Risk Assessment and Safety Advisory (RASA) Section
The Mission of the Safety and Enforcement Division’s Risk Assessment and Safety Advisory Section is to promote safety by improving the ways that regulated entities integrate risk analysis and risk management into their operational, planning and other decision-making processes.
The section primarily provides advisory support for Commission decision making.
The section’s professional engineers and analysts apply technical and regulatory policy expertise to a wide variety of Commission proceedings and initiatives in order to:
- Identify, analyze, mitigate present and potential risks in the natural gas & electric systems;
- Promote risk-informed decision making in Commission proceedings, particularly General Rate Cases;
- Identify safety concerns and issues that should be considered in new applications, rulemakings or investigations and provide recommendations to Commission decision makers;
- Suggest improvements in audits and inspections performed by SED;
- Coordinate with other Commission divisions and/or State agencies to promote safety in regulated utility operations and research expenditures;
- Identify and promote new approaches to Risk Assessment and energy policy development through whitepapers, reports and presentations at relevant industry conferences.
In 2015 and 2016, Risk Assessment staff led or was primary SED advisory support for:
- Implementation of the utility Safety Model Assessment Proceedings (S-MAP), as established by the Risk Informed Decisionmaking in General Rate Case Rulemaking decision (D.14-12-025);
- Rulemaking to Reduce Natural Gas Leakage consistent with SB 1371;
- Hosting five sets of workshops on S-MAP issues; three on Methane Emissions Reductions and one on Safety Considerations for Energy Storage projects (with Energy Division);
- Providing safety & risk assessment in four electric and natural gas rate cases.
- Issued report on Safety & Risk Aspects of PG&E's 2017-19 General Rate Case;
- Issued report on Safety & Risk Aspects of Sempra Utilities’ 2014 General Rate Case;
- Issued whitepaper on Best Practices for Methane Leak Abatement;
- Issued report on As Low As Reasonably Practicable (ALARP) concept for cost/benefit analysis;
- Established and led technical working groups on Risk Assessment lexicon development, energy storage safety, and methane reduction best practices;
- Established and led a working group to develop performance metrics and discuss data collection for the S-MAP proceeding;
- Identified and communicated to appropriate Commission personnel safety concerns or considerations in over 25 new regulatory proceedings, including new facility construction, distribution resource planning, wildfire and drought cost recovery, development of the State’s Fire Map 2, and construction of EV charging stations;
- Risk Assessment staff also worked collaboratively with other SED sections, Energy Division and Policy & Planning Division to provide technical analysis and subject matter expertise. Risk staff contributed to Electric Safety & Reliability Branch whitepaper on Physical Security of Utility Facilities. Risk staff also contributed to the Cybersecurity action plan proposal as part of 2015 implementation of CPUC’s Safety Management System and Action Plan.
Major Proceedings and Activities in the Risk Assessment Section
- Safety Model Assessment Proceeding (A.15-05-002, et al) (President Picker/ALJ Kersten) (Advisory): In compliance with D.14-12-025, the four major investor-owned utilities on May 1, 2015, filed applications to initiate a new Safety Model Assessment Proceeding (S-MAP). RASA provides advisory support, conducts workshops and facilitates working groups. Staff conducted initial review of the applications, and provided a preliminary assessment of how well the applications conform to Commission guidance in D.14-12-025. Staff worked closely with Assigned Commissioner and ALJ on drafting the Scoping Memo and case management plan. Staff organized and facilitated five workshops on S-MAP development and also issued a whitepaper on the “As Low As Reasonably Practicable” (ALARP) concept for safety cost/benefit analysis. The S-MAP proposed decision was adopted by Commission vote on August 18, 2016. 2016 Actions: RASA team is coordinating with the Sempra utilities to make sure that the first-ever pre-GRC presentation of the utilities’ safety budgets and mitigations is on track to be completed on time and with high quality. It will set the standard for future RAMP filings by the other utilities. Sempra’s top 28 risks will be covered, along with mitigations, alternatives that were considered, a discussion of safety culture, and costs.
