Provide the following additional information and documentation:
   1. A statement as to whether Tully seeks an interim order for its permanent variance request.  If granted, an interim order will permit Tully to operate under the alternate decompression conditions specified in the variance application, and any other conditions OSHA requires, until OSHA makes a final determination regarding the variance application.
Tully/OHL USA JV is seeking an interim order for its permanent variance request.
   2. Information about Tully's partners in its present joint ventures, including the name, mailing and email addresses, and telephone number for a designated project representative for each partner.  Note that the variance, if granted, will apply only to named employers (including subcontractors); if not named, the variance would not cover any of their employees exposed to the alternate decompression conditions.
   * OHL USA Inc.
780 Third Av. 9[th] Floor
New York, NY-10017
Tel. 646 515 7391 / 212 201 5885

Mr. Luis Alonso
lalonso@ohlusa.com 

   * Ballard Diving & Salvage
               800 NE Tenney Rd
               Suite 110-530
      Vancouver WA 98685
      Tel. 360-518-7905
      
      Mr. Joe Olsen
      JoeOlsen@BallardDiving.com
      
   3. A projected start date for the tunneling work.
Tunneling work has already started on July 25[th] 2012. First hyperbaric work is scheduled by October 16[th].

   4. A projected date by which Tully will be able to provide on-site training to local emergency responders to ensure the availability of trained personnel ready to provide emergency assistance to Tully if needed, including assistance during emergencies related to hyperbaric exposures.
Tully-OHL USA JV has already started that process with FDNY, they are aware of the emergency plans and they are following the performance of the tunnel. Staten Island FDNY has also a rescue team specialized in confined spaces, they know the project and visit it on a regular basis.
Tully-OHL USA JV will have  medical staff on site during hyperbaric inspections.
   5. Information about whether Tully provided project training to compliance safety and health officers in State-Plan states in the past and, if so, whether it will provide such training to OSHA's compliance safety and health officers and national-office personnel, and an approximate date by which it will do so.
We'll notify local compliance office when training takes place by Ballard Diving (Hyperbaric expert) and we'll be glad to invite him to attend.
Monday October 15[th]  Ballard will provide first training on site.
   6. Information regarding the hyperbaric-design features for the tunnel-boring machine and all associated components such as piping, including whether the machine and its components meet ASME standards and specifications or, if not, how the hyperbaric design features of the machine and components compare to ASME standards and specifications.
See attached document from CATERPILLAR.
Sent to Amanda L. Edens (Director of Technical Support and Emergency Management).
   7. Information about whether a Nationally Recognized Testing Laboratory (NRTL) tested and certified the tunnel-boring machine or its components in accordance with OSHA standards such as 29 CFR 1926.403(a) and (b) and 1926.449 and, if so, to which test standards.
See attached document from CATERPILLAR.
Sent to Amanda L. Edens (Director of Technical Support and Emergency Management).
   8. A detailed description of the dual-chamber man locks and how the man locks differ from the requirements contained in 29 CFR 1926.803(g)(2).  Include the number of planned occupants of a man lock, the volume of a man lock, and the estimated cubic feet of airspace allotted per worker in a man lock.
See attached document from CATERPILLAR.
Sent to Amanda L. Edens (Director of Technical Support and Emergency Management).
   9. A description of the precautions Tully will implement to keep intake-ventilation air compressors away from possible sources of contamination, such as truck exhaust.
      * There will be no operation performed in the vicinity of the compressor intakes that will contaminate the compressed air supply.  These prohibited operations would include welding, burning, running unnecessary engines, volatile chemical use or any other processes that could create hazardous atmosphere in the compressed air environment.
      * The air intakes to the air compressors are located and positioned so that exhaust fumes from diesel or gasoline powered engines are not drawn into the intakes.
      * The Plant Manager will check conditions around intakes for all air compressors to ensure that diesel or gasoline engines are not operating in the area prior to and during all hyperbaric interventions.
      * The air compressors are equipped with carbon monoxide (CO) monitors. 

   10. A description of whether Tully will use, transport, and store compressed gases in the tunnel in accordance with OSHA standards such as 29 CFR 1926.800(m) and (n), and how Tully would accomplish these tasks in this setting.
Oxygen will be used during decompression.  This will require oxygen cylinders to be transported into the tunnel.

