&ldquo;You know you&rsquo;re making fuel, right?&rdquo; This is a question I often found myself asking as new wood pellet and biomass plants started sprouting up in North America, especially in the Southeast U.S. I didn&rsquo;t say this to be rude, but to point out potential combustible dust and ignition issues. Every engineering firm and large equipment manufacturer seemed to think they could build a wood pellet plant better than the last, so naturally, many of the designs are different. Some are efficient, and some not so much. Some were built with the proper engineering controls designed in, and for others, fire and explosion protection seemed to be an afterthought. The Problem, Complacency In my job, I get the opportunity and privilege of making site visits to many of these wood pellet operations, as well as many other types of combustible dust processes. Often, there is a disconnect from safety theory to actual practice. I go through many variations of safety orientation at these plants, and then walking through the facility, will see posters that say &ldquo;safety first,&rdquo; all the while walking around on layers of combustible dust! What if I told you combustible dust could be just as flammable or explosive as gasoline? Or that wood dust bin explosions are just as powerful as grain elevator explosions? Would that change how you view combustible wood or biomass dust? Some established and reputable companies dismiss the idea of building a conveyor that is dust-tight. But if a plant had a combustible gas leak, it would not continue to operate. Instead, it would be shut down, and the leak fixed prior to starting back up. If they had a fuel, gasoline or other flammable liquids spill, their first responsibility would be to evacuate the area, fix the problem and clean up the mess. Yet, when it comes to combustible dust, we seem to be blind to the potential hazard. Because we work around it every day, over time, some level of complacency tends to develop. Training and housekeeping become critical to preventing fires, explosions and catastrophic secondary explosions. Another thing that makes me cringe is hearing someone say, &ldquo;That&rsquo;s the way we have always done it,&rdquo; or &ldquo;We have been running this way for years,&rdquo; or &ldquo;Fires are just part of the process.&rdquo; This is complacency, lack of education to the hazard, and really, a lack of respect for the danger of combustible dust. Plants change. Machinery wears over time, products change, specifications change. Change management is critical to stay on top of safety. So is constant improvement and training. Combustible dust layers on equipment and machinery, walls, floors, rafters, cable trays, conduit, and piping are an indication of this disconnect, complacency and understanding of a potential combustible dust incident. Many times after touring plants with layers of combustible dust around it, I find they have indeed had previous fires or explosions. Understand, if you are having fires and explosions, no matter how minor, they are potential precursors to a bigger event. You may be witnessing leading indicators of future problems. Any time you move or manipulate a combustible product, you are creating friction and heat as well as combustible dust, and therefore have potential for fires and explosions. Fire Triangle/Explosion Pentagon The three main areas of concern for creating fires in the biomass process are dryers, hammer mills and pelletizers. Conveyors and other moving machinery are a secondary concern for creating fires. These processes create friction and heat, which is one leg of the Fire Triangle, along with oxygen and fuel. Inherently, you have all the ingredients for a fire. If your dust is in an enclosure that contains a dust cloud such as a bin or dust collector, you not only have all the ingredients for a fire, but also all of the requirements for an explosion. Having combustible dust in suspension in a confined area or vessel are the last sides of the dust explosion pentagon. If you are storing wood dust or pellets in enclosures, you have dust collectors, you have all the ingredients necessary for an explosion. We see heat, friction and mechanical sparks as the cause of many of these fires and explosions. The controlling document for protecting wood biomass and wood pellet plants and processes is the NFPA 664 Standard for the Prevention of Fires and Explosions in Wood Processing and Wood Working Facilities. For agricultural-based biomass, see NFPA 61 Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities. NFPA 664 requires a dust hazard analysis&nbsp; (DHA) to identify and mitigate all potential combustible dust and ignition hazards. The primary areas of concern for explosions are enclosed vessels such as bins and hoppers, dust collectors and storage silos, and secondarily, enclosed conveyors such as bucket elevators. To protect these processes and equipment, facilities use a hierarchy of controls. Hierarchy of Controls The hierarchy of controls includes elimination, substitution, personal protective equipment (PPE), administrative controls and engineering controls, the last three of which this article will discuss. Personal protective equipment (PPE) and gear are the easiest to apply to keep personnel safe. Most of us know that when operating in areas where there are potential fire and explosion hazards, proper PPE must be worn. For example, safety glasses, hard hat, hearing protection, gloves and steel-toed boots are the most common. When working around processes where there is potential for combustible dust fires and explosions, you should also add fire-resistant clothing. While this article focuses on combustible dust, this also applies to processes with flammable gasses, other flammable products and hybrid mixtures. Administrative controls such as housekeeping, hazard communication and management of change are a primary level of prevention. For example, changing from softwoods to hardwoods, or adding a dryer to the process, necessitates hazard analysis, hazard communication and management of change. Engineering controls come in a variety of shapes and sizes. Several specific areas relevant to combustible dust are area classification for electrical controls; separation, isolation and segregation of dangerous processes from each other; and layered protection systems including fire prevention, and fire and explosion protection. &bull; Area classification: Two documents are used for the classification of combustible dust and hazardous locations&mdash;NFPA 499 Recommended Practices for the Classification of Combustible Dusts and Hazardous Locations for Electrical Installations in Chemical Process Areas, and NFPA 70, article 500 of the National Electrical Code. Also, refer to NFPA 77 Recommended Practice on Static Electricity, NFPA 79 Electrical Standard for Industrial Machinery, and again, NFPA 499 Recommended Practice for the Classification of Combustible Dusts and of Hazardous Locations for Electrical Installations in Chemical Process Areas. &bull; Class/Division Hazardous Location: Hazardous locations are described as locations where electrical equipment might present an ignition hazard. Class II Hazards are locations where combustible or conductive dusts are present (or may be present) in quantities sufficient to produce explosive or ignitable mixtures. Division refers to the probability of hazardous materials and mixtures. Division 1 has a high probability of producing an explosive or ignitable mixture due to it being present continuously, intermittently, or periodically from the equipment itself under normal operating conditions. Electrical equipment in these areas must meet the criteria for explosion proof rating. Division 2 has a low probability of producing an explosive or ignitable mixture, and is present only during abnormal conditions for a short period of time, such as a container failure or system breakdown. See NFPA 652 Standard on the Fundamentals of Combustible Dust requirement for a DHA, which requires all such facilities to perform a DHA and risk assessment for each process that handles or creates combustible dust. Engineering Principles An engineering principle outlined in NFPA 664 is to isolate, segregate and separate the various hazardous parts of the process. For example, there is a design of hammer mill process that uses a plenum in between the mill and the dust collector, thus creating a bomb. It is preferable to have a choke in between, such as a screw conveyor or an airlock, and to remove the dust collector to a remote location, outside the building, thus isolating a potential explosion or deflagration. Another principle of design found in NFPA 664 is layered protection systems for fire prevention, fire protection and explosion protection. NFPA 664 Chapter 8 applies to processes and systems such as mechanical conveyors, pneumatic conveyors, classifying and dust collection systems. Conveyors and ducts with a fire hazard are required to have fire prevention and/or fire protection. Fire prevention is typically spark detection. Spark detection and extinguishing systems are a primary tool to prevent sparks from propagating into fires by detecting and suppressing sparks or embers in the incipient stage. Spark detection systems are typically applied to mechanical conveyors, pneumatic conveyor and dust collection systems. Fire protection is typically deluge and sprinkler systems. We may also utilize other types of hazard monitoring equipment such as bearing temperature, heat detection, spark, ember, flame, smoke, CO detection and emissions monitoring, as well as other types of suppression, control and isolation devices. Interlocking machinery, conveyors, fire dumps and proper sequencing of shutdowns are also critical engineering controls. Explosion protection includes explosion venting or suppression, as well as chemical or mechanical isolation, to control and prevent a deflagration from transferring down or upstream, thus preventing catastrophic secondary explosions. Vessels, Venting Vessels and dust collectors with a deflagration hazard are required to have explosion protection and isolation. Mechanical or chemical isolation of these vessels and dust collectors is also required. See NFPA 68 Standard on Explosion Protection by Deflagration Venting, and NFPA 69 Standard on Explosion Prevention Systems. Explosion vents have to be engineered based on the explosive characteristics of the dust, thus dust testing is required. Venting needs to vent to a remote area away from buildings, machinery and people. Blast radius areas should be defined. Bins inside the building can be vented outside, provided the distance to the exterior wall is short enough. Alternately, indoor explosion vents, also called flameless venting, can be utilized. These flameless vents use a mechanical or chemical flame barrier to suppress the flame front, but still emit a pressure wave. Where explosion venting cannot be used, chemical explosion protection and isolation must be. Explosion protection systems consist of an optical and pressure sensor, a control panel and chemical canisters strategically located on the vessel and connected ducting. After implementing the above, you should consult your insurance company, as well as local codes and authorities having jurisdiction With proper analysis, design, engineering and administrative controls, training and housekeeping, you can reduce the probability of risk and the severity of consequences, while maintaining safety and business continuity, a safe environment for employees and stakeholders, and safeguarding your reputation in the industry. &nbsp; Author: Jeff Nichols CEO, Industrial Fire Protection jnichols@industrialfireprotection.com (770) 266-7223