- Gas Leak Abatement OIR (R.15-01-008) (President Picker/ALJ Kersten) (Advisory): To carry out the intent of Senate Bill 1371 (Leno, 2014), the Commission initiated this rulemaking to adopt rules and procedures for commission-regulated pipeline facilities to minimize natural gas leaks to reduce hazards and to advance greenhouse gas reduction goals. Gas corporations filed reports by May 15, 2015, on leaks, leak management practices and “best estimates” of gas losses. 2016 Actions: The working group prepared a report on best practices recommendations in early 2016. Revised templates were issued for use in annual reports beginning in May 2016. The Commission may set targets or other policies for maximizing cost-effective methane reduction as part of this proceeding.
- Electric Storage Procurement (R.15-03-011) (Commissioner Peterman/ALJs Halligan, Cooke, and DeAngelis) (Advisory): The Commission in March 2015 launched a new Rulemaking to meet the requirement of AB 2514 (Skinner, 2010) to revisit every three years its adopted policies and targets for load serving entities to procure energy storage. Among the issues addressed in Track One of the rulemaking was safety practices for permitting, interconnection and operation of grid-connected energy storage systems. The Risk Assessment section conducted a workshop on safety risks for energy storage systems co-located at utility substations or at electric generation facilities, and made recommendations for what safety considerations SED should take into account during substation and generation facility inspections. 2016 Actions: Commission Decision 16-01-032 on Track One of the proceeding was issued on January 28, 2016, and later adopted. It directs SED to establish a technical group to consider appropriate safety-related issues for facility inspections of grid-connected storage operated by utilities. A working group has deliberated on those issues, and SED is finalizing inspection guidelines for its own inspectors who may visit utility-scale, grid-connected energy storage sites in the future as California’s utilities procure 1,325 MW of storage by 2020 (to be operational by 2024). (For presentations from a workshop held jointly with the Commission's Energy Division and covering safety of energy storage, please follow this link and then scroll down: Energy Storage Workshop)
- Investigation into Safety Culture of Pacific Gas and Electric Company and PG&E Corp. (I.15-08-019) (President Picker/ALJ Bushey) (Advisory): On August 27, the Commission launched a new investigation into PG&E’s safety culture and management practices. Risk Section is primary advisory support and has been responsible for hiring and overseeing an expert witness/consultant to produce an independent report. 2016 Actions: Risk Section completed the selection process for an expert witness/consultant for this investigation, a contract has been finalized, and the expert witness/consultant has undertaken many interviews, field visits, and other aspects of the investigation. Staff continues to work closely with the consultant in conducting its investigation and preparing the report.
- Fire Map 2 proceeding (R.16-05-006) (Commissioner Florio/ALJ Kenney) (Advisory): RASA staff hosted workshops related to the development of a workplan for making Fire Map 2, which will show the areas of the state where more stringent regulations may apply to power lines, poles, and other technologies that could ignite a fire.
- SCE General Rate Case (A.13-11-003) (Commissioner Peterman/ALJs Dudney) (Advisory): Risk Assessment team and Electric Safety and Reliability Branch reviewed the Southern California Edison (SCE) GRC Application. SED issued an advisory report on risk and safety issues in August 2014. A final decision was issued November 5 2015.
- In order to help close out two major proceedings (PG&E 2014 GRC and Risk-Informed Ratemaking OIR) RASA staff analyzed over 50 consultants’ report recommendations to determine whether they were being addressed in related proceedings or if further action was required. In November, 2015, this analysis was incorporated into an Assigned Commissioner’s ruling in R.13-11-006 deferring residual matters into proceedings listed above (esp. PG&E 2017 GRC, SMAP and Leak Abatement).
The Risk Assessment Section recently held the following public workshops:
Fire Map 2 workshop, August 18, 2016: Presentation from SDG&E on a Proposed Workplan for Developing the Map
Fire Map 2 Workshop, August 11, 2016: Status Check on Progress Toward Developing a Workplan for Fire Map 2
Workshop on SED's Risk Assessment Report on the Pacific Gas & Electric 2017 General Rate Case (GRC) (A.15-09-001), March 25, 2016, presentations:
- SED: Overview and electric distribution example
- SED: S-MAP and RAMP overview
- PG&E: The Risk Informed Budget Allocation (RIBA)
- SED: Gas distribution example
- SED: Energy supply example
- SED: Senate bill 900 -- safety incidents
- SED: Next steps