NFPA- DUST EXPLOSION HAZARD RECOGNITION AND CONTROL: NEW

STRATEGIES SYMPOSIUM
Best Practice Guidance for Identifying and Mitigating Hazards- Panel Discussion
Electric Generating Perspective
W. D. Snell
Loss Prevention Manager
Luminant
This session is on Best Practices and I feel that the best Best Practice is exactly what we have
been doing here the last couple of days. That is to share information, learn from others, develop a
network of contacts that help each of us to expand and refine his knowledge of the hazards with
combustible dusts and the means to mitigate or eliminate the potential for dust explosions.
From the electric utility perspective, our main dust hazard is coal dust. If you look at the numbers,
coal dust has a Kst of 129 1511, has a dust layer ignition temperature of 338-3560F, and a dust
cloud ignition temperature of around 8240F2. Coal has a heat release rate ranging from 15,000
BTU/lb for anthracite to a low of around 4,000 BTU/lb for lignite. From this it appears that coal
is an excellent fuel and that is why according to the US DOE3 in 2007 1,127,997 short tons of
coal were consumed in the US with 92.7% being consumed by the electric utility industry.
The benefit of this is that coal has been used in the generation of electric power for a long time
and it is still the number one type of fuel used in the United States in the generation of electric
power (48.5 % in 2007)4. This has a benefit when it comes to the way the electric industry views
dust from two perspectives. First, since it is the main fuel utilized in the combustion process in
utility boilers, the industry understands that the fuel will burn and can lead to explosions. The
process that is utilized in the power plants is to take the solid coal, run it through pulverizers to
grind the solid coal into a fine powder/dust, dry the product with heated air, and then inject it into
the boiler for combustion. The second point is that the coal is an integral part of the process and
the loss of fuel through fugitive dust impacts the cost of generation. Keeping fuel in the process
not only reduces the potential for a dust explosion but also adds to the bottom line in the cost to
generate electricity.
As I stated in the beginning, the number one best practice is to get involved. In regard to the
issue of coal dust in the electric industry, there are three groups that I would recommend. These
groups get together to address the hazards found in the generating facilities, discuss common
issues, hear about losses and the lessons learned, and develop documents that can provide
guidance to addressing the hazards.
The first group is the NFPA. Obviously you agree, which is demonstrated by your attendance and
participation in this symposium. NFPA provides the documents that pave the way for addressing
numerous hazards in not only our workplaces but in our lives. In the Electric Utility area of
NFPA, I would like to propose your involvement and utilization of NFPA 850 Recommended
Practice for Fire protection for Electric Generating Plants and High Voltage Direct Current
NFPA 68 Explosion Protection by Deflagration Venting 2007 Edition Appendix F
Coal Dust Explosion Hazards by Clete R. Stephan, P.E.
3
Energy Information Administration, http://www.eia.doe.gov/cneaf/coal/page/acr/table26.html
4
Energy Information Administration, http://www.eia.doe.gov/cneaf/electricity/epa/figes1.html
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2

