03/13/2025
In the matter of: PETITION FOR MODIFICATION
Warrior Met Coal Mining, LLC
16243 Highway 216
Brookwood, Alabama 35444
No. 4 Mine, Mine I.D. 01-01247
No. 7 Mine, Mine I.D. 01-01401 Docket No. M-2023-012-C
PROPOSED DECISION AND ORDER
On March 13, 2023, MSHA received a petition for modification submitted on behalf of Warrior Met Coal Mining, LLC, for mining activities at the No. 4 Mine (MSHA I D 01-01247) and at the No. 7 Mine (MSHA ID 01-01401). The petition seeks an alternative method of compliance with Title 30 Code of Federal Regulations (CFR) 75.900 Low-and- medium-voltage circuits serving three-phase alternating current equipment; circuit breakers. The petitioner alleges that the alternative method proposed in the petition will at all times guarantee no less than the same measure of protection afforded by the standard.
The petitioned standard, 30 C.F.R. § 75.900 – Low-and medium-voltage circuits serving three-phase alternating current equipment; circuit breakers state:
Low- and medium-voltage power circuits serving three-phase alternating current equipment shall be protected by suitable circuit breakers of adequate interrupting capacity which are properly tested and maintained as prescribed by the Secretary. Such breakers shall be equipped with devices to provide protection against undervoltage, grounded phase, short circuit, and overcurrent.
Findings of Fact and Conclusions of Law
MSHA personnel conducted an investigation for the petition and filed a report of their findings with the Administrator for Mine Safety and Health Enforcement after a careful review of the entire record, including the petition and MSHA’s investigative report this Proposed Decision and Order is issued.
The following persons participated in the investigations:
1. Robert Steed (Electrical Engineering Manager, Warrior Met Coal)
2. Eddie Sparks (Director of Safety, Warrior Met Coal)
3. Tyler Key (Miners Representative, U.M.W.A.)
4. David Cooper (Miners Representative, U.M.W.A.)
The miners are represented by the United Mine Workers of America (U.M.W.A.) and there were miner's representatives involved in the investigation. Both miner representatives were interviewed and neither miner representatives had any issues, questions, or concerns at this time with the proposed petition. There were multiple company supervisors interviewed, and none had any issues, questions, or concerns at this time with the proposed petition.
The No. 4 mine is a vertical shaft underground mine that extracts bituminous coal from the Blue Creek coal seam by means of a longwall mining system and three continuous miner sections. This mine employees approximately 339 employees. This mine liberates 3,932,897 cubic feet of methane gas in a 24-hour period. The areas of the mine that would be affected will be continuous miner sections and outby belt areas to include some outby remote locations. The equipment that this would affect would be multiple power centers manufactured by Line Power and Tritech Engineering. The equipment receiving power from this affected equipment would be all continuous mining equipment on sections and all belt drive units. The number of miners affected by this would be approximately 60.
The No. 7 mine is a vertical shaft underground mine that extracts bituminous coal from the Blue Creek coal seam by means of two-longwall mining systems and six continuous miner sections. This mine employees approximately 529 employees. This mine liberates 19,311,891 cubic feet of methane gas in a 24-hour period. The areas of the mine that would be affected will be continuous miner sections and outby belt areas to include some outby remote locations. The equipment that this would affect would be multiple power centers manufactured by Line Power and Tritech Engineering. The equipment receiving power from this affected equipment would be all continuous mining equipment on sections and all belt drive units. The number of miners affected by this would be approximately 120 miners.
The mine operator is petitioning for a modification of application of the mandatory standard 30 30 CFR § 75.900 to permit the use of Contactors or Variable Frequency Drives ("VFD's") in series with the circuit breaker at the No. 4 and No. 7 mines. The combination of circuit breakers with Contactors or VFDs in the manner set forth would provide short circuit, undervoltage, grounded phase, and overcurrent protection. This set up would lessen the amount of direct physical contact between miners and electrical components.
During the investigation, an MSHA Electrical Specialist traveled underground at No. 4 mine North portal to the No. 4 section (C4) to observe testing of the combination of circuit breakers with Contactors (PLC). The petitioner conducted testing on a section power center that was manufactured by Line Power" 2500KVA S/N-U444. The circuit No. 10 was tested. The circuit included a molded case circuit breaker manufactured by Eaton E2K which protects the circuit from short circuit and overcurrent. The circuit breaker is rated at 600V A.C. 225-amp and a trip range of 200 amps to l 500amps.
The ground monitor unit is manufactured by Line Power, Model No. LPl 7-0145A, MSHA Acceptance No. 121390LP-001. The ground fault and undervoltage is manufactured by Line Power, Model No. GT-137. The contactor is manufactured by Eaton vacuum contactor, 610-amp 1500V. The testing was conducted with an SMC C-3100-1 test unit. Conducted testing per attached procedure for 995V & 600V testing procedure for 2500KVA power center. All tests conducted operated as it should, also conducted additional undervoltage bench tests of the circuit at Coalmont Development, a local electrical repair facility. The undervoltage protection averaged opening the contactor at 41.5% of the nominal voltage applied.
The investigator traveled to belt power center located on the No.4 section (C4) belt to observe testing of the combination of circuit breakers with Contactors (VFD). The petitioner conducted testing on a belt power center that was manufactured by Line Power/Tritech Engineering 1500KVA S/N U4440. The circuit No. 1 was tested. The circuit included a molded case circuit breaker manufactured by Eaton E2L which protects the circuit from short circuit and overcurrent. The circuit breaker is rated at 480V A.C. 600-amp and a trip range of 500 amps to 2500amps. This power center is not equipped with a ground monitor due to an existing petition for modification.
