NTSB Safety Recommendation P-88-002

NTSB safety recommendation P-88-002.

THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION: REVISE 49 CFR PART 191 TO REQUIRE THAT PIPELINE OPERATORS REPORT ALL INCIDENTS IN WHICH CONCENTRATIONS OF HYDROGEN SULFIDE IN EXCESS OF THE MAXIMUM ALLOWABLE CONCENTRATION ARE INTRODUCED INTO PIPELINE SYSTEMS THAT TRANSPORT NATURAL GAS INTENDED FOR DOMESTIC OR COMMERCIAL PURPOSES.

Priority: CLASS III

Overall Status: Closed - Unacceptable Action

Issued Date: 1988-05-10

Adopted Date: 1988-04-21

Overall Date Closed: 1999-06-18

Synopsis: ABOUT 10:30 A.M. ON AUGUST 11, 1987, A FLASHING RED LIGHT ALERTING DEVICE AT THE KG GAS PROCESSING PLANT NEAR WINTERS, TEXAS, INDICATED THAT AN EXCESSIVE AMOUNT OF HYDROGEN SULFIDE (H2S) WAS FLOWING INTO THE GAS STREAM BEING DELIVERED TO THE LONE STAR GAS COMPANY (LONE STAR). AT 11 A.M., THE KG PLANT SUPERINTENDENT CLOSED THE VALVE ON THE PIPELINE WHICH DIRECTED GAS INTO LONE STAR'S GAS RECEIVING FACILITIES LOCATED ABOUT 2,600 FEET FROM THE PLANT. THE KG SUPERINTENDENT STATED THAT HE ATTEMPTED TO NOTIFY LONE STAR BY TELEPHONE BUT THAT HE WAS UNABLE TO REACH ANYONE. THE SUPERINTENDENT TOOK NO FURTHER ACTIONS BECAUSE HE BELIEVED THAT ONLY A SMALL AMOUNT OF H2S-CONTAMINATED GAS HAD ENTERED THE LONE STAR SYSTEM.

Keywords: Hazmat

Ntsbnumber: PLD87XR001

Report Number: None

Addressee Name: RSPA

Addressee Status: Closed - Unacceptable Action

Addressee Date Closed: 1999-06-18

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1997-10-31

Communication Type: Official Correspondence

Communication Contents: NTSB REQUESTED A FOLLOWUP ON THIS DATE 10/31/97.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1999-06-18

Communication Type: Official Correspondence

Communication Contents: THE BOARD UNDERSTANDS THAT RSPA ISSUED AN ANPRM IN 1989, ASKING FOR INFORMATION THAT WOULD HELP RSPA DECIDE WHETHER REGULATIONS ARE NEEDED TO CONTROL THE CONCENTRATION OF HYDROGEN SULFIDE IN NATURAL GAS PIPELINE SYSTEMS. IN 1992, THE TECHNICAL PIPELINE SAFETY STANDARDS COMMITTEE VOTED THAT THE PROPOSED RULE WAS NOT FEASIBLE, REASONABLE, OR PRACTICABLE. THE BOARD RECOGNIZES THAT PIPELINE OPERATORS CAN CONTRACT FOR THE REMOVAL OF HYDROGEN SULFIDE AS A CONDITION OF PURCHASE; HOWEVER, SUCH CONTRACTS CANNOT PREVENT THE ENTRY OF HYDROGEN SULFIDE INTO PIPELINES. WHEN THE BOARD RECOMMENDED THE DEVELOPMENT OF REGULATIONS ON THIS SUBJECT, THE ACCIDENT CITED HAD OCCURRED AS A RESULT OF FAULTY EQUIPMENT AND DEFICIENT PROCEDURES. THE BOARD CONTINUES TO BELIEVE THAT PIPELINE OPERATORS WHO DO NOT INSTALL THEIR OWN MONITORING AND CONTROL DEVICES MUST BE REQUIRED TO VERIFY THAT EQUIPMENT IS PROPERLY INSTALLED AND MAINTAINED. IN ADDITION, THE BOARD DOES NOT BELIEVE THAT OPERATORS OF GATHERING LINES SHOULD BE ALLOWED TO TRANSPORT GAS NEAR POPULATED AREAS THROUGH A PIPELINE CONTAINING A HIGH LEVEL OF HYDROGEN SULFIDE. THE CALIFORNIA PUBLIC UTILITIES COMMISSION HAS RECOGNIZED THE DANGER AND DOES NOT ALLOW GAS UTILITIES TO SUPPLY GAS THAT CONTAINS MORE THAN 1/4 GRAIN OF HYDROGEN SULFIDE PER 100 STANDARD CUBIC FEET. GIVEN RSPA'S CONTINUED RESISTANCE TO IMPLEMENTING WHAT THE BOARD CONSIDERS A REASONABLE, FEASIBLE, AND USEFUL METHOD OF ADDRESSING AND IDENTIFYING A POTENTIALLY SERIOUS SAFETY PROBLEM, AND BECAUSE RSPA HAS ADVISED THE BOARD THAT IT DOES NOT PLAN TO PRESCRIBE ANY REQUIREMENTS ADDRESSING HYDROGEN SULFIDE CONCENTRATIONS IN PIPELINES, P-88-1, -2 AND -3 HAVE BEEN CLASSIFIED "CLOSED--UNACCEPTABLE ACTION."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1988-09-29

