WEBVTT 00:00:03.030 --> 00:00:05.403 The feed for this streaming event. 00:00:11.210 --> 00:00:13.590 Thank you, and welcome to The Future Implementation 00:00:13.590 --> 00:00:17.630 of the National Transportation Board Safety Recommendation 00:00:17.630 --> 00:00:21.360 P-19-016 Informal Workshop. 00:00:21.360 --> 00:00:23.160 My name is Angelique Juarez, 00:00:23.160 --> 00:00:26.410 I am an analyst in the Safety Policy Division 00:00:26.410 --> 00:00:29.350 Safety Culture and Governance Section. 00:00:29.350 --> 00:00:31.800 I will be hosting this workshop. 00:00:31.800 --> 00:00:36.800 Our workshop presenters include representatives from PG&E. 00:00:37.810 --> 00:00:42.070 SoCalGas, SDG&E, and Southwest Gas. 00:00:42.070 --> 00:00:43.347 Next slide please. 00:00:46.310 --> 00:00:49.430 This workshop will be presented in English 00:00:49.430 --> 00:00:52.190 with the option of Spanish subtitles. 00:00:52.190 --> 00:00:55.420 Workshop participants have the opportunity to make comments 00:00:55.420 --> 00:00:58.660 and ask questions during the public comment period, 00:00:58.660 --> 00:01:01.240 utilizing English and Spanish call in 00:01:01.240 --> 00:01:03.780 phone numbers shown on the slide. 00:01:03.780 --> 00:01:04.660 This workshop 00:01:07.000 --> 00:01:10.590 is being recorded and archived for future viewing. 00:01:10.590 --> 00:01:11.837 Next slide please. 00:01:19.500 --> 00:01:21.400 Please ensure that you know your safe, 00:01:22.270 --> 00:01:23.913 previous slide please. 00:01:30.810 --> 00:01:32.730 Please ensure that you know your safety routes 00:01:32.730 --> 00:01:35.170 and exits in case of an emergency, 00:01:35.170 --> 00:01:39.603 this is a three hour workshop with two 15 minute breaks, 00:01:40.490 --> 00:01:42.430 adjust your workstation to ensure 00:01:42.430 --> 00:01:44.860 your ergonomic needs are met 00:01:44.860 --> 00:01:48.380 and please comply with all federal, state 00:01:48.380 --> 00:01:51.343 and local jurisdiction COVID-19 requirements. 00:01:53.690 --> 00:01:54.823 Next slide, please. 00:01:58.720 --> 00:02:02.260 Here is the workshop schedule and topics to be presented. 00:02:02.260 --> 00:02:04.933 I'll leave this slide up for a few more seconds. 00:02:19.110 --> 00:02:20.173 Next slide please. 00:02:23.670 --> 00:02:27.120 This is an opportunity for panelists introductions. 00:02:27.120 --> 00:02:29.060 Let's start the introductions beginning 00:02:29.060 --> 00:02:32.470 with the PG&E presenter and then continuing 00:02:32.470 --> 00:02:36.520 with the SoCalGas and SDG&E presenter, 00:02:36.520 --> 00:02:39.113 and finally, the Southwest Gas presenter. 00:02:43.210 --> 00:02:44.043 Good afternoon. 00:02:44.043 --> 00:02:45.240 My name is Lily Gharib. 00:02:45.240 --> 00:02:48.320 I will be presenting on behalf of PG&E. 00:02:48.320 --> 00:02:51.360 I am an engineering supervisor in our gas standards 00:02:51.360 --> 00:02:52.680 engineering department, 00:02:52.680 --> 00:02:56.020 which is the part of our regulatory compliance organization. 00:02:56.020 --> 00:02:56.853 Thank you. 00:03:03.200 --> 00:03:04.033 Good afternoon, everyone. 00:03:04.033 --> 00:03:05.620 My name is Todd Dusteel. 00:03:05.620 --> 00:03:08.990 I have been with SoCalGas for 24 years. 00:03:08.990 --> 00:03:12.300 I'm currently a team lead in engineering design 00:03:12.300 --> 00:03:15.920 department supporting both SoCalGas and SDG&E, 00:03:15.920 --> 00:03:17.670 I'll be presenting on behalf 00:03:17.670 --> 00:03:19.543 of both utilities this afternoon. 00:03:24.170 --> 00:03:26.020 And good afternoon, my name is Kevin Lang. 00:03:26.020 --> 00:03:27.820 I'm the director of engineering services 00:03:27.820 --> 00:03:30.713 for Southwest Gas based out of Las Vegas, Nevada. 00:03:31.633 --> 00:03:34.570 My role at Southwest Gas includes providing technical 00:03:34.570 --> 00:03:37.630 direction and support to the company's five operating 00:03:37.630 --> 00:03:40.190 divisions in California, Nevada and Arizona. 00:03:40.190 --> 00:03:42.760 In addition to the company's transmission pipeline company 00:03:42.760 --> 00:03:44.830 Great Basin in Northern Nevada. 00:03:44.830 --> 00:03:46.230 I have a bachelor's degree in mining 00:03:46.230 --> 00:03:48.570 and minerals engineering from Virginia Tech, 00:03:48.570 --> 00:03:49.890 and I'm a registered professional 00:03:49.890 --> 00:03:52.260 civil engineer in the state of Nevada. 00:03:52.260 --> 00:03:55.240 I have over 18 years of experience in natural gas facility, 00:03:55.240 --> 00:03:57.147 design and construction practices 00:03:57.147 --> 00:04:00.430 and 25 years of general engineering experience. 00:04:02.830 --> 00:04:05.200 Thank you panelists for the introduction. 00:04:05.200 --> 00:04:06.607 Next slide please. 00:04:11.270 --> 00:04:14.090 So the purpose of this informal workshop 00:04:14.090 --> 00:04:16.333 is not related to a proceeding. 00:04:17.180 --> 00:04:20.210 No decisions will be made at today's workshop. 00:04:20.210 --> 00:04:22.730 The purpose of this informal workshop is to discuss 00:04:22.730 --> 00:04:27.370 the NTSBs recommendation 19-P-016 00:04:27.370 --> 00:04:32.370 and its impact on CPUC jurisdictional natural gas pipelines. 00:04:33.160 --> 00:04:35.150 This workshop will be an opportunity 00:04:35.150 --> 00:04:37.367 for PG&E, SoCalGas, SDG&E 00:04:39.780 --> 00:04:42.340 and Southwest Gas representatives 00:04:42.340 --> 00:04:43.820 to share their current companies 00:04:43.820 --> 00:04:45.520 professional engineering approval 00:04:45.520 --> 00:04:47.650 and standards and practices. 00:04:47.650 --> 00:04:49.410 Topics to be discussed 00:04:50.340 --> 00:04:52.600 at this informal workshop include an 00:04:52.600 --> 00:04:57.010 overview of the MTSBs safety recommendations 00:04:57.010 --> 00:05:00.440 and an overview of the utility companies 00:05:00.440 --> 00:05:03.510 PE approval and staffing practices 00:05:03.510 --> 00:05:05.103 for natural gas projects. 00:05:06.340 --> 00:05:07.313 Next slide, please. 00:05:13.920 --> 00:05:17.960 The presenters will also discuss the benefits 00:05:17.960 --> 00:05:21.720 of implementing the NTSB safety recommendations, 00:05:21.720 --> 00:05:26.720 challenges of implementing the NTSB safety recommendations, 00:05:27.250 --> 00:05:32.100 utility presenter recommendations, the CPUC's options 00:05:32.100 --> 00:05:35.970 for implementing the NTSB safety recommendations 00:05:35.970 --> 00:05:37.223 as the next step. 00:05:38.100 --> 00:05:40.940 This informal workshop is also an opportunity 00:05:40.940 --> 00:05:43.170 for parties and participants 00:05:43.170 --> 00:05:45.573 to ask questions and share comments. 00:05:47.300 --> 00:05:48.423 Next slide, please. 00:05:52.910 --> 00:05:54.643 Now let's begin with a background. 00:05:59.970 --> 00:06:04.960 On September 13th, 2018, about 4:00 p.m. local time, 00:06:04.960 --> 00:06:06.890 a series of structural fires 00:06:06.890 --> 00:06:10.150 and explosions occurred after high pressure 00:06:10.150 --> 00:06:14.470 natural gas was released into a low pressure natural gas 00:06:14.470 --> 00:06:18.070 distribution system in the Northeast region 00:06:18.070 --> 00:06:22.300 of Merrimack Valley in the Commonwealth of Massachusetts 00:06:22.300 --> 00:06:26.727 resulting in approximately 10,894 customers 00:06:28.750 --> 00:06:32.440 impacted by natural gas distribution shut down, 00:06:32.440 --> 00:06:36.730 one death, 22 hospitalizations, 00:06:36.730 --> 00:06:39.770 damage to 131 structures, 00:06:39.770 --> 00:06:44.120 including five homes with most of the damage occurring 00:06:44.120 --> 00:06:48.773 from fires ignited by natural gas fuel appliances. 00:06:50.710 --> 00:06:52.210 Several of these homes were destroyed 00:06:52.210 --> 00:06:55.170 by natural gas fuel explosion. 00:06:55.170 --> 00:06:57.970 The Merrimack Valley fire was also responsible 00:06:57.970 --> 00:07:01.630 for electric utility shut down, 00:07:01.630 --> 00:07:04.180 freight and passenger Railroad 00:07:04.180 --> 00:07:08.063 operations being suspended and local road closures. 00:07:10.180 --> 00:07:11.457 Next slide please. 00:07:14.640 --> 00:07:19.600 The NTSB performed an extensive investigation 00:07:19.600 --> 00:07:22.350 of the Merrimack Valley fire 00:07:22.350 --> 00:07:24.160 and detailed its findings in 00:07:24.160 --> 00:07:28.370 the pipeline accident report titled over pressurization 00:07:28.370 --> 00:07:31.290 of natural gas distribution system, 00:07:31.290 --> 00:07:36.290 explosions and fires in Merrimack Valley, Massachusetts 00:07:36.360 --> 00:07:39.393 September 13th, 2018. 00:07:41.814 --> 00:07:44.830 In the reports factual information 00:07:44.830 --> 00:07:49.830 subsection 1.9 professional engineering and review 00:07:50.280 --> 00:07:54.640 and approval table PE industrial exemption 00:07:54.640 --> 00:07:57.600 for infrastructure project practices, 00:07:57.600 --> 00:08:02.290 California is identified as a state with professional 00:08:02.290 --> 00:08:07.290 engineer approval exemption requiring a statutory amendment. 00:08:09.350 --> 00:08:10.587 Next slide please. 