Natural Gas Incident Investigation

1. Natural GasIncident Investigation Anthony Tetto Senior Utility Consultant Loss Control Division AEGIS Insurance Services, Inc. 201/888-7938

2. Name the Pro Football Team

3. Incident Investigation Flow Chart Pre-Investigative Planning Incident Response Fact-Finding Analysis & Documentation Conclusion & Recommendations

4. What Is An Incident? Title 49 CFR 191.3 An unexpected release of gas from a pipeline or of liquefied natural gas, liquefied petroleum gas, refrigerant gas, or gas from an LNG facility, which results in one of more of the following consequences: • A death, or personal injury necessitating in-patient hospitalization, or • Estimated property damage of $50,000 or more, including loss to the operator and others, or both, but excluding cost of gas lost. • Unintentional estimated gas loss of three million cubic feet or more

5. Pre-Investigation Planning

6. Personnel readiness Personnel training Communication (within the company and with outside organizations) Emergency Response Plan Coordination with fire service (on-site) Availability of and access tospecial equipment System records Involvement of Claims and Legal depts. Public Relations - media response Pre-Planning is Essential

7. When to Conduct an Incident Investigation • Company policy • General practice • Reporting requirements to state/federal agencies • Some states require notification when damages exceed $5,000 • Who within the company has this responsibility?

8. When to Conduct an Incident Investigation? Obvious situations - Explosions - Fires of suspicious origin - Fire personnel evaluation or suspicions Not so obvious situations - Carbon monoxide fatalities or hospitalizations - Gasoline fires – garage storage areas – children involved - Any fatality, serious injury or property loss fire

9. Investigation Objectives To determine: • Type of explosion • Type of fuel/explosive involved • Nature of explosion • High order vs. low order • Source of ignition • Cause of explosion • Reason for the presence of the fuel • Responsibility

10. Attitude • Be positive in your investigative efforts • Keep and open mind - Facts are not always as they initially appear - Don’t make judgments until you know all available facts • Initially, you are the gatherer of facts • You may be asked to offer an opinion – DON’T • Report what you observe and have been told only within your company • The incident investigator is the technical arm of the attorney

11. Credibility • Conduct appropriate, thorough and defensible investigation • Treat every investigation as if you will end up on the witness stand testifying to your findings.

12. Documentation and Evidence Preservation • Thorough documentation of an incident scene is essential. • Preservation of evidence is essential and expected. - Investigation may be prejudiced if evidence is not documented and preserved - Chain of Custody • Analysis and ultimate positions must be supported in fact and in science. - If not, your opinion is just speculation 4. Be sure field people know how to handle evidence.

13. Reports of incoming calls Service orders and reports “One call” records Repair orders and reports Employee training records Engineering records Leakage survey records and reports Pressure testing records of line in question Maps and valve location records Employee/contractor qualifications Odorant tests and injection records Instrument calibration records (PROVIDE COPIES ONLY) Typical Evidential Documents

14. Trained personnel to use the equipment Safety gear, ID card Combustible gas indicator Probe bar Surface sampling equipment Odorator/odorant testing device Pressure testing equipment Photographic documentation type to be determined in advance i.e., digital camera Memory card Calibration test kits Detailed investigative forms Rhino kit Conducting an InvestigationBasic Equipment Needed

15. Conducting an InvestigationAdditional Equipment that may be needed • Latex gloves • Measuring device • Tape recorder • Maps of area • Marking flags/paint • Pipe/valve locators • Valve key • Flashlight • Spare batteries (camera and flashlight) • Sample bags • Evidence containers • Soil test kits • Chain of custody forms • GPS device • Drawing tools(graph paper, pencils, ruler) • Caution Tape • Tools (wrenches)

16. Establishing An Investigative Team • Establish Team leader • Must be open-minded and able to handle pressure • Select Team Members • From various departments i.e., engineering, service, construction, public relations (spokesperson) • Establish each member’s responsibility • Coordinate • With Legal and Claims departments • Review standards/procedures and reports • Drug & alcohol testing procedures for those who might be required to be tested • Meet and traincivil authorities • Determine • Procedures • Equipment needed • Availability, trained operators • Identify • Labs and outside expertise • High risks such as problem contractors, and meet with them Very Important That Everyone On The Team Knows What To Do.

