VES-13-18-RR:IT:EC 112444 BEW/PH
Chief, Liquidation Section
U. S. Customs Service
P. O. Box 2450
San Francisco, California 94126
RE: Vessel Repair; Application for relief; M/V PRESIDENT
LINCOLN, Voyage 87; Entry No. C27-0061057-2; Modifications;
Inspection; Staging; Cleaning; Survey; Air Scavenger Space;
Maintenance; Timeliness; 19 CFR 4.14(d); 19 U.S.C. 1466
Dear Sir:
This letter is in response to your memorandum dated August 25,
1992, which forwarded for our review an application for relief
from duties relating to the above-referenced vessel repair entry.
Our ruling follows.
FACTS:
The vessel PRESIDENT LINCOLN, a United States-flag vessel owned
and operated by American President Lines (APL) of Oakland,
California, arrived at the port of San Pedro, California, on
November 26, 1991. A vessel repair entry was timely filed
(November 27, 1991, according to Customs records). According to
the vessel repair entry and other documents in the file, the
vessel underwent certain work at the China Shipbuilding
Corporation shipyard in Kaohsiung, Taiwan.
The vessel operator requested a 30 day extension to file an
application for relief (see 19 CFR 4.14(d)) and the extension was
granted until March 27, 1992. On February 6, 1992, the vessel
operator submitted an application for remission of duty (dated
February 15, 1992) on the cleaning of scavenger spaces. On March
26, 1992, the vessel operator submitted an application for
remission of duty (dated the same date) on other invoice items
listed below (except item 530)). On April 7, 1992, the vessel
operator submitted an application for remission of duty (dated
April 2, 1992), stated to "supplement" the March 26, 1992,
application, for item 530 (bow thruster space piping
modification).
In the above-referenced applications, the applicant identified
certain items as non-dutiable modification work, and claimed that
certain other items were non-dutiable as consisting of staging,
inspection, or cleaning. You requested that we review certain
items in the entry and provide you with our determination as to
the dutiability of those items. Those items, with descriptions
and other information from the invoice and other materials in the
file, are listed below:
The following items have been referred for our review.
Item no. Invoice description, etc.
509 Bow thruster survey. The portions of this
item in controversy are stated to consist of:
(1) erection of and removal of staging; and
(2) opening and closing blade hatch for
working. The remaining portions in this item
are conceded to be dutiable. The time,
material, and cost for item (1) (staging) are
segregated from time, material, and costs for
the other items, but the remaining time,
material, and costs are not segregated.
According to ABS Survey KS 7365-A, the
thrusters were cleaned as necessary, examined
and considered satisfactory. There is no
indication in the ABS Surveys that the survey
was performed to ascertain the extent of
damages.
509.3 Bow thruster tunnel bar removal. This item is
stated to consist of the removal of bow
thruster tunnel bars from tunnel entrances,
the grounding of tunnel and hull surfaces
flush and smooth, and the carrying out of a
dye check for ABS inspection. This item is
not referred to in the pertinent ABS Reports
(KS 7365-A and KS 7365-B).
514 Installation of lashing padeyes. This item is
stated to consist of cropping D-rings and
installation of new solid lashing padeyes as
per drawing 8616512-05-30 Alt. 2 (supplied
with the Application). The padeyes are stated
to change the container lashing system to
increase the allowable stack weight of on-deck
containers, improve operating efficiency, and
reduce maintenance and repair of deck/pedestal
fittings. This item is referred to in ABS
Report KS 7365-G as "Installation of Lashing
Padeyes." In item 514 and many other items in
the invoice, it is stated that "[d]estroied
area were disc-grinded or sandsweeped then
applied the coats as the specification."
515 Removal and replacement of hatch covers. This
item is stated to consist of the handling and
crane service for inspection of the hatch
covers. Included in this item are the
arrangement of blocks for each hatch cover,
the provision of riggers and crane to remove
the hatch covers, and the welding of temporary
"lifting pieces" for three of the hatch
covers. ABS Report KS 7365-G reports on
"hatch covers and hatch coamings modification
and repair ..."
515.1 Hatch coamings. The portions of this item in
controversy ("modification of longitudinal
hatch coaming at expansion joint" and
"longitudinal hatch coaming repaired at row
12, aft (P/S)") are stated to consist of the
modification of the hatch coaming as per
drawing HEC8803-4 in the first case and the
cropping and renewal of the longitudinal hatch
coaming top plate as per drawing HEC9106-3 in
the second case. In the case of row 12, this
work is described as repair in ABS Report KS
7365-G (hatch covers and hatch coamings
modification and repair survey) (this ABS
report distinguishes between repairs and
modifications). In the same ABS Report, we
could find no reference to the work at the
expansion joint.
