Belt Air Federal Advisory Committee Briefing Ronald Reagan Building Washington, DC January 9-10, 2007

Historical Background of Belt Air Rule

  1985 Ventilation Rule Pre-proposal included use of belt air   1988 Proposed Ventilation Rule included use of belt air – Six public hearings   1989 MSHA Belt Entry Ventilation Review Committee reports Belt Air can be used safely with precautions   1990 Belt- Air Hearing takes place in Reston, Virginia

Historical Background of Belt Air Rule (cont.)   1991 Secretary of Labor forms Federal Advisory Committee on Belt Air   1992 Final ventilation rule excludes Belt Air, defers to Advisory Committee which concludes that Belt Air can be used to safely ventilate working faces provided certain conditions are met   Belt-Air Rulemaking is placed on the Regulatory Agenda in 1992

Recent Belt Air History Proposed Rule published on January 27, Public Comment period ended March 28. Public Hearings held in April and May. Birmingham, AL Lexington, KY Charleston, WV Washington, PA Grand Junction, CO Post-Hearing comment period ended June 30.

Recent Belt Air History Belt Air Committee prepares responses to written comments and testimony from public hearings, and prepares Final Rule. Final Rule sent to Policy Planning Board November 21.

Recent Belt Air History Final rule published April 2, 2004 Most provisions effective June 1, Two provisions effective August 2, 2004 (Communications and Sensor Spacing) Mine operator challenges 500 fpm velocity cap requirement due to inadequate notice

Recent Belt Air History Court vacates 500 fpm velocity cap

Recent Belt Air History Aracoma Alma Mine # 1 belt fire claims two lives

Advantages of Belt Air Use   Allows quicker detection of combustion   Increases the efficiency of the ventilation system   Can allow for greater quantities of air at the face   When used to increase the total quantity of air, it dilutes methane and respirable dust  Ground conditions may be enhanced due to less entries needing to be developed.

Guidance in Developing The Proposed and Final Rule Advisory Committee – 1992 Report Granted Petitions for Modification Accident investigation reports (i.e. VP 8 Fire) Research reports (i.e. RI 9380)

Advisory Committee Recommendations 1992 Report

Recommendation 1 Belt entries can be safely used as intake air courses to ventilate working places provided additional safety and health conditions are met. These additional concerns are addressed in the regulation

Recommendation 2 The requirements of for installation and use of an atmospheric monitoring system is the cornerstone of the regulations permitting the use of belt air. The belt entry must have an early warning fire detection system. Fourteen individual items included under this recommendation.

Item 1 Actions required before using belt air Actions required before using belt air must include any ventilation system and monitoring changes in the mine ventilation plan must include any ventilation system and monitoring changes in the mine ventilation plan train miners and personnel for installation, maintenance, operation and inspection train miners and personnel for installation, maintenance, operation and inspection have MSHA inspect AMS have MSHA inspect AMS All changes to the ventilation system require changes in the mine ventilation plan under current regulations. Training requirements for all miners and specialized training are included in and 351. Specific training requirements are included in Inspection of the AMS will occur at least quarterly during MSHA inspections.

Item 2 Capabilities of the AMS Capabilities of the AMS must self-monitor for system malfunctions must self-monitor for system malfunctions can operate for 4 hours after belt is turned off can operate for 4 hours after belt is turned off These are required in sections (a) and (c)

Item 3 Minimum velocity and location of sensors Minimum velocity and location of sensors minimum 50 fpm velocity minimum 50 fpm velocity sensor spacing of 1,000 feet along belt entries sensor spacing of 1,000 feet along belt entries 50 feet inby the section tailpiece on same air split 50 feet inby the section tailpiece on same air split at belt drive, between 50 and 100 feet inby, on same air split at belt drive, between 50 and 100 feet inby, on same air split inby end of section track ( when belt and track are in separate entries not separated by stoppings) inby end of section track ( when belt and track are in separate entries not separated by stoppings) As a result of new research, spacing can be decreased to 350 feet where velocities are less than 50 fpm. For areas where velocities exceed 50 fpm, 1000 ft maximum spacing is required. Rather than a sensor located at the end of the track, the proposal requires a sensor at the end of the primary escapeway as well as in the panel.

Item 4 Section alarms Section alarms provide a visual and audible warning signal provide a visual and audible warning signal capable of being seen or heard by all section personnel capable of being seen or heard by all section personnel The rule requires alarm signals to be automatically indicated on the section as well as the surface. Alert signals are indicated on the surface and an investigation of the source is to be initiated.