00:08:22.190 --> 00:08:23.600 Thank you. 00:08:23.600 --> 00:08:28.280 Additionally, in the NTSB's report section 00:08:28.280 --> 00:08:30.640 5.1 new recommendations, 00:08:30.640 --> 00:08:33.750 the NTSB recommends that California 00:08:33.750 --> 00:08:37.670 and several other states remove the exemption 00:08:37.670 --> 00:08:40.360 so that all future natural gas 00:08:40.360 --> 00:08:44.030 infrastructure projects require licensed professional 00:08:44.030 --> 00:08:46.963 engineer approval and stamping. 00:08:47.830 --> 00:08:48.913 Next slide, please. 00:08:57.820 --> 00:09:01.780 The NTSB submitted a letter to 31 states 00:09:01.780 --> 00:09:04.090 that allow exemptions to professional 00:09:04.090 --> 00:09:05.710 engineer approval and staffing 00:09:05.710 --> 00:09:08.820 for natural gas infrastructure projects. 00:09:08.820 --> 00:09:12.400 On October 24th, 2019, 00:09:12.400 --> 00:09:16.423 the NTSC's then chairman Robert L. Sumwalt III 00:09:17.420 --> 00:09:21.340 submitted to California's Governor Gavin Newsome 00:09:21.340 --> 00:09:22.830 a letter with information 00:09:22.830 --> 00:09:27.830 about the NTSB's September 24th, 2019 report over 00:09:30.220 --> 00:09:34.090 pressurization of natural gas distribution system 00:09:34.090 --> 00:09:38.640 explosion and fire in Merrimack Valley, Massachusetts. 00:09:38.640 --> 00:09:41.093 In his letter to Gavin Newsome, 00:09:42.470 --> 00:09:47.020 Mr. Sumwalt recommended that California remove exemptions 00:09:47.020 --> 00:09:49.390 to professional engineer approval 00:09:49.390 --> 00:09:51.210 and stamping for natural gas 00:09:51.210 --> 00:09:55.000 infrastructure projects so that all future natural gas 00:09:55.000 --> 00:09:59.610 infrastructure projects require licensed professional 00:09:59.610 --> 00:10:03.060 engineer approval and stamping. 00:10:03.060 --> 00:10:08.060 The NTSB is vitally interested in these recommendations 00:10:08.770 --> 00:10:13.113 as they are designed to prevent accidents and save lives. 00:10:14.240 --> 00:10:15.403 Next slide please. 00:10:21.516 --> 00:10:25.593 Let's go back one more slide, my apologies. 00:10:29.620 --> 00:10:34.620 The CPUC is the California lead state regulatory agency 00:10:36.150 --> 00:10:39.270 or gas pipeline safety and is certified 00:10:39.270 --> 00:10:42.330 to inspect and regulate intrastate 00:10:42.330 --> 00:10:44.760 pipeline safety pursuant to the state 00:10:44.760 --> 00:10:47.580 certification program of the pipeline 00:10:47.580 --> 00:10:51.020 and hazardous material safety administration 00:10:51.020 --> 00:10:52.393 also known PHMSA. 00:10:53.550 --> 00:10:57.180 On March 8th, 2021, 00:10:57.180 --> 00:11:01.720 the CPUC staff responded to Chairman Sumwalt's letter 00:11:01.720 --> 00:11:04.170 that staff is planning to include language 00:11:04.170 --> 00:11:07.620 for future natural gas infrastructure projects 00:11:07.620 --> 00:11:12.427 to require licensed professional engineering approval 00:11:12.427 --> 00:11:16.630 for forthcoming in revisions 00:11:16.630 --> 00:11:20.810 to CPUC general order 112-S. 00:11:20.810 --> 00:11:24.100 CPUC general order 112-S 00:11:24.100 --> 00:11:27.510 addresses the design, construction, testing, 00:11:27.510 --> 00:11:32.440 maintenance and operation of natural gas gathering 00:11:32.440 --> 00:11:36.560 transmission and distribution piping system. 00:11:36.560 --> 00:11:39.650 This background information brings us up 00:11:39.650 --> 00:11:41.883 to date to this informal workshop. 00:11:42.950 --> 00:11:43.973 Next slide please. 00:11:47.910 --> 00:11:52.220 Our first utility presenter is Lily Gharib of PG&E. 00:11:55.860 --> 00:11:57.280 Thank you, Angelique. 00:11:57.280 --> 00:11:58.497 Next slide please. 00:12:04.720 --> 00:12:05.620 Next slide please. 00:12:07.960 --> 00:12:09.480 Okay. Good afternoon, everyone. 00:12:09.480 --> 00:12:13.020 So I will be speaking to the items here, 00:12:13.020 --> 00:12:14.470 which Angelique had highlighted, 00:12:14.470 --> 00:12:16.630 but just to discuss one more time, 00:12:16.630 --> 00:12:21.150 we will be discussing our company's current PE approval 00:12:21.150 --> 00:12:23.300 and stamping requirements, 00:12:23.300 --> 00:12:27.290 benefits of implementing the NTSB recommendation, 00:12:27.290 --> 00:12:30.950 challenges of implementing the NTSB recommendation 00:12:30.950 --> 00:12:33.010 as well as our company's specific 00:12:33.010 --> 00:12:37.620 recommendations associated with this safety recommendation. 00:12:37.620 --> 00:12:38.570 Next slide, please. 00:12:41.520 --> 00:12:44.150 For our company standards, 00:12:44.150 --> 00:12:47.750 PE review and stamping of certain gas design work 00:12:47.750 --> 00:12:52.140 has been required at PG&E for nearly 40 years. 00:12:52.140 --> 00:12:53.260 Prior to that, 00:12:53.260 --> 00:12:56.190 our engineering design standards dating back 00:12:56.190 --> 00:12:58.980 to the 1960s do make note 00:12:58.980 --> 00:13:02.180 of certain engineering management approvals. 00:13:02.180 --> 00:13:05.390 However, the explicit PE requirement 00:13:05.390 --> 00:13:07.860 was formerly formally issued 00:13:07.860 --> 00:13:11.253 in company-wide standards as of 1984. 00:13:12.140 --> 00:13:15.280 In this slide, we are providing a revision history 00:13:15.280 --> 00:13:17.700 to show in which company standard 00:13:17.700 --> 00:13:20.973 this requirement has been memorialized over the years. 00:13:21.880 --> 00:13:25.440 The fundamental requirement has remained consistent 00:13:25.440 --> 00:13:29.150 and what is reflected in our current gas design standards, 00:13:29.150 --> 00:13:31.423 A-36 is as follows. 00:13:32.260 --> 00:13:35.290 The current requirements states that new construction 00:13:36.214 --> 00:13:38.410 drawings for gas facilities to operate greater 00:13:38.410 --> 00:13:41.980 than 60 PSIG are to be reviewed 00:13:41.980 --> 00:13:45.470 and stamped by a current PE licensed 00:13:45.470 --> 00:13:46.923 in the state of California, 00:13:48.120 --> 00:13:49.820 gas facilities designed 00:13:49.820 --> 00:13:52.860 to operate over 60 PSIG is intended 00:13:52.860 --> 00:13:57.260 to be all encompassing and to include new design 00:13:57.260 --> 00:14:01.100 or replacement design of pipelines, 00:14:01.100 --> 00:14:04.860 measurement facilities, regulation facilities, 00:14:04.860 --> 00:14:08.450 compressor stations, storage facilities, 00:14:08.450 --> 00:14:09.943 and launchers and receivers. 00:14:11.600 --> 00:14:15.290 The scope of PE review and stamping being focused 00:14:15.290 --> 00:14:19.780 on facilities designed to operate over 60 PSIG 00:14:19.780 --> 00:14:22.990 is based on risk and complexity 00:14:22.990 --> 00:14:24.853 of this stacked design work. 00:14:26.010 --> 00:14:27.670 For these (indistinct) jobs, 00:14:27.670 --> 00:14:31.350 the responsible engineer affixes their PE stamp 00:14:31.350 --> 00:14:34.200 to every sheet of the construction drawing 00:14:34.200 --> 00:14:36.520 and also includes their signature 00:14:36.520 --> 00:14:39.763 and the date of their PE license expiration. 00:14:40.990 --> 00:14:42.290 Next slide, please. 00:14:47.170 --> 00:14:50.980 Given that PG&E has had a long standing requirement 00:14:50.980 --> 00:14:54.220 of PE stamping of certain gas design work 00:14:54.220 --> 00:14:58.160 we do acknowledge benefits of the NTSB recommendation 00:14:58.160 --> 00:15:01.800 for higher risk complex gas design facilities 00:15:03.090 --> 00:15:06.860 an engineer who can successfully obtain their license, 00:15:06.860 --> 00:15:08.690 demonstrates competency 00:15:08.690 --> 00:15:12.830 of foundational engineering codes and principles, 00:15:12.830 --> 00:15:16.063 as well as ethical and professionalism standards. 00:15:16.970 --> 00:15:21.060 Additionally, this is a broadly recognized licensure 00:15:21.060 --> 00:15:23.650 in the engineering and design communities, 00:15:23.650 --> 00:15:26.460 which illustrate a level of commitment 00:15:26.460 --> 00:15:29.550 of the company personnel who are responsible 00:15:29.550 --> 00:15:30.803 for this design work. 00:15:32.320 --> 00:15:37.320 By requiring a PE to affix their stamp on gas design work, 00:15:37.340 --> 00:15:41.010 it inherently promotes a level of accountability 00:15:41.010 --> 00:15:43.990 for safety of the project design. 00:15:43.990 --> 00:15:46.530 Similarly, this deepens the standard 00:15:46.530 --> 00:15:48.583 of care for project design. 00:15:49.670 --> 00:15:51.270 In addition to these items, 00:15:51.270 --> 00:15:53.940 the fundamental benefit is that PE review 00:15:53.940 --> 00:15:56.570 and stamping provides an additional layer 00:15:56.570 --> 00:16:00.410 of protection and rigor in the design phase 00:16:00.410 --> 00:16:04.323 for higher risk and more complex gas design work. 00:16:05.450 --> 00:16:06.400 Next slide, please. 00:16:09.830 --> 00:16:11.920 Moving into the challenges. 00:16:11.920 --> 00:16:15.630 These items are more so open items which remains 00:16:15.630 --> 00:16:18.320 to be addressed or have dependencies 00:16:18.320 --> 00:16:21.890 on other items before they can be addressed. 00:16:21.890 --> 00:16:25.420 The primary item of this nature is scope. 