UPDATES: These news items and statements of pressing issues regarding safety and compliance for Coal-fired Power Generation, are provided by Plant Professionals to continue “shedding light” on items which are critical to the Utility Practitioner, be it Operations, Maintenance, Management, Engineering, Safety, etc.
Some of these items may seem a bit disconnected, but contribute to our discovery of current affairs, OSHA focus, Incidents, etc.
OSHA Compliance Fines (from a paraphrased recent news article): OSHA has stepped up efforts to penalize violators after similar finely divided dust of different components caused an Imperial Sugar plant explosion in 2008 that killed 14 people. This auto parts manufacturer (X Company) was hit with $70,000 in fines by the Occupational Safety and Health Administration. An October inspection revealed combustible dust in a storage area. OSHA also cited the plant for failing to limit dust exposure to employees, exposing workers to fall hazards, failing to have a respiratory protection program, and failing to ensure there were lockout devices to trap energy during equipment maintenance.
X Company has been (1)fined for the dust and other violations before. Last March, an inspection revealed there was dust, employee exposure to formaldehyde, and other particles, among other health and safety violations. The company paid $135,000 in fines for those violations. (2) A spokesman allowed to speak for X Company says they hired a private firm to clean up the dust last year. This time, the company is contesting the penalties. They hope to work with OSHA to eliminate the fines, because (3) they thought they had done enough.
“These are small pockets of scraps,” said the spokesman of the Chamber of Commerce. “They can combust. (4) The good thing is it’s a non-combustible building.”
The Plant Manager did release a statement: “On Monday, February 8, 2010, X Company received notice from the Occupational Safety and Health Administration (OSHA) of potential safety hazards noted by an OSHA inspector during a visit in October of 2009. Worker safety is an issue of paramount importance to (X Company), and so interim steps were put in place to address the concerns, and an immediate investigation of items listed in the OSHA notice was commenced, and is in progress. X Company has asked for an immediate conference with the Area Director of OSHA in order to clarify conclusions reached in the notice, and discuss an agreement that will ensure the safest possible work environments at” X Company’s Facilities.
“(We want) to make sure where the disconnect is (with OSHA),” said the Plant Manager. “Correct it for the safety of their employees.”
That disconnect could come from the federal standard to regulate the dust. (5) There isn’t one. The U.S. Chemical Safety Board advises OSHA but does not have the power to regulate. OSHA is currently working on setting a federal standard for combustible dust.
Said…County Fire Chief…(of Combustible Dust): “It has the potential to create an explosion, just like a bomb going off.”
The fire department says it has responded to (6) Three or four fires at the company over the past two or three years. They are usually small fires, said (the Fire Chief), (7) contained within X Company’s duct system. It’s not known whether dust played a role in the fires.
“If you can get it (8) ventilatedand, get the dust removed, then the danger is removed,” added (the Fire Chief).
Said a Spokesman: ”They’ve got interior functions that draw the dust out. They’re working on it to get it totally perfect for a safety standard.”
X Company was also fined for OSHA violations in 2006. Because of the Imperial Sugar blast, OSHA could be trying to send a message. They fined Imperial $9,000,000 after it was determined dust was the cause.
OSHA told (news reporters) that (9) “they must work within the resources they have”. They (10) do not always do follow-up inspections on violations and must depend on companies to correct the problems that are found.
This paraphrased article holds several valuable lessons within:
- Once you have been fined, repeat violations are a focus of OSHA. There is additional risk of inspection, increased several times when repeat violations are found.
- Don’t allow the local Chamber of Commerce to be your spokesperson. Best case is to have an Information Officer or Public Relations Firm do your talking. A recent Mine Disaster was madeseveral times more hurtful and controversial because the President & CEO did not follow this simple concept. Judging from the poor understanding of the “spokesman” in this article, that lack of knowledge only caused X Company to appear more culpable when they may not have deserved it.
- Here is a quiz question: Is it adequate for you to simply think you have “done enough”? If you feel you have, say you have. If you feel you have not, don’t say you “thought” you had. “Thought” is not a functional word in such affairs.
- Is it a good thing that the building was non-combustible. Sure. Does it have value when talking about the potential for explosion from process material? No. The hazard here is explosion.
- When referring to existence of an actionable dust standard, the comment was: “there isn’t one”. Showing ignorance such as this is damning to a company. In October 2007 and revised in March 2008, OSHA launched a National Emphasis Program (quick standard) on Combustible Dust. It is a good document, but more importantly, it is actionable by OSHA Federal and State entities. While a new standard is being written at this time, claiming “there isn’t one” is a false statement.
- “Three or four fires at the company over the past two or three years” is not a trivial matter. First of all, have you read the recently published Recordkeeping NEP? Are your fires recorded? Second of all, never try to trivialize the meaning or potential a fire (primary event) brings to any facility.
- If there is a fire in a duct system, the odds of it being dust related are astronomically in favor. What else would it be?
- Make sure you are aware of the new standard for expectations of duct air velocity, which has been raised to 35,000 ft/min. to keep dust suspended, thus preventing dust from laying down on the floor of the duct.
