TECHNICAL MEMORANDUM

Duffin Creek WPCP Outfall Tunnel

Considerations regarding Potential Gas Occurrence
During Construction
PREPARED FOR: File
PREPARED BY: Steven Fradkin
REVIEWED BY: Don Del Nero
DATE: September 15, 2011

1. BACKGROUND
A new outfall is planned for the Duffin Creek Water Pollution Control Plant (WPCP) along
the Lake Ontario shoreline on the north side of Toronto. The existing outfall is shorter than
currently desired; the new outfall will extend approximately three times further into the
lake.
Two alignment alternatives are under consideration – one to the north of the existing outfall,
and the other to the south. A subsurface investigation is currently underway that includes
borings along both alternative alignments. At least two of the borings encountered gas in
the shale bedrock, and in one case continuous gas flow was observed from a Friday to the
following Monday when the borehole was sealed. The gas was reported by Coffey
Geotechnics (email from Ivan Lieszkowsky to Rich Tindall and Wayne Green, dated August
8, 2011) to be “combustible” gas, meaning methane.
The upper bedrock in the immediate vicinity of the Duffin Creek WPCP is shale of the Blue
Mountain Formation. It is noted that gas was observed during pumping tests of installed
wells earlier this year at the WPCP. The work plan (by AES International) for a proposed
gas investigation noted that combustible gas had been observed in some geotechnical
borings as far back as 1974. The work plan noted that the Blue Mountain Formation is
known to contain natural gas. The overlying Georgian Bay Formation is also known to
contain natural gas.
This memorandum addresses the issue of what measures should be considered for
tunneling of the outfall tunnel considering the potential for encountering natural gas during
the tunnel excavation. This includes a discussion of the regulatory framework.

2. CHARACTERISTICS OF HAZARDOUS GASES

The primary hazardous gases that are normally of concern during tunneling are methane,
hydrogen sulfide and volatile organic compounds (primarily gasoline component vapors).
As the concern for the Duffin Creek project is naturally occurring gas, the latter category
does not apply. Table 1 summarizes the concentrations and characteristics for these

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hazardous gases. Note that while most emphasis tends to be on the explosion risk, the toxic
risks are also important and often occur at much lower levels, particularly for hydrogen
sulfide. This means that actions should be taken in the tunnel to mitigate the toxic
conditions for these gases well before concentrations ever reach the explosive limits.

Table 1 - Summary of Characteristics of Underground Gases of Concern

Gas Lower Upper Toxic Solubility in Specific

Explosive Explosive Hazard, H2O Gravity
Limit (LEL), Limit (UEL), % By Air Vol (ppm or Relative to
% by Air % by Air Vol (ppm) mg/L) Air,
Vol (ppm) Gs
(ppm)
Methane 5% 15% By oxygen 40,000 ppm 0.6
CH4 50,000 ppm 150,000 ppm depletion @12oc
effects
Hydrogen 4% 46% 10 ppm (TWA) 2.9 vol gas per vol 1.3
Sulfide 40,000 460,000 15 ppm (STEL) H2O at 20oC
H2 S
Notes:
TWA = Time Weighted Average
STEL = Short Term Exposure Limit

Given the foregoing, there are two primary issues of concern:

1. Is there potential that naturally occurring gases will create an explosive atmosphere?
That is, is there the potential for gases, such as methane, to combine with the air in the
excavation within the range of concentrations that creates an explosion hazard in the
presence of a potential source of ignition?
2. Is there potential that naturally occurring gases will create a toxic atmosphere?
Note that for the two primary gases of interest, one is lighter than air and will tend to collect
in a tunnel excavation in the upper part of the tunnel, while the other is heavier than air and
will tend to collect in the lower part of the tunnel.

3. REGULATORY FRAMEWORK
3.1 Canadian Regulations
In Canada, occupational safety and health regulations exist both at the Federal and
Provincial levels, with most occupational safety and health regulation occurring at the
Provincial level. Federal-level regulations are provided at Canada Occupational Health and
Safety Regulations, SOR/86-304. Part III addresses Temporary Structures and Excavations,
but provides few requirements related to underground construction, and more importantly
it provides no specific requirements that are germane to the issue of naturally occurring
gases. Other parts of the regulation provide general requirements with respect to items

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such as ventilation and lighting in the workplace, but as noted for Part III, there are no
specific requirements that relate to underground construction.
At the Provincial level, Ontario’s Health and Safety requirements for construction projects
are addressed in Ontario’s regulations at O. Reg 213/91. Requirements for tunnels, shafts,
caissons and cofferdams are addressed in Part IV of the regulation, with requirements for
tunnels, tunnel equipment, explosives and ventilation being included at sections 306 to 331.
The requirements are quite general in nature and, in general, are not applicable to the issue
of natural gas occurrence. The specific requirements with respect to ventilation are:
329. An adequate supply of fresh air shall be provided and circulated throughout an
underground work place. O. Reg. 213/91, s. 329.