00:16:25.420 --> 00:16:29.740 The language from the NTSB recommendation does not provide 00:16:29.740 --> 00:16:33.970 specific details on scope and applicability, 00:16:33.970 --> 00:16:35.660 for the states that have implemented 00:16:35.660 --> 00:16:37.950 this NTSB recommendation, 00:16:37.950 --> 00:16:40.130 there are variations in each states 00:16:40.130 --> 00:16:44.213 respective regulatory language and scope details. 00:16:45.410 --> 00:16:48.320 Understanding the scope of the proposed California 00:16:48.320 --> 00:16:52.240 regulations will inform the necessary next steps 00:16:52.240 --> 00:16:54.063 for gas utility operators. 00:16:55.900 --> 00:16:59.330 Another overarching item to note is the fact 00:16:59.330 --> 00:17:02.410 that PE licensure does not explicitly 00:17:02.410 --> 00:17:05.183 address natural gas design engineering. 00:17:06.060 --> 00:17:11.060 Since our company PG&E already had been PE stamping, 00:17:11.150 --> 00:17:14.360 certain gas design work per our standards, 00:17:14.360 --> 00:17:18.453 we currently have licensed engineers of varying disciplines. 00:17:19.320 --> 00:17:23.260 Their competency is a qualitative determination based 00:17:23.260 --> 00:17:26.090 on the individual's professional experience 00:17:26.090 --> 00:17:28.760 and is demonstrated by their performance 00:17:28.760 --> 00:17:30.653 as judged by their management. 00:17:32.670 --> 00:17:37.070 Moving into items that may require actions dependent 00:17:37.070 --> 00:17:40.950 on the items above one piece is staffing 00:17:40.950 --> 00:17:45.530 and head count impacts, dependent on the state regulation, 00:17:45.530 --> 00:17:49.233 there may be a need for workflow modification. 00:17:50.110 --> 00:17:53.910 This can also tie to a need for reorganization 00:17:53.910 --> 00:17:55.800 to ensure that design groups 00:17:55.800 --> 00:17:59.223 are staffed accordingly with licensed engineers. 00:18:00.700 --> 00:18:03.860 Our company have represented personnel 00:18:03.860 --> 00:18:05.853 that perform gas design work, 00:18:06.690 --> 00:18:09.690 dependent on the items that we have just discussed, 00:18:09.690 --> 00:18:13.070 another potential action item is modification 00:18:13.070 --> 00:18:16.300 of union job profiles and contracts 00:18:16.300 --> 00:18:19.723 in support of PE review and stamping requirements. 00:18:20.830 --> 00:18:21.730 Next slide please. 00:18:26.050 --> 00:18:29.440 Regarding PG&E's recommendations, 00:18:29.440 --> 00:18:32.820 our company will continue our current process 00:18:32.820 --> 00:18:36.120 of PE review and stamping for higher risk 00:18:36.120 --> 00:18:40.480 and complex gas design work in consideration 00:18:40.480 --> 00:18:42.800 of the NTSB recommendation 00:18:42.800 --> 00:18:45.900 and the ongoing conversations regarding PE review 00:18:45.900 --> 00:18:49.920 and stamping PG&E is considering clarifying 00:18:49.920 --> 00:18:52.080 the scope of gas design work, 00:18:52.080 --> 00:18:54.743 which is governed by our PE requirements. 00:18:55.900 --> 00:18:57.510 As originally noted, 00:18:57.510 --> 00:19:01.730 PE review and stamping is required for all designs 00:19:01.730 --> 00:19:06.040 of pipelines that will operate over 60 PSIG. 00:19:06.040 --> 00:19:08.380 From the items noted on this slide 00:19:08.380 --> 00:19:11.280 that existing requirement encompasses 00:19:11.280 --> 00:19:15.280 compression, processing and storage facilities. 00:19:15.280 --> 00:19:18.963 It also includes design for launchers and receivers. 00:19:19.900 --> 00:19:23.390 One area of potential expansion shown on the slide 00:19:24.632 --> 00:19:28.410 is for the requirement for PE review 00:19:28.410 --> 00:19:31.500 and stamping for design of new 00:19:31.500 --> 00:19:34.483 or reconfigured district regulator stations, 00:19:36.075 --> 00:19:40.470 regardless of inlet or outlet operating pressure. 00:19:40.470 --> 00:19:44.040 As originally discussed, our current requirement applies 00:19:44.040 --> 00:19:49.040 to facilities operating over 60 PSIG, however, 00:19:49.040 --> 00:19:52.630 given the complexity and potential risks associated 00:19:52.630 --> 00:19:56.112 with district regulator stations design work, 00:19:56.112 --> 00:19:59.440 we are considering those items to be drivers 00:19:59.440 --> 00:20:01.683 for this potential expansion. 00:20:03.240 --> 00:20:06.130 Similarly, and based on risk, 00:20:06.130 --> 00:20:10.230 another proposed expansion is to require PE review 00:20:10.230 --> 00:20:14.403 and stamping for upgrades in accordance with sub-part K. 00:20:16.610 --> 00:20:17.593 Next slide please. 00:20:21.350 --> 00:20:22.920 I thank you for your time. 00:20:22.920 --> 00:20:26.190 This concludes the presentation on behalf of PG&E. 00:20:26.190 --> 00:20:27.900 Again, my name is Lily Gharib 00:20:27.900 --> 00:20:29.500 and I am an engineering supervisor 00:20:29.500 --> 00:20:31.803 with our gas standards organization. 00:20:32.910 --> 00:20:33.743 Thank you. 00:20:35.840 --> 00:20:36.993 Thank you, Lily. 00:20:37.860 --> 00:20:39.377 Next slide please. 00:20:51.940 --> 00:20:55.110 So let's go ahead and take our first 15 minute break. 00:20:55.110 --> 00:21:00.110 It is now 1:30, let's return promptly at 1:45, 00:21:01.780 --> 00:21:04.510 and we will begin with a presentation 00:21:04.510 --> 00:21:06.017 by SoCalGas and SDG&E. 00:21:11.700 --> 00:21:12.700 Welcome back. 00:21:12.700 --> 00:21:17.700 Our second presenter is Todd Dusteel of SoCalGas 00:21:19.590 --> 00:21:22.323 and SDG&E, next slide please. 00:21:31.950 --> 00:21:32.900 Hi. Good morning everyone. 00:21:32.900 --> 00:21:34.200 My name is Todd Dusteel, 00:21:34.200 --> 00:21:36.480 and I'll be sharing what the Southern California 00:21:36.480 --> 00:21:39.890 Gas Company and San Diego Gas and Electric have implemented 00:21:39.890 --> 00:21:42.470 for PE approval and stamping 00:21:42.470 --> 00:21:45.340 of natural gas pipeline projects. 00:21:45.340 --> 00:21:46.173 Next slide. 00:21:49.480 --> 00:21:53.990 So I'll also be going over what we recently implemented 00:21:53.990 --> 00:21:57.790 to satisfy the NTSB safety recommendation, 00:21:57.790 --> 00:22:01.030 as well as the benefits and challenges in doing so 00:22:01.030 --> 00:22:04.520 and what our recommendations are moving forward. 00:22:04.520 --> 00:22:05.353 Next slide. 00:22:12.010 --> 00:22:15.750 In order to implement the NTSB's recommendation, 00:22:15.750 --> 00:22:19.710 we began working with the CPUC's safety enforcement division 00:22:19.710 --> 00:22:23.810 back in 2019 to develop a framework for having some 00:22:23.810 --> 00:22:26.070 of our own engineering drawings reviewed 00:22:26.070 --> 00:22:28.323 and sealed by a professional engineer. 00:22:29.270 --> 00:22:32.280 In 2020, we developed the criteria 00:22:32.280 --> 00:22:34.040 for which engineering work needs 00:22:34.040 --> 00:22:37.740 to be completed under the oversight of a PE 00:22:37.740 --> 00:22:40.240 and later implemented the new policies 00:22:40.240 --> 00:22:42.720 for pipeline projects that were approved 00:22:42.720 --> 00:22:46.780 for construction on or after January 1st of 2021. 00:22:49.440 --> 00:22:53.480 Also in 2021, they published a new company operations 00:22:53.480 --> 00:22:55.990 standard on PE stamping. 00:22:55.990 --> 00:22:58.510 This document establishes the requirements 00:22:58.510 --> 00:23:03.180 for the PE signature and seal on qualifying drawings 00:23:03.180 --> 00:23:05.340 that was published in both SoCalGas 00:23:05.340 --> 00:23:07.543 and SDG&E simultaneously, 00:23:08.480 --> 00:23:12.080 we implemented these requirements in our transmission, 00:23:12.080 --> 00:23:13.960 distribution, construction 00:23:13.960 --> 00:23:17.900 and storage organizations at both utilities, 00:23:17.900 --> 00:23:20.850 final construction drawings would be stamped 00:23:20.850 --> 00:23:23.360 as opposed to preliminary drawings, 00:23:23.360 --> 00:23:26.050 which is consistent with the requirements defined 00:23:26.050 --> 00:23:28.433 in California's Professional Engineers Act, 00:23:29.400 --> 00:23:31.150 which we relied heavily on 00:23:32.150 --> 00:23:33.620 in the development of the new standard. 00:23:33.620 --> 00:23:35.860 So all stamping is done in accordance 00:23:35.860 --> 00:23:38.063 with the California State PE Act. 00:23:39.010 --> 00:23:41.770 This slide shows you the two main areas 00:23:41.770 --> 00:23:45.490 that we focused on for our PE standard. 00:23:45.490 --> 00:23:49.130 So our current PE approval and stamping practice 00:23:49.130 --> 00:23:51.000 applies to final drawings 00:23:51.000 --> 00:23:54.690 for the most critical natural gas infrastructure, 00:23:54.690 --> 00:23:59.210 which includes VOT defined transmission piping 00:23:59.210 --> 00:24:02.930 and non-standard design M&R facilities. 00:24:02.930 --> 00:24:04.853 So for transmission pipelines, 00:24:05.950 --> 00:24:07.900 the policy provides for stamping 00:24:07.900 --> 00:24:11.940 of new installations or replacement projects. 00:24:11.940 --> 00:24:14.980 We also included within the criteria high pressure 00:24:14.980 --> 00:24:18.020 distribution taps that are connected directly 00:24:18.020 --> 00:24:19.890 to transmission pipelines, 00:24:19.890 --> 00:24:23.040 and that includes both mains and services. 00:24:23.040 --> 00:24:25.580 Lastly, we also included any designs 00:24:25.580 --> 00:24:29.000 for new or replaced inline inspection tool 00:24:29.000 --> 00:24:30.593 launchers and receivers. 