Organization of 30 CFR The Mine Health and Safety Act The New Diesel Particulate Standards ©Feb 2003 Dr. Bradley C Paul

The Diesel Particulate Standards CoalNon-Coal SurfaceUndergroundSurfaceUnderground Chapter O Coal Mine Regs Chapter K Metal And Non-Metal Part 72 Underground Health Part 57 Underground Health Subpart D- 500 Series Diesel Particulate Subpart D Diesel Particulate Matter Note that these new Standards are found only In the Underground Regulations

New Diesel Particulate Standards Some roughly parallel regs in coal and metal –Since coal had long had special approval on diesel equipment results little less dramatic Standards are being phases in –Interim standards started in July 2002 Mostly an assistance phase –July 2003 come fully into force for interim standards –Full standards effective in 2006

The Diesel Particulate Problem Acute effects –Irritation and allergic reaction Chronic effects –Heart, cardiovascular and lung disease including cancer Miners exposure studies show U.G. Miner Exposure in the 200 to 2000 micrograms/cubic meter range –Ambient air is less than 10 –Rail workers and surface miners were high end around 160

Measurement Issues Problem – no way to really measure diesel particulate in the air at level needed for new protection standard Two approaches –Coal measures emissions from stack –Metal have substituted total carbon limit of 400 micrograms/cubic meter Studies shown that about 80 to 85% of total carbon comes from diesel particulate Used as a surrogate

Regulation is Split Coal and Metal Mines have almost a completely different approach to Diesel Particulate Control –Coal Standard is based on control of DPM levels from equipment If emissions are clean enough no further questions –Metal Standard is Performance Based Worker exposure is limited but operators have large discretion in determining how limits are met

Common Points Both Standards Require Inventories of Equipment –New equipment brought in after mid 2002 must meet new standards in terms of cleanliness of diesel engines –Whether equipment must comply is determined by whether the serial number of the engine was there or ordered before critical date (July 20, 2002) Coal Standard will require all mobile equipment to comply by July 2003 –Will phase in controls on other engines by 2005 Metal will retain grandfather status but still require occupational exposure results

The Coal Regs Engine output must be <2.5 grams DPM/hr –Unless fixed equipment discharging into a return or into intake air that goes directly to a return All miners must be trained in hazards of DPM –Health Risk –Methods Used by the Mine to Control –Identify who is in charge of compliance –What miners must do to make sure equipment works Must be trained every year –Can make it part of Part 48 training but then instructor must be MSHA certified –Not necessary if training is separate Must keep records of training and equipment

Acceptable Engines Can be stamped as approved –Can be MSHA approval –Or an EPA certification –Old equipment can be tested Independent contractors on site must meet the standard Engines must be worked on by qualified mechanics –Doesn’t say what qualified is but if equipment flunks the maintenance program goes under the microscope

Tagging Out If equipment not working must be tagged –Does not have to be taken out service –Do have to have worked on next maintenance shift or then must take out of service

Metal and Non-Metal Standards What is regulated is worker exposure over an 8 hour shift – not actual concentration –Sampling is done with personal samplers rather that workplace studies –MSHA did get one step ahead – banned the simple rotation of workers and jobs to meet compliance Other attempted regs turned back through court agreements –Wanted to ban personal protective equipment and so called administrative controls for compliance –Now PPE can be used if your not hitting interim standards –Administrative controls are allowed

Achieving the Standard Methods of Achieving Left to Operator –Interim Standard is worker exposure must be under 400 micrograms/meter cubed over an 8 hour shift –Final Standard after 2006 is set at 160 Still in litigation Regulation requires an ordering of trying controls –Must first attempt to control with engineering and administrative controls –Only then can personal protective equipment be considered

Compliance Techniques DPM Filters –Can cut 80 to 99% of DPM Easily bring common 800 micrograms/m^3 into line –Filter must be self regenerating Usually achieved by shifting hot exhaust flow and burning off –Some filters have come under fire for raising NOx which MSHA has now clamped –MSHA does provide some guidance and technical assistance

More Engineering Solutions Low Emission Engines –Old about 1 gram/break hp – hr –New are about 0.05 gram/break hp –hr –About 95% reduction – usually get compliance Environmental Cabs –Use filters to get cleaner in the cab (only about 50% effective – probably not enough by itself)

Environmental Cabs Cab needs to be pressurized HEPA Filter Need to maintain gaskets on doors and keep the windows up Does nothing for people outside the cab

Fuel Choices Some choices made –MSHA has required low sulfur in coal since 96 –Now coming into metal Has been required on highway since 92 Can use biodiesel (about 5 to 25% cut for 50% blend) –Diesel water emulsions about 30% cut Additives must be EPA approved –Concern about forming toxics

Other Engineering Solutions Remote Control –Effectiveness depends on location of remote operating stations and site character

Administrative Controls Job Rotation –This one is banned – rationale is it just exposes more people to carcinogens Ban unnecessary idling (puts out emissions with no work product) Train operators not to Lug engines –Ie low speed high load operation –Commonly an issue on older lower powered equipment

More Admin. Controls Using Speed Limits and limiting to one way travel Designate some areas off limits to diesel equipment (or perhaps non-equipment personnel) Control amount of horse power operating in any one area Miners must of course be trained that this is part of the DPM control plan and why it is important to them

Determining Compliance Mount filtered cyclones on peoples cloths They will love this inconspicuous contraption Based on personnel exposure – not area air conditions

How it Works Only submicron particles collected on the filter –Filter is analyzed for Elemental Carbon and Organic Carbon Organic carbon can be from other than DPM –Oil mists for example Measurements are used for compliance determinations

Avoiding False Positives Carbon concentration determined two ways –TC = Elemental Carbon + Organic Carbon –TC = Elemental Carbon * 1.3 (the proper ratio if it is DPM) Also put in an error range for testing –TC for combined * 1.14 –TC from elemental only * 1.12 –This gets a 95% confidence interval that if you are above you have a problem

Training and Record Keeping Required Training must be done yearly –Time, and duration not specified but record of training must be kept Mines must keep records of monitoring and inform miners when monitoring is to be done Must also keep inventory records on equipment