Converter Stations. The current published version is the 2005 edition but the document is in
revision for the 2009 fall approval. The document was first officially released in 1986. The
document covers all aspects of the generating facility including:
Fire Risk Control program
General Plant Design
General Fire Protection Systems and Equipment
Identification of and Protection against Hazards
Fire Protection for the Construction site
In regards to coal dust, the chapter on Identification of and Protection against Hazards addresses:
coal storage and cautions about spontaneous heating and how that can be limited in the
coal pile storage through separation of different types of coal that are not chemically
compatible, working the pile to prevent dead pockets of coal, and locating the pile away
from heat sources
storage in bins, silos and bunkers including the provision of dust tight barriers between
boiler houses and the area above the silos, bunkers, or bins
dust suppression and control including methods to control dust, proper cleaning
methods, warning against the use of vigorous sweeping or compressed air and the use of
listed vacuum cleaners for the dust environment or the use of low velocity water
coal conveying and handling structures with attention to designing the structures to limit
the ledges for the accumulation of dust by utilizing beam shields or placing the structural
members exterior to the building; the section also addresses the use of approved
equipment in the areas, the electrical classification of the areas and means to reduce the
hazard of static electricity through permanent bonding and grounding
fire protection being recommended in coal handling structures, conveyors, bag-type dust
collectors
The document is in revision and with the most recent revisions to NFPA 654 Standard for the
prevention of Fire and Dust Explosions from the Manufacturing, processing, and handling of
Combustible Particulate Solids, there are also references to utilize NFPA 654 in addressing the
hazard of dust. There are many other aspects of protecting an electric generating facility
contained in the document. I would strongly encourage those associated with electric utilities to
utilize the document and become part of the consensus process. This can be accomplished
through the use of the document, and by reviewing the document and providing proposals and
comments through the NFPA process.
The second group I would encourage you to participate in is the Edison Electric Institute (EEI)
Fire Protection and Loss Control Sub-Committee. The EEI is the association of U.S.
Shareholder-Owned Electric Companies. EEI members serve 95 percent of the ultimate
customers in the shareholder-owned segment of the industry, and represent approximately 70
percent of the U.S. electric power industry. The members of the committee are those individuals
involved in the area of fire protection at their respective utilities. While you have to be a member
of EEI to be a member of the committee, there are others representing insurance companies, AE
firms, manufactures, and consultants, who are involved in one way or another with electric
generating facilities. The committee generally meets twice a year and during the meeting there
are presentations on losses, topics of interest, topics that are receiving attention such as dust,
updates on codes and standards of interest to the group, tours as applicable and available such as
new generating technologies, and very importantly the opportunity to discuss with your peers
similar problems and suggestions for solutions. The committee has also published many papers
addressing the industry best practices and it is presently getting ready to publish a white paper

titled COAL DUST A PROBLEM HERE AND NOW A PRIMER ON HOW TO DEAL WITH
AN EXPLOSIVE ISSUE If you are interested in becoming a part of this group , you should
contact the present committee Chairman, Bob Green, Senior Consultant, Risk Management,
PSEG Services Corp, Newark, New Jersey, (973) 430 6501, email Robert.green2@pseg.com.
The third group that is relatively new is the PRB Coal Users Group. Its website is
www.prbcoals.com. PRB stands for Powder River Basin Coal which represents the low sulfur
western coals that utilities began to utilize to address the EPA national standard to restrict the
emission of sulfur dioxide.
The western fuel is a sub-bituminous coal that is usually blended
both with the lower ranked lignite grade coal and the higher BTU bituminous coal. When utilities
started to integrate the PRB coal, there was a notable increase in the frequency and severity of
fires associated with the coal. Since the PRB is a lower grade of coal, it is more likely to
experience spontaneous combustion, which was new to the utilities that had previously only
burned bituminous coal. The PRB coal also produces more dust than the bituminous coal and
since it had a lower BTU content, more fuel was being processed than the original systems may
have been designed for. This could increase the chance of spillage. With this increase in
problems, the PRB coal users group was formed to address this issue in a unified approach and to
provide a means to share information. The goals of the PRB Coal Users group are:
promote the safe, efficient and economic use of Powder River Basin coals by generating
companies who currently use, or are considering the use of PRB coals
encourage the safe, economical use of PRB coals by those who elect to utilize the
resource
establish best practices for the safe operation and maintenance of PRB coal handling and
storage systems based on best available technologies
develop and maintain a data base of PRB coal users, both in North America and overseas
work with EEI, the American Coal Council and other involved industry groups
The users group membership is comprised of not only electric generating utilities but also
vendors, manufacturers, and other experts who are involved with the industry in addressing
this issue. The PRB Coal users Group has been very active in addressing combustible dust
through the provision of free Webinars, especially PRB 101 which is available on its
website, the publishing of Best Practices paper including one being drafted on Electrical Best
Practices, and providing for an annual meeting to share information and present papers. This
annual meeting is held in conjunction with the annual Electric Power Conference.
Another function that the PRB Coal Users group performs is to recognize each year the PRB
Coal Plant of the Year for its innovation and the implementation of best practices and best
available technologies. An article is also published in Power magazine about the selected
facility. Luminant is proud to state that its Monticello Steam Electric Station was given this
recognition in 2006 and the Big Brown Steam Electric Station was recognized in 2008.
Luminant, a subsidiary of Energy Future Holdings Corp.(EFH), is a competitive power
generation business, including mining, wholesale marketing and trading, construction and
development operations. Luminant has over 18,300 MW of generation in Texas, including
2,300 MW of nuclear and 5,800 MW of coal-fueled generating capacity. Luminant is also
the largest purchaser of wind-generated electricity in Texas and fifth largest in the United
States. EFH is a Dallas-based energy holding company that has a portfolio of competitive
and regulated energy subsidiaries, primarily in Texas.

