit a proposal to Co~mnudant (G-MTH-4~. The proposal should cover, to the eaxlmum extent possible, the aspects of design and operation raised in this NVIC and should include the draft operations/safety plan. Thl8 to an important first step that will facilitate the certification process, especially plan review and inspection. B. Application for Inspection. An Application for Inspection (CG-3752) should be submitted to the Officer in Charge, Marine Inspection (OCMI) having responsibility for the location where the vessel will be built. Contact should also be made with the OCMI having Jurisdiction in the proposed operating area. C. Plan Review. 1. Plan review for most Subchapter ~ vessels is normally done by the cognizant OCMI. However, passenger submersibles are a unique clans of vessels of very novel designs and operations, therefore detailed plan review will be done by the Marine Safety Center (G-MSC). Plan submittal procedures should be discussed with the cognizant OCMI(~) as well. Detailed plan review will not normally be performed before Jurisdiction (evidence that Coast Guard inspection is required) has been established and substantial evidence (e.g., a contract) is provided that the submersible will in fact be constructed. Conceptual plan review, as noted in Section 2.A. above, say be performed by Co~ntant (G-M1lI) prior to substan~cl&ting intent to construct. In addition to the plans noted in Subchapter T. the following will be required for detailed plan review: a. Pressure hull strength calculations and construction tolerances including those for: viewports, hatches, Joint details, penetrations, attachments, and methods of attachment. b. Life support systems/equipment, material specifications (as appropriate), and supporting calculations for: (~) Carbon dioxide removal (2) Oxygen supply (3) Emergency breathin (4) Sensors and monitoring equipment c. Fire protection systems/equipment. d. Bilge system. Ballast system plans and calculations. 57

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Encl. (2) to NVIC In the intact condition, the only significant inclining moment submerged is due to passenger movement. If the distance GB is sufficiently large, the trim angle can be kept to scme safe maximum, even if a percentage of the passengers were to move the entire length of the submersible. The following criterion addresses this passenger movement hazard, but passenger movement should nevertheless be restricted as much as possible. The submersible must be inclined while submerged to determine the actual GB. Under full load conditions the distance, GB.CtU.1, determined by the inclining experiment must be not less than the minimum GB determined by the following formula: GBmin ~ nwNd / ~ tan e where n - 0.1 (This represents 101 of the passengers all moving at one time.) w - 160 pounds (72.5 kg) per person - the total number of passengers aboard d - the interior length of the main cabin accessible to passengers. This should not include machinery compartments if they are separated from the main cabin with a bulkhead. - the total weight (in units consistent with w) of the fully loaded submersible, not including soft ballast. e - 2S. (representing the maximum safe trim angle. This assumes that each passenger has an individual seat that is contoured or upholstered so that a person can remain in it at this angle.) An object in submerged equilibrium acts exactly as if its center of gravity at G were hanging frog' its center of buoyancy, B. This is true, regardless of the hydrostatic properties of the object, and regardless of the direction of inclining. This means that inclining in the longitudinal direction yields exactly the came rcault as inclining in the transverse direction. This in fortunate, because the extra distance available for moving inclining weights makes a longitudinal inclining much easier. Recall from NVIC 15-81 that an inclining experiment measures the relationship, wd / tan e where w is the inclining weight, and d is the distance the inclining weight moves. e is the inclined angle (trim angle, here) Since the weight of the submersible, if, and its center of gravity have been calculated precisely on the spreadsheet, the results of the inclining experiment can be used to calculate the actual G8 with the formula; GB.c~ua1 - ad / ~ tan e 83

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Encl . (2 ~ to NVIC Remember that ~ should be ache weight of the submersible, not including the weight of free floodlag water ballast (soft ballast). Below are some special procedures tat will help obtain valid results from the inclining experiment. In order to maintain its depth during the inclining experiment, the submersible should be suspended from a small buoy. See Figure 5. The buoy should displace 60 to 100 pounds. It should be attached near the submersible's longitudinal center of buoyancy by a line 30-SO feet long. The submersible should be trimmed to be 30-50 pounds "heavy" so that the buoy wi U be about 1/2 submerged. This should be observed throughout the experiment by the surface boat in attendance. The suspension buoy should be fairly rigid. Pneumatic fenders tend to compress as they submerge, and this can make it difficult to achieve neutral buoyancy. pendulums Lo Or ~ ~ ~ :~ inclining weights Inclining Experiment Figure 5 84