330. (1) An underground work place shall be tested regularly for noxious or toxic
gases, fumes or dust. O. Reg. 213/91, s. 330 (1).

(2) A competent worker shall regularly test the air and the mechanical ventilation for
an underground work place to ensure that the mechanical ventilation is adequate. O.
Reg. 213/91, s. 330 (2).

(3) When the results of the tests referred to in subsection (2) indicate there is a need
for respiratory protective equipment, the employer shall provide respiratory
protective equipment. O. Reg. 213/91, s. 330 (3).

331. (1) Mechanical ventilation shall be provided in a shaft in which an internal

combustion engine or other device which emits a noxious gas or fume operates. O.
Reg. 213/91, s. 331 (1).

(2) Subsection (1) does not apply if the noxious gas or fume is discharged outside the
shaft in such a way that its return to the shaft is prevented. O. Reg. 213/91, s. 331 (2).
In a broad way s. 329 to s. 331 can be construed to include naturally occurring gases as
“contaminants” of concern to workers in underground excavations. Elsewhere in the
regulation, however, such as Part II, General Construction, Housekeeping, s. 40 to s. 44, the
requirements concerning combustible, corrosive or toxic substances are clearly related to
substances that might be used in the work and address issues such as storage and transport.
Also, under Housekeeping, s.46 and s. 47 address general requirements for ventilation:
46. (1) A project shall be adequately ventilated by natural or mechanical means,

(a) if a worker may be injured by inhaling a noxious gas, vapour, dust or

fume or from a lack of oxygen; or

(b) if a gas, vapour, dust or fume may be capable of forming an explosive

mixture with air. O. Reg. 213/91, s. 46 (1).

(2) If it is not practicable to provide natural or mechanical ventilation in the

circumstances described in clause (1) (a), respiratory protective equipment suitable

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for the hazard shall be provided to and used by the workers. O. Reg. 213/91, s. 46
(2).

47. No internal combustion engine shall be operated,

(a) in an excavation unless provision is made to ensure that exhaust gases

and fumes will not accumulate in the excavation; or

(b) in a building or other enclosed structure,

(i) unless the exhaust gases and fumes from the engine are discharged
directly outside the building or structure to a point sufficiently remote
to prevent the return of the gases and fumes, or

(ii) unless there is an adequate supply of air for combustion and

adequate natural or mechanical ventilation to ensure exhaust gases
and fumes will not accumulate. O. Reg. 213/91, s. 47.
The focus of the Provincial regulations is on ventilation, but the requirement is only to
provide “an adequate supply of fresh air” or for the project to be “adequately ventilated.”
However, the regulations provide no specific guidance with regard to ventilation nor do
they address the issue of potential ignition sources should the potential exist for an
explosive atmosphere to form.
It is also appropriate to note that tunnels for civil works, such as the Duffin Creek outfall
tunnel do not fall under the regulatory requirements for mining, and tunnels for mines are
specifically exempted from the regulations described above. Similarly, tunnels for civil
works do not fall under regulatory requirements for confined spaces because tunnels are
designed and intended for human occupation during the construction period and include
engineered controls to address ventilation, groundwater control and other safety issues.
Although, as noted, tunnels for civil works do not fall under the mining regulations, Ontario
health and safety regulations relating to mining do have relevant provisions that are similar
to requirements embodied in U.S. regulations. The Ontario regulations are provided in
R.R.O. 1990, Reg. 854. Of particular interest are the requirements in Section 35:
35. (1) If a flow of flammable gas is encountered in a mine or in an enclosed building
housing a diamond drill on the surface and the concentration of the flammable gas is
unknown,

(a) all sources of ignition in the affected area shall be eliminated;

(b) all electrical equipment in the affected area shall be de-energized;
(c) the affected area shall be evacuated;
(d) precautions shall be taken to prevent persons from entering the affected
area inadvertently;
(e) a supervisor shall be notified;
(f) the affected area shall be tested by a competent person; and
(g) the affected area shall be designated as a fire hazard area. O. Reg. 236/99,
s. 3.