  1. Only qualified personnel will supervise transport of breathing oxygen within the tunnel.
  2. A suitable maximum quantity of oxygen will be calculated for normal operation and this volume will not be exceeded for storage purposes.
  3. Oxygen cylinders, when not manifolded at a lock position, will be stored in a designated area on the surface in a protected, clearly marked area.
  4. The location of all surface stored oxygen will be clearly marked on a site plan that will be made available to responding Fire and Emergency Services.
  5. Used or partially used cylinders will be stored on site for the minimum time possible.
  6. High Pressure Oxygen will only remain in the tunnel while compressed air exposures are in progress.  It will not be stored in-tunnel under any circumstances.
  7. The oxygen distribution system design is such that no high pressure connection or disconnection takes place in the tunnel.
  8. Oxygen pressure is regulated to the lowest possible pressure as close as possible to the oxygen cylinder.
  9. Defective or leaking cylinders will be isolated, marked and removed from underground areas immediately.
  10. All oxygen cylinders will be properly secured.

   11. A statement as to whether Tully expects methane gas or other potentially flammable atmospheric gases to be present in the tunnel (at concentrations between the lower and upper explosive limits) and, if so, what precautions Tully will take to avoid explosions.
No methane gas or other potencially flammable atmospheric is expected as per Geotechnical Baseline Report or any other information.
TBM also has a gas detector system implemented. 
   12. A description of any hot work Tully will perform in the tunnel, including a description of the hot-work permit system Tully will use (see OSHA's standard regarding permit-required confined spaces at 29 CFR 1910.146(e) for guidance on how to structure a permit system).
No hot work is expected under hyperbaric conditions.
   13. If known, the approximate frequency of planned interventions under hyperbaric conditions that Tully anticipates in this project.
2 Expected interventions. 1 every 3 months.
   14. Your application states that the tunnel "will require compressed air work with only three workers at a time, and only for cutterhead inspection; and limited maintenance and replacement of tools."  However, elsewhere your application states that "the tunnel could be exposed to pressures of up to 58 psi (4 bar) and all equipment and procedures will be designed for the full potential pressure of 58 psi (4 bar)" (both statements come from your cover letter, page 2). Provide clarification on whether Tully will pressurize the entire tunnel or just the cutting face and , if it pressurizes the entire tunnel, clarify if all workers in the tunnel will undergo hyperbaric exposure or just the workers performing interventions in the working chamber.
Only the cutting face (excavation chamber) is pressurized during normal excavation mode.  During maintenance, the motor chamber, located adjacent to the excavation chamber, is also pressurized.  The manlock is then pressurized to permit the passage of the three workers into the pressurized work area.  These three chambers are the only sections of the tunnel boring machine that are pressurized.  The tunnel itself is never pressurized and only the workers performing interventions in the working chamber undergo hyperbaric exposure.
   15. Information regarding the maximum pressure and working time at which employees will conduct interventions under hyperbaric conditions, expressed in both units of bar and psig.
The maximum anticipated pressure is 4 bar (approx. 58 psig). The French Tables permit a working time of 1 hour at that pressure.
   16. Information about whether Tully will be using diving subcontractors other than Ballard Diving & Hyperbaric Services to perform work under hyperbaric conditions while employees conduct interventions and, if possible, the identification of those subcontractors.
Ballard Diving & Hyperbaric Services will be the only diving subcontractor to perform work under hyperbaric conditions while employees conduct interventions.
   17. Information about which medical personnel will be on-site, including what periods they will be on-site (e.g., will such personnel always be on-site during interventions).
A minimum of one physician will be on-call at all times when workers are engaged in compressed air work and for a minimum of twenty-four (24) hours after the last workers have completed decompression.  The physician or a physician's assistant under the physician's direction will be on site during all interventions and for five hours after the last worker has completed his decompression.
   18. Information about any certifications held by the man-lock attendants, hyperbaric-operations manager, man-lock tenders, surface man-lock tenders, and medical attendants, and whether any of these certifications include training in the compression and decompression protocols specified in Tully's variance application.
All man-lock attendants, hyperbaric-operations managers, man-lock tenders, surface man-lock tenders, and medical attendants hold one or more of the following certifications:
   * Commercial diving certification
   * Diving Medical Technician (DMT)
   * Life Support Technician (LST) 
Each of the above certifications include training in compression and decompression theory and protocols.  Additionally, all of the above listed personnel have undergone additional training in the use of the specific protocols specified in this variance application, including the use of the French decompression tables.