515.2 Hatch covers. The portions of this item in
controversy ((1) modification of bearing pads,
(2) modification of cover no. 8 (referred to
in the invoice as "hatch cover #8(P/S)") in
way of 20 foot stowage outboard, (3)
modification of hatch covers 2 - 9 starboard
of sliding base socket, (4) modification of
hatch covers 10 and 11, (5) modifications to
hatch cover bearing pads) are stated to
consist of modifications for which drawings
are supplied ((1) - drawing 9106-5, (2) -
drawing 9106-7, (3) - drawing 9106-6, (4) -
drawing 9106-2) and, in the case of (5),
modifications to reinforce the hatch cover
bearing pad with additional "stifference"
behind the bearing pad. In the case of the
bearing pads the ABS report describing this
work (ABS Report KS 7365-G) states that "[a]ll
bearing pads were re-positioned at this time
on hatch cover Nos. 1 [through] 9 to take over
existing worn down ones". In the case of
cover no. 8, this work is described in ABS
Report KS 7365-G as modifications (adding two
new girders) and there is no reference to
repairs. In the case of covers 2 - 9 (sliding
base sockets), this work is described in ABS
Report KS 7365-G as modifications
(installation of sliding twistlock
foundations) and there is no reference to
repairs. In the case of hatch cover 10 and
11, this work is described in ABS Report KS
7365-G as "Modifications/Repairs" (as noted
above, the ABS Report distinguishes between
modifications and repairs). In the case of
the reinforcement of the hatch cover bearing
pads, we could find no reference in the ABS
Report.
516 Tailshaft survey. The portions of this item
in controversy are stated to consist of (1)
erection and removal of staging and various
inspections; and (2) removal and
reinstallation of the rope guard, welding and
cutting lifting pieces for propeller removal,
disconnection of the propeller, certain tests
and checks, force fitting the propeller,
cleaning certain tanks, and other work (the
applicant concedes that the portion of this
item consisting of the grinding smooth of an
area of pitting and/or corrosion on the
tailshaft is dutiable, as repairs). There is
no indication in the ABS Survey (KS 7365-B)
that the survey was performed to ascertain the
extent of damages.
519 Modification at bulkhead at frame Nos. 59 &
61. Both this item and item 519.1 (below) are
stated to be "modification[s] ... as a
consequence of failures arising from a basic
design deficiency[;] [the initial design is
stated to have] lacked the fundamental
requirement of structural continuity ..." In
regard to this item and item 519.1, there are
references in the ABS Survey Reports to
repairs which appear to relate to these items
(Report KS 7365-G refers to "Repairs and
Modifications of Longitudinal Bulkhead
Transition Between Fr. 60 and Transverse
Bulkhead at Fr. 65; Report KS 7365-D notes
Report KS 7365-G for the detail of "repairs"
for transverse watertight bulkhead at fr. 65;
and there are references to the "buckled
transverse floor in way at fr. 61" in Report
KS 7365).
519.1 Modification at bulkhead at frame Nos. 61 &
65. See item 519, above.
520 Fuel oil tank cleaning. This item is stated
to include the cleaning of the tanks to be
safe for men and surveys (disposal of oily
water or dead oil, removal of sludge, and
supplying of chemical cleaner). The ABS
Report for this item (Report KS 7365-D) refers
to repairs to the following tanks among the
tanks enumerated in this item: fuel oil wing
tank 3A (starboard), fuel oil wing tank 1
(starboard), and fuel oil wing tank 1 (port).
Report KS 7365-D refers to Report KS 7365-F
for details of the repairs. There is no
reference to fuel oil wing tank 3A in Report
KS 7365-F, but the report describes the
finding of fractures and the repair thereof in
regard to fuel oil tank no. 1 on the port and
starboard side (the frames for these tanks
indicate that they are the same as cited
above). Time, material, and costs are not
segregated in this item.
521 Relocate aft hose crane. This item is stated
to consist of cutting off and removal of
table, locker, and support, draining and
renewal of hydraulic oil, removal and
installation of newly made handrail, filling
hydraulic oil (supplied by yard), and erection
and removal of staging (only the last portion
is segregated). The reason given for the
relocation is "to improve the accessibility,
reliability and to extend the life of the
equipment [as] [i]t was an initial design
deficiency to place such equipment in an area
exposed to weather and exhaust stack gasses."
