While development and implementation of a commercial diving policy has tripled American Electric Power’s diving costs, the utility says the policy is necessary to ensure diver safety and quality work practices.
American Electric Power (AEP) may be the first investor-owned utility in the U.S. to develop and adopt a commercial diving policy for use at all of its hydro and fossil generating assets.
AEP, one of the largest electric utilities in the U.S., owns nearly 38,000 MW of generating capacity and delivers electricity to more than 5 million customers in 11 states. Implementation of a commercial diving policy has led to safer dive environments for contractors, better coordination among AEP generating facilities, and improved work practices.
During a diving inspection/repair project at the Smith Mountain pumped storage project in 2005, questions were asked by a visiting engineering manager about diving on AEP property: Were there laws and regulations pertaining to commercial diving? Was AEP in compliance with existing laws and regulations? Should AEP have a diving policy? What qualifications were required of a commercial diving contractor to perform work on AEP property? Did AEP have trained personnel providing oversight on their diving job sites? How did AEP know that the commercial diving company was diving in a safe environment? What was AEP doing to ensure that commercial divers would not be injured on AEP property?
An internal review revealed a need for a formal diving program designed to address the requirements of commercial diving. AEP’s Hydro Generation Group was identified as the “owner” of the program since it averaged more diving expenses per year than any other AEP group. The group was tasked with creating a diving program that addressed three goals:
- ) Provide safety to the commercial diver equal to or better than that being provided to AEP employees;
- ) Mitigate the liability exposure of AEP during diving operations; and
- ) Establish a training program for AEP personnel qualifying them as competent to provide commercial diving oversight.
Developing a policy for a commercial diving program
Soon after receiving ownership of the diving program, the Hydro Generation Group hired a full time diving coordinator to manage the yet-to-be-created diving program. Numerous discussions among group employees resulted in an overall vision for a diving program. The vision included a written policy describing requirements when performing diving work on AEP property, an AEP liaison to work with divers, and the creation of a list of qualified diving contractors close (within six hours driving distance) to AEP’s generating plants.
The company held discussions with commercial diving contractors and consultants with commercial diving experience. The information used to develop the policy came primarily from three sources: the Occupational Safety and Health Administration’s (OSHA) Code of Federal Regulations 29, 1910, the U.S. Coast Guard’s Code of Federal Regulations 46, and the Association of Diving Contractors International’s (ADCI) consensus standards, created by commercial diving contractors known by their peers as subject matter experts in the field of commercial diving.
Using these three sources, AEP’s Hydro Generation Group drafted a policy, which was reviewed by AEP’s safety, legal, contracts, and risk management departments. After many revisions, the final version was submitted to AEP’s senior management, which approved the policy in July 2007.
The policy is composed of two documents.
One explains what AEP requires of a commercial diving contractor. This includes the requirement that the contractor is in compliance with relevant U.S. law and with standards established through a consensus of commercial diving peers.
The second explains the role and responsibilities of the AEP personnel acting as the liaison, the “Diving Contact,” between the generating facility and the commercial diving contractor. This document clarifies that the AEP diving contact is not a diving expert or a commercial diver. Instead, the contact is to be educated about AEP’s expectations for commercial diving contractors and be able to enforce the AEP policy. The contact also is expected to act as the liaison between the commercial diving contractor and the generating site personnel.
Diving contacts assigned to each plant
In 2007, AEP hired a commercial diving consultant, MESSCO Diving, to teach a one-week program to prospective diving contacts. Being a diving contact for AEP is a collateral duty; most have technical jobs at AEP or work within an AEP plant’s safety group. The course is a one-time requirement, but each graduate must attend a refresher course every three years in order to remain certified.
The purpose of the program is to educate individuals to effectively serve as a liaison between AEP and the diving contractor. Following graduation, these individuals are knowledgeable about the conditions, depth, and time limitations a commercial diver faces. This is useful in specifying diving projects and writing scopes of work.
During the course, prospective diving contacts become familiar with diving physics, diving physiology, and underwater medicine. At the end of the week, the contacts are expected to be able to work repetitive dive schedules (A diver may be limited on how many dives he can make per day. The depth and duration of the dives dictate how many dives can be made per day. For example, a 30-minute, 200-feet dive could be performed once per day.) The contacts also are expected to be knowledgeable about surface decompression on air or oxygen, and follow the U.S. Navy diving tables.
The program includes a site visit to an actual commercial diving project to reinforce the classroom academia. On the last day of the program, the course instructor administers an exam. Passing the exam is a requirement to serve as a diving contact. Those who pass receive a certificate and a wallet-sized card stating they are qualified as an AEP diving contact.
As of December 2008, AEP had 43 qualified diving contacts, and nearly every generating plant has at least one diving contact.
Identifying qualified diving contractors
Once the policy was established, the diving coordinator completed a review of all commercial diving contractors to determine whether they met the requirements of the policy.
