Commanding Officer United States Coast Guard Marine Safety Center

2100 2nd St. SW Stop 7102 Washington, DC 20593-7102 Staff Symbol: MSC-2 Phone: (202) 475-3402 Fax: (202) 475-3920 Email: msc@uscg.mil

16710/P016046/naw Serial: E1-1205110 December 26, 2012 Bay Engineering, Inc. Attn: Mr. Darrell Askins 253 North First Avenue Sturgeon Bay, WI 54235 Subj: PAUL R. TREGURTHA, O.N. 631668 American Shipbuilding Co. Hull No. 909 999.6 x 105.2 x 54.1 Vessel Type (I) Natural Gas Fuel Ship Arrangement Concept Review Ref: (a) Commandant (CG-521) Policy Letter No. 01-12 Equivalency Determination Design Criteria for Natural Gas Fuel Systems (b) Interim Guidelines on Safety for Natural Gas-Fuelled Engine Installations in Ships IMO Resolution MSC.285(86)

Dear Mr. Askins: We reviewed the questions contained in your letter dated November 27, 2012 using references (a) and (b). The following comments are provided: 1. We understand the proposed LNG tank will be vertically mounted behind the house on the transom of the vessel. The tank or tanks must be located at least 760 mm from the ships sides and transom as per Chapter 2.8.3.2 of reference (b). This is measured from the edge of the transom or side to the tank. In addition, extending the transom by use of a bolster to meet the minimum required separation distance would be acceptable. In this case, the ABS requirement for 800 mm of separation distance will supersede the Coast Guard requirement. 2. You are correct that the bulkhead, including any windows or doors, of the superstructure which faces the LNG tank will have to meet A-60 structural fire protection requirements. 3. In addition, a water-spray system protecting the LNG tank and the side of the superstructure which faces the LNG tank must be provided as per section 3.3.2 of reference (a). 4. Since the LNG tank is mounted on an open deck, air locks will not be required.

16710/P016046/naw Serial: E1-1205110 December 26, 2012 Subj: PAUL R. TREGURTHA, O.N. 631668 Natural Gas Fuel Ship Arrangement Concept Review Our Project Number for this vessel is P016046. Ensure that future correspondence includes the Project Number and Official Number that appear in the subject line. Contact Lieutenant Nick Woessner at (202) 475-3374 with questions concerning our review. Sincerely,

S. J. KELLY Commander, U. S. Coast Guard Chief, Engineering Division By direction Copy: Coast Guard Headquarters, Office of Design and Engineering Standards (CG-ENG) Coast Guard Headquarters, Office of Commercial Vessel Compliance (CG-CVC) Coast Guard Headquarters, Office of Traveling Inspectors (CG-5P-TI) Coast Guard Liquefied Natural Gas Center of Expertise Mr. William Lind, Director, Technology and Business Development, ABS Americas