00:24:31.960 --> 00:24:33.930 For the M&R facilities, 00:24:33.930 --> 00:24:37.590 we included designs for large customer meter sets 00:24:37.590 --> 00:24:39.843 that are greater than four inches 00:24:39.843 --> 00:24:42.143 in size and operating above 60 PSI, 00:24:43.010 --> 00:24:47.230 new or replacement district regulator stations that require 00:24:47.230 --> 00:24:50.740 special designs as well as pressure limiting 00:24:50.740 --> 00:24:52.890 and city gate stations. 00:24:52.890 --> 00:24:56.520 We also included all natural gas producer 00:24:56.520 --> 00:24:58.540 facilities that we operate. 00:24:58.540 --> 00:25:00.950 So this would include the interconnection points 00:25:00.950 --> 00:25:03.700 of receipt from California producers, 00:25:03.700 --> 00:25:07.160 as well as our renewable natural gas producers. 00:25:07.160 --> 00:25:09.650 Lastly, we included any designs 00:25:09.650 --> 00:25:13.380 for automated or remote control shutoff valves 00:25:13.380 --> 00:25:15.770 that are installed in our critical pipelines. 00:25:15.770 --> 00:25:18.370 All of these facilities that you see here are currently 00:25:18.370 --> 00:25:20.860 being stamped by our California 00:25:20.860 --> 00:25:22.980 registered professional engineer. 00:25:22.980 --> 00:25:23.973 Next slide, please. 00:25:28.240 --> 00:25:30.270 In implementing the NTSB safety 00:25:30.270 --> 00:25:32.640 recommendation at both utilities 00:25:32.640 --> 00:25:35.240 we have realized several key benefits, 00:25:35.240 --> 00:25:38.443 in both safety and operations. 00:25:38.443 --> 00:25:41.350 At SoCalGas and SDG&E we place safety 00:25:41.350 --> 00:25:43.150 as our primary core value 00:25:44.020 --> 00:25:45.780 and continuous improvement of pipeline. 00:25:45.780 --> 00:25:47.663 Safety has always been a priority. 00:25:48.892 --> 00:25:50.700 The introduction of PE approval 00:25:50.700 --> 00:25:53.730 to the existing constructability review process 00:25:53.730 --> 00:25:56.340 has given way to increase the accountability 00:25:56.340 --> 00:26:00.490 for safety for design and engineering deliverables. 00:26:00.490 --> 00:26:02.960 We've communicated to our engineering workforce, 00:26:02.960 --> 00:26:05.780 the value of a PE license, 00:26:05.780 --> 00:26:08.390 and it's important to the pipeline safety, 00:26:08.390 --> 00:26:11.560 the current practice encourages professional growth 00:26:11.560 --> 00:26:15.800 of our engineering workforce to meet these new requirements, 00:26:15.800 --> 00:26:19.210 which has also led to an enhanced project awareness through 00:26:19.210 --> 00:26:22.963 all phases of a project from initiation to completion. 00:26:23.972 --> 00:26:27.170 We also believe PE licensure is beneficial, 00:26:27.170 --> 00:26:29.950 'cause it is recognized by governmental agencies, 00:26:29.950 --> 00:26:31.720 as well as the public. 00:26:31.720 --> 00:26:34.790 Licensure means a commitment to dedication, 00:26:34.790 --> 00:26:36.113 skill and quality. 00:26:37.250 --> 00:26:39.340 It promotes more communication 00:26:39.340 --> 00:26:42.160 and exchange of technical engineering concepts, 00:26:42.160 --> 00:26:43.940 as well as enhanced troubleshooting 00:26:43.940 --> 00:26:46.693 amongst licensed engineers in both utilities. 00:26:47.950 --> 00:26:51.880 Overall, we believe PE licensure and the implementation 00:26:51.880 --> 00:26:54.800 of this new practice demonstrates a commitment 00:26:54.800 --> 00:26:57.580 to the pipeline engineering profession, 00:26:57.580 --> 00:27:00.180 obviously with safety being at the forefront 00:27:00.180 --> 00:27:02.970 of the initiative was also realized benefits 00:27:02.970 --> 00:27:05.040 in areas of heightened leadership 00:27:05.040 --> 00:27:07.100 and management skills over-engineering 00:27:07.100 --> 00:27:10.110 deliverables and the increased authority 00:27:10.110 --> 00:27:13.363 and responsibility that comes with a PE license. 00:27:14.260 --> 00:27:15.160 Next slide please. 00:27:19.230 --> 00:27:22.450 In implementing the NTSB safety recommendation thus far, 00:27:22.450 --> 00:27:25.130 we have encountered several challenges, 00:27:25.130 --> 00:27:27.710 some of which we've overcome and others 00:27:27.710 --> 00:27:30.540 that we are still continuing to work through. 00:27:30.540 --> 00:27:32.790 One of the challenges we faced by implementing 00:27:32.790 --> 00:27:36.020 this new practice is that we've simultaneously 00:27:36.020 --> 00:27:38.870 introduced another requirement over 00:27:38.870 --> 00:27:43.000 our engineers that had not existed previously, 00:27:43.000 --> 00:27:47.050 even though both utilities had always valued employees 00:27:47.050 --> 00:27:49.360 who had their PE license, 00:27:49.360 --> 00:27:53.780 there was never a hard requirement that they be licensed 00:27:53.780 --> 00:27:57.430 or get licensed during the course of their employment. 00:27:57.430 --> 00:27:59.910 Attaining a PE license carries with it 00:27:59.910 --> 00:28:02.230 a challenge in and of itself. 00:28:02.230 --> 00:28:05.320 Another challenge we realized was the interpretation 00:28:05.320 --> 00:28:08.310 of utility or pipeline engineering 00:28:08.310 --> 00:28:10.410 as an engineering discipline, 00:28:10.410 --> 00:28:13.010 meaning it didn't appear to be specific 00:28:13.010 --> 00:28:16.737 to a single engineering branch, further to that, 00:28:16.737 --> 00:28:19.600 the engineering discipline question is not addressed 00:28:19.600 --> 00:28:22.660 in the NTSB recommendation, 00:28:22.660 --> 00:28:26.680 and as a utility, both SoCalGas and SDG&E employees, 00:28:26.680 --> 00:28:31.120 engineers from various disciplines, mechanical, civil, 00:28:31.120 --> 00:28:33.993 chemical, electrical, and many others. 00:28:34.840 --> 00:28:37.980 Additionally, we realized that our civil engineers 00:28:37.980 --> 00:28:41.330 who want to pursue the PE license are faced 00:28:41.330 --> 00:28:43.460 with much more rigorous testing 00:28:43.460 --> 00:28:47.470 and qualification requirements here in California 00:28:47.470 --> 00:28:49.300 when compared to a similarly 00:28:49.300 --> 00:28:51.683 situated mechanical or chemical engineer, 00:28:52.520 --> 00:28:56.130 the PE Board rules do not define natural gas 00:28:56.130 --> 00:29:00.820 or pipeline utility engineering specifically, 00:29:00.820 --> 00:29:02.480 therefore placing that challenge 00:29:02.480 --> 00:29:04.473 on us to define it ourselves. 00:29:05.420 --> 00:29:07.910 Another challenge we faced was the determination 00:29:07.910 --> 00:29:10.450 and scope of what engineering documents 00:29:10.450 --> 00:29:13.023 would be reviewed and stamped by a PE. 00:29:13.920 --> 00:29:17.380 We ultimately decided that only final construction plans 00:29:17.380 --> 00:29:19.790 that met the criteria and shared earlier 00:29:19.790 --> 00:29:22.860 would constitute qualifying engineering work. 00:29:22.860 --> 00:29:24.880 Likewise, we met challenges 00:29:24.880 --> 00:29:27.980 and further addressing modifications to 00:29:27.980 --> 00:29:30.780 those stamped plans that would have 00:29:30.780 --> 00:29:32.640 to be revised either ahead 00:29:32.640 --> 00:29:34.833 of construction or during construction. 00:29:35.810 --> 00:29:38.870 In many cases when there is a field change 00:29:38.870 --> 00:29:42.290 to the design drawing safety reasons would mandate 00:29:42.290 --> 00:29:45.373 an engineering review before construction can continue. 00:29:46.280 --> 00:29:48.640 So we had to come up with some new protocols 00:29:48.640 --> 00:29:51.810 within our existing RFI process 00:29:51.810 --> 00:29:55.740 for PE stamped drawings that were either nearing completion, 00:29:55.740 --> 00:29:58.483 nearing construction or already in construction. 00:29:59.350 --> 00:30:04.350 So we had to determine whether or not PE could approve 00:30:04.420 --> 00:30:08.330 a modification to plans originally approved by another PE 00:30:08.330 --> 00:30:11.423 if the original PE was not available to do so. 00:30:12.470 --> 00:30:15.710 So all of this led to a significant amount 00:30:15.710 --> 00:30:19.410 of change management that is currently ongoing 00:30:19.410 --> 00:30:22.550 making sure our workforce of not just engineers, 00:30:22.550 --> 00:30:26.500 but also project managers and project planners understand 00:30:26.500 --> 00:30:31.050 the criteria as well as our previous efforts 00:30:31.050 --> 00:30:33.540 in working with the PE Board as 00:30:33.540 --> 00:30:35.410 to which engineering disciplines 00:30:35.410 --> 00:30:38.250 can stamp pipeline engineering plans, 00:30:38.250 --> 00:30:40.240 that's been a challenge. 00:30:40.240 --> 00:30:43.030 We've also had to develop new workflows 00:30:43.030 --> 00:30:45.060 for our various departments to be able 00:30:45.060 --> 00:30:47.510 to integrate the new process 00:30:47.510 --> 00:30:52.360 into the existing planning engineering project life cycles. 