October 6, 1997
Federal Energy Regulatory Commission
Chairman James J. Hoecker
888 First Street NE
Washington, DC 20426
FERC OPEN LETTER
RE: CONTAMINATED NATURAL GAS REQUIRES CONSUMER PROTECTION
The Honorable Chairman Hoecker,
The following OPEN LETTER was published in an open forum on Gascape Publications Internet World Wide Web site http://www.gascape.org
FERC is the only regulatory agency with the power to correct contaminated natural gas and bring safeguards that will protect the health and safety of innocent consumers and the environment.
For example, a small group of concerned citizens in Maine, represented by Doctor J. Harrod, voiced their concerns about a new gas pipeline from Sable Island to the mainland, this past June before a FERC hearing. As Doctor Harrod expressed concerns relating to PCBs contaminating natural gas, the FERC chairperson countered, that PCBs were no longer in use and there were no PCBs in natural gas. Such misinformation before a public gathering cannot be tolerated, especially when it comes from such an august regulatory body.
Therefore, on behalf of the innocent and unsuspecting victims of contaminated natural gas, we humbly request that you:
1. Investigate the extent of contaminated natural gas and it's impact on: (1) the public's health, (2) safety, (3) consumer product safety, (4) our indoor air, (5) outdoor environments, (6) drinking watershed, (7) food chain, and share your findings with the public.
2. Enforce the existing safeguards to eliminate all forms of natural gas contamination before said gas is used by the consumer.
3. Support guidelines that will reimburse consumers who install pollution protection equipment when using contaminated natural gas. Examples being: (1) pollution abatement equipment incentives, (2) tax rebates, and, (3) insurance rate incentives.
4. Encourage consumers to install pollution abatement equipment such as: gas filtration, gas leak detection, gas pilot-lite auto-igniters, et al.
5. Develop guidelines that reduce greenhouse gas emissions, smog production and ozone depletion caused by the combustion of contaminated natural gas.
6. Encourage OSHA to implement indoor clean air standards, not only for the workplace environment but also for private citizen's indoor living environments where contaminated natural gas is used.
7. Offer employers amnesty from prosecution while they take the necessary corrective measures to install natural gas pollution abatement equipment required to meet OSHA's workplace regulations and other Clean Air Act requirements when using contaminated natural gas in their operations.
8. Follow OSHA's endorsement of California's PROPOSITION 65 as the national standard for protecting workers against employer endangerment from hazardous chemical found in natural gas.
9. Develop consumer standards for clean, safe natural gas. A national level assessment of natural gas quality is needed. At present, there are no such standards to protect the public's health and safety.
10. Support the manufacture of contaminated natural gas pollution prevention equipment for consumer use.
11. Encourage the USDA to list filter-cleaned natural gas as an approved energy source for any food storage, processing and production.
12. Encourage the FDA to list filter-cleaned natural gas as a GRAS ingredient.
13. Approve and support consumers who choose to replace sulfur based gas odorants with other methods of gas leak detection. SEE: APPENDIX A
14. Provide pollution credits to consumers who demonstrate they are reducing their production of smog, greenhouse gas and ozone depletion on an individual basis.
15. Help communities to implement smog, greenhouse gas and ozone reduction programs caused by contaminated natural gas use.
16. Develop a public education program regarding the dangers associated with using contaminated natural gas in commerce, homes and workplace.
17. Bring gas utilities into compliance and have them warn their customers on a monthly basis as exampled by California's PROP 65 GAS WARNING that natural gas is contaminated and is known to cause cancer, birth defects, reproductive harm, and hormone dysfunction. Such warnings must be written in simple terms that can easily be understood.
18. Commission third-party studies to determine what before and after effects occur when natural gas is filter cleaned before being burned.
19. Eliminate the National Fire Protection Association's Code 54. SEE: ATTACHMENT B
20. DOE and EPA must publish their archives relating to contaminated natural gas as regards to PCB levels, gas odorant levels, etc. SEE: ATTACHMENT C
Gascape Publications receives inquiries voicing consumers concerns about using contaminated gas and it's impact on their health and safety. The people of this great nation need your help to correct the despicable industry practice of dumping hazardous chemicals inside consumer premises, without warning, their knowledge or permission.
All things considered, natural gas is still the best energy source we have, it just needs to be cleaned before use.
If I may be of any further service to you, please contact me. On behalf of all consumers, we look forward to your help and response.
Richard F. Sowinski, consumer advocate
cc: Commissioners Vicky A. Bailey and William L. Massey
: certified mail
SULFUR BASED GAS ODORANTS
Sulfur based chemical odorants are added to natural gas to detect leakage within the gas distribution system. Of the many problems associated with these sulfurus chemicals, metal corrosion and health effects are the most serious.
When said odorants partially burn in the gas flame they come into direct and intimate contact with ambient moisture. At this point, sulfuric and hydrochloric acid is produced. These acids attack metal surfaces such as gas appliances and their attendant exhaust ducts. Metal pitting and holes are known to develop which allows carbon monoxide gas to enter the indoor air. It is not unheard of, where people have been found dead from carbon monoxide poisoning due to natural gas combustion. How many cases were caused by leaking exhaust ducts?