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(2) Subject to subsections (3), (4) and (5), work may resume if the concentration of
flammable gas is below 1.0 per cent. O. Reg. 236/99, s. 3.

(3) If the concentration is less than 0.25 per cent and the affected area is tested
periodically to ensure that the level of concentration is known, no precautions are
required. O. Reg. 236/99, s. 3.

(4) If the concentration is 0.25 per cent or greater but not more than 0.5 per cent, all of
the following precautions shall be taken:

1. The supervisor shall provide written instructions of any special

precautions.
2. The instructions, if any, shall be communicated to the workers.
3. The affected area shall be designated as a fire hazard area.
4. The affected area shall be tested at least once per shift before work begins
and, again, on release of any further flow of gas.
5. A flammable gas detector shall remain in the affected area for the purpose
of continued testing. O. Reg. 236/99, s. 3.

(5) If the concentration is 0.5 per cent or greater but not more than 1.0 per cent, all of
the precautions set out in subsection (4) shall be taken and the electrical equipment,
diesel engines, tools and other material used in the workplace shall be designed to
function safely in a flammable gas atmosphere. O. Reg. 236/99, s. 3.

(6) If concentrations of flammable gas exceed 1.0 per cent in an area, all of the
following precautions shall be taken:

1. All sources of ignition in the affected area shall be eliminated.

2. All electrical equipment in the affected area shall be de-energized.
3. All persons, other than competent persons necessary to measure the
concentration of flammable gas and to make ventilation changes, shall be
removed from the affected area. O. Reg. 236/99, s. 3.

(7) In mines where flammable gas is known to occur, workers who are underground
or diamond drillers who are on the surface shall be advised of,

(a) the probability of encountering a flow of the gas; and

(b) the measures and procedures prescribed in this section. O. Reg. 236/99, s.
3.

(8) For the purposes of this section, the concentration of flammable gas means the
percentage, by volume, of flammable gas in the general atmosphere. O. Reg. 236/99,
s. 3.
Of interest, the 2006 “Handbook for Methane Control in Mining” by Fred Kissell (U.S.
National Institute for Occupational Health and Safety, Information Circular 9486), in its

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discussion of methane control in metal and non-metal mines and action levels mandated by
the Mine Safety and Health Administration (MSHA) for methane detected at certain
concentrations includes:
“In Canada, Ontario has similar requirements in Section 35 of its regulations for
mines and mining plants under the Ontario Occupational Health and Safety Act
[1990], but with a few additional features (such as the need to provide written
instructions), which makes Section 35 worthwhile to read. It is reproduced in
Appendix A of this chapter.”

3.2 United States Regulations

In the United States, regulations relating to health and safety in the workplace are
promulgated by the Federal Occupational Health and Safety Administration (OSHA).
Regulations specifically related to underground construction are found in the portion of the
Federal Regulatory Code designated as 29 CFR Part 1926, Subpart S, Standard 1926.800,
Underground Construction (29 CFR 1926.800). Standard 1926.800 includes specific
requirements for mitigating the hazardous and toxic effects associated with natural gases
that either will or might be encountered during underground construction. The
requirements are more detailed and specific than those found in the Canadian Federal and
Provincial regulations for underground construction. They are similar, however, to the
requirements in the Ontario occupational health and safety regulations for mining.
Under OSHA regulations tunnels may be classified as non-gassy, potentially gassy or gassy.
Standard 1926.800 (h)(1) indicates that a tunnel operation is classified as potentially gassy if
either:
(i) Air monitoring discloses 10 percent or more of the lower explosive limit for
methane or other flammable gases measured at 12 inches (304.8 mm) ±0.25 inch (6.35
mm) from the roof, face, floor or walls in any underground work area for more than
a 24-hour period; or

(ii) The history of the geographical area or geological formation indicates that 10
percent or more of the lower explosive limit for methane or other flammable gases is
likely to be encountered in such underground operations.

Note that a gas concentration of 10 percent of the lower explosive limit for methane is
equivalent to a methane concentration 0f 0.5 percent of the volume of air. R.R.O. 1990, Reg.
854, cited above, provides action limits in terms of gas concentration in air.
Standard 1926.800 (h)(2) indicates that a tunnel operation is classified as gassy if either:
(i) Air monitoring discloses 10 per cent or more of the lower explosive limit for
methane or other flammable gases measured at 12 inches (304.8 mm) + or - inch (6.35
mm) from the roof, face, floor or walls in any underground work area for three
consecutive days: or

(ii) There has been an ignition of methane or of other flammable gases emanating
from the strata that indicates the presence of such gases: or

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(iii) The underground construction operation is both connected to an underground

work area which is currently classified as gassy and is also subject to a continuous
course of air containing the flammable gas concentration.