At Luminant, we have always been keenly aware of the issues involving coal and dust since
the fuel that we use is lignite. With lignite, there is more susceptibility to spontaneous
combustion. Due to the low BTU content, Luminant facilities handle a large volume of fuel.
In the mid 90s Luminant began to introduce the use of western fuel to address the EPA
standard for reduction in sulfur dioxide emissions. With this introduction of a new fuel and
based on the experience that other utilities were having, a review of the fuel handling
operations began. Upgrades were made in the following areas:
containment improvements on all loading zones of transfer points throughout the fuel
handling system through new impact and support roller beds and rubber skirting and
sealing of chutes and head boxes
the height and length of the load zone containment was increased to allow the dust
time to settle inside the containment area
capital improvements for dust suppression at unloading stations, crushers, and
transfer points
equipment is taken out of service on a daily basis to allow for wash down
repainted the tunnels and coal handling structures
improved the lighting
repaired beam shields that had corroded
utilization of high efficiency loading systems at transfer points
dust collector upgrades to N type rotoclones
While the above improvements are significant and resulted in an investment of budget dollars, the
most important action in the plants was a renewed level of management support, retraining, and
an increased emphasis on housekeeping. All of these have added greatly to improving the risk at
the Luminant coal fired units.
At the fall 2006 meeting of the EEI Fire Protection and Loss Control Sub-Committee, a
presentation was made on the Chemical Safety Board (CSB) investigation in the hazards
associated with combustible dust. Beginning with that presentation, the EEI has been actively
tracking and reporting on the activity associated with combustible dust. At Luminant, this was
reported to upper management and Luminant began to track the actions of the CSB. The CSB
report was released in November 2006. This report followed by the release in October 2007, of
OSHAs Combustible Dust National Emphasis Program inspired Luminant to again look at the
dust control program within the Luminant coal handling facilities.
Management decided that while we had made significant progress in addressing the concerns of
combustible dust, the issues involved and the catastrophic results of the Imperial Sugar explosion
mandated that we take another focused look at our facilities. Upper management directed a Coal
Dust Task force be developed headed by a coal plant Director of Generation and the Luminant
Generation Director of Safety. The team consists of the fuel handling superintendents from each
of the coal plants, members of the Luminant Loss prevention group, a facilitator with both plant
and environmental experience, and a member of the Luminant Operating System.
The team
decided that the best approach would be to develop a corporate program that would require each
site to develop a site specific program that mirrors the corporate program. The decision was
made to standardize, as far as practical, the training, forms, procedures, and audits that would be
utilized throughout the fleet.
The corporate program was developed based on the elements
discussed in the National Emphasis Program, the 2005 OSHA Safety and Health Information
Bulletin issued in July 2005 titled Combustible Dust in Industry: Preventing and Mitigating the

effects of Fire and Explosion, NFPA 654, OSHA 1910.272 Grain Handling Facilities, and the
principles of Process Safety Management.
After much discussion, the team decided on the program consisting of the following parts:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.

