Dusty Trail: The Movie

The season’s blockbuster includes white-hatted heroes, good-natured regulatory sidekicks, bar fights, and a lurking menace named Fugitive Dust.

Coal burns, and that’s good. Otherwise, it wouldn’t be of much use for generating electric power.

But getting it to burn in electric generating plants requires handling, and that creates coal dust. Coal dust explodes. That’s bad. Workers get hurt and killed, equipment gets damaged and destroyed.

And some coals—particularly the all-important subbituminous coal from the Powder River Basin (PRB) of Wyoming and Montana—are very prolific at producing combustible dust, which, when it escapes from the attention and control of the people who mine, move, and burn it, is known as fugitive dust. This fugitive is very dangerous indeed.

So it was that ELECTRIC POWER 2012’s conference track on coal and solid fuel power plants kicked off with a session on the importance of combustible dust management, in the form of a motion picture story board presented by American Electric Power’s Bob Taylor, the grand panjandrum of PRB coal, titled Dusty Trail.

The plot of Taylor’s celluloid extravaganza involved the trail of coal from mine to boiler, as it moves in trucks, rail cars, barges, and along belts of varying speed. It’s a parlous journey, as Taylor—AEP’s environment, safety, and health manager—knows well from his everyday experience. It’s also a tale of evolving, and sometimes confusing, regulation.

The characters in Dusty Trail include miners and plant workers, transporters, regulators, and, ultimately, consumers who pay the freight. Setting the stage, it’s important to recognize, as Bob Taylor said, that it isn’t just coal dust that can explode. So, too, can dust from woodworking, some metals (notably aluminum and magnesium), sugar, grain (grain elevator explosions can be spectacular), and even, notes the Occupational Safety and Health Administration (OSHA), dried blood.

Dusty Trail, Scene 1, takes us to Washington, D.C., and the U.S. Chemical Safety and Hazard Investigation Board, commonly known as the Chemical Safety Board. Established by the 1990 Clean Air Act amendments, this independent federal agency, which became operational in 1998, has the mission “to investigate accidents to determine the conditions and circumstances which led up to the event and to identify the cause or causes so that similar events might be prevented.” According to the board, as recounted by Taylor, between 1980 and 2005 there were 281 significant combustible dust “events” in the U.S., resulting in 718 injuries and 119 deaths.

The Chemical Safety Board finds facts after chemical accidents. In Scene 2 of Dusty Trail, we meet an actor, OSHA, part of the U.S. Department of Labor, that enforces laws and regulations aimed at protecting workers and preventing dust conditions that can cause damage and harm. OSHA also works with state agencies to police job sites. In the three years from 2007 to 2010, the U.S. experienced 1,566 federal and 423 state inspections under the occupational safety laws, with 7,053 federal violation notices and 2,198 state notices issued and $19 million in fines levied. Combustible dust violations, Taylor said at the Baltimore session, “continue to occur at an alarming rate.”

OSHA regulates through formal “standards” developed in a lengthy, complex, and cumbersome process, involving both the requirements of the Administrative Procedure Act and the specific law that established the agency. This year, the agency is expected to produce a new standard on “hazard communication,” which will include hazardous dust procedures. That process began three years ago. Meanwhile, a process to set a standard for combustible dust in the workplace, including power plants, is under way in what looks like a decade-long proceeding.

Congress has recently shown interest in combustible dust, bringing us to Scene 3 of Dusty Trail, where we meet the Education and the Workforce Committee in the House of Representatives (formerly known as the House Education and Labor Committee). Rep. George Miller (D-Calif.), the committee’s ranking minority member, in early 2011 introduced H.R. 522, the “Worker Protection Against Combustible Dust Explosions and Fires Act of 2011.” The purpose of the bill is to goose the OSHA standards process by requiring, according to the Congressional Research Service, an interim final standard regulating occupational exposure to combustible dust hazards. The standards would apply to manufacturing, processing, blending, conveying, repackaging, and handling combustible particulate solids and their dusts. In the wonderful world of Washington, the bill has languished in the House committee since it was introduced and has few prospects of moving any farther.

No Hollywood Western would be complete without a bar fight, and that brings us to Scenes 4 to 7 of Dusty Trail. The actors include OSHA, which is in the middle of what is likely to be a decade-long proceeding aimed at setting occupational exposure levels. In the meantime, the agency is functioning under a 2008 “national emphasis program” as it attempts to hammer out a final rule. Also in the mix is the National Fire Protection Association (NFPA), a voluntary industry group that develops consensus codes and standards, including NFPA 654, which covers preventing fire and dust explosions from the manufacturing, processing, and handling of combustible particulate solids. The standard was adopted in 2006 and is being revised with a new standard scheduled for this year, which will undoubtedly interact in some way with the OSHA process.

As Dusty Trail nears the end, it hits a fork in the road. Scene 8 poses the fundamental choice: Will those in the electric power industry who deal with the nasty side of coal and its propensity to ignite and explode choose the “proactive” path or the “reactive” path? As any good director would do, Taylor made the correct choice clear: The proactive strategy involves “acting in anticipation of future problems, needs, or changes,” while the alternative response means “reacting to the past, rather than anticipating the future.”

While Dusty Trail ends in ambiguity, with the choice clear but the outcome of the regulatory endeavors not yet in sight, there may be a sequel in the works. It’s likely the Powder River Basin Coal Users’ Group (PRBCUG) and ELECTRIC POWER’s general track on solid fuels will take another look at developments in the world of combustible dust at next year’s conference in Chicago, May 14–16.

For additional information about combustible dust and electric power plants, take a look at the PRBCUG website, http://www.prbcoals.com.

Kennedy Maize (kenmaize@gmail.com) is a contributing editor to POWER and executive editor of the online magazine MANAGING POWER (http://www.managingpowermag.com).