AEP Combustible Dust Initiative. Presented by Gary Hatcher, CIH EEI Spring Occupational Safety and Health Committee Conference April 21-24, 2009

Transcription

1 AEP Combustible Dust Initiative Presented by Gary Hatcher, CIH EEI Spring Occupational Safety and Health Committee Conference April 21-24, 2009

2 Agenda Overview of OSHA NEP AEP History with Combustible Dust Development of the Process Revelations of Zimmer Inspection The Process: AEP Combustible Dust Management Procedure Combustible Dust Checklist Tools and Resources Dust Hazard/Risk Process Engineering and Design Procedures Records Controls Ongoing Process

3 Overview OSHA Combustible Dust NEP NEP the acronym for National Emphasis Program Issued: October 18, 2007 Method used by OSHA to call attention or focus on existing standards as well as instructions for their enforcement Direct result of recent events Incorporates approximately 25 OSHA and NFPA Documents

4 AEP History with Combustible Dust Fatality during dust collector fire in 1993 Past efforts focused on eliminating housekeeping problems associated with combustible dust Focus on PRB coal Corporate driven, audit based Very little follow through Recurring problems as our focus shifted to other issues No process

5 AEP Initial Response to NEP We made fossil plants aware of the NEP and asked them to be prepared We established a small workgroup of S&H and Fire Protection employees to evaluate our program We quickly realized that there was no Process in place to anticipate, recognize, evaluate and control the hazard We listened attentively when Zimmer Plant experienced one of the first NEP inspections and adjusted our process

6 Jump Started Process Work group develop a comprehensive combustible dust process The process included a Combustible Dust policy and site review process to assist the facilities in determining compliance using internal resources The process included tools and resources to assist with the inspections and compliance Rolled out September Shared with local OSHA office

7 Engineering and Design Engineering & Design Electrical Classification Designations Equipment Grounding Methods Dust Collectors Location Equipment and Venting Configuration and Adequacy of Venting Material (type of dust) Feeders and Pulverizers Methods to Prevent Metals From Entering Design of Fire and Explosion Safety Provisions Process Hazard Analysis Documented and Maintained for Life of the Process Reviewed Every 5 Years and Changes Fire Protection (Detection and Suppression)

8 HazCom Program Procedures MSDSs for Coal On-Site Health Hazards Communicated Employee Rights How to Access Information Emergency Action Plan Fire Prevention Plan Drills and their Frequency Emergency Response (Industrial Fire Brigade) Ignition Control Programs Hot Work Process Smoking Policy Electrical Practices

9 Procedures Housekeeping Procedure Guidelines for Cleaning Methods (Washing) Frequency, (including Elevated Surfaces) PPE Hazard Assessment Clothing Requirements Industrial Hygiene Program Respirable Dust Sampling Frequency of Sampling

10 Records Plant history of fires, events & injuries Awareness/Education/Training Health Hazards/Risks Communicated Emergency Preparedness & Response Levels of Education/Training Drills and Exercises and Their Frequency Combustible Dust MSDS for Coal

11 Controls Process Hazard Analysis Review Initially and Every 5 Years Management of Change Equipment Operational and Maintenance Procedures Effective Dust Management Fire Detection and Suppression Housekeeping

12 Self-Assessment Housekeeping Effectiveness Frequency Effective Fugitive Dust Management Ignition Control Electrical Hot Work Process Fire Detection and Suppression

13 Next Steps Communicate successes and better practices Continuous Improve Refine Combustible Dust Procedures and Compliance Checklist Identify new tools Implement engineering controls as identified Ongoing Process Hazard Analysis 5 year reviews Design Review Board - Involvement with new projects and construction

14 The Compliance Checklist

15 Questions?