GAS LINE PURGING

Introduction
The process of installing or servicing natural or liquefied petroleum gas (LPG) fueled equipment is highly hazardous. This can be seen from a number of major explosion and fires that have occurred in the past several years. In a nine month period from June 2009 to February 2010 at least 10 workers have been killed and another 97 workers, emergency responders or members of the general public, were also seriously injured from natural gas purging operations. The purging of natural or LP gas lines can occur in a variety of situations; from the installation of a small water heater or boiler/furnace in a residential or commercial building to larger installations. Larger installations such as that seen in industrial manufacturing plants, power plants & pipe supply lines can involve significantly greater volumes which can easily create explosive hazard environments if purged or vented improperly. less than 20 feet off the ground. These vents were adjacent to the main power generation building and along the south wall. Public information indicates the Chemical Safety Board(1) (CSB) investigators have reviewed gas utility records for the morning of the accident. These records together with written pipe cleaning procedures and witness testimony confirm that the gas blows occurred intermittently over the course of the morning. At the same time that gas blows were underway, there was potential ignition sources present in the surrounding area, including inside the power plant building. There were many constructionrelated activities underway inside the building. Information from the CSB indicates that purging lines with natural gas during the testing/commissioning stage to remove moisture and debris from the line, is currently a common practice used in the trades. This picture below shows gas being vented shortly before the accident. The preliminary investigation

Recent Incidents
Kleen Energy Plant, Middletown, CT February 7, 2010 Six workers died and twenty-six others were injured when an explosion occurred during a planned work activity to clean debris from natural gas pipes at the plant. To remove the debris, workers allegedly used natural gas at a high pressure of approximately 650 pounds per square inch. The high velocity of the natural gas flow was intended to remove any debris in the new piping (a process referred to as a gas blow). At predetermined locations, this gas was vented to the atmosphere through open pipe ends which were located

(Photo courtesy of U.S. Chemical Safety Board)

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report from the U.S. Chemical Safety and Hazard Investigation Board (CSB) indicate the explosion was the result of venting a significant volume of natural gas (estimated at 400,000 cubic feet of gas) to the outdoors, but within an employee work area, during the purging of the main gas line. Any ignition source present (i.e. welding, portable heaters, electrical equipment, static electricity, etc.) would be able to initiate the explosion. ConAgra Slim Jim Plant, Garner, NC June 9, 2009 A major natural gas explosion heavily damaged the ConAgra Slim Jim meat processing factory in Garner, North Carolina. Four workers died in the resulting explosion & building collapse, there were at least 71 injuries and a large section of the building collapsed. Approximately 18,000 pounds of ammonia was released causing an evacuation of personnel. This release also resulted in a toxic exposure to emergency response personnel and the general public. Resulting environmental damage occurred from the large ammonia release.

control the release of purged gases. The purged fuel gas was vented indoors into the utility room, which was ventilated by an exhaust fan. Over 200 people who had no role in the installation were in the building when the natural gas found an ignition source and exploded at approximately 11:25 a.m. Other Similar Incidents During the construction of a 30 story hotel in 2008 in San Diego, an explosion injured 14 workers and damaged 3 levels of the building. CalOSHA cited a contractor for not venting from an enclosed space and failure to test for flammable gases. In 2007 two plumbers in Cheyenne, WY were severely burned during the purging of natural gas into the interior of a new hotel under construction. The workers stated they were unable to smell the odorized gas as it filled the room. In 1999 at a Ford power plant in Dearborn, MI six people were killed, 38 injured and $1 billion in property damage occurred. A gas pipe being removed from service was purged into a boiler. 1997 in Cary, NC a worker attempted to purge air from a natural gas line into a laundry room during a startup of a commercial dryer. Six workers injured, and a partial roof collapse occurred.

