wv AQegnpe REPOSITORY COLLECTION ) ne] Pas 2 Qo[AV VLS | GOL Fee OLR 4 Puy ae COMMENT ON DR. PRATT'S COMPLAINTS ici WREDICALG PREERAM No useful purpose will be served by an exhaustive point by point discussion of Dr. Pratt's complaints. However, a summary of where we stand on the entire problem area would be helpful. Such a summary follows: 1. <All medical objectives of the three.BNL medical survey trips in 1979 were accomplished in a satisfactory manner. This would seem to be a central consideration in reviewing what has transpired. However, this fact seems to have been lost under a mountain of trivia. 2. <All complaints that Dr. Pratt levied at Liktanur II, however trivial, have been rectified. Most had already been corrected by the time his trip reports were issued. The only exception to this statement is the adequacy of berthing space. Dr. Pratt has (inexplicably) refused PASO's offer to expand the berthing space available by making two 3. (2) more compartments available for berths. Dr. Pratt is adamant that Liktanur II should be classified as a "passenger carrying vessel" rather than as a “Oceanographic Research Vessel". If he is successful in having the U.S.Coast Guard agree with him that the classification of "passenger carrying vessel" applies to Liktanur II, then the BNL medical program as well as all other DOE programs which use Liktanur II are finished unless a Suitable replacement vessel can be located. A replacement vessel is neither economically nor operationally feasible in the near term. The subject of vessel classification is an extremely technical and complicated matter. Even the U.S. Coast Guard has difficulty in interpreting the CFR which pertains to the subject (CFR 46). it is possible, that DOE can obtain an exemption from the Coast Guard for Liktanur II on the basis that it is de facto if not dejure a "public vessel". CFR 46, Sub part 70.05-1 deals with the application of CFR 46 to vessels. It states "except as follows": ‘any vessel with title vested in the United States and which is used for public purposes’. I recognize that title to Liktanur II does not vest in the U.S., but possibly because of our total control of the vessel an exception can be granted. I am certain that Dr. Pratt will oppose such action, regardless of the alternative consequences. Page 1 of 13 ENCLOSURE I