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Proper analysis, design, engineering and administrative controls, training, and housekeeping will ensure your plant is safe as possible.  

Protecting the Process

Flavored wood pellets fueled grills on a mobile trailer used to smoke food served during an evening reception at the 2018 PFI Annual Conference. 

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A small group of dedicated wood pellet experts gathered in Myrtle Beach, South Carolina, for the 2018 PFI Annual Conference. 

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Adam Becker, sales and logistics manager for Energex American, provided musical entertainment during the evening reception, taking song requests from event goers. 

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From left, Robinson, Lisle, Weaver and Portz 

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From left, Walker, Coffey, Portz and Shimek 

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Members of the Pellet Fuels Institute gathered in Myrtle Beach, SC, to discuss growing the market for residential pellet stoves, policies to help achieve growth, and the mainstream approach of grilling to expose pellets to a wider audience.

Growing and Grilling: The Annual PFI Conference in Review

Those waiting in line for their morning coffee may not even notice the Prop 65 warning signs anymore. After all, they&rsquo;re everywhere, on everything, informing Californians about the potential risks of cancer that, nowadays, it seems nearly anything can cause. To date, over 900 &ldquo;chemicals&rdquo; have been added to California&rsquo;s list of known carcinogens, under Prop 65. Labeled by the Los Angeles Times as being &ldquo;so broad, its warnings may actually make it harder for Californians to assess the real dangers they encounter,&rdquo; Prop 65, formally known as the Safe Drinking Water and Toxic Enforcement Act, requires businesses with 10 or more employees &ldquo;to provide a clear and reasonable warning before knowingly and intentionally exposing anyone to a listed chemical.&rdquo; That warning might be a sign in a coffee shop or restaurant, a notice at a rental complex or hotel, or a label on food packaging. If in any instance a business is found to be in violation, intentional or not, it is liable to be sued for up to $2,500 per day, per violation, by any California citizen. &nbsp;Prop 65&rsquo;s most powerful opponent to date has been big coffee, whose powerful lobby has been disputing the claim that coffee may cause cancer due its acrylamide content, a naturally occurring chemical formed in coffee when it&rsquo;s roasted&mdash;and in many other foods, such as potatoes, cereal and bread&mdash;because acrylamide is on the Prop 65 list. Seizing opportunity, a small army of law firms and have been filing&mdash;and mostly settling&mdash;lawsuits against companies caught selling coffee without the required Prop 65 warning labels, while big names such as Starbucks, Dunkin&rsquo; Donuts and Whole Foods have taken the matters to court, with plenty of ammunition under their belts.For example, in 2016, the World Health Organization released guidelines that indicated drinking coffee may actually prevent cancer. More recently, WHO announced that, after reviewing 1,000 studies, it concludes that there is no proof that coffee causes cancer. And, some scientists have said, to reach dangerous acrylamide levels, a consumer would have to drink 100-plus cups of coffee each day. All that considered, in late March&mdash;with massive liability at stake&mdash;a judge maintained coffeemakers and sellers should have complied with, and must continue to meet Prop 65 requirements. However, coffee may have finally gotten its break in mid-June when&nbsp; California's Office of Environmental Health Hazard Assessment proposed to&nbsp; modify the rule, stating that, &ldquo;exposures to Prop 65-listed chemicals in coffee that are produced as part of, and inherent in, the processes of roasting coffee beans and brewing coffee pose no significant risk of cancer.&rdquo; Still unbeknownst to many in the industry, the regulation applies to wood pellets and other wood products sold in California. Not only does it require a warning about the risks of wood combustion and carbon monoxide inhalation, but wood dust was added to the list in late 2009, mandating an additional warning about the dangers of wood dust inhalation by 2011. And, on Aug. 30, the warning requirements will change yet again. But unlike big coffee, most pellet, animal bedding, wood chip, mulch and other related wood product producers don&rsquo;t have the financial capabilities to fight these lawsuits. Many have taken hits&mdash;some, more than once&mdash;via bounty hunter-type lawsuits that target smaller companies, many out-of-state, that are taken by surprise and pressured to settle out of court. Burden on Small Business One particular organization&mdash;the same attorney, almost always the same plaintiff&mdash;has brought dozens of lawsuits to pellet and other wood product manufacturers. The Pacific Justice Center and California attorney Robert Hancock have filed claims against companies including American Wood Fibers, Pacific Coast Fuels, West Oregon Wood Products, Traeger, Lignetics, Bear Mountain Forest Products, Greene Team and the list goes on. &ldquo;I would describe this as legalized extortion,&rdquo; says Stephen Faehner, president of American Wood Fibers. &ldquo;Not a whole lot can be done, other than to put a warning on everything that you make.&rdquo; AWF was slapped with a lawsuit in 2015, for unlabeled pet bedding, and settled out of court for upward of $100,000. &ldquo;We got a warning letter, and then it was broadcast to public record and the Prop 65 system,&rdquo; Faehner says. &ldquo;Two-thirds of the settlement went to the lawyer. About 15 percent went to the plaintiff, and the rest went to the attorney general. In these instances, the plaintiff has likely never even used the product&mdash;it&rsquo;s someone who partners up [with attorneys]. These are smart people who have found this wonderful loophole in the law, and are extorting it.