Problem Identified
The purging of lines with natural gas during the testing/commissioning stage to remove moisture and debris (known as gas blows) from the line, is currently a common practice used in the trades. Many times this gas may be vented into interior or restricted spaces that do not allow the gas to freely disperse that result in a concentration buildup. During the firing of equipment fueled by natural or LP gas it is common to purge the fuel supply line near the equipment. This often results in flammable gas being vented in an enclosed area as the air is purged from the line. These locations are typically confined and have many potential ignition sources. Historically workers have relied on the sense of smell to be able to detect the presence of the flammable gas. A chemical odorant (T-butyl mercaptan) is typically manually added to natural and LP gas. However, perception can be subjective, and some individuals can become desensitized after prolonged exposure (resulting in the inability to recognize the

CONAGRA PLANT, GARNER, NC

(Photo courtesy of U.S. Chemical Safety Board)

The accident occurred during the installation of a new fuel gas-fired industrial water heater in an interior utility room of the plant. Five days prior to the accident, a new section of three-inch steel piping which would provide natural gas to the heater was tied into a sixinch natural gas supply line located on the roof. The new natural gas piping ran horizontally over 120 feet along the roof and then descended into the utility room. The water heater manufacturer, was attempting to purge the new gas line by using natural gas to directly displace the air. This was done by removing threaded fittings, creating one or more pipe openings near the heater. The worker then opened a valve to

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odor). In addition the effect of odor fade is now being recognized. This can occur on new pipe installations and can react to remove the odorant effectiveness. The odorant manually added during the distribution process has the potential to be omitted by human error. All potential ignition sources are not effectively isolated or at times these sources can not be isolated (i.e. static electricity or lightning). The recognition of the inherent hazards of gas purging operations has been weak as evidenced by number of explosion incidents in recent years. The current regulatory codes do not adequately address the required safety measure when purging newly installed, modified or serviced fuel gas systems.

Emergency Actions
Following the ConAgra explosion investigation the CSB in September 2009 issued a Safety Bulletin entitled Dangers of Purging Gas Piping into Buildings. Five key lessons learned were identified in this bulletin: 1. Purging new or existing gas piping into buildings can be highly hazardous due to the possible accumulation of gas above the lower explosive limit (LEL)(3) and the associated danger of fire and explosion. Wherever practicable, directly vent purged gases to a safe location outdoors, away from people and ignition sources. This can be done using a temporary hose or piping or permanently installed vent pipes, depending on the facility design. 2. Purging indoors should only be done in limited circumstances where purging outdoors is not practicable. In such cases: Nonessential personnel should be evacuated; All ignition sources should be controlled or eliminated; Ventilation should be adequate to maintain the gas concentration well below the lower explosive limit at all times. 3. Never rely on odor alone to detect releases of fuel gases. An odorant(4) is typically added to fuel gases, such as natural gas and propane, to warn workers and consumers of releases. However, the perception of odor is highly subjective and varies from one person to another. People also become desensitized to odor during prolonged exposures. Additionally, new gas pipes and containers can react with or otherwise remove the odorant, an effect known as odor fade. 4. Always use combustible gas detectors(5) to monitor the gas concentration during purging operations. To provide the most accurate information about combustible gas levels, sampling should be conducted frequently or continuously at appropriate locations.(6) 5. Ensure personnel involved in gas purging operations are fully trained and knowledgeable about safe gas venting practices, the proper use of gas detectors, and the danger of relying on the sense of smell alone to detect gas releases. Include training on the problem of odor fade in new gas piping systems.