Communication Type: Official Correspondence

Communication Contents: We have reviewed your letter in response to the National Transportation Safety Board's Safety Recommendations P-88-l through -3, regarding the need to specify a maximum allowable concentration of hydrogen sulfide in natural gas pipeline systems, to require reporting of incidents in excess of the maximum allowable concentration, and to requi,re installation of equipment to detect and shut off the flow of gas when the maximum allowable concentrations of hydrogen sulfide-contaminated gas are exceeded. While the Safety Board appreciates being informed of the current Research and Special Programs Administration technical study concerning stress corrosion cracking induced by hydrogen sulfide, we do not see the relevance of this study to the toxicity problem cited in our safety recommendations. Pending receipt of an outline or synopsis of the study that shows direct reference to the problem of the toxic nature of excessive hydrogen sulfide, we will hold Safety Recommendations P-88-1 through -3 in an "Open--Unacceptable Action" status.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1989-07-06

Communication Type: Official Correspondence

Communication Contents: Thank you for your May 22, 1989, letter in further response to the National Transportation Safety Board's Recommendations P-88-l through -3 regarding excessive concentration of hydrogen sulfide in natural gas pipeline systems. The Safety Board is pleased that the Research and Special Programs Administration is developing an Advance Notice of Proposed Rulemaking to amend the Federal regulations in line with the requirements of these recommendations. We would appreciate receiving a periodic update on the progress of this regulatory initiative. Pending the results of this rulemaking effort, these recommendations will be held in an "Open--Acceptable Action" status.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1993-11-12