We could find no reference related to this
item in the ABS Reports in the file.
522 Stores & hose crane. This item is stated to
consist of the replacement of the rubber hoses
on stores and hose cranes with stainless steel
tubing and fittings. We could find no
reference related to this item in the ABS
Reports in the file.
525 Ballast tank inspection & survey. This item
is stated to consist of opening up bolted
manhole covers for the tanks, testing oxygen
contents, furnishing temporary lighting and
ventilator for one of the tanks, and providing
qualified inspectors to inspect the tanks.
The ABS Report for this item (Report KS 7365-D) refers to repairs to the following tanks
among the tanks enumerated in this item: deep
water ballast tanks 6B (port and starboard).
Report KS 7365-D refers to Report KS 7365 for
details of the repairs. The latter report
refers to outstanding recommendation in a
November 8, 1989, report for this vessel and
describes the permanent "repairs" made to the
vessel "at this time." Time, material, and
costs are not segregated in this item.
525.1 Ballast tank inspection. The portions of this
item in controversy ((1), (2), and (3)) are
stated to consist of cleaning out, (disposing
of oily water, removal of sludge, and
supplying chemical cleaner, and other cleaning
operations) as well as replacement of broken
and missing cover studs and bolts (No. 6A D.B.
tank starboard) and replacement of new
grommets (66 pieces supplied by the yard).
The ABS Report for this item (Report KS 7365-D) refers to repairs to deep upper fuel oil
tank No. 2 (port) among the tanks enumerated
in this item. Report KS 7365-D refers to
Report KS 7365-F for details of the repairs.
The latter report states that the tank top
plating for that tank "was found holed and
heavily wasted and was partly cropped and
renewed ...". Time, material, and costs are
not segregated in this item.
530 Bow thruster space piping. This item is
stated to consist of rerouting bilge piping.
We could find no reference related to this
item in the ABS Reports.
531 Anchor chain & chain locker. The portions of
this item in controversy ((1) and (3)) are
stated to consist of (portion (1)) ranging out
anchor chains for examination, washing down
chain to removal scale and foreign materials
to allow for examination, calibration of
chains, restowing chains, and arranging crane
to chains; and (portion (3)) opening manhole
cover of chain lockers, cleaning chain
lockers, mud removal, and closing manhole
cover with new gaskets. The applicant
concedes that portion (2) of this item is
dutiable. ABS Reports KS 7365-A and KS 7365-D
pertain to this item. There is no indication
in the Reports that the survey was performed
to ascertain the extent of damages.
532 Main engine sump survey. This item is stated
to consist of opening manhole covers, cleaning
and drying all engine parts and sump interior
(removal and disposal of dead oil, removal of
sludge, supplying chemical cleaner) and
closing manhole covers after survey. The
foregoing is consistent with the ABS Report
pertaining to this item (Report KS 7365-E).
There is no indication in the Report that the
survey was performed to ascertain the extent
of damages.
556 Salt water piping. This item is stated to
consist of gauging and recording all overboard
pipes and all pipes below floor plating in
narrow spaces and tank. In regard to this
item and item 561 (below), the only reference
we could find related to these items in the
ABS reports was for the survey of "[a]ll
openings to the sea ..." in Report KS 7365-E.
No repairs are referred to in this regard in
that Report.
561 No. 1, 2, & 3 sumps. This item is stated to
consist of opening and closing manhole covers,
cleaning (removal of sludge and supplying
chemical cleaner) the tank to be safe for men
and surveys.
8 Cleaning air scavenger space. This item is
stated to consist of opening main engine
scavenger space access doors for complete
cleaning, removal of all oily deposits and
waste material, and (upon completion of
inspection by vessel engineers), closing up of
all access doors. Also included are crating,
packing and shipment, tool rental, fees or
taxes, transportation of materials and men,
meals of labor crews, and materials and
equipment (rags and PVC bags).
ISSUES:
Whether the work described in the FACTS portion of this ruling is
dutiable under the vessel repair statute (19 U.S.C. 1466).