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Encl. (2) to ~~.C Pendulums should be rigged to wing in the lorlgitudiml direction. Whey should be as I88 as possible inside the pressure hull, but even a short pendulum can give good results. Since ache distance GB is constant and does not depend on a Small angle approximation (1ike Gll does), the inclining will be valid at whatever angle is necessary to get readable deflections of the pendulums. Trim angles of 10 degrees or even more must be considered normal during diving and ascent, and the results of the inclining will be Just as valid at these angles as at small ones. Take this into account when planol~g for damping baths and water tubes, since spilled oil or water can be slippery and hazardous on the decks at these angles. There w111 probably be no need for pendulum damping if the inclining can be conducted in relatively deep, calm water. If the surface is rough, the surge near the bottom will sweep the submersible back and forth, making it very dif ficult to get good pendulum readings in any case. It is best to choose a sheltered spot without any Swell. The submerged inclining experiment will require a number of people to be aboard. There should be one person for each pendulum, a pilot, and enough people to move weights or to act as inclining weights. The experiment can take several hours submerged, so life support and air conditioning aystemn must be functioning properly before the inclining begins. Air entrained by the structure and under the fashion failing can shift during the inclining and invalidate the experiment. There should be provisions for ventlug entrained air such as vene holes in the fashion failing. Once the sub is submerged, it should be rocked or trimmed to large enough angles to ensure that all air has been vented before starting the submerged inclining. SIMPLIFIED STABILITY TEST The submersible must pass a simplified stability test to confirm that it is adequately stable on the surface. This should be as outlined in 46 CFR 171.030 with the following modifications: A trim dive, the deadweight survey, and the inclining experiment should be done before the simplified stability teat. This will ensure that the submersible is in dialog trio'. The hard ballast tanks should be about half full and the soft ballast tanks should be blown as dry as possible. In calculating the weight of personnel, A, the weight of each person should be taken as 160 pounce. The beam, b, should be taken as the transverse dlatance between the embarkation deck railings. See Figure 6. The passenger weight should be placed on the embarkation deck at a height equal to the center of gravity of the personnel aboard. The submersible passes the test if no more than one half the freeboard is immersed. Por this purpose, the freeboard is measured from the waterline to the horizontal line through the outboard limit of b at the embarkation deck level. See Figure 6' 85

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Encl. (2 ~ to NNIIC \ freeboard Simplified Stability Test Figure 6 OPERATIONAL TESTS Certain operational teats relate closely to stability. These can conveniently be done in conjunction with the inclining esperimentse Emergency ascents: From several depths, including the certified test depth, all ballast tanks should be blown simultaneously. The time from the beginning of the procedure until the submersible breaks the surface should be recorded. A Coast Guard witness should be aboard to make an evaluation of the motion and attitude during ascent and especially upon breaking the surface. One ascent should be performed by dropping the external drop weights. These tests should verify thee the vessel does not attain a list such that the hatch becomes a downfloodi~g point once it is opened on the surface for disembarkation. Ilatch Height: The submersible must be capable of remaining surfaced under a sea state Waring average wave heights up to 4 feet and average winds up to 16 knots. This requirement is similar to ABS procedures which are not necessarily required or performed except to verify intent of the sub~eraible's operation. ABS has a forth for calculating hatch height, which requires a hydrostatic model aid which assumes that the critical motion for wave overtopping will be in roll. Obsenratiolls of existing submersibles suggest that wave overtopping is usually not a problem, and that any minor deck wetness comes from hea~re~pitch motions. As a check, the motion of the submersible on the surface should be observed and any tendency for deck wetness should be noted. 86

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Encl. (2) to N3tIC Damaged ballast tanks: Prom just below the surface, all possible combinations of ballast tanks should be blown and the equilibrium waterline obeenred. In each case it should be noted whether the hatches are clear to open. A photographic record of these teats should be kept and included in the vessel file. Trim weight effect: If the pilot controls a moveable trim weight or can control trim with liquid ballast, this should be shifted as far 88 Fusible, both fore and aft. Record the trim angles experienced due to these ballast shifts. Effect of passenger movement: With the aubmersible on an even tile, ahift 10: of the intended number of pa~sengere all the way forward and aft. Record the maximum and equilibrium trim angles achieved. The trim angle should not exceed the maximum safe angle for batteries or machinery, and all items of furnishing should remain secure. The maximum trim angle is not espec ted to be comfortable, but it should still be possible to move about the cabin. STABILITY OTTER The end product of the stability review is a stability letter similar to the example below. Note that the stability letter should specifically limit the route to waters not deeper than the certified test depth and to waters consistent with the route assumed in performing the simplified stability tent. Name Master SubJ: Submersible , O.N. Small Passenger Vessel Stability Letter Dear Sir: You are responsible for maintaining this vessel in a satisfactory stability condition at all times and for following the instructions and precautions listed below. A stability test witnessed by the U.S. Coast Guard was conducted on the Submersible , O.N. , at on on the basis of this test, and a deadweight survey performed on the subjec~c vessel at on , stability calculations have been performed. Results indicate that the stability of 88 presently outfitted and equipped is satlafactory for operation both surfaced and submerged on protected/pareially protected waters as indicated on the Certificate of Inspection, provided that the following restrictions are strictly observed: 87