The observations of gas in several borings drilled to date for the Duffin Creek outfall tunnel,
together with previous observations at the plant, leads to a classification of the future outfall
tunnel as potentially gassy. For the U.S., previous OSHA citations and cases before judges
or the OSHA commission has affirmed that methane encounters in borings (even if gas
quantities were small) or methane encounters during previous tunneling in the region is all
that is needed to result in a potentially gassy classification.
Standard 1926.800 (j)(2) gives the following additional monitoring requirements for a
potentially gassy or gassy tunnel (bolding added for emphasis):
(2) Additional monitoring for potentially gassy and gassy operations. Operations which
meet the criteria for potentially gassy and gassy operations set forth in paragraph (h)
of this section shall be subject to the additional monitoring requirements of this
paragraph.

(i) A test for oxygen content shall be conducted in the affected underground work
areas and work areas immediately adjacent to such areas at least at the beginning
and midpoint of each shift.

(ii) When using rapid excavation machines [TBMs], continuous automatic

flammable gas monitoring equipment shall be used to monitor the air at the heading,
on the rib, and in the return air duct. The continuous monitor shall signal the
heading, and shut down electric power in the affected underground work area,
except for acceptable pumping and ventilation equipment, when 20 percent or more
of the lower explosive limit for methane or other flammable gases is encountered.

(iii) A manual flammable gas monitor shall be used as needed, but at least at the
beginning and midpoint of each shift, to ensure that the limits prescribed in
paragraphs (h) and (j) are not exceeded. In addition, a manual electrical shut down
control shall be provided near the heading.

(iv) Local gas tests shall be made prior to and continuously during any welding,
cutting, or other hot work.

(v) In underground operations driven by drill-and-blast methods, the air in

the affected area shall be tested for flammable gas prior to re-entry after
blasting, and continuously when employees are working underground.

And, in 1926.800(k)(11):
(11) Potentially gassy or gassy operations shall have ventilation systems installed
which shall:

(i) Be constructed of fire-resistant materials; and

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(ii) Have acceptable electrical systems, including fan motors.” (Bolding added)

And, in 1926.800(k)(13):
(13) In potentially gassy or gassy operations, wherever mine-type ventilation
systems using an offset main fan installed on the surface are used, they shall be
equipped with explosion-doors or a weak-wall having an area at least equivalent to
the cross-sectional area of the airway.” (Bolding added)

A key word in these requirements is “accept” or “acceptable.” Subpart S in 1926.800(u)

provides the following definition:
"Accept" -- Any device, equipment, or appliance that is either approved by MSHA
and maintained in permissible condition, or is listed or labeled for the class and
location under subpart K of this part.” (Bolding added)

Basically, these statements require that at least the ventilation system for a potentially gassy
tunnel either meet Mine Safety and Health Administration (MSHA) requirements for
“approved” or meet the requirements of Subpart K for the class and division applicable the
tunnel conditions.
MSHA standards can be found on their website (http://www.msha.gov/). Procedures for
getting equipment “approved” are given and tables are provided for electrical and other
manufactured equipment that has been tested and approved. According to Barry Doyle,
author of Hazardous Gases Underground, the MSHA requirements for “approved”
equipment are more stringent than those needed to meet Class I, Division 1 or Class 1,
Division 2 requirements in Subpart K. In general, the MSHA approved equipment must be
either explosion proof or intrinsically safe (not capable of creating a spark or ignition).
OSHA Part 1926, Subpart K - Electrical, Standard 1926.449 provides the following regarding
Class I, Division 1 and Class 1, Division 2:
Class I locations. Class I locations are those in which flammable gases or vapors are
or may be present in the air in quantities sufficient to produce explosive or
ignitable mixtures. Class I locations include the following:

(a) Class I, Division 1. A Class I, Division 1 location is a location:

(1) In which ignitable concentrations of flammable gases or vapors may exist

under normal operating conditions; or

(2) In which ignitable concentrations of such gases or vapors may exist frequently
because of repair or maintenance operations or because of leakage; or

(3) In which breakdown or faulty operation of equipment or processes might release

ignitable concentrations of flammable gases or vapors, and might also cause
simultaneous failure of electric equipment.