&rdquo; According to the Center for Accountability in Science, an organization staunchly opposed to Prop 65 lawsuit abuse, there are heavy incentives for citizens to file as many lawsuits as possible, especially because there is no requirement that organizations or individuals prove that they have been injured in any way by whatever violation of Prop 65 they are claiming. Some of the most active bounty hunters have brought in more than $1 million per year in collected enforcement fees, according to the CAS. In 2017, there were a total of 688 settlements with multiple plaintiffs bringing dozens of lawsuits, resulting in $25 million, nearly $19.5 million of which went to attorney fees. Out of those, the Pacific Justice Center brought a total of 22 lawsuits against wood product manufacturers for wood dust warning violations, all between two plaintiffs. In 2016, Pacific Coast Pellets received a notice it was in violation of Prop 65. &ldquo;When we got nailed, the first thing we did was let everyone in the industry know what was going on,&rdquo; says Stan Elliot, president of PCP. &ldquo;We got a letter in the mail, and it was a complete surprise. Nobody had any idea what it was, so we forwarded it to our owner, who had practiced law in Sacramento a few years prior, and his lawyer friends confirmed that it was absolutely real. We hired California counsel, agreed to make corrections to our packaging and pay a $50,000 fine, so long as all three of our brands were listed in the same complaint, rather than separate claims.&rdquo; West Oregon Wood Products, which is no longer in business, was sued twice via Prop 65, the instances decades apart. And like Pacific Coast Pellets and American Wood Fibers, it was an out-of-state company simply unaware of the requirements. &ldquo;The first time was back in the late &lsquo;90s&mdash;we didn&rsquo;t have the combustion warning on our fuel pellets,&rdquo; says founder Chris Sharron. &ldquo;That was painful&mdash;we ended up paying about $30,000, but we got over it, and thought we learned our lesson. Everything was quiet until about 2014, when we got served the second lawsuit, relative to the fact that wood dust, unbeknownst to us, was listed as a carcinogen in 2009.&rdquo; WOWP had lots of product in the California market at the time, Sharron says, and adding a label to bags wouldn&rsquo;t have been a big deal. &ldquo;What&rsquo;s frustrating is not knowing,&rdquo; he says. &ldquo;How do you know when these chemicals are listed, or that the rules have changed? We went through trying to negotiate a settlement, and though I really didn&rsquo;t feel it was going to happen&mdash;I more so used it as a negotiation tool&mdash;I told them that my company was in financial dire straits, that we may not be around a year from now. They were going after $60,000. I said I could scrape together $10,000 to make it go away, but they held their ground, and we did end up going out of business, and they didn&rsquo;t get anything.&rdquo; Sharron admits that instances like these come with the cost of doing business, but change is needed regarding to how those affected by Prop 65 are notified. Or, perhaps more accurately, how they aren&rsquo;t notified. &ldquo;Small companies deal with all kinds of challenges, and this is just one more&mdash;the ridiculousness of it is what is so emotionally frustrating, on top of the time and money,&rdquo; he says. &ldquo;California should do a better job of alerting people who are sending products into the state. I don&rsquo;t know how, but some kind of campaign to bring this front and center to the public and the businesses throughout the world shipping to California.&rdquo; And, Sharron points out, there is no clear definition of what wood dust is, or how much inhalation can cause problems. &ldquo;So you can&rsquo;t go get some lab analysis done and use it in your defense, because it&rsquo;s so general,&rdquo; he says. &ldquo;It&rsquo;s so obvious that it&rsquo;s a moneymaking scheme&mdash;this money is extorted out of you; the law&rsquo;s true intent has been overridden for the sake of making people money.&rdquo; Faehner warns that, regardless of point of origin, a manufacturer with product on Amazon could get hit with a lawsuit if the product is ordered into California. &ldquo;It&rsquo;s an unfortunate scenario where a bad law is affecting some decent people,&rdquo; he says. &ldquo;These are products that have no business being in the net that they cast.&rdquo; The net Faehner refers to is that while the wood dust addition may have been aimed at cautioning those who work every day with wood dust in factory or industrial settings, all heating and grilling pellets, fire logs, animal bedding and other wood products are all swept into the same category, as no safe harbor levels have been set for wood dust. Safe harbor levels, or No Significant Risk Levels for cancer-causing chemicals, and Maximum Allowable Dose Levels for chemicals causing reproductive toxicity, have been established for many of the chemicals listed under Proposition 65, but not wood dust, and when it comes to establishing one, there is a laundry list of chemicals ahead of it. &ldquo;In 2012, we prioritized chemicals for potential NSRL development, and wood dust was placed in the third priority level,&rdquo; says Sam Delson, deputy director for external and legislative affairs at the California Office of Environmental Health Hazard Assessment. &ldquo;Ahead of wood dust, there were 40 chemicals in the first priority level, and 45 in the second priority group.&rdquo; As to when an NSRL will be developed for wood dust&mdash;which could potentially relieve wood pellet and other wood product manufactures of their Prop 65 requirements&mdash;or whether one will be developed at all, Delson says it depends on several factors. &ldquo;Prioritization is one factor. Wood dust is in the third priority level, and there are dozens of substances currently in the first and second priority groups.