PHMSA Clarifies Pipeline Safety Terms

Today the DOT’s Pipeline and Hazardous Material Safety Administration (PHMSA) published a safety advisory in the Federal Register (81 FR 54512-54514) clarifying terminology used to describe the operational status of pipelines and identifying the regulatory requirements operators must follow for the abandonment of pipelines. PHMSA was directed to take this action by Congress via Section 23 of PIPES Act of 2016 (PL 114-183).

As a result of a number of incidents where releases of natural gas or hazardous liquids resulted from inadequate maintenance of pipelines that were not active service PHMSA is issuing this safety advisory to remind pipeline operators that PHMSA only recognizes two types of pipeline status; active and abandoned. To be classified as abandoned the pipelines have to meet all of the standards under  49 CFR 192.727 (gas pipelines) 49 CFR 195.402(c)(10) (hazardous liquid pipelines). All pipelines not meeting the regulatory standards for being abandoned, must comply with all pipeline safety regulation requirements.

PHMSA is considering a rulemaking action addressing permissible deferred pipeline maintenance activities on pipeline segments that have not been abandoned, but that have been emptied and purged. Pending completion of that rulemaking, pipeline operators that intend to defer such activities on this type of idled pipeline should coordinate with PHMSA first.

PHMSA Publishes New Crude Oil Testing Advisory

Yesterday the Pipeline and Hazardous Material Safety Administration (PHMSA) published a new Safety Advisory concerning rail shipments of crude oil. Because of three recent high-profile derailments and fires of crude oil trains (North Dakota, Alabama and Lac-Megantic, Quebec) PHMSA is conducting spot checks of crude oil to determine if the material is properly classified for shipment.

Petroleum Crude Oil (UN 1267) is listed in 49 CFR 172.101 as a flammable liquid (Class 3) with three possible packing groups based upon its characteristics. Those packing groups determine which types of rail cars may be used to transport the material with a Packing Group I requiring more rigorous protections based upon its higher risk. The testing that PHMSA has been doing has been aimed at determining if the material being shipped has been assigned to the proper shipping group.

Generally speaking 49 CFR 173.121 bases the packing group assignments for flammable liquids on the flash point (the lowest temperature at which ignition can take place) and boiling point of the liquid in question. A flammable liquid is generally classified (49 CFR 173.120) as “having a flash point of not more than 60 °C (140 °F)”. Packing Group I flammable liquids have an initial boiling point of less than 35 °C. Packing Group II flammable liquids have a flash point of less than 23 °C. And Packing Group II flammable liquids have a flash point of greater than 23 °C.

The additional testing by PHMSA as part of Operation Classification seems to indicate that this classification scheme may not be adequate for describing the relative risk associated with crude oil. While their testing program is not yet complete, the Safety Advisory indicates that they are looking at the possibility of requiring additional testing to possibly include:

• Reid Vapor Pressure;

• Corrosivity;

• Hydrogen sulfide content; and

• Composition/concentration of the entrained gases in the material

PHMSA closes out their advisory with the following reminder:

“PHMSA also reminds offerors that the hazardous materials regulations require offerors of hazardous materials to properly classify and describe the hazardous materials being offered for transportation. 49 CFR 173.22. Accordingly, offerors should not delay completing their own tests while PHMSA collects additional information”

I expect that we will see this Safety Advisory officially published in the Federal Register next week.

PHMSA Safety Advisory – LPG Odorization

Today the Pipeline and Hazardous Material Safety Administration (PHMSA) published a safety advisory in the Federal Register (78 FR 42818-42819) concerning inadequately odorized liquefied petroleum gas (LPG). This action is being taken in response to ‘several incidents’ where inadequately odorized LPG contributed to the severity of the incident. Odorants are added to LPG to act as a warning of the presence of LPG to help avoid fires and explosions when LPG containers leak.

Inadequate Odorization

The advisory notes that there are apparently two causes of inadequate odorization: an inadequate injection of odorants into the LPG and odorant fade caused by the absorption of the odorant onto the walls of new or freshly cleaned LPG tanks.

Where odorants (typically ethyl mercaptan, thiopane, or amyl mercaptan) are manually injected into LPG, PHMSA suspects that human error is the common cause of under-odorization. They recommend that “quality control checks should be conducted to ensure that the requisite amount of odorant is being injected”. Where automated equipment is being used “equipment calibration checks should be periodically performed to ensure consistent injection levels of the required odorant”.

When new or freshly cleaned tanks are being put into LPG service, the advisory recommends “that persons who receive new or recently cleaned tanks be notified of this fact and that persons filling these tanks implement appropriate quality control measures to ensure that potential odorant fade is adequately addressed”.

Rail Car Regulatory Anomaly

While the advisory does not specifically claim that this has contributed to any LPG incidents, it does note that the way the Hazardous Materials Regulations (HMR) deals with odorization in truck and rail shipments does differ.

The advisory explains that the HMR {173.315(b)(1)} requires that LPG shipped by cargo tank or portable tank must be odorized unless doing so “would be harmful in the use or further processing of the LPG” (typically for shipments to industrial customers using LPG in other processes). There are no such requirements for rail shipments (NOTE: I assume that the presumption was that rail car shipments were defacto going to industrial customers and would thus not require odorization).