Regulatory Standards/References
The regulatory standards that apply to the installation of natural and LP gas installation are covered under voluntary consensus codes developed by several organizations. These codes are commonly adopted as regulations by various states or local municipalities across the United States. The agency/associations and codes are shown below: The National Fire Protection Association (NFPA) publishes the National Fuel Gas Code (NFPA 54/ ANSI Z223.1). The American Gas Association (AGA) publishes a technical guide entitles Purging Principles and Practice. The NFPA and AGA jointly publish the National Fuel Gas Code Handbook. The International Code Council (ICC) also has the International Fuel Gas Code. Additional Mandatory Standards apply to industry under the Occupational Safety and Heath Administration, such as: Occupational Safety and Heath Administration (OSHA) regulates LPG under 29 CFR 1910.110. OSHA also regulates flammable gases under 29 CFR 1910.119 where processes involve a flammable liquid or gas on site in one location, in a quantity of 10,000 pounds or more.(2)

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On February 4, 2010 just three days before the Kleen Energy Plant explosion, the CSB voted to approve 2 urgent recommendations that national fuel gas codes be changed. These changes are needed to improve safety when gas pipes are being purged (cleared of air) during maintenance or installation of new piping. The first recommendation was directed to the National Fire Protection Association (NFPA), the American Gas Association (AGA) and the Chair of the NFPA 54/ANSI Z223.1 Committee.

2009-12-I-NC-UR2
Incorporate the revised gas purging provisions of the National Fuel Gas Code, consistent with CSB recommendation 2009-12-I-NC-R1, into the International Fuel Gas Code. On February 24, 2010 a NFPA panel voted to move forward with the CSBs recommendations to make gas purging practices safer. Currently the National Fuel Gas Code Committee has not approved the language for a temporary interim amendment (TIA). The committee is working towards consensus language and expects to release a draft TIA for public review in the near future.

2009-12-I-NC-UR1
Enact a Tentative Interim Amendment as well as permanent changes to the National Fuel Gas Code (NFPA 54/ANSI Z223.1) to require that during the purging of fuel gas piping at industrial, commercial, and public facilities: a. Purged fuel gases shall be directly vented to a safe location outdoors, away from personnel and ignition sources b. If it is not possible to vent purged gases outdoors, purging gas to the inside of a building shall be allowed only upon approval by the authority having jurisdiction(7) of a documented risk evaluation and hazard control plan. The evaluation and plan shall establish that indoor purging is necessary and that adequate safeguards are in place such as: Evacuating nonessential personnel from the vicinity of the purging; Providing adequate ventilation to maintain the gas concentration at an established safe level, substantially below the lower explosive limit; and Controlling or eliminating potential ignition sources. c. Combustible gas detectors are used to continuously monitor the gas concentration at appropriate locations in the vicinity where purged gases are released. d. Personnel are trained about the problems of odor fade and odor fatigue and warned against relying on odor alone for detecting releases of fuel gases. The second recommendation was directed to the International Code Council (ICC) and the Chair of the International Fuel Gas Code Committee.

Lessons Learned
Training
All personnel should be properly trained in: 1. Lockout-Tagout 2. Safe Gas Purging Techniques 3. Hazard Identification 4. Use of Gas Monitoring Equipment

Lockout Tagout
1. Any potential ignition source should be identified and isolated in the proximity of the work area. All flames or potential ignition sources within proximity should be de-energized and locked out. Use the standard lockout-tagout protocols required under OSHA 1910. 2. Just closing and locking out the fuel line may not be enough. Has the line been purged of the fuel gas inside. (see purging section on page 5) 3. Fuel supplies in some cases upstream may also need to be secured and locked out. This may also require the installation of blinds in the fuel supply line in some situations.
(SPADE BLIND WITH LOCKOUT DEVICE)

BLANK (OR BLIND)