   19. Information about Tully's hyperbaric physician, including: whether the physician is board certified in undersea and hyperbaric medicine; the location of the physician during periods when employees are conducting interventions under hyperbaric conditions, and during decompression and treatment of hyperbaric-related injuries/illnesses (when necessary); and the hours the physician will be at this location.
A minimum of one physician, board certified in undersea and hyperbaric medicine, will be on-call at all times when workers are engaged in compressed air work and for a minimum of twenty-four (24) hours after the last workers have completed decompression.  The physician or a physician's assistant under the physician's direction will be on site during all interventions and for five hours after the last worker has completed his decompression.

   20. Information about any additional medical support Tully is arranging, including any arrangements with local emergency-medical services or a hospital emergency department with hyperbaric chambers, and any arrangements for transport of employees requiring treatment for hyperbaric-related injuries and illnesses.
   * Compressed Air Medical Services, LLC
      5050 NE HOYT #203
      Portland, Oregon 97213
      
   * Richmond University Medical Center
355 Barrd Ave.
Staten Island, NY 10310

   21. Describe the procedures that Tully will use to summon off-site medical resources, including the physician and emergency-medical services, and the estimated time it will take these resources to arrive on-site.
TBM has a phone system that can dial 911 and Rescue 5 dispatcher for emergency response and rescue. 
TBM has also a radio system connecting tunnel and outside installations and also medical staff at site.
   22. Is Tully using trimix breathing gas while the workers are conducting interventions under hyperbaric conditions or for decompression?  If used during interventions, provide information on the rate of oxygen toxicity (in %) during these exposures.  If used for decompression, provide OSHA with a copy of the tables used and any supporting documentation, including peer-reviewed English-language documentation, addressing validation of the trimix decompression tables.
Trimix breathing gas will not be utilized for interventions.
   23. Describe when Tully will use the various French decompression tables (tables n2 and n3, and back-up tables for air decompression and oxygen decompression).  Will any compressed-air worker (CAW) have a repetitive hyperbaric exposure during any 24-hour period?  If so, what decompression procedure will Tully use for repetitive exposures?
The French Air Standard Tables  -  Air Decompression (Table n2) will be used for work at pressures from 0 to 1.05 bar.  The French Air Standard Tables  -  Oxygen Decompression (Table n3) will be used for work at pressures from 1.05 to 4.2 bar.  Table n2 will be used at pressures from 1.05 to 4.2 bar only in the event of a failure of the oxygen system.  The back-up tables are only for emergency use.  No repetitive exposures are permitted.
   24. Provide information and evidence (beyond anecdotal evidence) comparing decompression-illness and oxygen-toxicity rates (in %) experienced by divers and/or CAWs using the OSHA decompression tables and the French decompression tables (for both air and trimix breathing gases, if Tully will use trimix breathing gas) under similar hyperbaric work exposures (i.e., for similar working times and pressures).
See Exhibit 3 of the original submittal (French Tables 1992 Operational Results - Pechon) and attached paper (Optimum schedules for caisson decompression"  -  Kindwall, 1992).

Trimix will not be utilized on this project.
   25. Provide any written documentation supporting the claim that it is safe to allow decompression times up to 360 minutes in the tunnel-boring machine.  In addition, include a statement that at no point in the project will decompression times exceed 360 minutes.
The maximum decompression time under normal conditions using the French tables is 153 minutes.  This occurs at a pressure between 2.7 and 3.0 bar (approx. 39 - 43.5 psig), with a working time of 2 hours using table n3 (Oxygen decompression).  At no point in the project will decompression times exceed 153 minutes under normal conditions.
   26. Provide a description of the procedure Tully will use to decant a hyperbaric-exposed employee when transferring the employee from the man lock to the medical lock.
In the event of an emergency decompression profile being required from the TBM lock system in potentially life threatening circumstances, then this will take the form of omitted decompression, "decanting", from either working pressure or the current pressure level in decompression. 

In this situation, where possible, workers should breathe oxygen via the BIBS system throughout the decompression.  The intention would be to complete as much of the decompression in the manlock as conditions and time allow, remove all workers from pressure in the TBM Lock, place the workers on oxygen, transport them directly to the Medical Lock and then be pressurized to a decompression or treatment pressure.  

Workers would then be treated as per the Medical Advisor's recommendations.

NOTE:  Decanting is a last resort and should only be applied in extreme emergency and with the knowledge and advice of the Contract Medical Advisor.