LAW AND ANALYSIS:
Initially we note, in regard to the timeliness of the application
for relief in this matter, that the Customs Regulations governing
such applications for relief (see 19 CFR 4.14(d)(1)(ii)), issued
under 19 U.S.C. 1466, require the application for relief, with
supporting evidence, to be filed within 90 days (with authority
for an extension of 30 additional days) from the first arrival of
the vessel. As stated above, an extension of the 90-day period
was granted until March 27, 1992. Therefore, the application for
relief (including the February 15 and March 26, 1992, letters and
materials submitted with them) was timely. However, since the
cited Customs Regulation requires the application for relief,
with supporting evidence, to be filed within the time period, and
since there is no provision for supplementing the application for
relief after expiration of the time period in regard to an issue
not previously raised, the April 2, 1992, letter (filed April 7,
1992) was untimely and is not being considered (see ruling HQ
111688).
Under 19 U.S.C. 1466:
The equipments, or any part thereof ... purchased for, or
the repair parts or materials to be used, or the expenses of
repairs made in a foreign country upon a vessel documented
under the laws of the United States to engage in the foreign
or coasting trade, or a vessel intended to be employed in
such trade, shall, on the first arrival of such vessel in
any port of the United States, be liable to entry and the
payment of an ad valorem duty of 50 per centum on the cost
thereof in such foreign country.
Section 1466 also provides, generally, for remission or refund of
such duties if it is established that the purchases or repairs
were compelled by stress of weather or other casualty, that the
equipments or repairs were manufactured or produced in the United
States and the labor necessary to install them or make the
repairs was performed by United States residents or members of
the regular crew of the vessel, or that the equipments or
materials or labor were used as dunnage for cargo, or similar
purposes. In addition, section 1466 provides for the exemption
from vessel repair duties for certain materials with respect to a
vessel which arrives in a United States port two years or more
after its last departure from a United States port, and for
certain materials for LASH (Lighter Aboard Ship) barges, or
certain spare parts or materials subject to various specified
conditions. The Customs Regulations issued under section 1466
are found in 19 CFR 4.14.
The Customs Service has issued many rulings applying and
interpreting 19 U.S.C. 1466. See, e.g., HQ 112851, dated March
22, 1996. Ruling HQ 112851, includes statements of the general
rules for the determination of what are modifications to the hull
and fittings of a vessel (held not to be dutiable under section
1466), and the dutiability under section 1466 of the cost of
inspections or surveys done by the American Bureau of Shipping
(ABS). Generally, qualifying modifications to the hull and
fittings of a vessel involve a permanent incorporation into the
hull or superstructure of a vessel, provide an improvement or
enhancement in operation or efficiency of the vessel, and may not
involve the replacement of a current part, fitting, or structure
which is not in good working order.
In regard to surveys or inspections, the general rule is that a
survey undertaken to meet the specific requirements of a
governmental entity, classification society, or insurance carrier
is not dutiable even when dutiable repairs are effected as a
result of a survey. When an inspection or survey is conducted to
ascertain the extent of damages sustained or whether repairs are
necessary, the costs are dutiable as part of the repairs which
are accomplished. The LAW AND ANALYSIS portion of ruling HQ
112851 is incorporated by reference into this ruling, in regard
to its description of the interpretation of these issues (i.e.,
the dutiability of modifications to the hull and fittings of a
vessel and surveys or inspections).
Insofar as cleaning operations are concerned, Customs has held
that cleaning operations which remove rust and deterioration or
worn parts, and which are a necessary factor in the effective
restoration of a vessel to its former state of preservation,
constitute vessel repairs. Analogous to Customs position
regarding the dutiability of surveys, Customs has long held that
the cost of cleaning is not dutiable unless it is performed as
part of, in preparation for, or in conjunction with dutiable
repairs or is an integral part of the overall maintenance of the
vessel (see C.I.E.'s 18/48; 125/48; 910/59; 820/60; 51/61;
569/62; and 698/62).
Also pertinent in this case are Customs positions regarding the
segregation of dutiable and non-dutiable costs and the
dutiability of accessing work. Pursuant to C.I.E. 1325/58 and
C.I.E. 565/55, duties may not be remitted where the invoice does
not segregate the dutiable costs from the non-dutiable costs.
Where accessing work is integral to dutiable repairs, the
accessing work is also dutiable (see HQ ruling 108366).
(As for the possible applicability of the decision in Texaco
Marine Services, Inc. v. United States, 44 F. 3d 1539 (Fed. Cir.
1994), to surveys or inspections (see above), we note that,
except for post-repair cleaning and protective coverings, the
decision in that case will not apply to vessel repair entries
filed prior to the date of that decision (December 29, 1994).