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Purging
1. Gas blows (or the purging) of pipe to remove contaminant or debris should be done using nonflammables that are inert such as air (not pure oxygen), carbon dioxide or nitrogen. This reduces the risk of fire or explosion. These gas blows have risks associated: Possible high pressure discharges to clean out the line. Where is the discharge point? This point should be located in an isolated area away from contact with personnel, equipment and buildings. These discharges should be outside in a well ventilated area that allows quick dispersion of gas concentration or buildup. Caution needs to be used with inert gases. Nitrogen can be used to reduce the risk of fire or explosion but it also can make the atmosphere in and around the equipment hazardous for humans to breathe(7). Its not toxic as it makes up 78% of the air we breath but it can displace the air we breathe as the inert concentration levels rise. If the concentration of oxygen is reduced to below 19.5% a person could become unconscious and die from lack of sufficient oxygen. High pressure gas blows or purging can cause catastrophic failure of pipe, valves or fittings. Pipe, valves, fittings, gauges, etc. should all be designed for the pressures that are intended. If not, precautions need to be taken to keep the pressures within design parameters or to isolate (i.e. via the installation of line blinds or blanks). 2. When purging of pipe for the purpose of displacing air or other gas within the pipe and replacing it with fuel gas (natural or LP) extreme caution is required due to the fuel gas that is charged into the system escaping into the atmosphere. This purging should be directed outdoors in a well ventilated space that is free from all ignition source hazards. A temporary pipe or hose could be used to purge from the source to a safe outside area. When locating the purge discharge take into consideration the physical properties of the gas being purged. For gas heavier than air consider low spots or depressions where heavier gas vapors will settle. Consider the effects of weather on dispersion of the gas being purged. The gas should be rapidly dispersed and not exceed 10% of the LEL.

The Tentative Interim Amendment (2009-12-I-NC-UR1) issued by the Chemical Safety Board states that if it is not possible to vent flammable gas outside then it shall only be allowed when approved by the Authority Having Jurisdiction(7) of a documented risk evaluation and hazard control plan. If it is not possible to purge to a safe outside location then interior purging should only be done with very careful planning. Develop a written Purging Plan that addresses: Employee training Lockout-tagout of ignition sources and fuel source minimization The purging process Monitoring of flammable gases (and oxygen levels) Minimizing exposure to non-essential personnel Evacuation/emergency response Have the written plan reviewed and approved by the Authority Having Jurisdiction.

Hazard Identification
Break down the purging task to identify all potential hazards by a job hazard analysis (JHA) process. 3 steps are involved in the development of a JHA. (see attachment) 1. Creating a step by step task analysis to complete the job. 2. Identify all the potential hazards associated with each task step. 3. List the methods of control for each of the hazards identified.

Monitoring
Checking for layers of gas at various levels

Whether performing a gas blow or a purging operation (inside or outside) with flammable gas a potential exists for an accumulation of gas at an explosive level. The only safe means to monitor for flammable gas concentrations is with a reliable combustible gas detector(6). Combustible gas detectors should be rated intrinsically safe by a

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certifying organization such as Underwriters Laboratory (UL) or Factory Mutual (FM). They also should be calibrated and serviced per the manufacturer instructions. Employee training in the proper use of this equipment is required. Following the manufacturers instructions is crucial to hazard identification. Testing should be done frequently and at predetermined locations during the purging process. At any time if the gas concentration exceeds 10% of the LEL, the purging process should be immediately stopped.

5. Combustible gas detectors measure combustible/ flammable gas concentration in the atmosphere, which is indicated on the device as a percentage of the lower explosive limit (LEL). 6. The evaluation of appropriate locations for combustible gas monitoring should include consideration of the purge location, characteristics of the gas (lighter or heavier than air), stratification or mixing of the gas, and existing ventilation. See the International Society for Automation (ISA) RP 12.13, Recommended Practice for the Installation, Operation, and Maintenance of Combustible Gas Detection Instruments (2003) and the American Petroleum Institute (API) 2009, Safe Welding, Cutting, and Hot Work Practices in the Petroleum and Petrochemical Industries (2002). 7. The NFPA defines the Authority Having Jurisdiction (AHJ) as an organization, office, or individual responsible for enforcing the requirements of a code or standard, or for approving equipment, materials, an installation, or a procedure such as a local fire marshal or building official. NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2006 Edition, 654-6. Where it is not possible to implement safety controls, NFPA standards can grant decision-making authority over exceptions to safety requirements to the authority having jurisdiction. 8. CSB identified 85 nitrogen asphyxiation incidents that occurred in the workplace between 1992 and 2002. Eighty people were killed and 50 were injured. Source USB Safety Bulletin No. 2003-10-B | June 2003

For More Information

For additional information specific to your need, please contact your Hartford loss control consultant, or visit us at www.thehartford.com.

