CC - Item 7A - Possible Support for California Public Utilities Commission Following SB 1371 r E M M .
4. ! lf. � ROSEMEAD CITY COUNCIL
STAFF REPORT
TO: THE HONORABLE MAYOR AND CITY COUNCIL
FROM: BILL R. MANIS, CITY MANAGER frj'-rN'
DATE: SEPTEMBER 13, 2016
SUBJECT: POSSIBLE SUPPORT FOR CALIFORNIA PUBLIC UTILITIES
COMMISSION STAFF RECOMMENDATIONS FOLLOWING SB 1371
(REQUESTED BY COUNCILMEMBER CLARK)
SUMMARY
This item is presented to the City Council at the request of Councilmember Clark. Please see a
letter of support from the Blue Green Alliance (Attachment A), a proposed draft letter of
from the City (Attachment 13), and the Natural Gas Leakage Abatement Summary of Best
Practices.
STAFF RECOMMENDATION
Discuss and provide direction to staff.
FISCAL IMPACT -None
PUBLIC NOTICE PROCESS
This item has been noticed through the regular agenda notification process.
Prepared by:
Air.
Marc Donohue.City Clerk
Attachment A: Letter of Support—Blue Green Alliance
Attachment 13: Draft Letter of Support—City of Rosemead
Attachment C: Natural Gas Leakage Abatement Summary of Best Practices
ITEM NUMBER: 7A
BLUECIREEN
A L L I A N C E
March 31,2016
Michael Picker, President
California Public Unities Commission
505 Van Ness Avenue
San Francisco,CA 94102
Re: Staff Recommendations on Natural Gas Leakage Abatement following SB 1371(Leno,2014)
Dear President Picker:
On behalf of the above organizations,we write to thank you for your leadership on climate change and .I
to express our support for the staff recommendations on the California Public Utilities Commission
(CPUC) rulemaking(R. 15-01-008)on natural gas leakage abatement as discussed in 561371(Leno,
2014).
The CPUC staff recommendations call for better training programs,more trained,experienced personnel
in the field,better leak detection processes,and a defined timeline to fix known leaks. These
recommendations, if adopted and implemented as proposed,will reduce the risk of damage to the
environment and workplaces from explosions,air pollution and other climate change impacts while
simultaneously employing California workers.
Natural gas is an integral part of California's energy portfolio and economy—over 12 million households
in the state heat their homes,food and water with it—and it accounts for more than 40 percent of the
state's electricity production.Statewide,utilities maintain more than 150,000 miles of natural gas
distribution pipe serving homes,apartments and businesses.
Unfortunately,as Aliso Canyon demonstrated,It is more critical than ever that we take action to protect
Californians from the dangers of natural gas pollution.
In 2014,the Governor signed the Gas Pipeline Leak Repair and Emissions Reduction Act(513 1371)to 'I
require all public utilities and storage providers In California to use the most advanced technology to
find leaks,and require them to repair the leaks they find.The CPUC was then tasked to determine and
to implement best practices for leak identification, repair,and avoidance,as well as better accounting of
the climate change impact of natural gas leaks in the distribution systems throughout our cities and
communities.
On March 24,the CPUC issued staff recommendations on best practices for natural gas leak detection
and repair. These recommendations represent a new way of doing things to include changes to policies
and practices, better training programs,new job classifications and staffing levels,and better leak
detection processes,and a defined timeline to fix known leaks.
These rules are sorely needed. For example,in 2014 the Southern California Gas Company reported a
backlog in repairing of over 9,400 leaks,of which more than 1,000 may wait a year or longer to be fixed.
• Furthermore,more than 2.4 million(out of 5.9 million) natural gas services—which connect buildings to
gas mains—have been identified as leak-prone.
While the majority of these leaks may not pose an immediate threat to life and property,significant
climate change and air pollution impacts of methane leaks natural gas systems are increasingly coming
Into focus. Methane—the primary component of natural gas—is a significant contributor to climate
change.The uncontrolled emissions from leaky pipes and components are estimated to be the
equivalent of millions of cars on the road.Worse yet,many of these leaks are in proximity to homes,
schools,hospitals,and other public facilities where they may develop into larger leaks that can pose
more of an immediate hazard.
We applaud CPUC's draft recommendations to minimize methane emissions from the natural gas
transmission and distribution system. These recommendations are a significant and necessary step to
reducing,finding and fixing natural gas leaks.
Thank you again for your leadership on climate change. We welcome you in joining us to see that these
recommendations are adopted by the CPUC and implemented by the utilities.
Sincerely,
California BlueGreen Nliance
C:Elizaveta Malashenko, Director of Safety and Enforcement,California Public Utilities Commission
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September 13, 2016
Michael Picker, President
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
RE: Staff Recommendations on Natural Gas Leakage Abatement following SB 1371 (Leno)
Dear President Picker:
We write to thank you for your leadership on climate change and to express our support for the
staff recommendations on the California Public Utilities Commission (CPUC) rulemaking on
natural gas leakage abatement as discussed in SB 1371.
The CPUC staff recommendations call for better training programs, more trained, experience
personnel in the field, better leak detection processes, and a defined timeline to fix known leaks.
These recommendations, if adopted and implemented as proposed, will reduce the risk of
damage to the environment and workplaces from explosions, air pollution and other climate
change impacts while simultaneously employing California workers.
