Belt Air Federal Advisory Committee Briefing. Ronald Reagan Building Washington, DC January 9-10, 2007. Historical Background of Belt Air Rule. Historical Background of Belt Air Rule. 1985 Ventilation Rule Pre-proposal included use of belt air
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Ronald Reagan Building
January 9-10, 2007
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.
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.
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
Court vacates 500 fpm velocity cap
Aracoma Alma Mine # 1 belt fire claims two lives
Advisory Committee – 1992 Report
Granted Petitions for Modification
Accident investigation reports (i.e. VP 8 Fire)
Research reports (i.e. RI 9380)
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
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.
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.
These are required in sections 75.351 (a) and (c)
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.
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.
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
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.
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.
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.
We have included requirements to include actions to be taken in the mine emergency evacuation and firefighting program.
All of these provisions are included in the rule.
All have been included but the requirement to report failures exceeding 8 hours. We believe this recommendation is not needed.
These provisions are included in the regulations.
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 .
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.
“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.
Extensive training requirements are included in the rule. Conducting competency examinations for AMS operators is not required.
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.
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.
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.
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.
Recent regulations address this issue..
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.
This issue was included in a separate rulemaking and was not included in this proposal.
The rule includes this requirement as recommended by the advisory committee
We believe existing regulations are adequate for enforcing cleanup and maintenance in the belt entry.
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.
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).
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
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
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
Mine Design requirement to protect intake escapeway
Maximum 50 percent section intake from belt
Intake Escapeway Restrictions on Equipment
Not required in 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
New Flame Resistant Belting required when available
Not required in Final Rule
Lifelines installed in escapeways
Lifelines in alternate escapeway (Return only)