Sulfuric and hydrochloric acid cause inflammation, swelling, and tissue damage to mucous membranes lining the human the nose, sinus, breathing passageways and lungs. Great Brition's Medical Journal Lancet reported a study directly linking coughing and wheezing being caused by exposure to natural gas appliances used indoors. The AGA criticized the Lancet report but never explained that these acids are produced when sulfur based odorants are burned.
April of 1994, the AGA and EPA met and agreed that the best gas leak detection method was to continue using the customer's nose. With the human nose being a fickle and capricious instrument plagued by colds, allergies, chemical sensitivity, medication, second hand smoke, cat dandruff, dust mite feces and who knows what else. It's estimated that 50% of the public can't detect the utilitie's warning odorant.
With men on the moon and remote controlled vehicles on Mars there's enough innovation in the marketplace to provide consumers with a gas leak detection method that works without relying upon one's nose.
A majority of the states require gas odorant to be added for the public's safety. Unfortunately, that's not the case, as we come to better understand that odorants produce acids that compromise our nose.
For example, the Ontario, Canada Ministry of Environment and Energy in Toronto published it's natural gas odorant regulation December 1996.
Z662-96 Oil and Gas Pipeline Systems
10.12.2 In the concentrations in which they are used, odorants shall comply with the following:
(a) Odorants shall not be deleterious to persons or pipeline systems.
(b) The products of combustion from odorants shall not be toxic, corrosive or harmful to those materials to which the products of combustion will be exposed.
Foremost is their regard for human safety, followed by the pipe system. Ontario's concern for it's citizens must be applauded. Countries where gas odorants are used would do well to follow Ontario's lead and expand upon it. The area for expansion is the implimentation of modern electronics that work 24 hours a day whether a human nose is present or not.
THE NATIONAL FIRE PROTECTION ASSOCIATION CODE 54
The National Fuel Code, ANSI Z223.1-1992, NFPA 54-1992 1992 Edition of ANSI Z223.1-NFPA 54
Part 5 Equipment Installation
5.5.7 Sediment Trap
If a segment trap is not incorporated as part of the gas utilization equipment, a sediment trap shall be installed as close to the inlet of the equipment as practical at the time of equipment installation. The sediment trap shall be either a tee fitting with a capped nipple in the bottom as illustrated in Figure 5 or other device recognized as an effective sediment trap. Illuminating appliances, ranges, clothes driers and outdoor grills need not be so equipped.
It is not our intent to dissect the The National Fuel Code 54. What we will attempt to do is explain our findings, that Code 54 is dangerous and misleading.
For over 150 years the gas utility industry has been delivering natural gas that was virtually dry and absent of liquids. On occasion, during a century and a half there have been cases where oil or water have been pumped into the customers appliances, but it's rare to nonexistent.
With the industry becoming aware that PCBs contaminate their gas pipe system, they decided to plush those pipes with mineral oil. Heavy injection of mineral oil fogging into the pressurized gas pipes produces excess liquids. Thus the reason behind instituting NFPA Code 54. Keep in mind, before CODE 54, can you recall hearing anyone in your family, neighborhood, church or community complain about liquids squirting out of their gas pipes?
Once the utilities determined they would be flushing their gas pipes to remove PCBs, the increased liquid, quite obviously would plug gas appliance controls. So it's safe to assume the industry started flushing their pipes after adopting the 1992 Code 54. Twenty five years after they started monitoring for PCBs in their pipes.
The danger Code 54 poses for an unsuspecting public, is the liquid in these sediment traps contains hazardous chemicals known to cause cancer, birth defects, reproductive harm and hormone disruption, and no one has warned the public.
The next question: where does one dispose of these contaminated liquids collected from the gas pipes? How does one protect themselves, their family, their homes and personal property should any of this liquid be accidentally spilled while the sediment trap is being emptied, removed, changed, etc.
ARCHIVE OF GAS PIPE PCB CONTAMINATION LEVELS
The AGA and it's member LDCs have been collecting data measurements of PCB levels in their respective gas pipes since before 1970. This PCB information has been shared with the EPA in Washington.
The first public disclosure of this PCB archive surfaced when the San Francisco Chronicle newspaper published on August 30, 1981, page A10: "Pipes where PCBs exceeded 50 parts per million standard. The table lists 25 locations in the San Francisco area with a single date after each reading.
Under the Freedom Of Information Act (FOIA) we were able to obtain court transcripts of the EPA Region 5 (Chicago) case against Southern Indiana Gas and Electric.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION V
DOCKET No. TSCA-V-C- 39 '91
Respondent's use of PCBs at greater than 50 ppm in its natural gas distribution system constitutes violations of 40 C.F.R. 761.20(a) and Section 15 TSCA, 15 U.S.C. 2614.
Testimony shows employees were aware of PCB monitoring before 1970.
More recently, the AGA contracted with Pennsylvania State University to determine how to flush PCBs of the nations millions of miles of gas pipes. Penn State reports finding PCB levels of 1,250 ppm in the gas pipes.
A national assessment of natural gas must be collected and published for the health and safety of the public. Such an assessment must include state, utility, gas distribution areas, utility chemical release docket numbers along with the PCB levels, times, dates and locations. Included in the national assessment publication must be records of the odorants used, amounts injected, dates and locations.
This national assessment of natural gas might follow EPA's new National Drinking Water Assessment Web Page www.epa.gov/surf/iwi
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