COMMONWEALTH OF KENTUCKY

BEFORE THE ENERGY REGULATORY COMMISSION

In the Natter ofTHE NATURAL GAS LEAK INCIDENT ON LOUISVILLEGAS & ELECTRIC COMPANY'S GAS DISTRIBUTIONSYSTEM AT VINE GROVE ELEMENTARY SCHOOL,HARDIN COUNTY, KENTUCKY

ORDER

On August 23, 1979, a natural gas leak was discovered atthe Vine Grove Elementary School in Vine Grove, Hardin County,

Kentucky.

On August 28„ 1979, the Commission received telephonicnotice of this incident from Louisville Gas & Electric Company.

On October 25, 1979, a Commission staff inspectox'ompletedhis investigation of this incident and submitted his Repoxt

(Appendix "A").On Novembex 13, 1979, the Report was forwarded to Louisville

Gas 6 Electric Company with a request that a response be submitted

within twenty (20) days.

On December 7, 1979 the Commission received the Decembex 6,1979 xesponse of Louisville Gas and Electric Company (Appendix "B").

The Commission, having considered the mattex and being ad-

vised, on its own motion ORDERS that this matter be and it hereby

is set for hearing on April 10, 1980 at 10:00 A,M. EasternStandard Time in the Commission's Offices at Frankfort, Kentucky.

It is further ORDERED that Louisville Gas and ElectricCompany shall appear at the scheduled hearing and present testimonyx'elative to this matter.

Done at Frankfort, Kentucky, this 19th day of Narch, 1980.

ONER TORY COMMISSION

For e ~mMs4f~

Secretary

REPORT

TO:

THRU:

John T. Snither, DirectorDivision of Engineering

E. Scott SmithChief Engineer, Gas Section

FROM: R. E. BruflatChief Utility Inspector

SUBJECT: Investigation of Gas Leak Incident on Louisvi11e Gas 5 E1ectricCompany (L.G. 4 E.) System at Vine Groove, Hardin County,Kentucky Elementar y School (School)

DATE- October 25, 1979

Mith the recent filing of L. G. 5 E.'s federal D 0 T Leak Form

Report (DOT F 7100.1) and the receipt of additional information, this

finalized Report can be written with the necessary overview.

Subject incident was mishandled at one level in L. G. 5 E.'s

Hatural Gas Oivision (Natural Gas). Certain aspects reflect the need for

more effective implementation of L. G. 8 E.'s system "Emergency Plan"

and the lack of periodic gas odorization checks. These communication and

training problems have surfaced in prior investigations of incidents on

L. 6. 5 E. gas systems, but this Report will outline only those relative to

subject incident.

The initial indication of the natural gas leak at the School

occurred on Thursday, August 23, 1979, when an employee flicked an electric

switch on a wall box in the School's kitchen. There was an explosive blast

involving a limited area. The School Principal, Warden Thomas, notified

his maintenance people at Elizabethtown (They serve the Hardin County School

District fr'Om one centrally located facility). Nr. Patterson, Hardin County

School Service Supervisor, promptly investigated and attributed the explosion

jFto electrical problems. On the following morning, Friday, August 24, 1979,

Mr. Thomas, School Principal and L. 6. 5 E. the gas company, were notified

that there was a gas problem at the School.

The attached sheets -1- and -2- are copies of L. G. 8 E. records

of their notification and response to this incident on 8-24-79 and 8-27-79.

Mr. Thomas signed and received a copy of the L. G. 8 E. notice/authorization

from L. G. 8 E. Employee Cain at ll:45 on 8-24-79 (See bottom of attached

Sheet -1-}.There reportedly was some misunderstanding, and/or incomplete

directions regarding the evacuation of the School. In the article on

attached Sheet -3- State Fire Narshall, Nr. Tom Nick1e, clarifies what

should have been done; both at the direction of the School officials and

the insistence of L. G. 8 E. service people. Nr. Nickle's office received

its notice of the incident from the Vine Grove Police Department on Saturday

morning, August 25, 1979.

This Commission received its telephonic notice at 9:30 A.M.,

Tuesday, August 28, 1979. The U.S., DOT, OPTO in YJashington, 0. C.

(DOT Data Center) received their telephonic notice at ll:15 A. N. , Tuesday,

August 28, 1979.

Ny investigation included interviews with School officials:Principal Marden Thomas, his secretary Nrs. Kizer and Hardin County Superin-

tendent Charles Akins. tQ repeated interroga',ion revealed that they were

pleased with L. G. 8 E.'s response and handling of the incident; but at no

time prior to, or during, the incident did they detect--or have reported to

them the odor of leaking natural gas. All tests for and concentrations of

natural gas were made with various combustible gas indicating (CGI) instruments.