17. Types of Natural Gas Explosions • High Order Explosion - a rapid pressure rise or high-force explosion characterized by shattering effect of the confining structure or container and long missile distance i.e. ripping & shredding. (Detonation) • Low Order Explosion - a slow rate of pressure rise or low force explosion characterized by pushing or dislodging effect on the confining structure and short missile distance i.e. pushing & shoving. (More typical of natural gas incidents)

18. Dry Explosion – No Fire Dry Explosion – No Fire Note the “pushing and shoving” effect • 2 x 4s intact, not ripped/shredded as would occur in “high order” explosion or from solid explosives such as dynamite • Could this be caused by the ignition of built-up natural gas?

19. Dry Explosion – No Fire Dry Explosion – No Fire Foundation damaged, but upper portion of house intact • Overall structural damage directly related to building’s design • Pressure wave takes path of least resistance

20. Dry Explosion – No Fire Dry Explosion – No Fire Notice the car on the right • The building was completely lifted and landed on the car, yet walls are intact • Exemplifies the “pushing and shoving” effect typical to natural gas explosions

21. Fire After Explosion Not much left; detailed investigation still warranted • Review floor plans; recover piping • Car in garage may indicate gasoline was possible accelerant

22. Incident Scene Procedures

23. High order vs. low order Type of fuel/explosive involved Cause of explosion Responsibility Type of explosion Nature of explosion Source of ignition Reason for the presence of the fuel Ultimate Objective of the Investigation To determine:

24. Review of actions taken by all parties Initiate additional measures Establish liaison with emergency response personnel Determine gas spread Initiate or continue makesafe operations Supervisor or Company Representative Responsibilities at Incident Scene *Remember Public & Personal Safety come first!

25. Utility Company and Fire Department Interaction • The main focus of the fire department should be securing the area • The gas company’s main focus should be securing the gas • The common focus of both parties’ actions should be Public Safety!

26. Utility Company and Fire Department Interaction • It is very important to develop a relationship with local fire departments prior to an emergency • AEGIS video programs Natural Gas: Recognizing and Avoiding the Hazards” Volumes I & II are designed to assist in understanding this relationship • Understand that once the fire department is on the scene, they are in charge

27. Initial Assessment of the Scene • Scan the scene and immediate area • Seek out the incident commander and the company’s First Responder • Are gas company employees wearing the appropriate safety equipment? • Inquire as to what has been done thus far? • Do additional structures need to be checked or evacuated or has this already been done? • Have available openings been checked (i.e. sewers)? • Has bar testing been performed and documented?

28. Initial Assessment of the Scene • Has it been determined that additional personnel and/or equipment are needed? If so, has the request been made? • Has someone been contacted to perform an odorant test in the vicinity? • Will a vapor sample, soil samples, pressure test be needed and is the proper equipment and expertise to perform these task on site or enroute? • Are pictures being taken of the incident scene/investigation by gas company personnel? Also, what pictures have been taken and need to be taken? • Are gas company employees wearing the appropriate safety equipment? • Who will be documenting the activities of the investigation? • Is Form 11 (Pipeline Failure Investigation Report) being used as a guide in the investigation?

29. Initial Assessment of the Scene • Have witnesses been identified for possible future interviews? • Are company emergency plans and procedures being followed? • Pipeline Failure Investigation Report being used as a guide in the investigation? • Who will be documenting the activities of the investigation? • Have the appropriate people/agencies been notified? (this should be handled by other designated company personnel) • Does it appear that the use of outside experts will be necessary and who will notify them to be prepared?