&rdquo; Another factor, Delson says, is if OEHHA receives a specific request to develop an NSRL for a specific substance, it will consider the request, which could potentially result in a safe harbor level for that substance before others that are currently in a higher priority group. &ldquo;The determination would be based in part on an assessment of the available research and data to determine whether there is sufficient information of sufficient quality to develop a reliable number,&rdquo; he adds. &ldquo;This would include information on the types and levels of exposure to the substance, as well as its inherent chemical properties.&rdquo; But for now, wood and grill pellets used at home by consumers will be categorized as just as dangerous as all other potential sources of wood dust, including daily occupational exposure in industrial settings. &ldquo;You might pour a 40-pound bag of pellets in your hopper during the winter, and the amount of dust that billows out&mdash;it&rsquo;s minute,&rdquo; says Sharron. But it&rsquo;s all lumped together.&rdquo; So for now, manufacturers selling into California, and those with even a slight chance of product ending up there, should&nbsp; ensure they are up-to-date on their Prop 65 requirements, which are set to change at the end of August. How to Comply There are no specific wording guidelines on either of the warnings currently required for wood pellets, leaving manufactures responsible for ensuring their warnings are sufficient, however, they should have some variation of the following statements: California Proposition 65 WARNING: Drilling, sawing, sanding or machining wood products can expose you to wood dust, a substance known to the State of California to cause cancer.&nbsp; Avoid inhaling wood dust or use a dust mask or other safeguards for personal protection.&nbsp; WARNING: Burning wood pellets results in the emission of carbon monoxide, soot and other combustion byproducts that are known by the state of California to cause cancer, birth defects or reproductive harm. And, as of Aug. 30, numerous changes will take effect, including clarifying responsibilities for manufacturers, distributors and retailers to provide warnings, adding the Prop 65 website address to warnings, specifying at least one Prop 65-listed chemical in the product, and, next to the required wording, all products subject to Prop 65 will have to include a yellow warning triangle with a centered exclamation point, which may catch many by surprise and prompt a new wave of lawsuits. Elliot says his company found out about the warning sign addition only a couple of months before it is set to take effect. &ldquo;I have 12,000 tons of product on the ground, and by the time I get a packaging change, I&rsquo;m already August,&rdquo; he says. &ldquo;It&rsquo;s such a waste of time, money and effort&mdash;how much does it cost to print these labels for everything, and what&rsquo;s the carbon footprint of that?&rdquo; Delson confirms with Pellet Mill Magazine that any product manufactured prior to Aug. 30 will not be required to have the new warnings format. Currently selling product into California or not, Elliot says some producers have decided to put the warnings on their bags as a safeguard. &ldquo;These Midwest and East producers don&rsquo;t want to risk that $40,000 penalty,&rdquo; he says. &ldquo;They only have to find one bag that doesn&rsquo;t have it, and they will go through inventory until they find something. For this latest requirement, we&rsquo;ll make immediate changes on our printing, and possibly delay some shipments into California. Those who really need to know about the Prop 65 requirements are the BBQ pellet manufacturers, Elliot adds. &ldquo;They can ship really small bags, and there are a lot more retailers. I have no doubt there will be another round of citations for this low-margin industry that can&rsquo;t afford to take these blows.&rdquo; Faehner agrees. &ldquo;It would have been wonderful, if a few years ago when this started to happen, we passed the hat and said, &lsquo;let&rsquo;s make sure this doesn&rsquo;t catch us.&rsquo; We would have likely put in as much as it&rsquo;s cost us so far. But in the meantime, we have elected to put a lot of these on our packages, and we&rsquo;re not taking any chances.&rdquo; Faehner says he believes the intentions behind Prop 65 were right. &ldquo;It&rsquo;s rare for a person not to be affected by cancer,&rdquo; he adds. &ldquo;But wood dust, in this case, isn&rsquo;t one of the things that do it. If you go to court, the defense is $1 million, and that&rsquo;s just stepping into the fray.&nbsp; I&rsquo;m not sure how to fix this, except a coalition of manufacturers coming together and saying enough is enough.&rdquo; -------------------------------------- SIDE BAR------------------------------------------------------------- Key Changes to Proposition 65 (Effective Aug. 30) New OEHHA regulations, adopted in August 2016 and that will take full effect in August 2018, change the safe harbor warnings that are deemed to comply with the law in several important ways. For example, the new warnings for consumer products will say the product &ldquo;can expose you to&rdquo; a Proposition 65 chemical rather than saying the product &ldquo;contains&rdquo; the chemical. They will also include: &bull; The name of at least one listed chemical that prompted the warning. &bull; The internet address for OEHHA&rsquo;s new Proposition 65 warnings website, www.P65Warnings.ca.gov. &bull; A triangular yellow warning symbol on most warnings. The new warning regulation also: &bull; Adds new &ldquo;tailored&rdquo; warnings that provide more specific information for certain kinds of exposures, products, and places. &bull; Provides for website warnings for products purchased over the internet. &bull; Provides for warnings in languages other than English, in some cases. &bull; Clarifies the roles and responsibilities of manufacturers and retailers in providing warnings. -------------------------------------- SIDE BAR------------------------------------------------------------- Author: Anna Simet Editor, Pellet Mill Magazine asimet@bbiinternational.com 701-738-4961