Item 5 Responsible person at surface at all times Responsible person at surface at all times be on duty to see or hear alert/alarm be on duty to see or hear alert/alarm maintain records of alerts and alarms maintain records of alerts and alarms have 2-way communication with all sections have 2-way communication with all sections be trained be trained take appropriate action take appropriate action All provisions are included in the rule. Appropriate actions to be taken are to be specified in the fire fighting and evacuation plan required under existing section

Item 6 Actions underground upon alert or alarm Actions underground upon alert or alarm alert - miners withdrawn to a safe location outby affected sensor until cause is determined (unless known not to be hazardous) alert - miners withdrawn to a safe location outby affected sensor until cause is determined (unless known not to be hazardous) alarm - same as alert, plus mine fire fighting and evacuation plan is implemented alarm - same as alert, plus mine fire fighting and evacuation plan is implemented belt may continue to operate at the discretion of the mine operator belt may continue to operate at the discretion of the mine operator Actions required are included in Withdrawal of personnel on alert is not required, but rather an investigation is to be initiated to determine the source of the alert. We have not restricted operation of the belt as suggested by the advisory committee report.

Item 7 Actions at surface upon alert or alarm Actions at surface upon alert or alarm alert - no one enters affected area except to investigate the cause of the alert (unless known not to be hazardous) alert - no one enters affected area except to investigate the cause of the alert (unless known not to be hazardous) alarm - no one enters the mine except to investigate the cause of the alarm (unless known not to be hazardous) alarm - no one enters the mine except to investigate the cause of the alarm (unless known not to be hazardous) Actions to be taken are included in We have not included restrictions on personnel entering affected areas on alert or alarms. Our experience is that only persons required to conduct an investigation or assist in fire fighting activities will be entering under these circumstances.

Item 8 Known causes for nuisance alarms include diesel, welding, blasting, calibration. The nuisance alerts can be reduced or avoided through Known causes for nuisance alarms include diesel, welding, blasting, calibration. The nuisance alerts can be reduced or avoided through time delays, trending, other techniques time delays, trending, other techniques experience from petition process experience from petition process planning and communication planning and communication We have included in the provisions for using techniques for reducing the frequency of nuisance alarms with a requirement of demonstrated need. Our experience from petitions has limited time delays to three minutes.

Item 9 Contents of fire fighting and evacuation plan Contents of fire fighting and evacuation plan action required to determine cause of alert/alarm action required to determine cause of alert/alarm location for withdrawal of miners location for withdrawal of miners specific procedures to follow when alert/alarm activates specific procedures to follow when alert/alarm activates We have included requirements to include actions to be taken in the mine emergency evacuation and firefighting program.

Item 10 AMS calibration, testing examination and records AMS calibration, testing examination and records visual exam of each sensor each shift visual exam of each sensor each shift weekly testing of alert and alarm signals weekly testing of alert and alarm signals calibration of each sensor every 31 days calibration of each sensor every 31 days maintain records on the surface for 1 year maintain records on the surface for 1 year All of these provisions are included in the rule.

Item 11 AMS malfunction AMS malfunction belt may continue to operate belt may continue to operate responsible person notifies all sections affected responsible person notifies all sections affected when a malfunction is determined when a malfunction is determined qualified person monitors at malfunctioning sensor location and patrols if multiple sensors fail qualified person monitors at malfunctioning sensor location and patrols if multiple sensors fail if system fails, walk entire belt entry each hour; after 8 hours call MSHA district manager if system fails, walk entire belt entry each hour; after 8 hours call MSHA district manager All have been included but the requirement to report failures exceeding 8 hours. We believe this recommendation is not needed.

Item 12 The mine ventilation map should contain details of the AMS, including type of sensor and sensor location The mine ventilation map should contain details of the AMS, including type of sensor and sensor location The mine ventilation map should be posted at the mine The mine ventilation map should be posted at the mine These provisions are included in the regulations.

Item 13 Slippage switches should be integrated into the early warning fire detection system. Smoke sensors, when available, should be installed at all belt drives. Slippage switches should be integrated into the early warning fire detection system. Smoke sensors, when available, should be installed at all belt drives. We have not included a requirement for smoke sensors to be installed at all drives. This is an option for the mine operator as these sensors become commercially available. Slippage switches are not included in the AMS system but act independently.

Item 14 Backup communication systems are recommended for redundancy. Backup communication systems are recommended for redundancy. The rule requires two separate means of communication installed in separate entries. We consider the AMS one form of communication; the second is required to be two- way.

Velocity Caps “The Committee expects that in establishing alert and alarm levels the Agency will be guided by all appropriate research including RI 9380 and Dr. Grosshandler’s independent review” The rule allows the district manager to require reduced alert and alarm levels on a mine by mine basis. We agree with the advisory committee report discussion that all available research should be considered as guidance in this matter.

Recommendation 3 Miners should be trained in basic principles of the systems and actions required in alarms. Miners should be trained in basic principles of the systems and actions required in alarms. Personnel responsible for installation, maintenance, operation and inspection of the system should be trained Personnel responsible for installation, maintenance, operation and inspection of the system should be trained The AMS operator competency should be assured by examination by MSHA The AMS operator competency should be assured by examination by MSHA Extensive training requirements are included in the rule. Conducting competency examinations for AMS operators is not required.

Recommendation 4 In mines using an AMS as a condition for using belt air, the minimum air velocity in the belt entry must be 50 fpm. In mines using an AMS as a condition for using belt air, the minimum air velocity in the belt entry must be 50 fpm. Until recent research indicated lower velocities with reduced sensor spacing was effective for fire detection, this was required in all petitions. With the results of this research, the rule requires 1000 foot spacing with a minimum velocity of 50 fpm, or 350 foot spacing for less than 50 fpm.