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Encl. (2) to NVIC OPERATING RESTRICTIONS ROUTE. Partially protected waters not more than feet deep. 2. PASSENGERS. A maximum of _ passengers may be carried. A maximum of persons (pssseDgers and crew) may be carried. In no case shall the number of persons exceed that allowed by the Certificate of Inspection. All passengere are to remain Seated ~ in the individual seats provided, for the entire duration of each voyage. 3. FREEBOARD AND DRAFT. When surfaced to embark or disembark pssse~gers, 811 air ballast tanks are to be blown dry so that animus freeboard is maintained. Trim on the surface should be minimized. A load line is not authorized. 4. WATERTIGHT OPENINGS. Hatches are to be secured closed and checked before . _ commencing each dive. They are to remain secured until the surface craft has verified that they are clear of obstructions after resurfacing. Due to the danger of d~wnflooding, hatches are not to be opened in seas having average wave heights exceeding 4 feet. S. CARGO. No cargo is to be carried. 6. WEIGHT CHANGES. No solid ballast or other such weighes shall be added, removed, altered, or relocated without the authorization and supervision of the cognizant OCMI. All such ballast shall conform to ballast drawing No. . The vessel is fitted with pounds of permanent lead ballast in the skids as well as pounds of moveable lead ballast tn the drop weight tray between the skids and pounds of lead Pl8s secured in the battery compartment. 7. BILGES. The vessel's bilges shall be kept dry at all times consistent with pollution prevention requirements. 8. FREEING PORTS. Deck freeing ports shall be maintained operable and completely unobstructed at all times. This stability letter s~11 be posted under suitable ~cransparent material inside the submersible so that all pages are ~risible. It supersedes the temporary stability letter dated . Sincerely' (Authorized Coast Guard Official be: CCGD (m) 88

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Encl. (3) to NVIC References American Bureau of Shipping Rules for Building and Classing Underwater Systems and Vehicles 1979, American Bureau of Shipping, P.0. Box 910, Paramus, NJ 07653-091 ~ "Safety Standard for Pressure Vessels for Human Occupancy,- ANSI/AMSE PVHO 1, The American Society of Mechanical Engineers, United Engineering Center, 345 East 47th Street, New York, NY 10017 Code of Federal Regulatlons: Title 46 - Shipping Chapter I - Cosat Guard, Department of Transportation: Subchapter T - Small Passenger Vessels (Under 100 Gross Tons), Parts 175 to 186 Subchapter C - Uninapected Vessels, Parts 24 to 26 Subchapter S - Subdivision and Stability, Parts 170 to 174 Subchapter V - Marine Occupational Safety and Health Standards, Part/197 Subchapter H - Passenger Vessels, Parts 70 to 89 Subchapter B - Herchant Marine Officers and Seamen, Parts 10 to 15 Subchapter ~ - Marine Engineering, Parts 50 to 64 Subehapter J - Electrical Engineering Parts 110 to 113 Title 33 - Navigation and Navigable Waters, Chapter I - Coast Guard, Department of Transportation Subchapter S - Boating Safety, Parts 173 to 183 Subchapter P - Ports and Waterways Safety, Parts 160 to 167 Subchapter O - Pollution, Parts 151 to 159 Marine Technology Society, Washington, DC: Safety and Operational Guidelines for Undersea Vehicles Safety and Operational Guidelines for Undersea Vehicles Book II International Safety Standard Guidelines for the Operation of - Undersea Vehicles 89

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Bucl. (3) to NVIC References (cont'd) Manned Submersibles by R. Frank Busby, Office of the Oceanographer of the Nary "Systems Certification Procedures and Criteria Manual for Deep Submergence Systems, NAVMAT P-9290" June 1976, Department of the Nay,, Washington, DC 20362 "Code of Practice for Operation of Marched Submeralble Craft,- Association of Offshore Diving Contractors, 28-20 Little Russel Street, London WCLA 2HN "Guidelines for the Selection, Training and Qualificatlon of Deep Submersible Pilots" by the Deep Submersible Pilots Association 90