00:30:52.360 --> 00:30:54.740 So again, it's not just the engineers 00:30:54.740 --> 00:30:56.300 who have been impacted by this, 00:30:56.300 --> 00:30:59.463 but many on our various project teams as well. 00:31:00.397 --> 00:31:03.560 We've also worked with our human resources department 00:31:03.560 --> 00:31:06.680 to revise some of our engineering job profiles 00:31:06.680 --> 00:31:10.340 to require the PE license or to provide 00:31:10.340 --> 00:31:13.120 for PE stamping responsibilities. 00:31:13.120 --> 00:31:17.120 For example, we recently made it a requirement 00:31:17.120 --> 00:31:20.930 for our senior engineers to possess a PE license. 00:31:20.930 --> 00:31:24.150 Lastly, we've had to develop an entire process 00:31:24.150 --> 00:31:26.610 for tracking and reconciling 00:31:26.610 --> 00:31:28.940 work that's been stamped by a PE 00:31:28.940 --> 00:31:30.900 in order to be able to report 00:31:30.900 --> 00:31:33.490 on the overall progress of our initiative 00:31:33.490 --> 00:31:36.890 and also to ensure the requirements are being met. 00:31:36.890 --> 00:31:37.903 Next slide, please. 00:31:41.440 --> 00:31:45.270 Moving forward, SoCalGas and SDG&E needs recommendations 00:31:45.270 --> 00:31:48.363 for CPUC consideration are as follows, 00:31:49.340 --> 00:31:52.000 first, we would recommend continuing 00:31:52.000 --> 00:31:54.740 with the current PE stamping criteria 00:31:54.740 --> 00:31:57.990 on final transmission facility designs 00:31:57.990 --> 00:32:01.320 and non-standard M&R designs as well 00:32:01.320 --> 00:32:04.120 as require PE review and approval 00:32:04.120 --> 00:32:08.000 for the modification of those plans prior to, 00:32:08.000 --> 00:32:10.670 and during the course of construction. 00:32:10.670 --> 00:32:12.410 That occurs during the RFI 00:32:12.410 --> 00:32:14.763 or request for information process. 00:32:15.850 --> 00:32:19.220 In order to ensure safety over lower risk projects, 00:32:19.220 --> 00:32:22.750 we are also recommending to establish a baseline training 00:32:22.750 --> 00:32:25.800 and knowledge requirement moving forward. 00:32:25.800 --> 00:32:29.160 This means that engineers who are currently unlicensed, 00:32:29.160 --> 00:32:32.590 but are in responsible charge of lower risk routine 00:32:32.590 --> 00:32:36.110 engineering work receive specialized training, 00:32:36.110 --> 00:32:39.355 be able to demonstrate a baseline level of 00:32:39.355 --> 00:32:43.210 and knowledge within their areas of expertise. 00:32:43.210 --> 00:32:46.310 Lastly, we propose to continue leveraging 00:32:46.310 --> 00:32:48.960 a risk-based approach on our focus 00:32:48.960 --> 00:32:52.680 on higher risk complex construction projects, 00:32:52.680 --> 00:32:54.410 that would ensure that accountability 00:32:54.410 --> 00:32:57.380 for safety that we mentioned earlier, 00:32:57.380 --> 00:32:59.530 that design and engineering deliverables 00:32:59.530 --> 00:33:01.873 for complex facility is maintained. 00:33:02.920 --> 00:33:04.410 In conclusion, 00:33:04.410 --> 00:33:06.920 we look forward to continue to dialogue 00:33:06.920 --> 00:33:10.080 with the SPD in their efforts to implement 00:33:10.080 --> 00:33:12.440 the NTSB safety recommendation. 00:33:12.440 --> 00:33:13.940 And I thank you for your time. 00:33:21.490 --> 00:33:22.900 Next slide please. 00:33:22.900 --> 00:33:23.900 And thank you, Todd. 00:33:26.470 --> 00:33:27.413 You're welcome. 00:33:29.610 --> 00:33:32.190 Our third presenter is Kevin Lang 00:33:32.190 --> 00:33:33.363 of Southwest Gas. 00:33:36.720 --> 00:33:38.450 Good afternoon, and thank you. 00:33:38.450 --> 00:33:41.120 We appreciate the opportunity to be a part of this workshop 00:33:41.120 --> 00:33:45.030 today with the CPUC safety policy division to discuss 00:33:45.030 --> 00:33:48.070 the topic of potential implementation of the NTSB's 00:33:48.070 --> 00:33:50.563 recommendation for utility natural gas design. 00:33:51.780 --> 00:33:52.833 Next slide, please. 00:33:57.640 --> 00:33:59.230 In my presentation today, 00:33:59.230 --> 00:34:02.810 we'll cover the company's current PE stamping practices, 00:34:02.810 --> 00:34:04.720 the perceived benefits and challenges 00:34:04.720 --> 00:34:07.277 of implementing the NTSB recommendation 00:34:07.277 --> 00:34:10.720 and our initial recommendations on next steps. 00:34:10.720 --> 00:34:11.883 Next slide please. 00:34:16.800 --> 00:34:18.790 Before I speak on our current practices, 00:34:18.790 --> 00:34:22.210 I wanted to provide a high-level overview of our company. 00:34:22.210 --> 00:34:25.570 Southwest Gas serves approximately 200,000 customers 00:34:25.570 --> 00:34:29.190 in the state of California and operates over 3,200 miles 00:34:29.190 --> 00:34:33.920 of distribution mains, 2,500 miles of distribution services, 00:34:33.920 --> 00:34:35.440 and less than a thousand feet 00:34:35.440 --> 00:34:38.250 of natural gas transmission pipelines in the state. 00:34:38.250 --> 00:34:41.170 The company has no natural gas storage 00:34:41.170 --> 00:34:44.340 or compression facilities in the state of California. 00:34:44.340 --> 00:34:48.920 And over 86% of our current system was installed in 1980 00:34:48.920 --> 00:34:51.585 or later as a result of continued proactive 00:34:51.585 --> 00:34:53.683 infrastructure asset management. 00:34:56.650 --> 00:34:58.670 Southwest Gas currently operates 00:34:58.670 --> 00:35:00.800 under the professional engineering public 00:35:00.800 --> 00:35:03.480 utility exemption for natural gas project 00:35:03.480 --> 00:35:05.910 designs provided in the California Business 00:35:05.910 --> 00:35:09.203 and Professions Code section 6747. 00:35:10.210 --> 00:35:11.440 While I'm not going to discuss 00:35:11.440 --> 00:35:15.123 the history or the purpose of the original public exemption. 00:35:16.050 --> 00:35:18.030 We believe that the exemption recognized 00:35:18.030 --> 00:35:20.990 that natural gas utility work in the state fell under 00:35:20.990 --> 00:35:23.360 the additional jurisdictional authority 00:35:23.360 --> 00:35:26.160 of the Commission for Pipeline Safety Reviews, 00:35:26.160 --> 00:35:30.620 including 49 CFR part 192 at a federal level, 00:35:30.620 --> 00:35:32.947 as well as the California General Order 112. 00:35:34.992 --> 00:35:39.060 Exception rather to this practice at Southwest Gas is when 00:35:39.060 --> 00:35:42.290 an underlying agency requires a professional engineering 00:35:42.290 --> 00:35:45.610 signature or review on certain plans. 00:35:45.610 --> 00:35:49.280 These can include structural bridge or canal crossings, 00:35:49.280 --> 00:35:53.280 some traffic control plans and other specialized design work 00:35:53.280 --> 00:35:55.540 that falls outside of the existing 00:35:55.540 --> 00:35:57.623 state public utilities exemption, 00:35:59.200 --> 00:36:02.240 Southwest Gas utilizes approved design standards 00:36:02.240 --> 00:36:04.900 for all natural gas design work. 00:36:04.900 --> 00:36:07.650 These design standards are developed at a corporate level 00:36:07.650 --> 00:36:09.750 and include considerations for state 00:36:09.750 --> 00:36:12.260 and federal pipeline safety standards, 00:36:12.260 --> 00:36:16.180 as well as industry consensus standards from organizations 00:36:16.180 --> 00:36:19.620 such as the American Society of Mechanical Engineers, 00:36:19.620 --> 00:36:22.800 the American National Standards Institute, 00:36:22.800 --> 00:36:25.560 the American Society for Testing and Materials 00:36:25.560 --> 00:36:27.823 and the American Petroleum Institute. 00:36:29.990 --> 00:36:33.030 Our company design standards set for the minimum level 00:36:33.030 --> 00:36:35.010 of technical engineering requirements 00:36:35.010 --> 00:36:38.460 for the selection of material, material testing, 00:36:38.460 --> 00:36:40.090 construction specifications, 00:36:40.090 --> 00:36:43.360 such as pressure testing type and material welding 00:36:43.360 --> 00:36:47.370 and joining practices and the safe and reliable design 00:36:47.370 --> 00:36:50.083 and operation of our natural gas pipeline system. 00:36:51.690 --> 00:36:52.740 In addition, 00:36:52.740 --> 00:36:56.450 Southwest Gas utilizes a corporate level non-standard design 00:36:56.450 --> 00:37:00.790 review here in Las Vegas for all company-wide large 00:37:00.790 --> 00:37:03.610 and complex projects that are provided, 00:37:03.610 --> 00:37:05.690 or that provide rather an additional level 00:37:05.690 --> 00:37:07.550 of engineering oversight and review 00:37:07.550 --> 00:37:09.183 on these types of designs. 00:37:10.040 --> 00:37:11.070 At Southwest Gas, 00:37:11.070 --> 00:37:12.970 we believe that an engineering degree 00:37:12.970 --> 00:37:15.190 or professional engineering license alone 00:37:15.190 --> 00:37:17.580 does not provide our engineering personnel 00:37:17.580 --> 00:37:20.000 with the necessary competencies and knowledge 00:37:20.000 --> 00:37:22.884 to design natural gas facilities. 00:37:22.884 --> 00:37:23.910 To further supplement 00:37:23.910 --> 00:37:26.750 our engineering personnel's knowledge and competencies 00:37:26.750 --> 00:37:29.350 the company has implemented a formal engineering training 00:37:29.350 --> 00:37:33.970 program that leverages both internal and external training 00:37:33.970 --> 00:37:37.510 materials for company engineers and focuses on key 00:37:37.510 --> 00:37:41.010 competencies required to perform natural gas designs 00:37:41.010 --> 00:37:42.713 of increasing complexity. 