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(b) Class I, Division 2. A Class I, Division 2 location is a location:

(1) In which volatile flammable liquids or flammable gases are handled, processed,
or used, but in which the hazardous liquids, vapors, or gases will normally be
confined within closed containers or closed systems from which they can escape
only in case of accidental rupture or breakdown of such containers or systems, or in
case of abnormal operation of equipment; or

(2) In which ignitable concentrations of gases or vapors are normally prevented by

positive mechanical ventilation, and which might become hazardous through
failure or abnormal operations of the ventilating equipment; or

(3) That is adjacent to a Class I, Division 1 location, and to which ignitable

concentrations of gases or vapors might occasionally be communicated unless such
communication is prevented by adequate positive-pressure ventilation from a source
of clean air, and effective safeguards against ventilation failure are provided.”
(bolding added)

And,
Acceptable. An installation or equipment is acceptable to the Assistant Secretary of
Labor, and approved within the meaning of this Subpart K:
(a) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be
safe by a qualified testing laboratory capable of determining the suitability of
materials and equipment for installation and use in accordance with this standard; or
(b) With respect to an installation or equipment of a kind which no qualified testing
laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or
tested by another Federal agency, or by a State, municipal, or other local authority
responsible for enforcing occupational safety provisions of the National Electrical
Code, and found in compliance with those provisions; or
(c) With respect to custom-made equipment or related installations which are
designed, fabricated for, and intended for use by a particular customer, if it is
determined to be safe for its intended use by its manufacturer on the basis of test data
which the employer keeps and makes available for inspection to the Assistant
Secretary and his authorized representatives.
Accepted. An installation is "accepted" if it has been inspected and found to be safe
by a qualified testing laboratory.
3.3 DISCUSSION OF OSHA STANDARDS
Since 1989 when Subpart S was issued, much confusion has existed about the electrical
component requirements needed for the TBM and other tunneling equipment for potentially
gassy tunnels. Prior to 1989, the courts determined that portions of Subpart S (particularly
1926.407 and 1926.449) apply to tunneling. The rulings against CH2M Hill and S.A. Healy
after the 1988 CT-7 tunnel explosion and deaths in Milwaukee, Wisconsin were based in
part on non-compliance with Subpart S requirements for some of the tunnel equipment (e.g.

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parts of TBM, lighting, and segment annulus grout pump). The new Subpart S standard
that was issued in 1989 changed the requirements, but confusion followed.
On March 27, 1991, OSHA issued a Standard Interpretation entitled “Clarification of
approval requirements for equipment to classify underground construction operations as
potentially gassy.” In the clarification document OSHA asserted that:
“Therefore, in further clarification of the requirements of 29 CFR 1926.800(h)(1)
through (h)(3), we offer the following discussion:

Should an underground tunneling face be emitting methane gas into the tunnel, and
the ventilation system ducting is used to effectively exhaust the hazardous methane
containing atmosphere within the tunnel, the tunnel volume would be considered a
Class 1, Division 2 location. (A hazardous atmosphere would not exist under normal
operating circumstances.) However, were the ventilation system run in reverse and
the tunnel become the conduit for exhausting the methane filled atmosphere, the
tunnel would be classified as Class 1, Division 1.

In either case, the area ahead of the forward end of the ventilation ducting (that area
from the tunnel face to the ducting) would be classified Class 1, Division 1.

Unfortunately, this OSHA interpretation was confusing, did not provide the intended
clarification and was not correct based on subsequent OSHA citations and Federal trials
regarding the cases. The most notable and important is the case of the Secretary of Labor
(for OSHA) vs. McNally Construction and Tunneling Company. OSHA cited McNally
alleging that their tunnel was potentially gassy and that all of the electrical equipment
should have had met requirements for Class I, Division 2 installations. The OSHA review
Commission report stated:
“The cited tunnel, a part of the Southwest Interceptor sewage project in Cleveland,
Ohio, (2) was dug in Cleveland shale, a geological formation in which methane gas
can be encountered. The Secretary alleges that McNally committed a serious
violation of section 1926.407(b) because "lighting equipment and wiring methods of
lighting equipment in hazardous (classified) locations [in that tunnel] were not
approved as intrinsically safe," and that one method of abatement would be the
installation of electrical equipment required for Class I, Division 2 locations as
defined at section 1926.449.”
Basically, OSHA was claiming the electrical standard, Subpart K (1926.400), requirements
preempted those given in Subpart S, Standard 1926.800. OSHA said that because some of
the borings encountered methane the entire tunnel should be considered to be a location
requiring all electrical equipment to meet requirements for Class I, Division 2 locations. The
Commission stated:
“Here, the Secretary claims that the tunnel is Class I, Division 2 because test borings
(9) indicated the possibility that ignitable concentrations of methane could
accumulate in the tunnel which might then become hazardous if the tunnel
ventilation failed. Sections 1926.407 and 1926.449 require that such locations have
"approved"(10) equipment if combustible levels of gas, which is 100 percent of the