Recommendation 5 MSHA should develop approval schedules for AMS, including performance standards, while maintaining flexibility to permit advances in technology. MSHA should develop approval schedules for AMS, including performance standards, while maintaining flexibility to permit advances in technology. The rule does not include approval schedules. Rather, the rule requires that all components of the AMS be listed or certified by a nationally recognized testing laboratory, or be approved for use by the Secretary.

Recommendation 6 Velocities, both minimum and maximum, must provide air that will : Velocities, both minimum and maximum, must provide air that will : contain methane within limits contain methane within limits contain dust within limits contain dust within limits The rule includes requirements for air quality as suggested by the committee, and includes establishing permanent designated areas for respirable dust sampling. Methane limits are already addressed in existing regulations.

Recommendation 7 The minimum air velocity should be able to reduce the potential for methane layering and transport the products of combustion between sensors The minimum air velocity should be able to reduce the potential for methane layering and transport the products of combustion between sensors Recent research has shown that spacing requirements for velocities both above and below 50 fpm will provide adequate fire detection capabilities. Methane layering is prohibited by existing regulations.

Recommendation 8 Directional lifelines should be installed and maintained in all primary and alternate escapeways Directional lifelines should be installed and maintained in all primary and alternate escapeways Recent regulations address this issue..

Recommendation 9 Ventilation of the escapeways should consider the interrelationships among all aspects of the mining system (Haulage, production, ventilation, etc) Ventilation of the escapeways should consider the interrelationships among all aspects of the mining system (Haulage, production, ventilation, etc) the integrity of the air in the primary escapeway the integrity of the air in the primary escapeway the alternate escapeway should be in intake air and use a physically separated split of intake air the alternate escapeway should be in intake air and use a physically separated split of intake air While these issues have merit, even the Advisory Committee realized the difficulty in requiring these provisions in regulation. The rule does require monitoring of the intake escape way.

Recommendation 10 Improved conveyor belting material should be required by regulation - MSHA should move rapidly. Improved conveyor belting material should be required by regulation - MSHA should move rapidly. This issue was included in a separate rulemaking and was not included in this proposal.

Recommendation 11 Alert and alarm levels for AMS should not exceed 5 ppm and 10 ppm above ambient respectively Alert and alarm levels for AMS should not exceed 5 ppm and 10 ppm above ambient respectively MSHA may require lower limits should conditions warrant MSHA may require lower limits should conditions warrant The rule includes this requirement as recommended by the advisory committee

Recommendation 12 Increased emphasis should be placed on belt entry cleanup and conveyor belt maintenance. Increased emphasis should be placed on belt entry cleanup and conveyor belt maintenance. We believe existing regulations are adequate for enforcing cleanup and maintenance in the belt entry.

Granted Petition for Modification Requirements

Agency Experience Our experience with petitions for and belt fire accident investigations has been valuable in determining provisions of current petitions, which should be included in the proposed rule.

Recent Requirements for Proposed Decision and Orders Nearly all requirements of Proposed Decision and Orders are included in the final rule. The following exceptions are identified from all PDOs for the years 2000 and 2001 (20 petitions).

Latest PDO Requirements Modified for the Final Rule Section alarms automatic feet Final rule exceeds petition language and requires possible according to conditions all sensors activation for all affected areas – not limited to 4000 feet Alert/Alarm settings from Tables Rule maximum of 5/10 ppm with lower levels Alarm signals for consecutive sensors in alert status

Latest PDO Requirements Modified for the Final Rule Maximum air quantity 202,000 cfm No limits in rule - reduced alert/alarms may be required through mine ventilation plan approval Velocity cap of 500 fpm unless otherwise approved (This requirement was later stayed) Air velocities must be compatible with fire detection and suppression systems

Latest PDO Requirements Modified for the Final Rule Method for determining ambient CO levels specified Method and level approved in mine ventilation plan Study required for multiple entries in common with belt Not required in draft - mine by mine basis Petitions allowed for alternate methods

Latest PDO Requirements Modified for the Final Rule Mine Design requirement to protect intake escapeway Maximum 50 percent section intake from belt Intake Escapeway Restrictions on Equipment Not required in Final Rule

Latest PDO Requirements Modified for the Final Rule Minimum velocity of 50 fpm Lower velocities are permitted with reduced CO sensor spacing (350 feet) Automatic activation of alarms for sections on same split Changed to sections in affected areas

Latest PDO Requirements Modified for the Final Rule New Flame Resistant Belting required when available Not required in Final Rule Lifelines in alternate escapeway (Return only) Lifelines installed in escapeways

Conclusions Final rule closely tracks Advisory Committee recommendations. Final rule closely tracks Advisory Committee recommendations. Most requirements from existing Petitions are included in some form. Most requirements from existing Petitions are included in some form. Rule has the potential for improving health and safety while providing cost savings to the mining industry. Rule has the potential for improving health and safety while providing cost savings to the mining industry.