00:37:43.910 --> 00:37:46.050 The company also leverages 00:37:46.050 --> 00:37:49.230 a tiered engineering job classification system 00:37:49.230 --> 00:37:52.190 that recognizes key knowledge and competencies 00:37:52.190 --> 00:37:54.200 in advancing engineering design 00:37:54.200 --> 00:37:56.773 of more complex natural gas projects. 00:37:58.630 --> 00:37:59.980 Now as part of the company's 00:37:59.980 --> 00:38:01.980 pipeline safety management system, 00:38:01.980 --> 00:38:04.450 Southwest Gas actively monitors pipeline, 00:38:04.450 --> 00:38:05.340 safety incidents, 00:38:05.340 --> 00:38:08.990 and NTSB pipeline accident investigation across 00:38:08.990 --> 00:38:11.470 the nation to identify lessons learned 00:38:11.470 --> 00:38:14.220 that can be applied to the company's operations 00:38:14.220 --> 00:38:15.810 and minimize the probability 00:38:15.810 --> 00:38:18.403 of a similar accident occurring on our system. 00:38:19.520 --> 00:38:22.758 Southwest Gas closely followed the NiSource incident 00:38:22.758 --> 00:38:26.100 that Angelique spoke of in the opening statement 00:38:26.100 --> 00:38:29.520 that occurred in Merrimack Valley, Massachusetts in 2018, 00:38:29.520 --> 00:38:33.440 as well as the subsequent NTSB accident investigation. 00:38:33.440 --> 00:38:35.827 As part of our review, 00:38:35.827 --> 00:38:39.200 we proactively developed a company position paper 00:38:39.200 --> 00:38:43.130 that supported the intent of the NTSB recommendation. 00:38:43.130 --> 00:38:44.690 This position paper was shared 00:38:44.690 --> 00:38:46.910 with the Commission Safety Enforcement Division, 00:38:46.910 --> 00:38:49.590 as well as the California Board of Professional Engineers 00:38:49.590 --> 00:38:53.793 and Land Surveyors in late 2019 and early 2020. 00:38:54.930 --> 00:38:57.850 I've also included a copy of our position paper 00:38:57.850 --> 00:38:59.980 as well as a brief overview 00:38:59.980 --> 00:39:01.480 of the Merrimack Valley incident 00:39:01.480 --> 00:39:05.200 for reference as an appendix on the last two slides 00:39:05.200 --> 00:39:06.833 of my presentation today. 00:39:08.320 --> 00:39:09.403 Next slide, please. 00:39:15.130 --> 00:39:17.090 As identified in our position paper, 00:39:17.090 --> 00:39:19.710 Southwest Gas believes that implementing the NTSB 00:39:19.710 --> 00:39:22.450 recommendation in California would further elevate 00:39:22.450 --> 00:39:25.630 the standard of care and risk mitigation on complex 00:39:25.630 --> 00:39:28.190 and high risk natural gas projects, 00:39:28.190 --> 00:39:29.680 where those plans are approved 00:39:29.680 --> 00:39:31.830 by an accredited professional 00:39:31.830 --> 00:39:33.720 with the requisite knowledge, skills, 00:39:33.720 --> 00:39:36.830 and experience to provide a comprehensive review 00:39:36.830 --> 00:39:38.803 of certain natural gas design flaws. 00:39:40.082 --> 00:39:41.440 It's also the company's belief 00:39:41.440 --> 00:39:43.100 that a professional engineering license 00:39:43.100 --> 00:39:45.347 alone does not suffice as the engineer 00:39:45.347 --> 00:39:47.590 must have the necessary experience 00:39:47.590 --> 00:39:50.053 and competency in natural gas design. 00:39:51.430 --> 00:39:54.380 Implementing the requirement for professional engineering 00:39:54.380 --> 00:39:57.610 review of certain natural gas designs would further 00:39:57.610 --> 00:40:00.990 demonstrate competencies of the applicable engineering 00:40:00.990 --> 00:40:03.000 principles and industry standards 00:40:03.000 --> 00:40:05.770 such as 49-CFR part 192 00:40:05.770 --> 00:40:08.540 and the California General Order 112 app 00:40:08.540 --> 00:40:09.943 that I mentioned earlier. 00:40:10.930 --> 00:40:14.283 In addition, as part of being a professional engineer, 00:40:15.960 --> 00:40:18.200 there's a recognition and personal commitment 00:40:18.200 --> 00:40:20.970 to a code of ethics and professional standards. 00:40:20.970 --> 00:40:22.120 To further this point, 00:40:22.120 --> 00:40:24.500 the National Society of Professional Engineers 00:40:24.500 --> 00:40:27.270 reinforces this in their code of ethics. 00:40:27.270 --> 00:40:30.580 By stating that engineers are expected to exhibit 00:40:30.580 --> 00:40:33.360 the highest level and highest standards 00:40:33.360 --> 00:40:35.043 of honesty and integrity. 00:40:35.950 --> 00:40:37.230 Engineering has a direct 00:40:37.230 --> 00:40:38.940 and vital impact on the quality 00:40:38.940 --> 00:40:41.090 of life for all people, accordingly, 00:40:41.090 --> 00:40:44.280 the services provided by engineers require honesty, 00:40:44.280 --> 00:40:47.480 impartiality, fairness, and equity, 00:40:47.480 --> 00:40:51.260 and must be dedicated to the protection of the health, 00:40:51.260 --> 00:40:53.633 safety and welfare of the public. 00:40:55.130 --> 00:40:56.450 Engineers must perform 00:40:56.450 --> 00:40:58.350 under a standard of professional behavior 00:40:58.350 --> 00:40:59.530 that requires adherence 00:40:59.530 --> 00:41:01.933 to the highest principles of ethical conduct. 00:41:03.620 --> 00:41:06.510 So now we're gonna cover the potential challenges 00:41:06.510 --> 00:41:08.530 that Southwest Gas sees with implementing 00:41:08.530 --> 00:41:10.650 the NTSB recommendations. 00:41:10.650 --> 00:41:11.823 Next slide, please. 00:41:15.360 --> 00:41:17.640 As a result of the longstanding exemption 00:41:17.640 --> 00:41:20.140 for public utilities in the state of California, 00:41:20.140 --> 00:41:22.540 one challenge for Southwest Gas with implementing 00:41:22.540 --> 00:41:26.040 the NTSB recommendation is change management, 00:41:26.040 --> 00:41:27.720 similar to PG&E, 00:41:27.720 --> 00:41:32.720 and what Semper provided implementing the recommendations 00:41:33.020 --> 00:41:35.800 will require modifications to our work practices, 00:41:35.800 --> 00:41:38.180 specifically because today we fall under 00:41:38.180 --> 00:41:39.560 the existing exemption 00:41:39.560 --> 00:41:43.050 and we don't require professional engineering reviews 00:41:43.050 --> 00:41:44.860 of any of our plans unless 00:41:44.860 --> 00:41:47.860 the underlying agency requires so. 00:41:47.860 --> 00:41:52.410 It also requires or will require reviewing current 00:41:52.410 --> 00:41:55.670 company policies and procedures and our recruitment 00:41:55.670 --> 00:41:58.730 and retention processes for incoming engineers, 00:41:58.730 --> 00:42:00.590 as well as the process and timing 00:42:00.590 --> 00:42:04.190 for existing company engineers to obtain their PD license, 00:42:04.190 --> 00:42:07.243 if they do not already hold one in the state of California. 00:42:09.200 --> 00:42:12.100 Another aspect of change management that Todd touched 00:42:12.100 --> 00:42:15.900 on earlier is identified when a subsequent PE review 00:42:15.900 --> 00:42:17.670 is required for field changes, 00:42:17.670 --> 00:42:20.530 such as the modification of a pipeline running line 00:42:20.530 --> 00:42:22.930 or a change in material specifications 00:42:22.930 --> 00:42:24.980 that occurs during construction. 00:42:24.980 --> 00:42:28.240 Effective change management of an approved project design 00:42:28.240 --> 00:42:31.370 will need to be considered as these discussions continue 00:42:31.370 --> 00:42:33.970 and focus on the scope and applicability 00:42:33.970 --> 00:42:36.480 of which natural gas designs would require 00:42:36.480 --> 00:42:38.040 a professional engineering review 00:42:38.040 --> 00:42:39.433 in the state of California. 00:42:40.980 --> 00:42:43.670 Southwest Gas supports the application of a professional 00:42:43.670 --> 00:42:46.683 engineering review on complex and high-risk design, 00:42:47.590 --> 00:42:48.590 I'll speak to our initial 00:42:48.590 --> 00:42:51.450 recommendations a little bit more in my next slide. 00:42:51.450 --> 00:42:54.400 Future discussions will need to include which types 00:42:54.400 --> 00:42:56.680 of natural gas work will be applicable 00:42:56.680 --> 00:42:58.680 for our professional engineering review. 00:42:59.820 --> 00:43:03.118 As Angelique mentioned in her opening statements 00:43:03.118 --> 00:43:06.070 and maybe elaborating on those a little bit more, 00:43:06.070 --> 00:43:08.970 one of the root causes of the Merrimack Valley incident 00:43:08.970 --> 00:43:11.670 that occurred in Massachusetts occurred 00:43:11.670 --> 00:43:13.520 when the construction crew connected 00:43:13.520 --> 00:43:17.310 the existing low pressure gas distribution system 00:43:17.310 --> 00:43:20.130 to the outlet of a pressure regulator station 00:43:20.130 --> 00:43:22.570 without verifying system pressures 00:43:22.570 --> 00:43:24.370 and without sufficient detail 00:43:24.370 --> 00:43:26.660 in the original engineering plan, 00:43:26.660 --> 00:43:28.800 the signal that a catastrophic failure 00:43:28.800 --> 00:43:30.543 could result from their actions. 00:43:31.410 --> 00:43:33.710 These types of complex projects involving 00:43:33.710 --> 00:43:36.270 the reconfiguration of a pressure system 00:43:36.270 --> 00:43:38.660 or pressure regulating station remain 00:43:38.660 --> 00:43:40.097 the focus of Southwest Gas. 00:43:40.097 --> 00:43:44.410 And we believe the intent of the NTSB recommendation. 