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LEL, might accumulate. If section 1926.800 did not exist, it appears that these
provisions would govern here.”
FOOTNOTE (10):
While section 1926.407 describes spark-proof equipment as "approved," section
1926.800 refers to such equipment as "acceptable."
The Commission carefully reviewed these standards and all the legal arguments and
determined that OSHA was wrong and vacated the citation. They found that McNally was
in compliance with requirements for a potentially gassy tunnel because the ventilation
system did meet the requirements for “acceptable” equipment even though most of the
other electrical equipment for the TBM, lighting, pumps and other tunnel facilities did not.
The Commission concluded:
“Having examined the text and structure of the two standards, we hold that the
provision of sections 1926.407 and 1926.449 are preempted by the provisions of
section 1926.800. We reach this conclusion not only because section 1926.800
addresses the same hazard as section 1926.407 but also because these two standards
set forth conflicting requirements, rather than complementary ones, as the Secretary
contends.”
From review of Subpart S (1926.800) and the Commission’s decision, the following key
conclusions were established:

 A potentially gassy classification does not require the TBM motors, other TBM
electronics, lighting, communications, grout pumps, etc to be meet Subpart K
requirements for “acceptable” under conditions for either Class I, Division 1 or
Class I, Division 2 locations.
 A potentially gassy classification does require that the ventilation system be
“acceptable” which can be met by either being MSHA “approved” or meet
Subpart K requirements for “acceptable” under conditions for Class 1, Division 2
locations.
 A potentially gassy tunnel is not a Class 1, Division 1 location.

3.4 CONCLUSION
The Kissell 2006 NIOSH publication cited previously includes a section on methane in civil
tunnel projects. Kissell notes:
“The gas in a tunnel can originate in the strata being excavated, or it can migrate a
considerable distance from adjacent strata.”
“Gas flowing from just one test boring indicates a potentially larger gas problem.”
“There have been many methane explosions in places where the existence of gas was
never suspected or was thought to be minimal.”
He goes on to note:
“Simultaneous application of three basic elements reduces the methane hazard:

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• Adequate ventilation.
• Regular monitoring of air quantities and gas concentrations, with automatic
equipment shutoff at high gas concentrations.
• Elimination of ignition sources, including those that are worker-related.
The simultaneous application of several elements is necessary because if one fails,
the others continue to ensure safety.”
Based on the foregoing from Kissell (2006) and the preceding discussion of regulations in
Canada, Ontario and the United States, the following are the primary conclusions to be
drawn:

 Based on the local geology and the observations of gas occurrence in some of the
project borings, the Duffin Creek outfall tunnel would be classified as potentially
gassy under U.S. OSHA regulations. Although the Ontario mining regulations do
not apply to a civil project such as Duffin Creek, from the standpoint of worker
safety and minimizing project risk, it would seem advisable to apply the action limits
of R.R.O. 1990, Reg. 854 and other relevant requirements of the U.S. OSHA
regulations.

 Ventilation is key to minimizing the concentrations of methane or other gases in the

atmosphere to which workers are exposed in tunnels. The system must be designed
to provide an adequate supply of fresh air to the tunnel heading (requirements are
stated in the OSHA regulations), sufficient to keep gas concentrations below the 5
percent LEL action level.

 In the U.S., the use of a TBM requires continuous, automated monitoring for gas,
with alarms for action levels and automatic shutdown of the TBM and certain other
electrical systems along with evacuation of the tunnel should concentrations above
20 percent LEL be encountered.

 Kissell (2006) notes that in the event that high gas concentrations are observed,
certain equipment must still function – notably ventilation and communications.
Therefore, Kissell states that such equipment must be explosion-proof. Other
equipment that must remain functional, such as handheld gas monitors and miner’s
lamps must be intrinsically safe, meaning they are not capable of generating a spark
of sufficient energy to ignite flammable gas or cause an explosion. By de-energizing
and shutting down other non-explosion-proof equipment, and leaving only
equipment operational that is either explosion-proof or intrinsically safe, potential
ignition sources are removed.

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