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California's notorious Prop 65 has cost wood product manufacturers around the country millions of dollars, and an upcoming requirement could exacerbate the issue. 

Seller Beware

It&rsquo;s not difficult to understand how fires and explosions occur in pellet mills. Combustible dust in enclosed areas&mdash;process equipment, ducts and pipes&mdash;can be ignited by a spark, a hot surface or a flame. When mixed with the oxygen in the air, dust becomes the fuel for fires, flash fires and explosions. The dispersion of a dust cloud generated after an initial explosion can lead to even larger fires or bigger explosions. Most pellet mill operators are aware of the potential hazard of fires and explosions from dust generated by their processes. But what&rsquo;s the best way to prevent them from occurring? The first step, says Jason Krbec, sales engineering manager for CV Technology, is a dust hazard analysis (DHA). Krbec notes that in 2020, facilities handling combustible dust will be required to conduct a DHA to meet National Fire Protection Association standards, which also require the analysis to be brought up to date at least every five years. A registered professional engineer in the state of Florida, Krbec is an active member in the American Society of Mechanical Engineers, the American Society of Safety Engineers and the NFPA. He serves on several NFPA technical committees related to combustible dust. He has experience and knowledge in a variety of mitigation technologies, including explosion venting, flameless venting, mechanical isolation valves and chemical suppression equipment. CV Technology, a Jupiter, Florida, company that specializes in explosion and fire prevention solutions for industries manufacturing and handling dry bulk material, was founded with the goal of providing a passive means of protection against combustible dust explosions. Its engineering, manufacturing and system integration capabilities can tailor specific safety solutions to conditions within an operation that can put employees and equipment at risk. At CV Technology, Krbec is involved in the development of mitigation solutions, research and development projects, dust hazard analysis, full-scale explosion testing, dust testing and prevention solutions. He spoke to Pellet Mill Magazine on what pellet mill operators should know about conducting a DHA. What is a DHA, and what does it entail? Krbec: DHA stands for dust hazard analysis, and it is a relatively new requirement in the National Fire Protection Association combustible dust standards. A DHA is a review of a facility to identify and evaluate the fire flash fire, and explosion hazards associated with combustible dust. The basic goals of a DHA are to evaluate the hazard, determine what safeguards exist, and identify where safeguards are needed. This requirement is also retroactive to all processes handling combustible dust. What special challenges do wood pellet plants pose when it comes to understanding and managing dust-related risks at their facilities? Krbec: Combustible dust poses both a fire and potential explosion risk in wood pellet plants. Both hazards need to be considered, since the material being handled is ultimately making a fuel. Typical processes in wood pellet plants also lend themselves to potential sources of ignition. Mechanical conveying equipment can often produce sparks or overheated elements. Milling is always an area of potential ignition source generation. The pellet mills or presses heat up the pellets, and can create issues in the dust extraction or cooler systems. Wood pellets themselves may even be at risk for self-heating or spontaneous combustion, depending on how they are stored. Silo fires have become an expected event that almost every wood pellet plant has had to deal with during operation. The goal of total elimination of fires and explosions is not very practical in a wood pellet plant. Implementing mitigation tactics for fires and explosions is a realistic goal for a wood pellet facility. The DHA is the first step in that process. Under what circumstances should an outside consultant or expert be brought in for a DHA? What type of qualifications and experience should this person have? How much should a producer expect to spend? Krbec: The person leading or performing the DHA should be qualified. Generally, that means a level of familiarity with pellet milling processes and some expertise with the hazards of combustible dust. A DHA is generally conducted by a team, as it may take more than one person to achieve this level of knowledge. Team members typically include engineers, operators, maintenance staff and safety personnel. Still, in some cases, an outside expert or consultant should be involved.&nbsp; Experts are able to provide experience with combustible dust hazards, and typically have conducted multiple DHAs. Consultants can also provide a level of practicality to the process, which is of great benefit. A consultant with DHA experience, knowledge of the NFPA standards, and an understanding of bulk material handling systems is recommended. DHA consultant costs are the same as any other engineering consulting services. Expect the consultant to need one to three days on-site, and another seven to 10 days to complete the report. Additional resources exist that can help a producer understand the DHA process. The Center for Chemical Process Safety has published a book on how to conduct DHAs. NFPA 652 Standard on the Fundamentals of Combustible Dust has an example DHA in the annex of the document. At what interval do you recommend that pellet mill operators have DHAs conducted? Krbec: All facilities handling combustible dust should have a DHA completed by September 7, 2020, in accordance with the latest NFPA 652 Standard. NFPA 652 requires a DHA to be reviewed and updated every five years. However, you may need to update a DHA more often depending on your operation. If your process or facility undergoes any modifications, you should review and update your DHA to reflect the changes. An example would be replacing a piece of process equipment like a dust collector. This change may not require the entire DHA to be updated, but you will need to update the section of your DHA that covered the replaced dust collector. A good management of change (MOC) process in a facility is a good start to prompt when a DHA should be reviewed. What do you consider the least understood aspect of conducting a DHA? Krbec: A DHA does not always have to take the form of a prescriptive, traditional DHA. In some cases, facilities can decide to go with risk-based approach. A risk-based DHA involves incorporating a severity of the consequence and the frequency of an event aspect to the analysis. A risk-based DHA might be used in conjunction with or as an alternative to a traditional DHA. The challenge with using a risk-based DHA in a wood pellet process is that the risk level is already documented to be higher in these types of operations than other types of processes handling combustible dust. Explosion and fires have occurred in almost every type of process equipment in a wood pellet plant. After all, these facilities are producing a fuel product. In terms of dust hazards, what are some of the most common hazardous scenarios you see at pellet plants that producers tend to be unaware of? What are the most serious overlooked issues that lead to fires or explosions? Krbec: Bucket elevators are an often overlooked piece of process equipment in wood pellet plants. Elevators can create ignitions through overheated bearings, misaligned or slipping belts, and sparks generated from friction or impacts. Bucket elevators themselves should be equipped with explosion mitigation systems. Additionally, the discharge and dust aspiration lines of the elevator should be considered for spark detection monitoring to prevent fires and explosions in other areas of the process. Explosion propagation is the other hazard often overlooked or misunderstood. Many plants will point to explosion vents on a dust collector and think they are properly protected. When you have a deflagration inside a piece of equipment, the flame front and pressure wave can travel through pipelines to interconnected equipment or building compartments. This event is commonly referred to as a secondary explosion. Explosion propagation can be the difference between a localized event and a catastrophic event in a facility. Explosion isolation is a mitigation strategy that can prevent a secondary explosion. Examples of isolation devices include fast-acting mechanical explosion isolation valves or chemical isolation barriers. What are the most important types of safeguards (equipment or systems) that you most often recommend for pellet mill operations? Krbec: Wood pellet plants are somewhat unique in that a variety of different safeguards are needed. The fire and ignition hazards are generally addressed using spark detection and extinguishing (usually water) systems that have become commonplace. Explosion venting has become a common mitigation technology seen in wood pellet plants. A growing number of wood pellet plants have equipment located indoors. As a result, safeguards like flameless vents, which can be used indoors, are more common. A flameless vent is an explosion vent with a flame arrestor that allows the vent to be exhausted indoors. Passive safeguards like vents and flameless vents tend to work best in wood pellet operations. These types of safeguards require little or no maintenance and have a longer service life in environment of a pellet mill. Chemical suppression systems are another safeguard used in facilities when venting is less practical. Bearing temperature and belt slippage monitors are very important safeguards that should be included on any type of mechanical conveyor. What should a finished DHA look like, and what are a producer&rsquo;s next steps when one is completed? How can pellet mill operators ensure a DHAs long-term effectiveness? Krbec: A DHA should be your roadmap to providing a safe operating facility. Smaller facilities may only have a document that is a few pages long. A larger pellet operation may have a full report that covers every processing area. The DHA may result in action items like adding safeguards, increasing housekeeping activities, or even changing a process to make it inherently safer. In some cases, your DHA may reaffirm that you have all of the safeguards in place, and now you have them documented. The effectiveness of the DHA really comes down to whether training and hazard awareness systems are implemented to make everyone in the facility understand potential hazards posed by combustible dust.&nbsp; Author: Patrick C. Miller Staff Writer, Pellet Mill Magazine pmiller@bbiinternational.com 701-738-4923