00:43:44.410 --> 00:43:46.250 Conversely, we did not believe 00:43:46.250 --> 00:43:48.720 that other more routine and less complex 00:43:48.720 --> 00:43:51.680 natural gas projects such as distribution main 00:43:51.680 --> 00:43:53.680 or service installation meets 00:43:53.680 --> 00:43:55.483 the intent of the recommendation. 00:43:56.840 --> 00:43:59.330 Another challenge with implementing the recommendation 00:43:59.330 --> 00:44:01.900 is that there is not a professional engineering discipline 00:44:01.900 --> 00:44:05.320 specific to the design of natural gas infrastructure, 00:44:05.320 --> 00:44:08.020 as the other speakers have mentioned as well. 00:44:08.020 --> 00:44:10.270 Southwest Gas generally hires engineers 00:44:10.270 --> 00:44:11.340 with a bachelor's degree 00:44:11.340 --> 00:44:13.880 in either mechanical or civil engineering. 00:44:13.880 --> 00:44:16.000 But as I mentioned in my introduction, 00:44:16.000 --> 00:44:19.223 I, myself am a mining and minerals engineer, 00:44:20.870 --> 00:44:24.120 the accreditation Board for engineering and technology, 00:44:24.120 --> 00:44:27.370 or ABET, serves to provide assurances that a college 00:44:27.370 --> 00:44:29.700 or university engineering program meets 00:44:29.700 --> 00:44:31.890 the quality standards of the profession 00:44:31.890 --> 00:44:34.990 for which that program prepares graduates. 00:44:34.990 --> 00:44:38.570 The company ensures that incoming engineers received 00:44:38.570 --> 00:44:40.960 their bachelor's degrees in engineering from an 00:44:40.960 --> 00:44:42.810 ABET accredited university. 00:44:42.810 --> 00:44:45.070 However, ABET recognizes only 00:44:45.070 --> 00:44:47.160 a handful of secondary educational 00:44:47.160 --> 00:44:50.340 institution in the United States with a bachelor 00:44:50.340 --> 00:44:52.560 of science program in what's called 00:44:52.560 --> 00:44:54.253 natural gas engineering. 00:44:55.450 --> 00:44:59.100 Further, the National Council on Examiners for Engineers 00:44:59.100 --> 00:45:02.930 and Surveyors or NCDES is a nonprofit 00:45:02.930 --> 00:45:06.230 organization dedicated to advancing professional licensure 00:45:06.230 --> 00:45:08.220 for engineers and surveyors 00:45:08.220 --> 00:45:10.760 and the organization that developed the standard 00:45:10.760 --> 00:45:12.940 professional engineering exam requirements 00:45:12.940 --> 00:45:14.980 that each state follows. 00:45:14.980 --> 00:45:16.870 This organization does not recognize 00:45:16.870 --> 00:45:19.250 a specific engineering discipline 00:45:19.250 --> 00:45:22.493 for natural gas or public utilities engineering. 00:45:24.070 --> 00:45:26.670 The final challenge that Southwest Gas recognizes 00:45:26.670 --> 00:45:28.450 is regulatory related. 00:45:28.450 --> 00:45:32.260 The existing exemption language contained within 00:45:32.260 --> 00:45:37.050 the California Business and Professions Code is specific 00:45:37.050 --> 00:45:40.810 to professional engineers and governs 00:45:40.810 --> 00:45:43.500 professional engineers and licensing surveyors 00:45:43.500 --> 00:45:46.150 in the state while the natural gas public utilities 00:45:46.150 --> 00:45:47.940 in the state are regulated 00:45:47.940 --> 00:45:50.200 by the Commission's general orders 00:45:50.200 --> 00:45:52.540 and other state regulations 00:45:52.540 --> 00:45:54.930 California Board of Professional Engineers 00:45:54.930 --> 00:45:56.770 and Land Surveyors serves to protect 00:45:56.770 --> 00:45:59.210 the public safety and property 00:45:59.210 --> 00:46:01.290 by promoting standards for competence 00:46:01.290 --> 00:46:03.040 and integrity through licensing 00:46:03.040 --> 00:46:05.600 and regulating of Boards professions, 00:46:05.600 --> 00:46:08.810 including the licensing of professional engineers. 00:46:08.810 --> 00:46:12.740 In contrast, the CPUC serves to empower California 00:46:12.740 --> 00:46:14.410 through access, to safe, clean, 00:46:14.410 --> 00:46:17.203 and affordable utility services and infrastructure. 00:46:18.420 --> 00:46:20.870 Future discussions on the subject of removing 00:46:20.870 --> 00:46:22.980 the existing exemption must consider 00:46:22.980 --> 00:46:25.740 both agency's mission while maintaining 00:46:25.740 --> 00:46:28.230 a clear regulatory delineation between 00:46:28.230 --> 00:46:31.410 the Commission's jurisdictional authority for natural gas, 00:46:31.410 --> 00:46:34.610 safety compliance, and the state Board's oversight 00:46:34.610 --> 00:46:37.123 and licensing of professional engineers. 00:46:38.300 --> 00:46:39.480 Now that we've covered 00:46:39.480 --> 00:46:41.410 the current practices of Southwest Gas, 00:46:41.410 --> 00:46:43.610 as well as the potential benefits and challenges 00:46:43.610 --> 00:46:46.330 of implementing the NTSB recommendation, 00:46:46.330 --> 00:46:48.690 I'd like to briefly discuss our recommendations 00:46:48.690 --> 00:46:50.650 for next steps on this subject. 00:46:50.650 --> 00:46:51.733 Next slide please. 00:46:58.100 --> 00:46:59.760 In the company's position paper, 00:46:59.760 --> 00:47:03.080 we recommend developing proposed criteria that focuses 00:47:03.080 --> 00:47:07.270 on complex and high risk natural gas infrastructure work. 00:47:07.270 --> 00:47:09.670 Southwest Gas identified the following criteria 00:47:09.670 --> 00:47:12.120 for consideration that we believe focuses 00:47:12.120 --> 00:47:13.531 on the root cause 00:47:13.531 --> 00:47:16.260 of the NiSource Merrimack Valley incident 00:47:16.260 --> 00:47:20.190 as identified in NTSB's accident report. 00:47:20.190 --> 00:47:23.170 These criteria include design work that creates 00:47:23.170 --> 00:47:26.480 or reconfigures a pressure regulating station, 00:47:26.480 --> 00:47:29.310 design work for new compressor station, 00:47:29.310 --> 00:47:32.000 design work for new transmission pipeline 00:47:32.000 --> 00:47:34.270 and pressure increase projects for transmission 00:47:34.270 --> 00:47:35.803 and distribution pipeline. 00:47:36.950 --> 00:47:39.200 As Southwest Gas operates in California, 00:47:39.200 --> 00:47:40.940 Arizona, and Nevada. 00:47:40.940 --> 00:47:42.770 We initially reviewed these criteria 00:47:42.770 --> 00:47:45.650 from a company-wide asset perspective. 00:47:45.650 --> 00:47:46.483 For clarity, 00:47:46.483 --> 00:47:49.670 Southwest Gas does not operate any compressor stations 00:47:50.690 --> 00:47:52.750 in California and operates less than 00:47:52.750 --> 00:47:53.870 a thousand feet of natural 00:47:53.870 --> 00:47:56.003 gas transmission assets in the state. 00:47:57.438 --> 00:48:01.010 In addition to further discussions on the proposed criteria, 00:48:01.010 --> 00:48:03.010 the company recommends considering, 00:48:03.010 --> 00:48:04.960 or considerations rather, 00:48:04.960 --> 00:48:08.850 for legislative change between the California Business 00:48:08.850 --> 00:48:10.540 and Professions Code containing 00:48:10.540 --> 00:48:13.480 the existing public utilities exemption, 00:48:13.480 --> 00:48:15.990 and whether or not modifications are required 00:48:15.990 --> 00:48:17.870 to General Order 112 00:48:17.870 --> 00:48:20.840 or other applicable Commission general orders. 00:48:20.840 --> 00:48:24.640 This would outline the specific set of criteria for complex 00:48:24.640 --> 00:48:27.673 and high risk natural gas design that require 00:48:27.673 --> 00:48:30.370 a professional engineer review in the future 00:48:30.370 --> 00:48:32.530 once the existing exemption 00:48:32.530 --> 00:48:34.143 is either removed or modified. 00:48:36.520 --> 00:48:39.290 Southwest Gas is operated in California under 00:48:39.290 --> 00:48:41.500 the existing public utilities exemption 00:48:41.500 --> 00:48:43.770 since the exemption was established, 00:48:43.770 --> 00:48:46.840 while our peers and PG&E and Sempra have voluntarily 00:48:46.840 --> 00:48:49.881 implemented some levels of PE design review, 00:48:49.881 --> 00:48:53.560 the natural gas utilities as a whole would require time 00:48:53.560 --> 00:48:55.260 to effectively implement changes 00:48:55.260 --> 00:48:57.560 and standardized work processes, 00:48:57.560 --> 00:49:01.040 should the exemption be removed or modified. 00:49:01.040 --> 00:49:03.640 And then finally, as mentioned in my previous slides, 00:49:03.640 --> 00:49:05.840 a clear delineation must be maintained 00:49:05.840 --> 00:49:08.430 between the authority of the California Board 00:49:08.430 --> 00:49:10.870 of Professional Engineers and Land Surveyors 00:49:10.870 --> 00:49:13.640 and the Commission, Southwest Gas looks forward 00:49:13.640 --> 00:49:16.870 to continuing discussions with all parties on this matter. 00:49:16.870 --> 00:49:17.703 Next slide. 00:49:22.310 --> 00:49:25.090 That concludes my presentation for this afternoon. 00:49:25.090 --> 00:49:27.770 Southwest Gas really appreciate the opportunity to present 00:49:27.770 --> 00:49:30.700 at this workshop today to discuss the implementation 00:49:30.700 --> 00:49:35.050 of the NTSB recommendation P-19-016 stemming 00:49:35.050 --> 00:49:36.660 from the accident investigation 00:49:36.660 --> 00:49:38.330 into the Merrimack Valley incident 00:49:38.330 --> 00:49:41.250 that occurred in September of 2018. 