August 21, 2012
Western Regional Gas Conference
Paul Gustilo
Southwest Gas Corporation
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Driving forces
Changes in effect today
Changes in the pipeline
California Public Utilities Commission (CPUC)
organizational changes
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NTSB/PHMSA Investigations
CPUC Independent Panel Review
Public Awareness
California
Companies
and Mileage
Alpine Natural Gas
Gill Ranch Storage, LLC
Lodi Gas Storage, LLC
Pacific Gas & Electric Co
San Diego Gas & Electric Co
Southern California Edison Co
Southern California Gas Co
Southwest Gas Corp
West Coast Gas Co Inc
Wild Goose Storage LLC
Total Jurisdictional
Total for State (Inter and Intra)
% Jurisdictional
Distribution
(Mains)
Transmission
34
32
45
42,309
5,744
8,417
9
49,008
3,640
3,106
15
38
34
102,921
9,510
104,337
11,642
99%
82%
Source: PHMSA 2011 Annual reports
Historical
Operating
Pressure
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Elimination of grandfather
clause for transmission
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Tougher enforcement
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New pipeline safety plan
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Management and financial
audits
Rulemaking R.11-02-019 (June 2011)
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Pressure test required for all transmission pipe
Remote Control Valves/Automatic Shut-off Valves
must be considered
Rulemaking R.11-02-019 (June 2011)
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Modifications to accommodate in-line inspection
devices must be considered
Operators had to submit a plan in August 2011
addressing requirements
Caption from Figure 16
from the CPUC
Independent Panel
Report, June 2011
Statistics are from the
period from 2001-2009
and were derived from
PHMSA data.
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Resolution approved in December 2011
Gives Consumer Protection and Safety Division
(CPSD) direct authority
Increased fines from $20,000 - $50,000 per
violation
Encourages self reporting
Establishes process for citations
Citation Process
Citation
Received
(fine issued)
w/in
10 days
Correct
Violation or
Submit
Appeal
Include
Compliance Plan
signed by CEO
Notify Local
Officials
ALJ
Schedules
Hearing
w/in
60 days
ALJ Issues
Draft
Resolution
to
Commission
Inspections and Investigations
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More of them
More in-depth
More questions
R.11-02-019 (April 2012)
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“…each gas corporation to develop and implement
a plan for the safe and reliable operation of its gas
pipeline facilities, and the Commission to accept,
modify, or reject the plan by year-end 2012.”
R.11-02-019 (April 2012)
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“provide opportunities for meaningful, substantial,
and ongoing participation by the gas corporation
workforce in the development and implementation
of the plan.”
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“Section 961(e) sets creating a “culture of safety”
as an objective of the Commission’s regulation of
California natural gas systems operators.”
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“To evaluate whether California’s natural gas
system operators have established a “culture of
safety,” we must start with executive
management.”
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“We also order financial audits which include, but
will not be limited to, comparing the authorized
gas safety expenditures and capital investments to
actual recorded amounts, and the rationale for any
deviations.”
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Damage prevention enforcement (AB 1514)
Emergency response standards (SB 44)
Master meter systems (R.11-02-018)
Access to safety records (ALJ-436)
Whistleblower protection (R.11-02-019)
Commissioners
Executive Director
Risk Assessment
Unit
Consumer Protection and
Safety Division (CPSD)
Consumer
Protection and
Reliability
Electric
Generation
Rail Transit and
Crossing Safety
Branch
Gas Safety &
Reliability
Program
South Office
(Los Angeles)
Electric Safety &
Reliability
Program
North Offices
(San Francisco
& Sacramento)
Railroad
Operations
Safety Branch
1. Susceptibility of older plastic pipe to premature
brittle-like cracking
2. Grandfathering provisions in 49 CFR Part 192
3. Excavation damage (AB 1514)
4. Location and specification of pipe in the ground
5. Unmonitored class location change
6. Aging infrastructure and interacting threats
7. Infrastructure, maintenance, and parts
8. Utility resource management and workforce
development
9. Gas leak identification and response
10. Pipe with characteristics susceptible to failure
11. Protection redundancy.
12. Accommodating in-line inspection tools (smart pigs)
13. Utility management deficiencies (safety first culture)
14. RCVs/ASVs
15. Customer-owned or operated lines
16. Master-metered systems not in mobile home parks
17. Inadequate regulations
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More regulations
More inspection and investigations
More enforcement actions
More to come