Communication Type: Official Correspondence

Communication Contents: THE BOARD UNDERSTANDS THAT RSPA ISSUED AN ADVANCE NOTICE OF PROPOSED RULEMAKING (54 FR 24361) ON JUNE 7, 1989, ASKING FOR INFORMATION THAT WOULD HELP IT DECIDE ON THE NEED FOR REGULATIONS TO CONTROL THE CONCENTRATION OF H2S IN NATURAL GAS PIPELINE SYSTEMS. ON MARCH 11, 1992, THE TECHNICAL PIPELINE SAFETY STANDARDS COMMITTEE VOTED THAT THE PROPOSED RULE WAS NOT FEASIBLE REASONBLE, OR PRACTICABLE. THE BOARD RECOGNIZES THAT PIPELINE OPERATORS CAN CONTRACT FOR THE REMOVAL OF H2S AS A CONDITION OF PURCHASE; HOWEVER, SUCH CONTRACTS CANNOT PREVENT THE ENTRY OF H2S INTO PIPELINES. WHEN THE BOARD RECOMMENDED THE DEVELOPMENT OF REGULATIONS ON THIS SUBJECT, THE ACCIDENTS CITED HAD OCCURRED AS A RESULT OF FAULTY EQUIPMENT AND DEFICIENT PROCEDURES. WE BELIEVE THAT PIPELINE OPERATORS WHO DO NOT INSTALL THEIR OWN MONITORING AND CONTROL DEVICES MUST BE REQUIRED TO VERIFY THAT EQUIPMENT IS PROPERLY INSTALLED AND MAINTAINED. THE BOARD DOES NOT BELIEVE THAT OPERATORS OF GATHERING LINES SHOULD BE ALLOWED TO TRANSPORT GAS NEAR POPULATED AREAS THROUGH A PIPELINE CONTAINING A HIGH LEVEL OF H2S. THE CALIFORNIA PUBLIC UTILITIES COMMISSION RECOGNIZES THE DANGER; IT DOES NOT ALLOW GAS UTILITIES TO SUPPLY GAS THAT CONTAINS MORE THAN 1/4 GRAIN OF H2S PER 100 STANDARD CUBIC FEET. GIVEN RSPA'S CONTINUED RESISTANCE TO IMPLEMENTING WHAT THE BOARD CONSIDERS A REASONABLE, FEASIBLE, AND USEFUL METHOD OF ADDRESSING AND IDENTIFYING A POTENTIALLY SERIOUS SAFETY PROBLEM, RECOMMENDATIONS P-88-1 THROUGH -3 HAVE BEEN CLASSIFIED "OPEN--UNACCEPTABLE RESPONSE," PENDING RSPA REVIEW OF OUR COMMENTS. CONTRACT

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-06-30

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 7/2/98 1:03:47 PM MC# 980837 AFTER CAREFUL CONSIDERATION OF THIS ISSUE IN A RULEMAKING, RSPA DOES NOT PLAN TO PRESCRIBE ANY REQUIREMENTS TO ADDRESS HYDROGEN SULFIDE CONCENTRATIONS IN PIPELINES. RSPA PUBLISHED AN ADVANCE NOTICE OF PROPOSED RULEMAKING (ANPRM) ON 6/7/89, (54 FR 24361) TO GATHER INFORMATION TO ASSESS THE NEED FOR REGULATION OF HYDROGEN SULFIDE IN GAS TRANSMISSION PIPELINES. A SUBSEQUENT NOTICE OF PROPOSED RULEMAKING (NPRM) ON 3/18/91, (56 FR 11 490) PROPOSED RULE CHANGES IN 49 CFR PARTS 191 AND 192. THE COMMENTS RECEIVED WERE OVERWHELMINGLY NEGATIVE ON THE NEED FOR A RULE ON HYDROGEN SULFIDE IN TRANSMISSION PIPELINES. IN ADDITION, THE GAS PIPELINE SAFETY ADVISORY COMMITTEE VOTED UNANIMOUSLY THAT THE LIMITED NUMBER OF INCIDENTS OF HYDROGEN SULFIDE IN TRANSMISSION LINES DID NOT WARRANT A RULEMAKING. RSPA CONCLUDED THAT THE PROPOSED HYDROGEN SULFIDE REGULATIONS ARE NOT WARRANTED BECAUSE THERE HAVE NOT BEEN ANY DEATHS OR INJURIES ATTRIBUTABLE TO HYDROGEN SULFIDE IN GAS TRANSMISSION LINES AND HYDROGEN SULFIDE RELEASES INTO TRANSMISSION LINES HAVE BEEN INFREQUENT, OF BRIEF DURATION, AND INVOLVED MINUTE AMOUNTS. FURTHER, HYDROGEN SULFIDE THAT IS RELEASED INTO A TRANSMISSION LINE REMAINS CONFINED WITH VERY LITTLE LIKELIHOOD THAT THERE WOULD BE A LEAK IN THE TRANSMISSION LINE AT THE SAME TIME AND IN THE SAME VICINITY AS THE RELEASE. FINALLY, HYDROGEN SULFIDE RELEASED INTO A TRANSMISSION LINE FROM A PROCESSING PLANT WILL LIKELY BE DILUTED BY NATURAL GAS FROM OTHER SOURCES. FOR THESE REASONS, RSPA PUBLISHED A WITHDRAWAL OF NOTICE OF PROPOSED RULEMAKING ON 3/7/96, (61 FR 9133). RSPA IS NOT PURSUING THIS MATTER ANY FURTHER. ACCORDINGLY, WE REQUEST THAT NTSB CLASSIFY THIS RECOMMENDATION AS "CLOSED--RECONSIDERED."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1988-07-05