Footnotes
1. The Chemical Safety Board (CSB) is an independent federal agency charged with investigating industrial chemical accidents. The CSB conducts root cause investigations of chemical accidents at fixed industrial facilities. 2. Except for hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by 29 CFR 1910.119. 3. The LEL, also known as the Lower Flammable Limit (LFL), is defined as that concentration of a combustible material in air below which ignition will not occur. Recommended Practice for Handling Releases of Flammable and Combustible Liquids and Gases, NFPA 329 (2005). 4. Natural gas is primarily composed of methane, an odorless and colorless gas. In order to heighten an individuals ability to detect natural gas, small quantities of odorant are added. T-butyl mercaptan (typically described as having a skunk-like odor), is one such odorant.

Sources
Various U.S. Chemical Safety Board, available public Investigation and Safety Bulletin information

The information provided in these materials is intended to be general and advisory in nature. It shall not be considered legal advice. The Hartford does not warrant that the implementation of any view or recommendation contained herein will: (i) result in the elimination of any unsafe conditions at your business locations or with respect to your business operations; or (ii) will be an appropriate legal or business practice. The Hartford assumes no responsibility for the control or correction of hazards or legal compliance with respect to your business practices, and the views and recommendations contained herein shall not constitute our undertaking, on your behalf or for the benefit of others, to determine or warrant that your business premises, locations or operations are safe or healthful, or are in compliance with any law, rule or regulation. Readers seeking to resolve specific safety, legal or business issues or concerns related to the information provided in these materials should consult their safety consultant, attorney or business advisors. All information contained herein is as of September 2011.
September 2011 The Hartford Financial Services Group, Inc., Hartford, CT 06155 All Rights Reserved

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PURGING JOB HAZARD ANALYSIS

TASK NAME: LOCATION: DATE:

EQUIPMENT BEING PURGED:

TASK STEP

HAZARD

CONTROL

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PURGING CHECKLIST
The below sample checklist is not all-inclusive and should be used as a means to help monitor your worksite. YES Has a Purging Job Hazard Analysis been completed? Have all fuel line sources been identified? Have all fuel lines not required for the purging operation been secured and locked out? Are line blanks or blinds required to safely isolate fuel lines, fitting, gauges? Is the purging discharge line located outside away from personnel, equipment & buildings? If No, a written Gas Purging Plan should be developed. Could high pressure discharge direct gases or foreign objects towards personnel, equipment & buildings? Is inert gas being used as the purging medium? If Yes a.) Will oxygen levels be monitored to maintain adequate concentration between 19.5% and 23.5%? Will purging operation involve a flammable gas? Will the flammable gas purged settle into low areas where there are uncontrolled ignition sources? Has the written Gas Purging Plan been communicated to and approved by the local Authority Having Jurisdiction? Have all non-essential personnel been evacuated to a safe location from the purging operations? Are reliable combustible gas meters being used to sample for gas concentrations? Have employees using the combustible gas meters been trained on their use? Have the combustible gas meters been properly calibrated and tested per the manufacturer specifications? Have all employees been specifically trained in safe procedures for the gas purging operations? Is a temporary hose or line required to direct the purged gas to safe locations outside of the building? Has emergency response personnel (Fire Department, EMS, etc.) been notified of the gas purging activities planned? Are additional ventilation sources required to maintain gas concentrations within acceptable levels? Have all potential ignition sources been isolated, de-energized and locked-out?
COMPLETED BY: DATE:

NO

NOTES