Scope
Requirements
Responsibility
Emergency Action Plan
Training
Housekeeping
Dust Control equipment
Preventative Maintenance
Fire protection
Control of Ignition Sources
Audits
Management of Change
Record keeping

In the scope, it has been determined that the program will apply to the fuel handling area of
the facility from unloading of the coal cars to the bottom of the silos on the boiler. These
areas are defined in the NESC Article 127A as coal handling areas and therefore are
classified as Class II Division II Group F in all areas except for the inside of chutes,
headboxes, or silos where we consider that to be Class II Division I group F locations. The
area from the silo through the feeders, the pulverizers, and to the boiler are not considered as
fuel handling per item 5 of the NESC, where it states that locations having completely dusttight pulverized systems designed and installed in compliance with NFPA 8503-1997 shall
not be considered classified. It is also necessary to realize that the Luminant plants are open
design with the boiler structure not enclosed.
It is recognized that sometimes there might be a leak in fuel piping or other equipment that
could release dust in an area that is not intended to have dust. The program recognizes this
and states that if dust is found in an area not covered by the program that: the Fuel
Housekeeping procedures developed for handling dust be utilized; the reason for the dust be
investigated and corrected to prevent future infiltration of dust; and if the reason for the dust
cannot be corrected, then the area where the dust was found might need to be reclassified and
be added to the program.
The requirements of the corporate program call for each site to develop a site specific
program, a site drawing showing the areas of the facility covered by the program including
the electrical classifications contained within the scope of the program, and a sheet containing
factual information of the facility.
Overall responsibility for the corporate program is given to the Senior Vice President over
fossil generation and each sites director of generation has responsibility for their site. The
program also calls for the appointment of a coal dust management program coordinator who
will be responsible for the implementation of the program of the site. They will not be

responsible for performing all activities with the program but are responsible for ensuring that
it is being completed.
The sites Emergency Action Plan is referenced which already exists and details actions to
take in the event of an emergency. The provision of escape routes for the areas covered by
the program and annual drills are also specified.
Training is a key part of the program, as the team felt that it was the lynchpin of the entire
program. The program calls for initial training for all new employees to address dust control,
recognition, and prevention of combustible dust hazards. This is in addition to the basic
safety training that covers hot work, lock out tag out, confined space, HAZCOM, proper use
of personal protective equipment, etc. The program calls for initial site training for site
specific actions and annual refresher to cover all of the above. A training program was also
developed to be provided to contractors who work on site to ensure they are aware of the
hazards of coal dust associated with the area they will be working in at the specific site.
Keeping the area free of combustible dust and ensuring that proper methods are employed is
covered through the use of a Fuel Handling Housekeeping procedure which calls for daily
wash down, reporting of fuel spills, and cautions involving hot fuel. Large fuel spills and dust
accumulations should only be removed utilizing non-sparking tools or water hoses. The use
of compressed air is strictly prohibited. Vacuums must meet the proper classification to be
used. Vacuuming by a contractor who specializes in the removal of coal dust is acceptable
if they have written procedures for the activity that have been reviewed and approved by the
sites coal dust coordinator. This includes ensuring that the vacuum truck is grounded and the
area is watered down initially and during operations. The vacuuming is not of dry dust but
wet coal/dust.
A Luminant form has been developed for each site listing the dust control equipment that has
been provided on site. The form will list each piece of equipment including the name plate
data, the design basis, and the procedures for the inspection, testing, and maintenance of the
equipment. While the procedure is not included, the number of the PM is listed along with the
frequency. The handling of impairments to dust control equipment identical to the handling
of fire protection system impairments was also included.
The inspection and maintenance practices for the equipment in the fuel handling area are also
listed in a summary table. The equipment includes: fuel flow elements such as chutes, hoods,
belt scrapers, electrical ignition sources including lights, grounding, control cabinets;
mechanical heat sources such as bearings, belt alignment, pulleys and couplings, and safety
equipment such as emergency lighting, magnetic separator, emergency stops, pull cords,
misalignment switches and guarding. In our review we found that some of the PMs for these
activities needed to be revisited and that some needed additional development to be
developed to ensure the equipment was being properly maintained.
Each site has a Site Fire Protection Program which covers all aspects of the sites fire
protection including:
systems, procedures, fire brigade organization and response,
development of fire preplans, fire impairment handling, and the inspection, testing, and
maintenance of fire protection equipment including the areas covered by the dust
management program.