Communication Type: Official Correspondence

Communication Contents: RSPA BELIEVES THAT THESE RECOMMENDATIONS SHOULD BE ADDRESSED IN RULEMAKING. RSPA CURRENTLY HAS A TECHNICAL STUDY UNDERWAY WITH REGARD TO STRESS CORROSION CRACKING INDUCED BY HYDROGEN SULFIDE. THE INFORMATION FROM THIS REPORT WILL BE USED AS A BASIS FOR BROADENING THE SCOPE OF H S STUDIES AND INITIATE REGULATORY ACTION ON THESE RECOMMENDATIONS IN 1989 PROVIDING RSPA RESOURCES ARE SUFFICIENT TO SUPPORT ANY NECESSARY DEVELOPMENTAL STUDIES.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1989-05-22

Communication Type: Official Correspondence

Communication Contents: RSPA HAS RECENTLY COMPLETED A STUDY INVOLVING THE SULFIDE STRESS CRACKING OF LINE PIPE, AS REFERENCED IN OUR LETTER OF JULY 5, 1988, AND WE ARE NOW DEVELOPING A REGULATORY PROJECT THAT SPECIFICALLY ADDRESSES THE THREE KEY ISSUES CITED IN THOSE RECOMMENDATIONS. THIS ADVANCE NOTICE OF PROPOSED RULEMAKING (ANPRM) WILL ADDRESS NOT ONLY A MAXIMUM ALLOWABLE CONCENTRATION OF H2S RELEASE, BUT WILL ALSO ADDRESS A REQUIREMENT THAT OPERATORS REPORT ALL INCIDENTS INVOLVING THE RELEASE OF H2S GAS INTO THE GAS STREAM. THE REGULATORY PROJECT WILL FOCUS ON CANADIAN EXPERIENCE IN HIGH-LEVEL H2S GAS GATHERING FIELDS IN ALBERTA AS WELL AS TEXAS AND CALIFORNIA EXPERIENCE AND STANDARDS. I ANTICIPATE THAT THE ANPRM WILL BE ISSUED IN JUNE OF 1989. THE ANPRM WILL PROVIDE RSPA INFORMATION NEEDED TO PROCEED WITH FURTHER RULEMAKING. I ANTICIPATE THAT A FINAL RULE COULD BE ISSUED BY THE END OF 1990.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1993-09-24

Communication Type: Official Correspondence

Communication Contents: RSPA ISSUED AN ADVANCE NOTICE OF PROPOSED RULEMAKING ON JUNE 7, 1989, REQUESTING INFORMATION TO ASSIST IN DETERMINING THE NEED FOR REGULATIONS TO CONTROL THE CONCENTRATION OF HYDROGEN SULFIDE IN NATURAL GAS PIPELINE SYSTEMS. ON MARCH 11, 1992, THE TECHNICAL PIPELINE SAFETY STANDARDS COMMITTEE VOTED THAT THE PROPOSED RULE WAS NOT FEASIBLE OR PRACTICABLE. RSPA HAS CONCLUDED THAT ISSUING A FINAL RULE ON THIS ISSUE IS NOT WARRANTED.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1992-08-31

Communication Type: Official Correspondence