WEBVTT
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The feed
for this streaming event.
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Thank you, and welcome
to The Future Implementation
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of the National Transportation
Board Safety Recommendation
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P-19-016 Informal Workshop.
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My name is Angelique Juarez,
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I am an analyst in the
Safety Policy Division
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Safety Culture and Governance Section.
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I will be hosting this workshop.
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Our workshop presenters
include representatives from PG&E.
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SoCalGas, SDG&E, and Southwest Gas.
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Next slide please.
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This workshop will
be presented in English
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with the option of Spanish subtitles.
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Workshop participants have
the opportunity to make comments
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and ask questions during
the public comment period,
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utilizing English and Spanish call in
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phone numbers shown on the slide.
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This workshop
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is being recorded and
archived for future viewing.
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Next slide please.
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Please ensure that you know your safe,
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previous slide please.
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Please ensure that you
know your safety routes
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and exits in case of an emergency,
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this is a three hour workshop
with two 15 minute breaks,
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adjust your workstation to ensure
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your ergonomic needs are met
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and please comply
with all federal, state
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and local jurisdiction
COVID-19 requirements.
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Next slide, please.
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Here is the workshop schedule
and topics to be presented.
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I'll leave this slide up
for a few more seconds.
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Next slide please.
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This is an opportunity
for panelists introductions.
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Let's start the introductions beginning
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with the PG&E presenter
and then continuing
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with the SoCalGas and SDG&E presenter,
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and finally, the
Southwest Gas presenter.
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Good afternoon.
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My name is Lily Gharib.
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I will be presenting on behalf of PG&E.
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I am an engineering
supervisor in our gas standards
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engineering department,
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which is the part of our
regulatory compliance organization.
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Thank you.
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Good afternoon, everyone.
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My name is Todd Dusteel.
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I have been with SoCalGas for 24 years.
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I'm currently a team
lead in engineering design
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department supporting
both SoCalGas and SDG&E,
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I'll be presenting on behalf
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of both utilities this afternoon.
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And good afternoon,
my name is Kevin Lang.
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I'm the director of engineering services
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for Southwest Gas based
out of Las Vegas, Nevada.
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My role at Southwest Gas
includes providing technical
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direction and support to
the company's five operating
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divisions in California,
Nevada and Arizona.
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In addition to the company's
transmission pipeline company
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Great Basin in Northern Nevada.
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I have a bachelor's degree in mining
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and minerals engineering
from Virginia Tech,
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and I'm a registered professional
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civil engineer in the state of Nevada.
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I have over 18 years of
experience in natural gas facility,
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design and construction practices
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and 25 years of general
engineering experience.
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Thank you panelists
for the introduction.
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Next slide please.
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So the purpose of this informal workshop
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is not related to a proceeding.
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No decisions will be
made at today's workshop.
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The purpose of this informal
workshop is to discuss
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the NTSBs recommendation 19-P-016
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and its impact on CPUC
jurisdictional natural gas pipelines.
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This workshop will be an opportunity
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for PG&E, SoCalGas, SDG&E
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and Southwest Gas representatives
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to share their current companies
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professional engineering approval
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and standards and practices.
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Topics to be discussed
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at this informal workshop include an
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overview of the MTSBs
safety recommendations
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and an overview of the utility companies
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PE approval and staffing practices
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for natural gas projects.
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Next slide, please.
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The presenters will
also discuss the benefits
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of implementing the NTSB
safety recommendations,
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challenges of implementing the
NTSB safety recommendations,
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utility presenter recommendations,
the CPUC's options
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for implementing the NTSB
safety recommendations
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as the next step.
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This informal workshop
is also an opportunity
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for parties and participants
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to ask questions and share comments.
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Next slide, please.
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Now let's begin with a background.
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On September 13th, 2018,
about 4:00 p.m. local time,
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a series of structural fires
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and explosions occurred
after high pressure
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natural gas was released
into a low pressure natural gas
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distribution system
in the Northeast region
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of Merrimack Valley in the
Commonwealth of Massachusetts
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resulting in approximately
10,894 customers
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impacted by natural gas
distribution shut down,
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one death, 22 hospitalizations,
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damage to 131 structures,
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including five homes with
most of the damage occurring
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from fires ignited by
natural gas fuel appliances.