Since the vessel repair entry under consideration was filed prior
to that date, Texaco would not affect Customs position regarding
surveys in the entry under consideration.)
The applicant claims that items 509.3, 514, 515.1 (portions
only), 515.2 (portions only), 519, 519.1, 521, 522, and 530 (as
noted, the application for item 530 was untimely; no relief may
be granted in regard to this item) are non-dutiable, as
modifications to the hull and fittings of the vessel. Item 509.3
is non-dutiable on that basis (see rulings 111881 and 111884;
contrast to ruling 112864, in which the same work by the same
shipyard on the same class of vessel was held dutiable because
the work included a welding build-up of corroded areas, as
described in an invoice from the same shipyard as is involved in
this case). Item 514 is non-dutiable on the same basis (see
rulings 112454 (invoice from same shipyard as in this case
relating to the same work on the same class of vessel) and
112851) (in the case of the work in this item and other items
described as "[d]estroied area were disc-grinded or sandsweeped
then applied the coats as the specification", we assume that this
work consists of restoring the area where the modifications were
made to its original condition so that it is not dutiable as
repairs (see C.I.E. 1043/60, see also, e.g., rulings 112851 and
112454)). The portion of item 515.1 consisting of work on the
"longitudinal hatch coaming at expansion joint" is non-dutiable
as a modification (see ruling 112454 in which the same work on
the same class of vessel, described in an invoice from the same
shipyard as is involved in this case, was held non-dutiable).
The portion of item 515.1 consisting of "longitudinal hatch
coaming repaired at row 12 ..." is dutiable as a repair (as
described in the invoice and ABS Report KS 7365-G).
The portions of item 515.2 under consideration are dutiable or
non-dutiable as follows. The portion of item 515.2 consisting of
modification of bearing pads is dutiable (note that ABS Report
KS-7365-G describes the existing pads as "worn down" (see
discussion of modifications in ruling HQ 112851 - qualifying
modifications may not involve the replacement of a current part,
fitting, or structure which is not in good working order). The
portions of item 515.2 consisting of work on (1) cover no. 8; and
(2) sliding base sockets are nondutiable as modifications (see
ruling HQ 112454 in which similar work on the same class of
vessel by the same shipyard as is involved in this case was held
non-dutiable (note also that the same drawing of the modification
(No. HEC9106-6 is referred to in both case and that the
applicable ABS Report describes the work as modifications)). The
portion of item 515.2 consisting of work on hatch covers 10 and
11 is dutiable, on the basis of the description of the work as
"Modifications/Repairs" in ABS Report KS 7365-G (note that the
ABS report distinguishes between repairs and modifications). The
portion of item 515.2 consisting of reinforcement of the bearing
pads (with the addition of "stifference") is dutiable in the
absence of satisfactory evidence to establish that it is a non-dutiable modification (we note that it is not referred to in the
ABS Reports).
In regard to items 519 and 519.1, as noted in the FACTS portion
of this ruling about these items, references to related areas
and/or work in the referenced ABS Reports appear to indicate that
this work may have involved the modification of structures of the
hull and fittings which were not in good working order. We note
that in ruling HQ 112864 we held similar work to be non-dutiable,
as modifications, on the basis of communication between the
vessel operator and the ABS and the U.S. Coast Guard (the
communication referred to the vessel involved in that case as
well as the M/V PRESIDENT LINCOLN). However, on the basis of the
above-described evidence indicating that this work may have
involved the modification of structures not in good working
order, we must hold this work to be dutiable.
Item 521, consisting of the relocation of the aft hose crane, and
item 522, consisting of the replacement of rubber hoses on stores
and hose cranes with stainless steel tubings and fittings, are
non-dutiable (see ruling HQ 112864; note that the work held non-dutiable in that case was the same work on the same class of
vessel in the same shipyard; note further that there is no
evidence of repairs regarding these items).
The applicant claims that items 509 (portions only), 515, 516
(portions only), 520, 525, 525.1 (portions only), 531 (portions
only), 532, and 561 are non-dutiable, as relating to surveys or
inspections. In the case of item 509, the costs for staging are
segregated from the other costs but the costs for opening and
closing the blade hatch are not segregated from the costs
conceded by the applicant to be dutiable. The costs for staging
are non-dutiable (see C.I.E. 1822/58). The remaining costs are
dutiable (see the rulings cited above in this regard, C.I.E.