- Telling OSHA that you must work “within the resources you have”, suggests a lack of innovation on better ways to “skin the cat”. You are either telling OSHA that you don’t/won’t expend the manpower (lack of committment), or you are showing your lack of a “good faith effort” in finding solutions.
- The current Combustible Dust NEP requires each company/facility to protect the safety and life of workers by insuring compliance with the NEP and it’s referenced documents (mostly NFPA). One of the most critical documents referenced in the NEP is NFPA 654, which establishes the %of total area coverage and a certain thickness. If visited by OSHA, ask for their expectations regarding allowable thickness. Otherwise, follow the suggestions given in 654 and inspect regularly to insure that dust limits are not exceeded. The future of the OSHA Combustible Dust Standards will see an expectation of regular Internal Assessments regarding any gap between standards and actual conditions. At the very least, dust levels and efforts to elliminate the accumulation (containment), or mitigation should be taken seriously every shift of operation.
OSHA Completes its Second Pair of Stakeholder Meetings in Atlanta: See my post of the same title to find detailed notes of this event.
OSHA Widows of miners killed in disaster file suit in U.S. This article comes to us courtesy of Reuters, Feb 19. It is included to call attention regarding the powerful connection between methane primary events and the devastating secondary explosion of Combustible Dust (coal) that often occurs. Within the past several months, there has been a similar incident which occured at a Power Generation Facility in the US. It started with a methane explosion in the underground Coal Stockpile Reclaim Tunnel, which sonically caused dispersion of dust from the cable trays, pipe racks, and conveyor frame, resulting in an explosion which engulfed the entire tunnel and conveyor structure sloping upward away from the reclaim tunnel. While this article is from the mining industry, it has application in our Utility Coal Industry. NOTE: The PRB Coal User’s Group Conference to be held in Baltimore, MD on May 17 – 20, 2010, features a presentation on the aforementioned explosion at a Power Generation Reclaim Tunnel.
MEXICO CITY, Feb 19 (Reuters) – Widows of Mexican miners killed by an explosion in a coal mine in 2006 are suing owner Grupo Mexico for $300 million in a U.S. court, the United Steelworkers Union representing the women said on Friday
Sixty-five miners were killed in a pre-dawn explosion of methane gas and coal dust which tore throughout the the Pasta de Conchos mine in Mexico’s northern state of Coahuila, trapping some workers almost 1.5 miles (2.5 km) underground.
The blast sent temperatures soaring above 1,100 Fahrenheit (600 Celsius) and filled mine shafts and tunnels with methane and carbon monoxide as well as collapsed rock.
The Steelworkers Union is arguing, on behalf of three widows, that Grupo Mexico (GMEXICOB.MX) knew of the potential dangers and was negligent. The union believes more relatives could join the suit.
“The (company) knew that there were high levels of methane gas, combustible dust and a lack of ventilation that was creating a perfect storm for the very type of disaster that did happen and they did nothing,” said the Steelworkers lead counsel Dan Kovalik.
Grupo Mexico said it did not yet have any comment on the case, which was filed on Friday in a U.S. District Court in Phoenix, Arizona, where Grupo Mexico has offices.
The company already faced a Mexican judge over the disaster but the 2007 manslaughter trial ended with payouts of about $16,500 to each family.
Grupo Mexico has been hit by repeated labor problems at its Mexican mines, including a 2-1/2 year strike at its largest copper pit Cananea that began over health and safety concerns. [ID:nN18198161] (Reporting by Mica Rosenberg; Editing by Lisa Shumaker)
Kleen River Gas Plant Explosion
There are parrallels which are worth noting, between the Coal Fueled Power Generation Industry and the recent Kleen River Gas Explosion in Conneticut. Those parrallels will yeild additional points of safety and technical best practices which can be used in our industry. However, the parrallel I wish to identify is that of being informed and noting any recent updates from agencies such as the Chemical Safety Board (CSB), OSHA, or MSHA. Such warnings can also come from Associations and User’s Groups who publish Best Practices.
Only three days before the massive explosion that killed at least five workers at a newly constructed natural gas plant in Middletown, Conn., the US Chemical Safety Board (CSB) issued urgent new recommendations on how to prevent explosions when handling or purging natural gas pipelines.
It is too soon to know what happened at Kleen Energy Systems. But workers at the site were reportedly purging a natural gas pipeline prior to the explosion.
In its documentation detailing why it was recommending new safety standards, the CSB cited incidents that show striking similarities to the Connecticut disaster. In at least seven incidents since 1997, workers have died and large-scale damage has been done to buildings as a result of pipelines being purged in an enclosed area.
“We have far more incidents in the database than the half dozen that we have listed,” says Sandy Gilmour, a CSB spokesman. “The incidents listed were just the ones that jumped out to our investigators, because they were severe cases or because they could be documented.”
I have worked with the CSB on occasion, and find them to be dedicated to the cause of safety and hazard prevention. They are not consumed with writing fines (they DON’T levy fines), rather they are consumed with finding causes, commonality, and methods by which Industries can be notified of unknown or little-known hazards.
We certainly should pay close attention to their findings, videos, papers, etc. Mr. Bresland, Director of the CSB will be speaking at the PRB Coal User’s Group Conference on May 18, 2010, in regards to Combustible Dust. OSHA leadership will also be speaking.