The advisory notes that:

“Therefore, in this safety alert, PHMSA recommends that all LPG transported in rail tank car tanks or cylinders be odorized in accordance with the requirements of § 173.315(b)(1), of the HMR, unless odorization would be harmful in the use or further processing of the LPG, or if odorization will serve no useful purpose as a warning agent in such use or further processing.”

PHMSA Safety Advisory – Improperly Filled Cylinders

The Pipeline and Hazardous Material Safety Administration (PHMSA) published a safety advisory in today’s Federal Register (78 FR 42817-42818) concerning the improper filling of compressed gas cylinders by the American Coil and Beverage Group in East Point, MI. According to the advisory, the problem was brought to PHMSA’s attention due to the catastrophic failure of a cylinder filled by that organization.

PHMSA reports that:

“The DOT 3A 1800 cylinder that failed was manufactured by Morcar in 1973 and had not been requalified since May, 1996. DOT 3A 1800 cylinders used in carbon dioxide service must be successfully requalified through a visual inspection and a pressure test at least once every 5 years.”

PHMSA goes on to conclude that because “North American Coil and Beverage Group did not have their cylinders requalified prior to filling them and the fact that one catastrophically failed, PHMSA questions the condition of all of the cylinders owned and filled by North American Coil and Beverage.”

PHMSA recommends that any cylinders filled by North American Coil and Beverage Group be immediately pulled from services. They also advise that anyone possessing such a cylinder should “contact a cylinder filler to have the cylinders depressurized”.

PHMSA Compressed Gas Cylinder Safety Advisory

Today the Pipeline and Hazardous Material Safety Administration (PHMSA) published a safety advisory in the Federal Register (78 FR 33891) concerning improperly marked gas cylinders. This is the third safety advisory of this sort in the last year (10-13-12 and 03-13-13).

In this instance Shasta Fire Equipment, Inc. of Redding, CA has been identified by PHMSA as having certified DOT-specification gas cylinders without doing the required testing. This means that the cylinders marked by this company between March 6^th, 2013 and May 6^th, 2013 may not be safe for containing or shipping pressurized gasses.

Anyone having a  DOT-specification 3AA, 3AL, 3HT, and exemption (DOT-E) and special permit (DOT-SP) cylinders, marked with ‘RIN D183’ between March 6, 2013 and May 6, is advised to promptly remove it from service, safely discharge the contents, and send it to a an authorized retester for proper testing.

PHMSA Gas Cylinder Safety Advisory

Today the Pipeline and Hazardous Material Safety Administration published a Safety Advisory in the Federal Register (78 FR 16045) concerning inadequately tested gas cylinders in carbon dioxide service.

The advisory notes that approximately 496 DOT 3AA and 3AL cylinders from Flint Welding Supply (Flint, MI) used in carbon dioxide service were improperly marked from approximately June 2010 to December 2012 by Kraus Fire Equipment Co. According to the notice cylinders marked with an ‘A978’ or a partial ‘A978’ or just the Month/Year, without a RIN mark in the middle “may not possess the structural integrity to safely contain their contents under pressure during normal transportation and use”.

Any cylinders with these marks should be vented or otherwise safely discharged by authorized personnel and returned to Flint Welding Supply.

PHMSA Publishes Gas Cylinder Safety Advisory Notice

The Pipeline and Hazardous Material Safety Administration has published a safety advisory notice (77 FR 64590-64591) in Monday’s Federal Register (available on line yesterday) concerning an unknown number of high-pressure gas cylinders that were improperly marked and certified by George Welding and Supply Company of Montoursville, PA between 2001 and 2012.

The Safety Advisory notes that George Welding and Supply Company is not “approved to requalify DOT-specification cylinders or mark such cylinders as being requalified”. Apparently George Welding and Supply marked some number of cylinders with the Requalifier Identification Number (RIN) of the following approved companies:

C171--Proshield Fire Protection, Waterloo, IA;

C004--Swartz Fire & Safety Equipment Co., Inc., Bellefonte, PA;

C411--Advanced Fire Protection Services, Inc., Ft. Walton Beach, FL;

C951--Peifer's Fire Protection, Inc., Pillow, PA;

D477--NASCO, Colorado Springs, CO;

D575--Sea Sports, Inc., Hyannis, MA;

D576--Chenango Welding Supply, LLC;

A101--Airgas North Central, Waterloo, IA; and

D322--Allstate Fire Equipment Co.

The notice states that cylinders actually requalified by the above company are not covered by this notice; only cylinders serviced by George Welding and Supply Company are affected. People that have cylinders with the above listed RINs should check with their supplier to see who was responsible for their most recent requalification.

For cylinders reported requalified by George Welding and Supply Company, the Safety Advisory notes that they may not be safe and recommends the following actions be taken:

• Cylinders that are filled with an atmospheric gas should be vented or otherwise safely discharged; or

• Cylinders that are filled with a material other than an atmospheric gas should not be vented but instead should be safely discharged; and

• Prior to refilling, the cylinders must be taken to a DOT-authorized cylinder requalifier to ensure their suitability for continued service.