ADCI and OSHA establish a Delta P Task Force
In August of 2020, the ADCI and OSHA established a Delta P Task Force to address the 5 Delta P-related fatalities at power-generating facilities over a 25-month period. The task force will look at ways to educate facility operators of power-generating facilities that utilize divers for inspection, maintenance, and repairs. The task force will produce ways to:
- Educate clients/end-users on who should perform underwater work on their facilities;
- Propose operational recommendations on best industry practices for performing underwater inspections, maintenance and repairs;
- Propose what actions (surveys and revisions if needed) should be taken by operators to ensure that blueprints of the facilities accurately note all intakes and outfalls.
The task force is comprised of three diving contractors that specialize in working at these types of facilities, ADCI, OSHA, one end-user and one trade association for facility operators (American Electric Power, Institute of Nuclear Power Operations), U.S. Army Corps of Engineers, and a subject matter expert on sonar and ROV use at these types of facilities.
To date, the task force has developed a contractor’s checklist for operations at power-generating facilities, an OSHA informational notice to contractors and facility operators, development of a white paper on “Addressing Water Intakes,” development of a list of contractor tasks that may involve Delta P (list of possible tasks that a diving company may be contracted to complete), assembled a library of JHAs and safety documents from diving companies to be used as examples, development of technology briefings on detection and statements on domain awareness, and development of a marketing plan and media updates for deliverables to industry.
The task force has also outlined contractor tasks – areas that may involve differential pressure. The list is not specific to just power-generating facilities:
- Spillways, water towers, reservoirs, and dams
- Pipes, pipelines, hoses
- Water intakes, gates, valves, and screens
- Cracks / voids in dams, pipes or hoses
- Desilting, jetting, airlifting, and diver dredging
- Cofferdam dewatering and sealing
- Pump bay work
- Navigation locks and dams
- Hydro-electric, coal, and nuclear plants
- Stop logs, weirs, and bulkheads
- Clear wells
- Ship intakes, sea chests, thrusters, and propellers
- Dewatering, dredging, and pumping equipment
In looking at the summary of issues for diving contractors, these problems and solutions were uncovered: (see above).
The summary of issues for facility owners/operators were: (above)
The task force will initially look to address Delta P issues at power-generating facilities, since this is where the bubble of fatalities is located. Once this has been thoroughly addressed, the task force will venture into other areas of Delta P which pose a hazard to divers, such as ship husbandry and work on offshore installations.
Delta P Task Force Participants
David Dodd, CONSOR Engineers (Chairman)
Don Dryden, Dryden Diving
Randy Jacobs, J.F. Brennan
Phil Newsum, ADCI
Eric Kampert, OSHA
Kyra Richter, AEP
Neal McKenny, INPO
Albert Wong, USACE
Mark Klein, Hudson Engineers
Recommendations and deliverables from the task force will likely lead to the development of a new subsection on Guidelines for Working at Power-Generating Facilities in the International Consensus Standards for Commercial Diving and Underwater Operations, as well as possible revisions to the current subsection on Differential Pressure (Delta P).
Finally, I want to thank Mr. Eric Kampert (Fed. OSHA Compliance and Enforcement – Commercial Diving) for his contributions to the task force and information cited in this article. I want to also thank the task force Chairman, Mr. David Dodd for keeping the group on course. All task force members are passionate about making a difference with diver safety and the issue of Delta P. As the task force continues its work, I will keep industry appraised of all new developments and deliverables.