
1
MEMO
TO:
Record
FROM:
Kelly
Meadows,
Tetra
Tech
DATE:
8/
25/
2003
RE:
Diver
safety
issues
relating
to
the
implementation
of
316(
b)
at
marine
intakes
Introduction
Tetra
Tech
was
directed
by
EPA
to
investigate
the
issue
of
diver
safety
as
it
related
to
the
possible
implementation
of
316(
b)
at
marine
intakes,
such
as
oil
and
gas
platforms.
Industry
commenters
had
raised
the
issue
to
EPA,
noting
that
commercial
diving
is
inherently
a
very
dangerous
activity
and
that
EPA
should
consider
the
risks
and
costs
associated
with
such
activities.

Tetra
Tech's
findings
suggest
that
while
commercial
diving
is
a
dangerous
activity,
properly
executed
dives
should
not
result
in
any
additional
risk
to
human
health
or
worker
safety.
These
findings,
however,
do
not
reflect
upon
the
potentially
extensive
safety
measures
in
place
that
may
have
a
significant
effect
on
the
cost
of
any
commercial
diving
operations
as
a
result
of
the
rule.

Information
Gathering
Tetra
Tech's
efforts
focused
primarily
on
internet
searches
and
phone
calls.
The
first
resource
was
the
website
for
the
US
Navy's
"
Seabees,"
a
branch
comprised
of
naval
engineers.
After
an
email,
I
was
contacted
by
Phil
Vitale
(
7/
10/
2003),
who
referred
me
to
the
Corps
of
Engineers
safety
regulations.
He
stated
that
Navy
divers
usually
followed
these
regulations
in
performing
dives,
as
opposed
to
similar
OSHA
regulations,
as
the
Navy's
dive
tables
are
more
conservative
than
OSHA.
However,
he
stated
that
qualified
divers
don't
tend
to
have
problems
performing
complex
dives,
as
long
as
the
dive
team
is
properly
trained,
equipped,
and
staffed.
He
also
agreed
that
deeper
dives
would
be
more
expensive.
He
then
referred
me
to
the
Association
of
Diving
Contractors
(
ADC),
which
represents
certified
commercial
dive
companies
across
the
U.
S.

I
spoke
to
Ross
Saxon,
the
executive
director
of
ADC
(
7/
10/
2003).
He
stated
that
it
would
be
very
difficult
to
approximate
dive
times,
the
number
of
divers
required,
and
other
factors
without
knowing
more
specific
information,
but
did
offer
that
many
intake
pipes
already
have
screens.
ADC
does
keep
some
statistics
on
diver
safety
issues,
but
these
are
not
for
publication.
In
general,
Mr.
Saxon
expressed
great
concern
over
the
feasibility
of
performing
modifications
of
water
intakes,
as
the
procedure
would
be
very
complex
and
offer
minimal
benefits
in
return.

Following
some
further
websurfing
at
OSHA's
website,
I
discovered
that
OSHA
is
presently
revising
its
safety
regulations
governing
commercial
dive
operations.
I
was
contacted
by
Rob
Bell
(
7/
29/
2003),
who
stated
that
changes
in
pressure
are
the
greatest
danger
to
dive
teams
(
e.
g.,
2
suction
at
a
pipe,
water
flowing
over
a
dam,
etc.).
He
also
stated
that
dive
teams
are
to
be
comprised
of
a
minimum
of
three
divers.
He
referred
me
to
another
contact
at
the
Department
of
Labor
(
DOL)
involved
with
maritime
compliance.

I
then
spoke
to
Steve
Butler
(
7/
29/
2003)
at
DOL.
He
stated
that
OSHA's
regulations
are
very
thorough
and
cover
all
portions
of
a
dive
operation.
He
was
also
able
to
provide
some
generic
statistics
regarding
diver
safety
and
noted
that
the
leading
cause
of
injury
is
due
to
non­
compliant
dives.
There
have
been
approximately
100
deaths
during
commercial
dives
in
the
U.
S.
in
the
past
10+
years,
out
of
a
population
of
about
7000
commercial
divers.
About
half
of
those
deaths
were
due
to
unsafe
or
non­
complaint
dives
or
due
to
poor
training.
Of
the
remaining
dives,
about
2/
3
of
the
fatalities
were
due
to
pressure
differentials.

Mr.
Butler
went
on
to
state
that
the
current
revisions
that
OSHA
is
seeking
(
with
the
support
of
ADC)
would
be
more
conservative
and
require
additional
safety
measures.
For
example,
dives
near
a
suction
would
enact
a
safety
plan
with
a
full
shutdown
of
the
source
of
the
suction.
He
also
expressed
concern
that
any
regulations
proposed
by
EPA
should
not
override
or
conflict
with
safety
regulations
from
OSHA.
He
requested
that
OSHA
be
consulted
in
the
regulatory
development
process
if
EPA
decides
to
require
modifications
to
marine
intakes.
I
sent
him
an
email
with
some
background
information,
the
schedule
for
the
rulemaking,
and
a
link
to
the
316(
b)
homepage.

I
also
sent
all
of
this
information
to
our
costing
engineers,
so
that
they
could
cross­
check
the
personnel
requirements
and
account
for
any
safety
concerns
in
the
cost
estimates.

Conclusions
Based
on
the
above
information,
there
is
no
reason
to
suspect
that
a
properly
executed
dive
to
modify
an
intake
structure
will
create
any
additional
risk
to
human
health
or
worker
safety.
Presumably,
EPA
would
direct
facilities
to
fully
adhere
to
any
and
all
safety
regulations
when
performing
any
modifications.
EPA
and
Tetra
Tech
should,
however,
ensure
that
a
properly
equipped
and
staffed
dive
team
is
included
in
its
costs
estimates.
