POWER May 2011 - 82

HEALTH & SAFETY
6. Squeaky clean. Have confidence that
you can keep your facility as clean as the
Dominion Kinkaid Power Plant, shown here.
Cleaning systems can be automatic or manual
(with hose reels, as shown). Note how effective
white walls are in showing dust accumulations.
Source: Mark Collett
ly cut back on the washdown and decrease
the amount of water used (Figure 6).
In addition, plant personnel should focus
on preventing mill puffs and associated explosions
by ensuring that the coal storage facility
is blanketed with an inert gas and by adequately
applying instrumentation to each system.
Creating a Plant Culture That
Promotes Safety
Plant management needs to assess and then
try to eliminate negative attitudes toward
housekeeping among the staff. Management
should encourage plant workers to
adopt a proactive culture that promotes a
full understanding of the gap analysis and
a well-prepared plan to resolve issues.
Another important way plant personnel can
most common causes of dust emissions
is the exit of entrained air and dust.)
■ Dust suppression, containment skirting,
and belt cleaners are also important
tools in dust management (Figure 5).
■ Dry fog requires specific water supply
standards and special care to eliminate
the aspiration of infectious pathogens
into the oropharynx (back of the throat)
of exposed plant workers. (See " Use
Dry Fog to Control Coal Dust Hazards, "
July 2010.)
Approximately 60% of all fire events in
our industry from 2008 to 2011 were attributable
to dry dust collectors, according to
comments made during the approval phase
of this EPA regulation. That estimate appears
to be accurate when compared with
the list of explosion/deflagration incidents
kept by the CSB.
The National Fire Protection Association
(NFPA) Standards further express the
requirements related to locations and conditions
surrounding such equipment, including
the need to move all indoor dust collectors
to outdoor locations. Facility workers need to
take care to maintain and clean these devices
if they are not removed or replaced.
Plant personnel need to practice regular
housekeeping to prevent combustible dust
from accumulating deeper than 1/16 inch
and covering more than 5% of a room's
total area. When enacted, the new combustible
dust standard will no doubt introduce
a new way to determine maximum depth.
Wash water designs first require adequate
drainage before one drop of water is
used. Yet, plant personnel will always need
to perform housekeeping washdown. As
workers' efforts to promote adequate POS
containment improve, they should carefulMay
2011 | POWER
Unlike service providers that have entered
the energy service business from other
industries, TurboCare has always focused
on the unique needs of the utility
and industrial turbomachinery operator.
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81
promote safety is through documentation of
safety-related issues. Recordkeeping can include
using the " Globally Harmonized System
of Classification and Labeling of Chemicals "
for managing chemicals. (See " HAZCOM Is
Essential for Avoiding Explosive Situations, "
p. 70.) In addition, job safety analysis procedures
and other standards can be useful to a
plant hazard analysis. The NEP lists the documentation
requirements that are essential to
complying with OSHA regulations.
In addition, plant management should
write out specific safety procedures related
to handling combustible dust and
train employees on those procedures.
They should make sure everyone is well
versed in the dangers specific to PRB coal
and combustible dust. Furthermore, plant
personnel should not try to apply grandfathering
rules related to specific practices
that have been established as " unsafe " by
OSHA and the NFPA.
Proactive Management of
Combustible Dust
Be aware that an unannounced in-depth
inspection by an OSHA compliance safety
and health officer is possible at any time. It
is critical that executives and plant managers
take a proactive approach in addressing
combustible dust hazards and other safety
issues. Manage the risk that combustible
dust poses to employees and equipment by
developing a culture of safety that is embedded
in each and every work activity. ■
-Mark R. Collett (markrcollett@gmail
.com) is a safety specialist who handles
compliance and projects and works for
Plant Professionals (P2), a division of
Benetech Inc.
The energy service business
is our only business
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POWER May 2011

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