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Several of these homes were destroyed
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by natural gas fuel explosion.
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The Merrimack Valley
fire was also responsible
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for electric utility shut down,
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freight and passenger Railroad
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operations being suspended
and local road closures.
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Next slide please.
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The NTSB performed
an extensive investigation
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of the Merrimack Valley fire
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and detailed its findings in
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the pipeline accident report
titled over pressurization
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of natural gas distribution system,
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explosions and fires in
Merrimack Valley, Massachusetts
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September 13th, 2018.
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In the reports factual information
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subsection 1.9 professional
engineering and review
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and approval table
PE industrial exemption
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for infrastructure project practices,
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California is identified as
a state with professional
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engineer approval exemption
requiring a statutory amendment.
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Next slide please.
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Thank you.
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Additionally, in the
NTSB's report section
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5.1 new recommendations,
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the NTSB recommends that California
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and several other states
remove the exemption
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so that all future natural gas
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infrastructure projects
require licensed professional
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engineer approval and stamping.
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Next slide, please.
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The NTSB submitted a letter to 31 states
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that allow exemptions to professional
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engineer approval and staffing
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for natural gas infrastructure projects.
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On October 24th, 2019,
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the NTSC's then chairman
Robert L. Sumwalt III
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submitted to California's
Governor Gavin Newsome
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a letter with information
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about the NTSB's September
24th, 2019 report over
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pressurization of natural
gas distribution system
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explosion and fire in Merrimack
Valley, Massachusetts.
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In his letter to Gavin Newsome,
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Mr. Sumwalt recommended
that California remove exemptions
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to professional engineer approval
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and stamping for natural gas
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infrastructure projects so
that all future natural gas
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infrastructure projects
require licensed professional
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engineer approval and stamping.
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The NTSB is vitally interested
in these recommendations
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as they are designed to
prevent accidents and save lives.
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Next slide please.
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Let's go back one more
slide, my apologies.
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The CPUC is the California
lead state regulatory agency
00:10:36.150 --> 00:10:39.270
or gas pipeline safety and is certified
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to inspect and regulate intrastate
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pipeline safety pursuant to the state
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certification program of the pipeline
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and hazardous material
safety administration
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also known PHMSA.
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On March 8th, 2021,
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the CPUC staff responded
to Chairman Sumwalt's letter
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that staff is planning
to include language
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for future natural gas
infrastructure projects
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to require licensed professional
engineering approval
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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
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addresses the design,
construction, testing,
00:11:27.510 --> 00:11:32.440
maintenance and operation
of natural gas gathering
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transmission and
distribution piping system.
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This background information brings us up
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to date to this informal workshop.
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Next slide please.
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Our first utility presenter
is Lily Gharib of PG&E.
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Thank you, Angelique.
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Next slide please.
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Next slide please.
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Okay. Good afternoon, everyone.
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So I will be speaking to the items here,
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which Angelique had highlighted,
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but just to discuss one more time,
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we will be discussing our
company's current PE approval
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and stamping requirements,
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benefits of implementing
the NTSB recommendation,
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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.
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For our company standards,
00:12:44.150 --> 00:12:47.750
PE review and stamping
of certain gas design work
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has been required at
PG&E for nearly 40 years.
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Prior to that,
00:12:53.260 --> 00:12:56.190
our engineering design
standards dating back
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to the 1960s do make note
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of certain engineering
management approvals.
00:13:02.180 --> 00:13:05.390
However, the explicit PE requirement
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was formerly formally issued
00:13:07.860 --> 00:13:11.253
in company-wide standards as of 1984.
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In this slide, we are
providing a revision history
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to show in which company standard
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this requirement has been
memorialized over the years.
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The fundamental requirement
has remained consistent
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and what is reflected in our
current gas design standards,
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A-36 is as follows.
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The current requirements
states that new construction
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drawings for gas
facilities to operate greater
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than 60 PSIG are to be reviewed
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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
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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.
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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.