Ingram Industries, Inc. & Subsidiaries - Page 8




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               The work performed by petitioners is included in the engine            
          manufacturer’s maintenance manuals.  These procedures are routine           
          and recurring and necessary to maintain a towboat in good                   
          operating condition. Petitioners’ towboats were in good working             
          order and operating condition when they were brought in to have             
          the above procedures performed.                                             
               Petitioners perform these procedures after a towboat has               
          operated for 25,000 to 35,000 hours.  A representative towboat is           
          used about 8,000 hours per year so that the procedures are                  
          performed on a towboat every 3 to 4 years.  Petitioners select a            
          towboat for these procedures by utilizing a series of criteria.             
          First, they use a 25,000-hour guideline to screen towboats to               
          determine whether it is time to perform the procedures.  Next,              
          for towboats that have accrued 25,000 to 30,000 hours of use                
          since the last procedure, wear on a piston’s compression ring is            
          measured for each engine and the towboat’s oil consumption                  
          patterns are studied.  Petitioners do not remove a towboat                  
          engine’s power assemblies to measure the ring wear for each of              
          the pistons in the engine.  These measurements are taken by                 
          removing the “air box handhole covers”, positioning the pistons             
          so that they are accessible from the air box handholes, and using           
          a “feeler gauge” to take these measurements.  If the ring wear              
          indicates that procedures involved are appropriate or if a                  
          towboat appears to be consuming more oil than normal, the                   






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Last modified: May 25, 2011