LE

rIn my investigative contacts with L. G. 5 E. official representa;ives

(Mr. Don Oeering, Assistant Superintendent of tiatural Gas; Mr. Bill tieblett,

Chief Gas Engineer and Mr. Fred Lutz, Accident Investigator) a historiC

pattern of service call odorization checks was established and indicated

on maps to show the relative location to the School. There were no records

of the periodic checks for proper odorant level. Recent immediate area checks

and the area service call records, as mapped, indicate that the gas in the

main serving the School was adequately odorired.

Attached as Sheets -4- and -5- are pages 15 and 59, respectively,

oF L. G. 8 E.'s "Gas Emergency Procedure" ("E" Plan) manual on file with this

Commission. The management information requirement in item 9 on page 15

could be interpreted as dependent upon the on site service supervisor's

definition of an emergency. The recently revised regulation CFR-192.615

under the Natural Gas Pipeline Safety Act deals in detail with operator

requirements that should have made the School situation readily recognizable

as an emergency. Sheet -5- (page 59) from L.G. 5 E.'s "E" Plan lists some

outdated information. The undersigned has previously been informed that the1

L. G. 5 E. "E" Plan is being updated, and this exemplary page is being used

only to cite the importance for some diligent, continuing update activity.A review of the above, my notes, the regulations and other. infor-

mation on file has led 'to the following determinations:

1. That L. G. 5 E. has violated Section CFR191.5 "Telephonic

notice of certain leaks."

2. That L. G. 5 E. has violated Section CFR192.615 Emergency .Plans "(b) Each operator shall — (2) train the appropriate operating

personnel to assure that they are knowledgeable of the emergency procedures

EL

and verify that the training is effective." /and (d) -- outlining the

required education program pursuant to this section.

3. That L. G. 8 E./ Natural Gas has violated 807KAR50:O35 Gas

Section 6. Odorization (4) Each utility shall make periodic checks to

dete'rmine that proper level of odorization is maintained and keep records

of same.

4. That L. G. 8 E. has been lax, or lacks adequate staff, to

properly and periodically update their Emergency Plan and to implement

related requirements.

From the above determinations, it is recommended that L. G. 8 E.

be sent a copy of this Report along with a request for detailed responses

to items 2 and 4 of the above findings;

It is further recomnended that L. G. 8 E. be cited for the

following violations:

1. Failure to make prompt and proper telephonic notice of this

School incident (CFR191.5).

2. Failure to make periodic checks to determine and to keep ':

I

records of proper odorization level {807KAR50:035 Gas Section 6).

It is further recommended that L. G. 8 E. be ordered to show

cause, if any they can, as to why this Commission should not fine L. G. 8 E.

according to law for these ci ted violations.

RES/eag

J E

niSTohirR SERViCF. LIKE RFPORT FOR CAS INSI'f'CTION SECTION,:, '„;:A<dew r ~8~ ~~<C ~~~.,'<ri'<I"

ir' crt&~ -:-'- '', :,Property Owner's Name M~~ ~~ P HA. '-. Phone

r ere<i< 0 sees'e Addi<vs J/0 cf re<jeff'&9% d<u««H ' ' ~ 'i: ...PEJ"-'.::e: ' i':.-'::::i i -: i - - >:-::-;:-."-«

Notice oCCas IAsk Ceard Number J «e d +4- Card Returned by You'.'Yrs) '' (No)4/ .'~s~,'.

If No, Person Card Left With

.; Location WItere Card Was Leftr I,, ' I,':. Company Meter IIII<tnber from One Gag Meter, IC Availabte +94-2P cP -,W~ A Z D

'ufnberof Gas Meters Involved* , 'r< 1

,4< House Line Test.'--'Metern.(dny —,c~Ai~(r),'oft-'( 4 ~ ~ 'adies: C '4 " " p.K.;;f.4+~ . ~dl«5:t

gdr<tA ->An~w- N '"H "~.M.'":4'&.-c'i@5~7«'-deil'Zan.'see v

No 5-1564'tO< I.DVISVIl LK GAS Ar<D Kt KCYRIC CDMRANV

fp<tate print t

i(r s~ Qg rffA

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(frttsrfs or<rill

'I' .J r receiving tfas service ~I

I r i tnos Ida fh, acknow edge ece nt o I ce of a gas leal and recogniesponpb<tety for latrine coeeecllve act<or<. I <tout\I Ihet oi<t ol the fotlowlng be done, as Indica<tdi

