OK, I know someone involved with the operation there. The real problem has to do with 3 sets of rules...
The first set, setup by the DOT says that all people involved in commercial transport must follow all the rules, NO EXCEPTIONS. This followed an incident 15-20 years ago in PA when a tourist railroad managed to run their engine up beyond the fouling point of a switch, and got creamed by an Amtrak train, killing a BUNCH of people. After that, there came a blanket "No exceptions" policy
USCG rules say that operators of boats in the inland naviagable waterways have to have their USCG credentials and TWIC cards
Then comes the question - what is a navigable waterway - and the EPA keeps defining that down, to the point that even some temporary streams are now considered navigable
My friend says that some of the questions on they exam they had fun with. For instance "when passing another boat in the other direction, what do you do?" The test expects something like, slow down, move to starboard side, and keep eyesight on the captain of the other boat
Their answer "There has not been another boat on the waterway in 89 years, mules have 2 speeds - go and stop, and the problem with move to starboard side is there is only ONE tow path - what you actully do is go till the boats are point to point, the Captains meet on the tow path. The upstream boat passes his lines over the downstream boats team, and you bridge around" (by historical practice).
They were asked about lifeboat drills - they pointed out that the boat has no liveboat, that unless they open the lower lock, they are never in more than about 3 ft of water, and the 2 times/year they DO go out the lock, the maximum water depth is something like 4 ft, and the lowest deck is 3.5 ft from the keel, so their lifeboat drill is "folks get their feet wet, until we get there with a ladder"