PG&E Class Code Waiver
CFR 49 Section 192.5 specifies four class locations based on population density. Safety requirements for pipelines increase as the class code increases. Section 192.611 requires that when a change in population increases the class code, an existing pipeline must meet the new safety requirements. This may require reducing the maximum operating pressure or replacing sections of the pipeline.
The city of Tracy is planning to build an outdoor Youth Sports Facility (sports facility) which will change the class location from Class 1 to Class 3 after it is completed. PG&E has two gas transmission pipelines in the area. The newer of the two pipelines does not meet the requirements for Class 3 while the older pipeline does. In a test case for a new DOT policy, PG&E applied for a waiver from the Class 3 requirements for the newer pipeline. In exchange for the waiver, PG&E offered to perform risk reduction activities on both pipelines. Following guidelines established by DOT, USRB studied the PG&E proposal and recommended that the Commission approve it. The Commission did so in Resolution SU-58 adopted December 16, 2004. DOT subsequently also approved the waiver. USRB will monitor PG&E's compliance with the terms of the waiver during construction of the Youth Sports Facility
Code of Federal Regulations, Title 49, Part 192, Subpart N requires that pipeline operators have a program to insure that only qualified persons perform critical work on gas pipelines. Subpart N was developed through an industry consensus process over a period of more than ten years. The Pipeline Safety Improvement Act of 2002 amended the pipeline safety law by adding section 49 USC 60131. Section 60131 provides standards and criteria for operator qualification (OQ) programs, directs The Pipeline and Hazardous Materials Safety Administration (PHMSA) to ensure their inclusion in industry programs, and directs PHMSA to report to Congress on the status and results of operator qualification progress. The American Society of Mechanical Engineers sponsors a Technical Committee (B31Q) to continue development of standards for qualification. USRB is represented on this committee. USRB has completed its first round of audits of the OQ programs of all major utilities.
To enforce the OQ program for small operators, USRB conducts combined OQ inspections and training during regularly scheduled safety inspections which occur on a five-year cycle. In addition, USRB invites small operators to annual seminars where OQ is one of the subjects covered. Finally, USRB has audited the OQ programs of contractors who help many small operators meet federal requirements.
Pipeline Integrity Management
The Pipeline Safety Improvement Act of 2002 also directed PHMSA to establish a Pipeline Integrity Management Program (IMP). In response PHMSA issued Subpart "O" containing sections 192.903 to 192.949 on May 26, 2004. This Subpart establishes a risk-based assessment program that requires operators of gas transmission pipelines to (1) identify all the segments located in "high consequence areas" (HCAs) - areas adjacent to significant population or frequently used areas, such as parks; (2) develop an IMP to reduce the risks to the public in such areas; (3) undertake baseline integrity assessments (inspections) at all segments located in the HCAs within 10 years; (4) develop a process for repairing any anomalies found in these inspections; and (5) reassess these segments every seven years thereafter to verify continued pipeline integrity. One-half of the baseline assessments must be done by December 2007 and the remainder by December 2012. The risks to be assessed include corrosion, welding defects and failures, third-party damage, land movement, and improper operation. USRB has incorporated inspection of utility IMP programs in its safety audits. The Branch is preparing for the next phase of the program which will extend to distribution pipelines.
General Order 112-E Rule 122.2 d requires utilities to submit quarterly reports to the Commission of all gas leaks that involved loss of gas or property damage in excess of $1,000, fire, explosion, or underground dig-ins. USRB has been entering this data into a database for about six years and it now exceeds 80 thousand records. By analyzing this data, USRB hopes to find ways to reduce losses due to excavation, the single largest cause of gas incidents. USRB is beginning an effort to refine the available data and to add detail to the data collected that will make it possible to better identify the causes of dig-ins