Venting and chemical isolation on bucket elevators and silos at pellet plant 

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Flameless vent on bucket elevator and cooler bag house in pellet plant 

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Flameless vent on a conveyor in a pellet plant

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Combustible dust fire and explosion expert Jason Krbec discusses the critical role dust hazard analyses play in incident prevention. 

Dissecting a DHA

E3 Consulting names Elbaum managing director E3 Consulting has selected Ginger Elbaum as managing director. Elbaum joined E3 in 2007, and most recently served as the firm's director of operations.&nbsp;&nbsp; Elbaum has 18 years of experience providing engineering, construction and project management services to the power generation, water reclamation and industrial process sectors. At E3, she has focused on wind, solar, natural gas, coal, transmission installations and infrastructure.&nbsp;&nbsp; Elbaum has managed a range of high-profile projects, including the Petra Nova Carbon Capture project near Houston, one of only two coal-fired power plants worldwide to use carbon capture and storage.&nbsp; She also managed the groundbreaking San Antonio Vista Ridge water pipeline project, one of the first projects in the water sector to use a public-private partnership. Before joining E3, Elbaum worked in Calpine Corp.&rsquo;s centralized engineering group. She holds a bachelor&rsquo;s degree in Mechanical Engineering from Texas A&amp;M University. ProcessBarron subsidiary buys Environmental Elements&nbsp;&nbsp; Southern Field, a wholly owned subsidiary of ProcessBarron, announced the asset purchase of the Environmental Elements business line from Delta Ducon LLC. EEC specializes in air pollution control (APC) equipment and technology for power and industrial markets, consisting mainly of pulse jet fabric filters and electrostatic precipitators. &ldquo;We are very pleased with the addition of Environmental Elements to our group,&rdquo; said Steve Moore, president of Southern Field. &ldquo;EEC is one of the largest and most respected APC equipment and technology suppliers in the U.S.&rdquo; Pellets sold in California to require new bag labels Under California&rsquo;s Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, any bagged pellets sold in California will be required to comply with changes to an existing wood dust warning label on bags, as of Aug. 30. The requirement applies to any product, manufactured in- or out-of-state, sold in California. The existing wood dust warning required on the bags reads, &ldquo;This product contains a chemical known to the state of California to cause cancer.&rdquo; The new label must include a yellow triangle icon with a centered exclamation point, and read, &ldquo;WARNING: Drilling, sawing, sanding or machining wood products can expose you to wood dust, a substance known to the state of California to cause cancer. Avoid inhaling wood dust or use a dust mask or other safeguards for personal protection.&nbsp; For more information go to www.P65Warnings.ca.gov/wood.&rdquo; Failure to comply may result in up to a $2,500 fine per violation, per day. Questions regarding Prop 65 should be directed to the California Environmental Protection Agency Office of Environmental Health Hazard Assessment. Forest Concepts wins DOE funding to improve biomass handling Forest Concepts LLC has been awarded a $1.8 million cooperative agreement from the U.S. Department of Energy&rsquo;s Bioenergy Technologies Office to address the critical issues of poor flowability, high friction, and highly variable physical properties that have plagued the biomass industry. Forest Concepts, led by Chief Technology Officer Jim Dooley, in collaboration with Penn State University&rsquo;s Virendra Puri, has an overall project goal to contribute to the design and operation of reliable, cost effective, continuous feeding of biomass feedstocks into various reactors typical of integrated biorefineries. For the past 30-plus years, Puri has greatly advanced the modeling of compression, flowability, and storage of particulate materials, while Dooley has made significant advances in low-energy processing of uniform, flowable precision feedstocks from a variety of high-moisture biomass.