The ground fault is manufactured by Line Power, Model No. GT-137. Conducted testing per attached procedure for VFD output testing procedure for belt power center. The undervoltage was tested by single phasing the drive. Confirmed that the undervoltage of the circuit opened at 55% of the nominal voltage applied. All test conducted operated as it should.
MSHA finds that the alternate method proposed by the Petitioner (and as amended herein by MSHA) will at all times guarantee no less than the same measure of protection afforded the miners under 30 CFR § 75.900.
ORDER
Wherefore, pursuant to the authority delegated by the Secretary of Labor to the Administrator for Mine Safety and Health Enforcement, and pursuant to Section 101(c) of the Federal Mine Safety and Health Act of 1977, 30 U.S.C., Sec. 811(c), it is ordered that Warrior Met Coal LLC. Petition for Modification at Mine No. 4, MSHA ID 01-01247 and No. 7, MSHA ID 01-01401 for the application of 30 CFR § 75.900 is hereby:
GRANTED, to allow the use of contactors, in series with circuit breakers, to provide undervoltage and ground fault protection for three-phase alternating current low-voltage power circuits conditioned upon compliance with the following special terms and conditions:
1. The nominal voltage of the power circuit(s) shall not exceed 995 volts.
2. The nominal voltage of the control circuit(s) shall not exceed 120 volts.
3. The vacuum contactor shall be rated for the maximum voltage of the circuit being protected and the continuous full load current of the utilization equipment.
4. Vacuum contactors shall be located in the same enclosure as the circuit breaker.
5. Vacuum contactors with associated protective relays shall provide undervoltage protection for low- and medium-voltage circuits serving three-phase alternating current equipment.
6. Each circuit breaker installed in conjunction with a contactor shall be equipped with devices to provide short-circuit protection for each piece of equipment.
7. When a contactor trips on a ground fault condition or when a ground check monitor trips, it shall not automatically reset and must require manual reset. Undervoltage circuits must be wired so that contactors can be closed remotely only when undervoltage or loss of voltage condition no longer exists. All other conditions that cause the contactor to open shall require manual reset at the contactor.
8. The fail-safe ground check circuit shall cause the contactor to open when either the ground or pilot wire is broken.
9. Circuits providing power to portable or mobile equipment shall not be designed to be capable of being remotely started or remotely closed.
10. A monthly examination shall be conducted on each circuit to assure proper operation of the contactor. The monthly examination shall include activating the undervoltage, grounded-phase, and ground-monitor trip devices. The results of the contactor tests shall be recorded with the required circuit breakers monthly tests.
11. Prior to each start-up, an audible alarm at each affected vacuum contactor or affected area shall be activated for at least 15 seconds.
12. The Petitioner's alternative method shall not be implemented until all qualified persons who perform work on the equipment and circuits have received training in safe maintenance procedures and in the terms and conditions of the Proposed Decision and Order.
13. Within 60 days of this Petition for Modification being granted, the Petitioner shall submit proposed revisions for its approved 30 C.F.R. Part 48 training plan to the Coal Mine Safety and Health District Manager for the area in which the mine is located. These proposed revisions shall specify task training for all miners who are assigned to work in the area. The training shall include the following elements:
(a) The purpose of the pre-start alarm systems and vacuum contactor systems.
(b) The potential hazards of working on or near belt conveyors and belt conveyor drives; and
(c) The requirements of 30 C.F.R. § 75.1725(c) and (d).
The procedures of 30 C.F.R. § 48.3 for approval of proposed revisions to already approved training plans shall apply.
Unless specifically mentioned herein, nothing in this Proposed Decision and Order changes or supersedes the requirements otherwise imposed by the Mine Act, other mandatory standards or regulations, or approved ventilation or other plans.
Any party to this action desiring a hearing on this matter must file in accordance with 30 C.F.R. § 44.14 within 30 days. The request for hearing must be filed with the Administrator for Mine Safety and Health Enforcement, 200 Constitution Ave NW, Suite C3522, Washington, DC, 20210.
Any hearing request must contain a concise summary of position on the issues of fact or law to be raised by the party requesting the hearing, including specific objections to the proposed decision. A party other than the Petitioner who has requested a hearing may also comment on all issues of fact or law presented in the petition, and any party to this action requesting a hearing may indicate a desired hearing site.
If no request for a hearing is filed within 30 days after service of this Proposed Decision and Order, the Decision and Order will become final and must be posted by the operator on the bulletin board at the mine.
Dustan W. Crelly
Acting Administrator for
Mine Safety and Health Enforcement
Certificate of Service
I hereby certify that a copy of this proposed decision was served personally or mailed, postage paid, or provided by other electronic means this 13th day of March, 2025, to:
Brian Fredrickson
Warrior Met Coal LLC 14730 Lock 17 Road
Brookwood, Al 35444
Brian.fredrickson@warroirmetcoal.com
Chris Thielen
Warrior Met Coal LLC 16243 Highway 216 Brookwood, Al 35444
Chris.thielen@warriormetcoal.com
Errol Scott Arnett
Mine Safety and Health Specialist
Cc: Mr. James R. West
Mine Safety and Inspection Chief
Alabama Department of Labor
11 West Oxmoor Road, Ste 201
Birmingham, AL 35309
james.west@labor.alabama.gov