Control of ignition sources was one of the easiest sections but also the one we are having the
most difficult finishing. The section was easy as Luminant already has existing programs for
prohibiting smoking, and a cutting and welding permit program. Added to the program was
the requirement for the placement of dust warning signs. The difficult task was the
development of a program to address the use or limiting the use of spark producing
equipment in the classified areas covered by the program. Through our property insurance
carrier, FM Global, we were made aware of the criteria contained in ISA RP-12.12.03-2002
Recommended practice for Portable Electronic Products Suitable for Use in Class I and II,
Division 2, Class I Zone 2 and Class II, Division 1 and 2 hazardous ( Classified) Locations.
This document provides guidance for handheld equipment such as cell phones that might be
needed in a classified area. It also contains a permit system referred to as a Gas Free Work
permit that details a program for allowing work involving potential ignition sources to be
performed in a classified area by ensuring that the atmosphere where the work is to be
conducted does not contain an ignitable concentration of flammable gas or vapors. The
document mentions that it could be utilized in class II locations. The team is working
through the development of a permit system for utilization in the classified areas of the plant
following the guidance in the ISA document. The team realizes that in some instances that
equipment not listed or approved for the classified area has to be used. In those instances,
similar to cutting and welding, the area has to be made and remain safe during the work
operations.
The program also calls for audits to be conducted and documented. Audits consist of both
internal audits and external audits and even a five year overall independent review of the
entire program by a company not involved in the other audits to ensure that the program is
functioning as intended and to add a third party review. The internal audits consist of daily
inspections by operators, monthly inspections by the fuel area superintendant/supervisor,
monthly fire prevention inspections as called for by the sites Fire protection Program, and a
semi-annual Corporate Loss Prevention inspection of the entire facility including the area
covered by the dust control program. The program also requires that a biennial audit of each
sites program by an internal audit team be performed to ensure compliance with the Dust
Control Program. External inspections of the areas covered by this program are conducted by
Luminants property insurance carrier and annually by an organization/vendor knowledgeable
in dust control. An integral part of the audit program is the provision of a tracking system to
capture the results of the audits, prioritize the recommendations/actions and then track the
recommendations to closure. Documentation of implementation of the recommendation or
justification for not implementing is also necessary.
In following the guidance of process safety management, the program requires that an audit
of the entire Luminant Dust Control Program be conducted by a third party every five years.
The intent of this audit is to provide a complete review of the corporate program to ensure
that the program is dynamic and is keeping current.
A Management of Change procedure is necessary to ensure that changes that could impact
personnel safety, safe equipment operation, and process reliability in the coal handling
process, other than replacement in kind, are identified, assessed, and the results of the
assessment are communicated to employees.
The documentation to provide evidence of the completion of the components of the program
is required to be kept in a readily available location and format. Without any other
requirements, the team decided that the following criteria shall be used.

annual drill- five years

training- duration of employment
housekeeping /audits as applicable
o

daily- three months

weekly- six months

monthly one year

quarterly/semiannual- two years

annual - five years

greater than annual life of plant

A great deal of effort and time has been committed to the development of the Luminant Coal
Dust Management Program and it is recognized that the program will be a dynamic living
document that must be modified to address site needs and integrate potential legislation.
Luminant management discussed that we had what is considered a good approach in
addressing combustible dust and that in the absence of a specific standard, it might be better
to wait for its development. However, due to the nature of the problem and potential impact,
management decided that it would not be prudent or in the best interest of the company to
wait.
It has been and continues to be a great lesson in teamwork to address a common problem that
the Luminants coal plants need to address. As I said earlier, the best Best Practice is get
involved. Talk to your peers and jointly and together solve your problems.
In closing I would like to quote Edmund Burke Irish orator, philosopher, & politician (1729 1797) who said "Nobody makes a greater mistake than he who does nothing...".