I KAVK SKRVICK PSF. Vnu Wln be nOI<fied When Sapaiit ar ~ COmpl ~ ltd, SO thai ynu Can <n<peel Ihe faCilily and reine<at ~~ 'dr vice.t<LKASE RE57ORK SKRVICK 7<f ROUG<d A 7 e<tf<ORARV SUR'57<7 U7E ~A RV<cf I <ce<F. I rtctuv.t that you provide eltmooiary <uoslitu<c service ii "et ror nol mort Ihan I es caitnda ~ dayt: during ~bien period I wi<f ha«e tht necessary~ toracemtnt os stoa< ~ s madt. EJ+n comoiclion of such reniaccmenl os repairs, I will ca« you lo shsotcl the piping and makelhe reouiitd conf<tel<one. I agste lo pay 4."0 lor tf<e inst ~«aliort and removal of Ihis ttmfeordiy sti vice lent. and assume full~ tsponsib« ity for any accldtnll dr< ~ ing I<<tie<rom< and w«i ho<d Ihe Company ti ~ i<nit« for ~ <i occurrences ar I ~ing oul ot lheinstallation or mainttntnce ol \arcs ltmooiasy stivict lint not caustd by the cnmnaiiy < sole neerivtnct. I ~«o acunowitogethat If <hest conditions ~ ie not mtt, gas <tr vice mey be discontinued without further notice.

I have erreployed a dual<lied person lo perform lhe wo<L whose ntmt encl ~ d<tss Is

Irmo<oyee

<came end Kmp. fdo.

Date

-//'.Customer Signature

I+ ~ 7<yrs

Ca'. ~ f:! N SYSffM

ADDRESSCITY .7 l~~ fflAM ECOORDINATE LOCATION

LEAK DCCURRFD ON1 HAIN2) COMI'ANY MKTKIIING OR REGULATINO fACILITY

SCRVICK COMPANYSKRVICK CUS'TQMKR

6) CUSTOMER MEIKRIHQ OR RKGULATIQN

SURVf Y NUMBf R

DATE OF DETECTIONTIME //' 6)

tr r»CAUSE OF I.KAK!~(7) oreosiee

{9) DAMAGE BY OUTS)OF. FORCES (IDENTIFY)(9) CO)tSTRUCT ION Df fECT

MA1 KRIAL fA)I.URE(11) OTHER

ETHOO OF REPARII PART THAT LEARED (61) CLASS OF LEAK I (2) I (3)P~Pr IPE( CAST )RON JOINT

DRIPflTTINQMETKI4S1OPSWIVELREGULATORRELIEFTAP CONNECTIONVALVEOTHER

I~ RKEPLACE Fl TTIHCI 211()5 RKLINK PIPEIS WELD SLEEVE11 LUBIIICA1K VALVE1~ QTNKR

INSTALL TEMP. SKIL

QA'TE OF RKPAIR + ~ ~ tie I28)TIMK OF START ~+r -R O ~ jief~ A.M. I29I

(32) PRESSURF- (1) L (2) E, (3~ (4) H

{33) (34) YEAR INSTALLED 19( ) ( )SIZE ~ MATERIAL (W) (CQ

(BARK) (MILL WRAPPED), 1

CATHODIC PROTECTION) (VKS) {NO)

ANODE INSTALLEDT (YKS) fNQ)

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FIREPUBLICOTHER (Spec))y)

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TIME COMP!.KTEQ ~ ~ ~ I FURTHER ATTENTION RK{)UIRED) (YKS)DEPARTMENT (GAS DIST.) (HALT. C$S)~ D~ l/X {40) CANCEL IlEPORT - MO LEAK FOUND

METER NO.REPORTED BY:

'REGULATOR NO,~

(41) OPFRATOR PKRSONNFLADDI JIONAL INFORMATION . I»ar{)r~i4 OrL!9 Ag') 3~» {42) AGENCY CAUSING DAMAGE

-~FrJ-r+rrrh . /re.~~t3 {igggr4) POLICE

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'TUESDAY. AUGUST 28, i&79

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-.-VINE GROVF Ky. —Vine GroveElementary School eras closed yester-cfsy because of a natural~ leak, but%fardin County School Superintendent

. Charles Aklns said there is a possibility,gasses could resume by tomorrocv.

hklns said that lf repairs cannot be-. dhmpleted by tomofroslc &n &lternt55tive

gHan Creuld be considered to enable 750chl)dren to return to classes.

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: -My first knowledge of the leak waSFriday morning." Aklns said. "but Ititidn't appear to be serious."

