Belt Air Federal Advisory Committee Briefing

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

6. Historical Background of Belt Air Rule

7. 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

8. 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

9. Recent Belt Air History - 2003 Proposed Rule published on January 27, 2003. 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.

10. Recent Belt Air History - 2003 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.

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

12. Recent Belt Air History - 2005 Court vacates 500 fpm velocity cap

13. Recent Belt Air History - 2006 Aracoma Alma Mine # 1 belt fire claims two lives

14. 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.

15. 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)

16. Advisory Committee Recommendations1992 Report

17. 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

18. Recommendation 2 The belt entry must have an early warning fire detection system. Fourteen individual items included under this recommendation. The requirements of 75.350 for installation and use of an atmospheric monitoring system is the cornerstone of the regulations permitting the use of belt air.

19. Item 1 • Actions required before using belt air • must include any ventilation system and monitoring changes in the mine ventilation plan • train miners and personnel for installation, maintenance, operation and inspection • 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 75.350 and 351. Specific training requirements are included in 48.23. Inspection of the AMS will occur at least quarterly during MSHA inspections.

20. Item 2 • Capabilities of the AMS • must self-monitor for system malfunctions • can operate for 4 hours after belt is turned off These are required in sections 75.351 (a) and (c)

21. Item 3 • Minimum velocity and location of sensors • minimum 50 fpm velocity • sensor spacing of 1,000 feet along belt entries • 50 feet inby the section tailpiece 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) 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.

22. Item 4 • Section alarms • provide a visual and audible warning signal • 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.

23. Item 5 • Responsible person at surface at all times • be on duty to see or hear alert/alarm • maintain records of alerts and alarms • have 2-way communication with all sections • be trained • 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 75.1502

24. Item 6 • 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) • 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 Actions required are included in 75.352. 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.

25. Item 7 • 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) • 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 75.352. 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.

26. Item 8 • Known causes for nuisance alarms include diesel, welding, blasting, calibration. The nuisance alerts can be reduced or avoided through • time delays, trending, other techniques • experience from petition process • 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.

27. Item 9 • Contents of fire fighting and evacuation plan • action required to determine cause of alert/alarm • location for withdrawal of miners • 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.

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

29. Item 11 • AMS malfunction • belt may continue to operate • responsible person notifies all sections affected • when a malfunction is determined • 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 All have been included but the requirement to report failures exceeding 8 hours. We believe this recommendation is not needed.

30. Item 12 • 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 These provisions are included in the regulations.

31. 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. 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 .

32. Item 14 • 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.

33. 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.

34. Recommendation 3 • 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 • 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.

35. 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. 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.

36. Recommendation 5 • 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.

37. Recommendation 6 • Velocities, both minimum and maximum, must provide air that will : • contain methane 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.

38. Recommendation 7 • 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.

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

40. Recommendation 9 • 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 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.

41. Recommendation 10 • 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.

42. Recommendation 11 • 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 The rule includes this requirement as recommended by the advisory committee

43. Recommendation 12 • 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.

44. Granted Petition for Modification Requirements

45. Agency Experience Our experience with petitions for 75.350 and belt fire accident investigations has been valuable in determining provisions of current petitions, which should be included in the proposed rule.

46. Recent Requirements for 75.350 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).

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

48. 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

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

50. 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