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Business Briefs

Industrial explosions present serious risk to any wood- or cellulose-processing facility, such as a biomass plant, that handles combustible dusts and vapors. Ignition of a dust or vapor cloud in process equipment can not only destroy the primary vessel, but also propagate to interconnected equipment and into the plant, causing secondary explosions with devastating results. Fortunately, there are proven ways to deal with this threat.&nbsp; Not long ago, IEP Technologies received a call from a leading North American manufacturer of wood products. With several plants in the U.S. and Canada, the company&rsquo;s management was concerned that its employees were at risk from devastating explosions. The threat of uncontrolled ignition of fine wood particles and dusts was present in every plant vessel. The project began in our lab. We collected seven samples of dust samples from the pilot plant, and brought them back to the IEP Technologies Combustion Research Center for explosivity testing. The CRC is an independent laboratory specializing in the combustion characteristic testing of dusts, liquids and gases. IEP engineers then conducted a review of the equipment suspected of being explosion risks. More than 30 vessels and wood processing production machines were identified for inclusion in the explosion protection strategy. This equipment included dust collectors, cyclones, weigh hoppers, fiber bins and forming heads along with connecting conveyors and ducting. The scale of the project required a considerable amount of prework by IEP sales, support and engineering teams, involving five site visits. The purpose was to ensure the customer&rsquo;s complete understanding of and satisfaction with the design concept. From the project&rsquo;s outset, the objective was to provide an integrated safety net for the plant to protect against explosions, as well as false system actuations and costly production shutdowns due to occasional over-pressure situations in the process line. This required the company to reinforce or upgrade older unprotected vessels and machines where the pressure rating was insufficient to enable the developing explosive effects to be safely vented and controlled. One specific technical challenge encountered was that, since the process line is pressurized, dynamic pressure detection would be required to differentiate between normal process pressure fluctuations and actual explosion events. We proposed our SmartDS Dynamic Pressure Detection System to fulfill this requirement. The SmartDS is a rate-of-pressure rise detector that uses multiple algorithms to constantly interrogate pressure data. This enables explosion detection while providing excellent false alarm immunity. The SmartDS is SIL-2 certified and ATEX approved. After IEP presented multiple plant explosion protection scenarios, our customer chose the one that offered the very highest safety level. This solution included 25 zones of protection incorporating explosion venting, detection, suppression and isolation, linking back to four of IEP&rsquo;s EX8000 Multi-Channel Control Systems. A key feature of this system is that each EX8000 Controller can handle up to 16 zones, therefore building plenty of scope for future plant expansion into the customer&rsquo;s current installation. The integrated explosion protection system combined several elements including passive explosion venting for outdoor vessels, together with detection, suppression and isolation to safeguard against the propagation of explosion products to interconnected vessels and machines in the form of secondary explosions. In view of the significant investment being made by the customer to protect their people, assets and business continuity, they commissioned an independent, third-party study by a reputable safety engineering group, which validated the approach and solution. Due to the size of the project, it was managed by several mechanical engineering teams, reporting to a veteran integrator. System supply, engineering and checkout from IEP Technologies were included in the scope of supply to the customer. Once online, local support and any necessary spare parts will be supplied by the IEP service center located in the region. Looking ahead, IEP will be working with the customer to help train their local engineers to enable them to investigate and identify explosion protection issues in other company plant sites throughout North America and Canada. Author: Geffrey Mitchell Regional Sales Manager, IEP Technologies 855-793-8407 www.ieptechnologies.com

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Industrial explosions present serious risk to any wood- or cellulose-processing facility, such as a biomass plant, that handles combustible dusts and vapors.

Explosion Protection for Biomass,  Wood Processing Plants

With nearly a decade of experience in renewable energies, I work with a Swiss supplier for the pellet industry, Bathan AG. My position requires knowledge of all aspects of a pellet plant, so I joined our service and maintenance team on several jobs to enhance my knowledge of the inside of mills&mdash;in particular, what to observe, and how to keep plants running smoothly. In this column and future editions, I plan to share with you lessons I have learned while on the job. I have two very talented and experienced engineers on my team, go-to guys with a combined 30-plus years of experience, who brought me up to speed on technical aspects of pellet mills and other equipment in pellet plants. As you know, the process of pelletizing is conceptually simple: dried and ground-up sawdust is compressed under high pressure and temperature to ensure sufficient density. However, efficient and reliable operation of the pellet mill requires considerable skills, experience and, sometimes, a lot of improvisation. Therefore, the learning curve in the pellet-making business is long and steep, especially when you see different companies with individual setups and feedstock mixtures. North America and Europe contribute 67 percent of global pellet production, so it is worth knowing much about both markets. From several visits of pellet plants in Europe and North America, I perceived several differences. In Europe, almost all pellet plants use starch as binder, and the majority of pellets is produced under the EN Plus standard for residential heating. In the U.S. and Canada, industrial pellets for export, make up the bulk of the market, and the biggest share is for industrial heating, such as Drax power plants in the U.K. Hardwood and mixtures of softwood and hardwood are processed quite often, and debarking does not always take place, thus wear on equipment is much higher. As a result, North America cup and cone bearings are very popular, because in comparison to cartridge bearings, they are serviceable. Also, the absence of a race from a cup and cone system frees up space, placing more surface area in contact with the cup, thus spreading the load more effectively. Besides the setup, another major difference lies with operation&mdash;temperature monitoring is often nonexistent, which leaves the operators blind regarding the condition of the rollers, increasing the risk of fires. This led us to develop a retrofit temperature monitoring upgrade to track individual roller temperatures. On both continents, the trend is in-house roller refurbishment, to keep track of quality and reduce maintenance costs. The best way to refurbish rollers is warm-fitting to prevent assembly damages. The shell may be heated up through a gradual temperature increase using an inductive heater or an oven. The ideal temperature is around 260 degrees Fahrenheit for the shell, and 155 degrees F for the bearing, which should slide into the shell easily. With cup and cone rollers, it is easy to just change the shell, and not dismantle a well-running bearings-shaft package. Pictured right is a roller after 1,000 operating hours&mdash;the bearings are reusable. Dirty grease distribution of a refurbished roller is shown in the left image&mdash;initial damages are obvious. I am looking forward to sharing more recommendations, best practices and observations. Please do not hesitate to reach out and ask questions that I can address privately, or in future columns. Author: Holger Streetz International Operations Manager, Bathan AG h.streetz@bathan.ch +491-735918-550

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Pelletizing is conceptually simple: dried and ground-up sawdust is compressed under high pressure and temperature to ensure sufficient density, but efficient, reliable operation of the pellet mill requires considerable skills and experience.