00:49:41.250 --> 00:49:43.290 We thank the safety policy division 00:49:43.290 --> 00:49:45.490 for coordinating this informal workshop, 00:49:45.490 --> 00:49:48.400 and we look forward to future discussions on the subject. 00:49:48.400 --> 00:49:49.233 Thank you. 00:49:53.250 --> 00:49:54.240 Thank you, Todd. 00:49:54.240 --> 00:49:55.363 Next slide, please. 00:50:00.600 --> 00:50:03.750 Let's take our 15 minutes scheduled break. 00:50:03.750 --> 00:50:05.440 It is now 2:13, 00:50:07.490 --> 00:50:10.063 let's return at 2:32. 00:50:28.720 --> 00:50:30.540 Let's get started. 00:50:30.540 --> 00:50:31.573 Next slide please. 00:50:40.130 --> 00:50:42.720 CPUC staff carefully analyzed 00:50:42.720 --> 00:50:47.177 the NTSC safety recommendation P-19-016, 00:50:49.100 --> 00:50:52.210 it's effects on gas pipeline 00:50:52.210 --> 00:50:55.360 utilities under CPUC jurisdiction 00:50:55.360 --> 00:50:57.073 and its impact on public safety. 00:50:58.162 --> 00:51:01.870 CPUC staff has determined that the implementation 00:51:01.870 --> 00:51:04.060 of the NTSB recommendation 00:51:04.060 --> 00:51:08.070 would be beneficial to gas pipeline safety. 00:51:08.070 --> 00:51:09.347 Next slide please. 00:51:15.920 --> 00:51:18.980 Staff have determined that a licensed professional engineer 00:51:18.980 --> 00:51:22.940 by training has proper technical expertise, 00:51:22.940 --> 00:51:27.260 a duty to safety that overrides all other considerations 00:51:27.260 --> 00:51:31.240 and bound my enforceable ethical and legal duties 00:51:31.240 --> 00:51:35.900 for the protection of public health, safety and welfare. 00:51:35.900 --> 00:51:37.040 In addition, 00:51:37.040 --> 00:51:39.500 having a professional engineering staff 00:51:39.500 --> 00:51:43.193 infill or construction plans will, 00:51:44.120 --> 00:51:45.193 next slide please. 00:51:51.600 --> 00:51:52.930 Next slide, please. 00:51:58.104 --> 00:52:00.923 Reduce risk increase safety. 00:52:03.830 --> 00:52:07.453 I think let's go back to slide 19. 00:52:12.530 --> 00:52:14.220 So will reduce risk, 00:52:14.220 --> 00:52:15.930 increase safety and strengthen 00:52:15.930 --> 00:52:18.940 the engineering management system. 00:52:18.940 --> 00:52:21.670 Certify that all aspects of the project 00:52:21.670 --> 00:52:23.660 are performed under the supervision 00:52:23.660 --> 00:52:26.550 and direction of a qualified engineer 00:52:26.550 --> 00:52:30.270 demonstrate that the construction plans will, 00:52:30.270 --> 00:52:33.510 will have been approved by an accredited professional 00:52:33.510 --> 00:52:35.600 with the requisite skills, 00:52:35.600 --> 00:52:37.670 knowledge and experience to provide 00:52:37.670 --> 00:52:40.200 a comprehensive review. 00:52:40.200 --> 00:52:41.760 Enhance public safety 00:52:41.760 --> 00:52:45.820 with negligible effects on gas utilities, 00:52:45.820 --> 00:52:49.280 ensure that construction plans are traceable, 00:52:49.280 --> 00:52:51.930 verifiable and complete. 00:52:51.930 --> 00:52:53.233 Next slide, please. 00:52:58.640 --> 00:53:03.010 The CPUC has two options for the implementation 00:53:03.010 --> 00:53:07.763 of the NTSB safety recommendation T-19-016 00:53:09.680 --> 00:53:13.533 by revising general order 112-S. 00:53:14.690 --> 00:53:17.700 The first option is a resolution. 00:53:17.700 --> 00:53:20.470 The section option is an order instituting 00:53:20.470 --> 00:53:25.190 a rulemaking commonly referred to as an OIR. 00:53:25.190 --> 00:53:28.870 Both options require Commission approval. 00:53:28.870 --> 00:53:32.220 Additional OIR proceeding information can be found 00:53:32.220 --> 00:53:37.220 on the CPUC proceeding and rule-making web page. 00:53:37.600 --> 00:53:40.833 I included a link to the wEPPage on the slide. 00:53:46.150 --> 00:53:47.283 Next slide please. 00:53:53.010 --> 00:53:54.330 Next steps. 00:53:54.330 --> 00:53:56.270 Staff may make a recommendation on 00:53:56.270 --> 00:54:00.210 how to best implement the NTSB recommendation. 00:54:00.210 --> 00:54:02.890 Staff may hosts an additional workshop. 00:54:02.890 --> 00:54:06.750 If staff post an additional workshop service list 00:54:06.750 --> 00:54:08.463 members will be notified. 00:54:10.560 --> 00:54:11.860 Next slide, please. 00:54:16.980 --> 00:54:20.320 I'm going to open the workshops for public comments. 00:54:20.320 --> 00:54:23.840 Workshop participants may call in utilizing the English 00:54:23.840 --> 00:54:26.240 or Spanish call in phone numbers 00:54:26.240 --> 00:54:28.750 and pass codes shown on the slide. 00:54:28.750 --> 00:54:31.250 In addition to use the line the public 00:54:32.590 --> 00:54:35.680 call in phone numbers the participants 00:54:35.680 --> 00:54:38.440 may email questions and comments utilizing 00:54:38.440 --> 00:54:41.340 my contact information shown on the slide. 00:54:41.340 --> 00:54:44.520 I will leave the site up a bit longer 00:54:44.520 --> 00:54:47.203 so that remote participants can call in. 00:54:51.600 --> 00:54:53.120 If you'd like to make a public comment, 00:54:53.120 --> 00:54:55.190 please press star one, 00:54:55.190 --> 00:54:57.100 unmute your phone and clearly state 00:54:57.100 --> 00:54:59.720 your name for public comment introduction. 00:54:59.720 --> 00:55:01.600 If you'd like to retract your public comment, 00:55:01.600 --> 00:55:03.680 please press star two. 00:55:03.680 --> 00:55:05.490 Again, if you'd like to make a public comment, 00:55:05.490 --> 00:55:08.200 please press star one, unmute your phone 00:55:08.200 --> 00:55:09.420 and clearly state your name 00:55:09.420 --> 00:55:12.133 for public comment introduction, one moment. 00:55:33.520 --> 00:55:36.020 I will leave the phone lines open a minute more 00:55:36.020 --> 00:55:38.103 before moving on with the presentation. 00:55:54.200 --> 00:55:57.163 I currently have no public comments at this time. 00:56:00.560 --> 00:56:03.060 Okay, I'm gonna give it another 30 seconds or so 00:56:03.950 --> 00:56:06.113 until 2:39. 00:56:06.960 --> 00:56:09.760 And then I'll go ahead and reform with the presentation. 00:56:16.530 --> 00:56:18.070 Can you also verify that there 00:56:18.070 --> 00:56:21.790 are no public commenters on the Spanish line? 00:56:21.790 --> 00:56:23.620 I currently have no public comments 00:56:23.620 --> 00:56:25.823 on the Spanish line either. 00:56:27.040 --> 00:56:28.510 Okay, thank you. 00:56:28.510 --> 00:56:30.060 You're welcome. 00:56:30.060 --> 00:56:32.810 Okay, as there are no call in participants, 00:56:32.810 --> 00:56:35.003 I will move forward with the presentation. 00:56:36.120 --> 00:56:37.133 Next slide, please. 00:56:39.560 --> 00:56:41.243 This is an opportunity. 00:56:48.610 --> 00:56:49.480 Thank you. 00:56:49.480 --> 00:56:51.310 This is an opportunity for panelists 00:56:51.310 --> 00:56:53.390 to provide closing comments. 00:56:53.390 --> 00:56:56.130 Each presenter will have two minutes to comment. 00:56:56.130 --> 00:57:00.590 Let's begin in order of presentation starting with PG&E. 00:57:01.550 --> 00:57:05.048 And then SoCalGas and SDF&E, 00:57:05.048 --> 00:57:07.283 and finally with Southwest Gas. 00:57:14.161 --> 00:57:16.730 This is Lily Gharib, I have no further comments. 00:57:16.730 --> 00:57:17.563 Thank you. 00:57:22.387 --> 00:57:23.355 Hi this is Todd Dusteel, 00:57:23.355 --> 00:57:24.705 I have no further comments. 00:57:30.710 --> 00:57:31.543 Afternoon again, 00:57:31.543 --> 00:57:33.100 this is Kevin Lang at Southwest Gas. 00:57:33.100 --> 00:57:37.053 I have no further comments at this juncture, thank you. 00:57:37.053 --> 00:57:38.540 Thank you, panelists, 00:57:38.540 --> 00:57:41.760 I would also like to thank the CPUCs information 00:57:41.760 --> 00:57:44.470 technology support team for their assistance, 00:57:44.470 --> 00:57:47.270 as well as my safety policy division, 00:57:47.270 --> 00:57:50.440 safety enforcement division, legal office, 00:57:50.440 --> 00:57:52.520 and use and outreach office colleagues 00:57:52.520 --> 00:57:54.753 for their assistance with this workshop. 00:57:55.600 --> 00:57:56.663 Next slide, please. 00:58:00.056 --> 00:58:03.040 Again, thank you for your participation, 00:58:03.040 --> 00:58:05.340 for additional information regarding 00:58:05.340 --> 00:58:08.220 the CPUC's future implementation 00:58:08.220 --> 00:58:09.850 of the National Transportation 00:58:09.850 --> 00:58:14.377 Safety Board safety recommendation P-19-016, 00:58:16.475 --> 00:58:20.230 please contact me via email at 00:58:20.230 --> 00:58:25.230 angelique.juarez@cpuc.ca.gov, 00:58:26.870 --> 00:58:30.700 and my contact information is also on the slide 00:58:30.700 --> 00:58:32.830 that's on the screen right now. 00:58:32.830 --> 00:58:36.343 This concludes the informal workshop. 00:58:53.650 --> 00:58:55.370 Excuse me, it's Dexter, operator. 00:58:55.370 --> 00:58:57.360 You're currently in post-conference. 00:58:57.360 --> 00:58:59.020 You guys can stay as long as you like. 00:58:59.020 --> 00:59:00.740 Thank you so much for using our services 00:59:00.740 --> 00:59:02.660 and have a great night. 00:59:02.660 --> 00:59:03.797 Stay safe. 00:59:03.797 --> 00:59:05.953 Thank you, you too. Thank you, Dexter.