5 ~ >" c.™L"We turned eff the gas Friday." Coi-gn Anderson of Louisville Gas t Elec-:tric Co. said. "The leak. Is the .Qslomei's responsibility, and it's up to,their plumber or reps'lrman to fix lt," '.

h'e added.

«.''They «sill not be having school thereentil the problem ls corrected," Vine

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i>pen rccciving noti firation of an emergency Ehc p".r.-<n Sn <bar9 .

wi 11

:Obtain as much information as possible about the emergency.

7 Analyze the information and inform the Gas Dispatcher or others

as to what extent to alert other key personnel as $ ndicated on

page

3 Assume complete charge of the emergency, if it af fccts only the

Natural Gas Department

4 Check that necessary sections of the Emergency Organization Chart

are properly staffed. (See page > far personnel who normally fillthe Coordinator positions)

5. check &at a sufficient number of personnel are being notified

and hw'e the Office Coordinator to make a booster of all personnel

rrpnrting.. Th roster should indirate th".ir location and radio

call number

6. Determine the extent of the emergency and if it vill affect the

supply of gas to the system.

7. Consult with th Gas Dispatcher Coordinator as to <>e immediate

gas requirenents and decide if any curtailment will be necessary

Consult with the Gas Distribution Supcrintcndcnt as to what loads

to curtail, if there is to be a curtailment.

''Keep management personnel informed through~ut. the cm~rgency

10. ', Viaintain contact with all key personnel in both gas departments~

'1'1- ':Do.tcrmine if it will be necessary to have supervisors schedule

".'heir personnel on a shift basis

12'l~l:e final deci.",$ons on a11 functions nf each section,

iii»» '«rc„.»s il. 0 i~ rr wi inc» r

a. o. vox saoio Louisv>i.Lr. xv. <ossa @Hoes sos sss-osis

VICC PPK5<OKHT-OPtAAtiONS RECElVFDDecember 6, 1979 DEC 71~»

Mr. John T ~ Smither, DirectorDivision of'ngineering k Sex'vicesZRC/URCP, 0, Box 615Frankfort, KY 40602

ENERGY REGULATORY COMhl.

DIVISION OF ENGINEERING

Dear Hr. Smither,

In response to your cover letter, dated November 1$, 1$7g, to aninvestigation of a gas leak at, the Vine Grove Elementary Schoolthat occurred August 2), 1979~ the following comments are sub-mitted. Although detailed responses to Items 2. and 4. inMr. Bruflat's report were requested, additional comments willbe made.

Commenting on Item 1. of the report, a copy of a memo, datedOctober 15, lgp9, and signed by the Chief Engineer of the ERC,regarding telephonic notices, was forwarded t.o all Natural GasDepartment Cas Distribution service sections (copy enclosed).Specific instructions were given to see that the memo was con-spicuously posted and made a topic for discussion in subsequentweekly "Tail Gate" Safety Meetings as appropriate

In response to Item 2. of the report, shortly after the revised192.615 to part 192 was implemented, a program wa,s initiatedto train all departmental Gas Distribution personnel in emer-gency plan procedures. This was accomplished through trainingsessions, including formal classroom meetings and assignmentsof responsibilit at the supervisor level. Updating and re-instituting these training sessions has been and will continueto be conduct,ed since the Vine Grove incident. The trainingcan be regarded as being effective.

In reference to Item @. of the xeport, the IGEcE Company gasemergency procedures is now in process of being up-dated and isexpected to be ready for printing by the first week of January1980. Distribution to company personnel and the Energy RegulatoryCommission staff will ba about Pabruary l5, 1990'rovisions toperiodically up-date the procedures have also been made,

1.111il~1il11. nI;1~ ~ ~ 111} i:I< I fri( f 111uIn111

Nr. John T. SmitherDecember 6, lgp9,Page 2

On the last page of Mr, Bruflat's report ~ reference is wade Cothe lack of odorization checks and records keeping. Changes inthis procedure have been made. Quantitative checks will be madeat each odorant injection point every two weeks to confirm properamounts of odorant being injected ~ and odorant levels will bemonitored at two diffex'ent points each week in each town

ox'ocalizedGas Distxibution system.

In conclusion, it would seem that a recommendation for a finein the case oi'his incident would not be in the spirit of therules, ox consistent with recent Commission actions, Originally,the incident its not recognized by the authox"ities as s ga.semex'gency, and it was not repoxted to MkE until some twenty (20)houxs after the occurance< There was no serious injury or lossof property. I hope you concur in this conclusion.

Vice President-Operations

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