From Plant to Plant: Lessons Learned 

I love working at an organization where the boss wrote a blog titled &ldquo;Eat Kale, Use Wood.&rdquo; The recent blog, by Northern Forest Center President Rob Riley, focused on why people have embraced the idea that eating more kale sustains local farms, but haven&rsquo;t yet realized it is just as important to use forest products to support our local forests. This is a message we work with every day at the center. We&rsquo;re driven by our mission to build economic vitality and community well-being based on sound forest stewardship across the Northern Forest.&nbsp; We are a nonprofit organization serving a 30 million-acre region that stretches from Lake Ontario to the Atlantic across northern New York, Vermont, New Hampshire and Maine. Our programs support many elements of the forest-based economy, from wood products manufacturing to destination development to community forests. Across all programs, we measure impact based on jobs supported, acres conserved for community benefit, and dollars invested in projects that benefit the region&rsquo;s communities, the economy and forest stewardship. At last tally, we had benefited 4,951 jobs, helped conserve 255,562 acres, and secured and leveraged $199 million for the region&rsquo;s benefit. And we&rsquo;re passionate about using wood pellets from the region&rsquo;s well-managed forests to heat homes and buildings. We believe that automated wood heat presents a tremendous renewable energy opportunity for rural communities where wood is abundant, winters are cold and heating oil dependence is high. That&rsquo;s why the center has been promoting high-efficiency, central wood pellet boilers since 2011 (coincidentally, that&rsquo;s the same year Pellet Mill Magazine started publishing). Pellet Mill Magazine has covered our work over the years, including the cover story in the March 2018 issue and a feature on our first Model Neighborhood initiative.&nbsp; Now, I&rsquo;m delighted to be contributing this new quarterly column to tell you more about our approach to this work, and share my insights as someone who sees automated wood heat as a triple win for the region&rsquo;s people, forest and economy. The center is not a retailer or manufacturer, so our perspective is different. Our automated wood heat program generates and promotes the economic, environmental, and social benefits of switching from fossil fuels to regional wood pellets.&nbsp; To start, we work on all parts of the value chain, but focus especially on the demand side. We support demonstration projects, provide incentives for installation of pellet boilers and stoves using bulk-supplied and stored pellets, and try to drive up awareness with public events and marketing. As we go, we work closely with industry partners, but equally seek to engage the environmental community and partners within state and federal agencies. The automated wood heat sector is small and fragile in the U.S., and we need supporters in every corner. We also present an integrated case for the technology, talking as much about social and environmental benefits as technical and economic. We find this message catches the attention of a much wider audience than would ordinarily be interested in heating systems. As of June 30, the center has helped fund installation of more than 160 wood pellet boilers in homes, schools, businesses, and public buildings, and collectively, those systems have contributed more than $3 million to the regional economy and cut greenhouse gas emissions by 4,000 tons. We recognize that these installations alone aren&rsquo;t enough to catalyze market growth. To really scale up and achieve significant, lasting benefits for rural communities, we need to make far more people aware that automated wood heat is even an option. In my next column, I&rsquo;ll tell you about the Feel Good Heat campaign and how to get involved, but for now be sure to check out www.feelgoodheat.org! I look forward to sharing more about the different elements and outcomes of our wood heat work in this magazine, and encourage you to reach out with comments or questions. Author: Maura Adams Program Director, Northern Forest Center madams@northernforest.org www.northernforest.org

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Installations alone aren't enough to catalyze modern wood heat market growth. To really scale up and achieve significant, lasting benefits for rural communities, we need to make far more people aware that automated wood heat is even an option.

The Opportunity in Modern Wood Heat

Wood dust. It&rsquo;s the lifeblood of a pellet plant, but it can be the force behind an operation&rsquo;s demise, if not properly managed. This is well-known across both the domestic and industrial segments, but still, incidents continue to occur at a rate that I've heard some industry stakeholders describe as too frequent. As one plant manager told me, a bad incident at one plant reflects on the industry as a whole; the impact extends far beyond that particular facility and the surrounding community. This rings true for sectors of all kinds, but it&rsquo;s particularly detrimental to a young industry working to expand and compete in today&rsquo;s energy market. I continue to hear both of the following arguments from a range of stakeholders. Stance one: The pellet industry should be as cautious and proactive as possible, but it has a predisposition to accidents, and they are inevitable, given the material and circumstances under which these facilities operate. And stance two: One accident is too many, and they are all preventable. Regardless of which side you agree with, it&rsquo;s up to personnel at every pellet operation to keep things as safe as possible, and up to code. As Industrial Fire Protection LLC&rsquo;s Jeffrey Nichols points out in the page-32 piece he authored on fire and explosion protection, if conditions at your plant aren&rsquo;t aligned with best practices just because it&rsquo;s what you have always done, it doesn&rsquo;t mean you won&rsquo;t have an incident. It will be what you have always done, up until it isn&rsquo;t anymore. Other stories in our dust management, fire and explosion protection issue include, on page 10, discussion of a relevant case study by IEP Technologies&rsquo; Geff Mitchell, and, on page 14, a Q&amp;A with CV Technologies&rsquo; Jason Krbec, who discusses dust hazard analyses. Had one before? It may be time for another. Pellet plants change over the years&mdash;new equipment, modifications, expansions, etc., so these analyses may bring to light some previously unidentified or new risks. Expanding outside plant safety and into regulatory compliance, I dove into California&rsquo;s Proposition 65 law, in our page-20 feature, &ldquo;Seller Beware.&rdquo; Simply because they were unaware of its requirements, there are many in the industry who have faced steep penalties for product sold into California, due to an unfortunate loophole and bountyhunter-type lawsuits that have become commonplace under Prop 65. There are some upcoming changes to the law, so if you&rsquo;re selling any product into California&mdash;not just pellets, but wood chips, animal bedding, and other wood products&mdash;you need to know about them. Our final feature, written by Senior Editor Ron Kotrba, provides an in-depth overview of the Pellet Fuel Institute&rsquo;s annual conference, which took place in Myrtle Beach, South Carolina, end of June. Lots of honest, critical, thought-provoking and hopeful conversations took place, and Kotrba expertly captured the topics of real significance and brought them to our pages&mdash;enjoy.&nbsp;&nbsp; Author: Anna Simet EDITOR asimet@bbiinternational.com

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Wood dust. It's the lifeblood of a pellet plant, but it can be the force behind an operation's demise, if not properly managed.

July-August Pellet Mill Magazine

Business Briefs

Business Briefs

Columns

Explosion Protection for Biomass, Wood Processing Plants

From Plant to Plant: Lessons Learned

The Opportunity in Modern Wood Heat

Digging into Combustible Dust

Featured

Growing and Grilling: The Annual PFI Conference in Review

Seller Beware

Dissecting a DHA

Contributions

Protecting the Process

July-August Pellet Mill Magazine.css-7jxktu{position:absolute;bottom:0px;left:0px;right:0px;height:3px;border-radius:3px;background-color:var(--chakra-colors-brandBlack);}

Business Briefs

Business Briefs

Columns

Explosion Protection for Biomass, Wood Processing Plants

From Plant to Plant: Lessons Learned

The Opportunity in Modern Wood Heat

Digging into Combustible Dust

Featured

Growing and Grilling: The Annual PFI Conference in Review

Seller Beware

Dissecting a DHA

Contributions

Protecting the Process

July-August Pellet Mill Magazine