1325/58 and C.I.E. 565/55 (failure of an invoice to segregate
dutiable costs from non-dutiable costs) and HQ ruling 108366
(accessing work which is integral to dutiable repairs)). Item
515 is dutiable, as involving unsegregated costs other than
transportation (see rulings HQ 112454, HQ 112864, and HQ 113085,
in which the same work by the same shipyard on the same class of
vessel was held dutiable on the same basis).
In the case of item 516, the costs for staging are segregated
from the other costs and are non-dutiable (see C.I.E. 1822/58).
The costs for removing and reinstalling the rope guard,
disconnecting the propeller, and other work under the second
portion of this item are dutiable, as work performed, in part, in
preparation for repairs in the third portion of this item,
conceded by the applicant to be dutiable (see rulings HQ 112454,
HQ 112864, and HQ 113085, in which the same work by the same
shipyard on the same class of vessel was held dutiable on the
same basis).
Items 520, 525, and 525.1 are dutiable as including unsegregated
preparation for dutiable tank repairs (see ABS Reports describing
such repairs and referred to in the FACTS portion of this ruling)
(see rulings HQ 112454, HQ 112864, and HQ 113085, in which
similar work by the same shipyard on the same class of vessel was
held dutiable on the same basis; see also, above discussion of
cleaning and segregation of dutiable and non-dutiable work). (In
regard to item 525.1, we note that part of the unsegregated costs
in this item were for the replacement of broken and missing cover
studs and bolts, which has been held dutiable (ruling HQ
112894).)
In item 531, the portion of that item including ranging out
anchor chains for examinations and other work is dutiable as
including preparation for repairs conceded to be dutiable by the
applicant (see rulings HQ 112454, HQ 112864, and HQ 113085, in
which the same work by the same shipyard on the same class of
vessel was held dutiable on the same basis; see also, above
discussion of cleaning and segregation of dutiable and non-dutiable work). The portion of item 531 consisting of opening
the manhole cover of the chain lockers and related work is non-dutiable, as not done in conjunction with repair work (see
rulings HQ 112454, HQ 112864, and HQ 113085, in which the same
work by the same shipyard on the same class of vessel was held
non-dutiable on the same basis).
Items 532 and 561 are non-dutiable, as cleaning and preparation
for inspections (see ruling HQ 112454, in which similar work by
the same shipyard on the same class of vessel was held non-dutiable on the same basis; see also, above discussion of
cleaning and surveys or inspections).
In regard to item 556, we note that it is Customs position that
gauging for the purpose of ascertaining whether repairs are
required is considered an integral part of the repair work
performed and is dutiable (ruling HQ 109144). When the result of
gauging is that all readings are satisfactory and no repairs are
connected with the gauging, the cost of gauging is non-dutiable
(see, e.g., rulings HQ 112756, HQ 112222). In this case, the
invoice describes this item as "SALT WATER PIPING, REPAIRS ABS &
USCG INSPECTION" (emphasis added). Since the invoice describes
the work as "repairs" (we note that the invoice describes other
gauging items without referring to repairs (see item 571)) and
since the ABS Reports in the file do not clarify this matter, we
are unable to grant relief for this item. Item 556 is dutiable.
The dutiability of cleaning air scavenger spaces (item 8) has
been thoroughly considered by Customs (see, e.g., rulings HQ
111700 and HQ 112454). It is Customs position that this
operation is the correction (by cleaning) of a deterioration (the
collection of carbon and oil deposits in air scavenger spaces).
Therefore, this operation is a maintenance operation and is
dutiable.
HOLDING:
Among the items about which you requested advice, items 509
(staging), 509.3, 514, 515.1 (longitudinal hatch coaming at
expansion joint), 515.2 (cover no. 8), 515.2 (sliding base
sockets), 516 (staging), 521, 522, 531 (opening manhole cover of
chain lockers and related work), 532, and 561 are NON-DUTIABLE.
Items 509 (portions other than staging), 515, 515.1 (longitudinal
hatch coaming repaired at row 12), 515.2 ("modification" of
bearing pads), 515.2 (hatch covers 10 and 11), 515.2
(reinforcement of bearing pads), 516 (portions other than
staging), 519, 519.1, 520, 525, 525.1, 530, 531 (ranging out
anchor chains for examinations and other work), 556, and 8
(cleaning air scavenger spaces) are DUTIABLE.
Sincerely,
William G. Rosoff Chief
Entry and Carrier Rulings Branch