If a contractor did not meet the requirements, the diving coordinator contacts the contractor to explain the non-compliance and to offer assistance to bring the contractor into compliance. Several contractors complimented AEP’s efforts to improve site safety and readily complied.
Many elected not to meet the AEP standards, stating that, because AEP was a small percentage of their overall business, they could not justify the expenses necessary for compliance.
AEP now has eight qualified commercial diving contractors in areas where AEP plants are operated. Regardless of location, a qualified commercial diving contractor is within a four-hour drive. AEP’s diving coordinator regularly evaluates the diving contractors to ensure they are meeting the company’s expectations for performance and compliance.
Putting the program to work
If personnel at an AEP plant identify a need for divers, they communicate the need to their plant’s diving contact. The personnel brief the contact about the work scope and desired end result. The diving contact then notifies the plant’s safety representative of the need for commercial divers and the diving coordinator of the pending work.
The diving contact reviews the list of AEP-approved diving contractors and chooses one based on the specifics of the work scope. Upon the concurrence of the diving coordinator, the preferred contractor is contacted. Either the diving contact or the diving coordinator provides the contractor a detailed overview of the work.
The contractor then provides AEP with the required information and certifications as outlined in the AEP policy manual. These include, but are not limited to, a dive plan, physicals for the divers who are expected to perform the work, calibration records on equipment planned to be used for the work, and certifications and test records for the equipment planned to be used for the work.
The documentation is required to be submitted at least five working days in advance of the planned dive. In instances where there is an eminent danger to life, the environment, or property, the diving coordinator has the authority to approve emergency diving operations.
Once the commercial diving contractor arrives at the site, the diving contact completes a check sheet to ensure the contractor is in compliance with AEP’s policy. The diving contact also reviews all clearance permits with the contractor and remains with the contractor at all times.
All diving work is video recorded by the diving contractor, as specified in the policy, and the video becomes the property of AEP upon the conclusion of the work.
Results: Better quality and safety
Since implementation of the commercial diving policy in 2007, AEP has seen changes in the type of diving companies the utility contracts with, an improvement in safety practices, better diving reports, an increase in the sharing of resources and information, establishment of a single point of contact, and a more structured work process.
Many of the smaller contractors AEP used in the past are no longer being used. Either they elected not to meet the standards within the written policy or they proved through their performance that they were incapable of meeting the standards.
Overall, the commercial diving contractors being used today are larger than the contractors used in the past. These larger contractors offer an increased inventory of specialty tools – remotely operated vehicles, sonar, barges, cameras, hydraulic dredges, cofferdams, etc. – that meet the needs of all AEP plants.
Since AEP now interfaces with the commercial diving contractor prior to the work start date, specialty tooling and diver requirements are known upfront. Consequently, downtime on the job site can be eliminated.
Some commercial divers have thanked AEP’s diving contacts for creating and enforcing a diving policy. They are much more at ease on an AEP site where they participate in the “checks and balances” leading to a safe work environment. They say that typically the customer takes them to the site of an underwater problem and states: “The problem is down there; stop by the office after you fix it.”
AEP requires written diving reports for nearly all inspection work and on many repair projects. The reports received in the past were very poor; they were normally re-written by site engineers or other technical staff. The reports being received today are very professional, accurate, and complete.
The 60 trained AEP diving contacts can be shared, when necessary, from plant to plant. The diving program also forced the sharing of information between plants. Since AEP has only one diving coordinator, he is involved in all AEP diving operations. He receives feedback and reports from each operation, which is stored in a database. AEP now has the capability of sharing lessons learned from a multitude of diving operations throughout the 11 states in which AEP owns plants.
The diving coordinator provides a single point of contact for the plants and the contractors. If questions or concerns arise prior to, during, or after a diving job, only one telephone call is necessary. This has reduced confusion and streamlined the program.
All diving operations follow the same protocol. Each diving contractor has a copy of the AEP diving policy. The contractor uses the policy as a guide during the initial stages of the job process. The process is the same on every job, which has mitigated confusion and improved productivity.
Money well spent
These improvements have not come without increased costs. The cost of a typical diving project has increased by an average factor of three. Why? In the past, AEP was not enforcing the laws pertaining to the commercial diving industry; contractors were not manning jobs with enough people, their equipment was not calibrated, and their divers did not physically qualify. Meeting the legal requirements is expensive for contractors, which is reflected in the prices they charge.
Even though the implementation of the commercial diving policy has increased costs for the utility, AEP believes the extra expense can be justified. AEP is fully committed to the safety of its employees and contractors, and this commitment is strongly reflected in its diving policy.
AEP has developed and adopted a commercial diving policy for all fossil/hydro generating assets, which may be a first for the industry.
David Scarberry, Plant Support Specialist, American Electric Power (AEP), and James R. Thrasher, P.E., Maintenance Production Supervisor, AEP, worked together to create a commercial diving policy for AEP and trained personnel in certain aspects of the commercial diving industry, including risk management, commercial contracts, and safety and environmental compliance.