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Encl. (4) to NVIC Addresses Department of the Treasury, U.S. Customs Service, Carriers, Drawbacks, and Bonds Division, Carrier Rullags Branch, 1301 Constitution Avenue NW, Washington, D.C. 20229 Commandant (G-MTH), U.S. Coast Guard, 2100 2nt Street SW, Washington, DC 20593-0001 Commandant (G-MYI), U.S. Coast Guard, 2100 2nd Street SW, Washington, DC 20593-0001 Marine Safety Center (G-MSC), 400 7th Street SW, Washington, D.C. 20593-0100 Officer in Charge, Marine Inspection The addresses for each OCMI are as follows. The zone of responsibility for each OCMI is described in 33 CFR 3. ATLANTIC COAST Commending Officer, Marine Safety Office, PO Box JOB, Portland, ME 04112-0108 Commanding Officer, Marine Safety Office, 447 Commercial St., Boston, MA 02109-1096 Commanding Officer, Marine Safety Office, John O'Pastore Federal Bldg., Providence, RI 02903-1790 Commanding Officer, Marine Inspection Office, Battery Parley Bldg., New York, NY 10004-1466 Commanding Officer, Harine Inspection Office, 801 Custom House, Philadelphia, PA 19106-2974 Commanding Officer, Marine Safety Office, Customhouse, Baltimore, MD 21202-4022 Com - ndin8 Officer, Marine Safety Office, Norfolk Federal Bldg., 200 Granby May, Norfolk, VA 23510-1888 Commanding Officer, Marine Safety Office, Suite 500, 272 North Front St., Wilmington, NC 28401-3907 Commanding Officer, Marine Safety Office, P.O. Box 724, 196 Tradd Street, Charleston, SC 29401-1899 91

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Encl. (4) to N1IIC Addresses (con~c'd) Commending Officer, Marine Safety Office, PO Box 8191, Sabbath, GA 31402-8191 Commanding Officer, brine Safety Office, Room 213, 2831 Talleyrand Ave., Jacksonville, PI. 32206-3497 Compendia Officer, Marine Safety Office, Justice Bldg., 155 South Miami Are., Miami, E1 33130-1609 Commanding Officer, Marine Safety Office, PO Box S-3666, Old San Juan, PR 00904-3666 GULF OF MEXICO Commanding Officer, Marine Safety Office, 155 Columbia Drive, Tampa, FL 33606-3598 Co~ndlug Officer, Marine Safety Office, 1900 Firat Nat'1 Bank Bltg., PO Box 2924, Mobile, AL 36652-2924 Commanding Officer, Marine Safety Office, 1440 Canal Street, New Orleans, LA 70112-7116 Commanding Officer, Marine Safety Office, 800 David Dr. - Rm. 232, Morgan City, LA 70380-1304 Commanding Officer, Marine Safety Office, Federal Bl~g., 2875 75th St. & Hwy. 69, Port Arthur, TO 77640-2099 Commanding Officer, Marine Safety Office, Post Office BIdg., 601 Rosenberg, Galveston, TO 77S50-1705 Commending Officer, Marine Inspection Office, 8876 Gulf Freeway, Suite 210, Houston, TO 77017-6595 Commanding Officer, Marine Safety Office, PO Box 1621, Corpus Christi, 1~ 78403-1621 GREAT LARKS , Commanding Officer, Marine Safety Office, Rm 1111, Federal Bldg., lllW. Huron St., Buffalo, NY 14202-2395 Commanding Officer, Marine Safety Office, 1055 East Nintl. Cleveland, OR 4414-1092 92 ~ St.,

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Encl. (4) to NVIC Addresses (cont'd) Commanding Officer, Harlne Safety Office, Federal Bldg., Room 101, 234 Suit St., Toledo, ON 43604-1590 Corroding Officer, Marine Safety Office, 2660 East Atwa~cer Street, De~croie, HI 48207-4413 Commanding Officer, Marine Inspection Office, Municipal Bldg., St. Ignace, ~ 49781-1425 Commanding Officer, Marine Safety Office, Card Park, Duluth, MN S5802-2352 Commanding Officer, Marine Inspection Office, 360 I`ouisiana St., Sturgeon Bay, ~ 54235-2479 Commanding Officer, Marine Safety Office, 2420 S. Lincoln Memorial Dr., Milwaukee, W! 53207-1997 Commanding Officer, Marine Safety Office, 610 South Ca~1 Street, Chicago, IL 60607-4573 INI~ND REARS Com - ndlag Offlcer, Marine Safety Office, Suite 700/Koss~an Bldg, Forbes Ave ~ S.c~wis St, Pittsburgh, PA 15222-1371 Commanding Officer, Marine Safety Office, PO Box 2412, Huntl~gton, W? 25725-2412 Commending Offlcer, thrice Saint, Office, 600 Federal Place, Room 360, I`ouis~rille, RY 40202-2230 Commanding Officer, thrice Safety Office, PO 80s 7509, Paducah, 1~! 42002-7509 Commanding Officer, Marine Safety Office, PO Box D~17, St. Louis, MO 63188~0017 Commending Officer, brine Safety Office, Suite 1134, 100 N. Main Bldg., Memphis, 111 38103-5014 PACIFIC COAST Commanding Officer, 2larine Safety Office, 2710 Harbor Drives North, San Diego, CA 92101-1064 93