30. Incident InvestigationConsiderations • The investigative team leader should coordinate the incident investigation fact finding efforts through fire officials, company management and the company’s legal department • Photograph and document all relevant aspects of the investigation • If necessary to use outside experts as site investigators; they must be contacted immediately • Documentation of the investigation; must be concise and accurate • NFPA 921 (reference, to be used as a guide)

31. Check the Equipment • Odormeter, CGI, CO detector • Selection of unit – check service history - Used unit – track record - Record serial number for unit - Check calibration of unit • Combustible Gas Indicator (CGI) - Odorometer - Hose new – type prescribed by the manufacturer of unit

32. Odorization Testing Only after MAKESAFE is completed, but as soon as possible • Take a gas sample at the closest location to the incident location • Consider several locations (in the immediate area) • Consider using different testers i.e. company personnel, civil authorities official investigator on scene and ensure all samples are witnessed • Establish “readily detectable” levels • Difference between a compliance test and a “making sure you are odorized test.”

33. Scene Work – Checking for leaks • Bar-hole company service lines and mains and document both positive and negative readings - Locate mains and services – flag (don’t damage) - Diagram and flag the bar-hole locations - HFI, OMD, RMLD (surface sampling instruments – confirm w/CGI) - Focus on the immediate area (depending on the scene) • Pressure test at the operating pressure and follow your company’s procedures. Don’t get rushed into a test that may be flawed. The test is valid whether performed at 1:00 am or noon the next day. • Customer piping – perform a shut in test, if possible. Be aware that internal piping may have been exposed to heat

34. Photographic Documentation of the Incident Scene • Photographer Must be trained in investigative photography. The photographer should be called ASAP. • Camcorders May be used to document the proceedings, but be careful about audio recordings. • Digital Cameras May be used to document the proceedings; Discuss this with your attorney!

35. Photographic Documentation - Be Aware of Images Captured Notice the old meter and range connector in the bottom left of the photograph

36. Handling Physical Evidence • Photograph the evidence in place - The fire scene is evidence - Note the location on diagrams • Who owns the evidence? - If some one else: - Document the preservation request - In extreme cases your company may need to take legal action • If your company: - Chain of custody documentation and secure storage location

37. Handling Physical Evidence • Meters & Regulators • These are your property; if possible maintain custody. If not possible, insure a chain of custody and protect your right of access and to witness testing. • Pressure Testing • Conduct integrity testing, not strength testing. This testing should only be performed by trained individuals with the proper equipment. It must be a non-destructive test. This test should be witnessed and documented. • Customer Piping • If possible, recover and reconstruct the interior piping system. Watch for missing piping and clean threads. Test with monometer at operating pressure (ounces) or shut- in test if piping is intact. Exercise caution when testing piping exposed to fire/heat

38. Dealing with the Media at the Scene • The Gas company should have one person whose responsibility is to deal with the media at the scene; this person should be easily accessible • Miranda warning – “anything you say can and will be used against you” • Public’s initial perception will carry forward and is hard to change • Develop Message Points- Stick to Home Base • A “no comment” statement vs. “the matter is still being investigated”

39. Debriefing of Responding Company Personnel • Debrief initial responders as soon as possible • Conduct debriefing in a relaxed atmosphere • Express the importance of honest and accurate information • Question responders about what they personally saw and did at the scene. They should not speculate on the cause or actions of others at the scene • Document their responses

40. Initial Analysis of the Incident • Review and document actions taken • Review records – leak survey – odor complaint – service calls – cathodic protection – atmospheric corrosion – past leak history/classified leaks • Establish level of the investigation including the use of outside experts • Identify company policies/practices that may be pertinent and whether they were followed • Review time line based on debriefing and dispatch records

41. Giving Depositions • Work with your attorney • Follow his/her instructions • Be honest…honesty is always the best policy! • It is okay to say, “I don’t know.”

42. AEGIS Gas Litigation Service • Designed to assist with major natural gas-related claims • Special counsel to assist local or in-house counsel • Free initial AGLS consultation • http://www.aegislink.com/portal/products

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