Natural gas is an integral part of California's energy portfolio and economy — over 12 million
households in the state heat their homes, food and water with it—and it accounts for more than
40 percent of the state's electricity production. Statewide, utilities maintain more than 150,000
miles of natural gas distribution pipe serving homes, apartments and businesses.
Unfortunately, as Aliso Canyon demonstrated, it is more critical than ever that we take action to
protect Californians from the dangers of natural gas pollution.
In 2014, the Governor signed the Gas Pipeline Leak Repair and Emissions Reduction Act (SB
1371) to require all public utilities and storage providers in California to use the most advanced
technology to find leaks, and require them to repair the leaks they find. The CPUC was then
tasked to determine and to implement best practices for leak identification, repair, and avoidance,
as well as better accounting of the climate change impact of natural gas leaks in the distribution
systems throughout our cities and communities.
On March 24, the CPUC issued staff recommendations on best practices for natural gas leak
detection and repair. These recommendations represent a new way of doing things to include
changes to policies and practices, better training programs, new job classifications and staffing
levels. and better leak detection processes, and a defined timeline to fix known leaks.
These rules are sorely needed. For example, in 2014 the Southern California Gas Company
reported a backlog in repairing of over 9,400 leaks, of which more than 1,000 may wait a year or
longer to be fixed. Furthermore, more than 2.4 million (out of 5.9 million) natural gas services —
which connect buildings to gas mains—have been identified as leak-prone.
While the majority of these leaks may not pose an immediate threat to life and property,
significant climate change and air pollution impacts of methane leaks natural gas systems are
increasingly coming into focus. Methane —the primary component of natural gas- is a significant
contributor to climate change. The uncontrolled emissions from leaky pipes and components are
estimated to be the equivalent of millions of cars on the road. Worse yet, many of these leaks are
in proximity to homes, schools,hospitals. and other public facilities where they may develop into
larger leaks that can pose more of an immediate hazard.
We applaud CPUC's draft recommendations to minimize methane emissions from the natural
gas transmission and distribution system. These recommendations are a significant and necessary
step to reducing,finding, and fixing natural gas leaks.
Thank you again for your leadership on climate change. We welcome you in joining us to see
that these recommendations are adopted by the CPUC and implemented by the utilities.
Sincerely,
Sandra Armenia
Mayor
CC: Elizaveta Malashenko,Director of Safety and Enforcement, California Public Utilities
Commission
California Public Utilities Commission and
California Air Resources Board
Natural Gas Leakage Abatement
Summary of Best Practices Working Group
Activities
And Staff Recommendations
In partial fulfillment of
Senate Bill 1371 (Leno, 2014) &
Order Instituting Rulemaking (OIR) 15-01 -008
Elizabeth Scheehle, CARE
Winardi Setiawan, CARB
Charles Magee, CPUC
March 2016
Table of Contents
INTRODUCTION 2
IDENTIFICATION OF BEST PRACTICES 3
RECOMMENDATIONS 9
ATTACHMENTS 22
DISCLAIMER
This report was prepared by California Public Utilities Commission (CPUC) and
California Air Resources Board staff. It does not necessarily represent the views of the
CPUC, its Commissioners, the CARB, or the State of California. The CPUC, CARB, the
State of California, its employees, contractors, and subcontractors make no warrant,
expressed or implied, and assume no legal liability for the information in this report.
This report has not been approved or disapproved by the CPUC or the CARB, nor have
the agencies passed upon the accuracy or adequacy of the information in this report.
Summary of Best Practices Working Group Activities- R.1S-01-008 Page 1 of 22
INTRODUCTION
Methane is a greenhouse gas (GHG) 72 times more potent than carbon dioxide
on a 20 year timeframe. Researchers have identified the oil and gas industry as a
significant source of methane emissions. In California, Senate Bill (SB) 1371 (Leno, 2014)
was signed by Governor Brown on September 21, 2014, to reduce methane emissions
from leaks in the gas transmission, distribution and storage facilities in California. SB
1371 adds Article 3 (commencing with Section 975) to Chapter 4.5 of Part 1 of Division 1
of the Public Utilities Code. Included in Article 3 is Section 975. (e) (4) which states, in
part, that the Commission shall:
"(4) Establish and require the use of best practices for leak surveys, patrols, leak
survey technology, leak prevention, and leak reduction. The commission shall
consider in the development of best practices the quality of materials and
equipment."
In addition, SB 1371 states, "The bill would require the commission to commence
a proceeding by January 15, 2015, to adopt those rules and procedures, in consultation
with the State Air Resources Board'."
In January 2015, the California Public Utilities Commission (CPUC or
Commission) launched Rulemaking (R.) 15-01-008 in response to SB 1371 to investigate
new technologies in gas leak detection in the transmission, distribution and storage
process, specifically optimizing for methane reductions.' The July 24, 2015, Scoping
Memo and Assigned Commissioner Ruling (Scoping Memo) for this rulemaking states,
' This is a reference to the California State Air Resources Board (CARB).
2"Order Instituting Rulemaking to Adopt Rules and Procedures Governing
Commission-Regulated Natural Gas Pipelines and Facilities to Reduce Natural Gas
Leakage Consistent with Senate Bill 1371," issued January 22,2015.
Summary of Best Practices Working Group Activities- R.15-01-008 Page 2 of 22
"CARB will work with the Commission to determine the best management practices
and other mitigation technologies for achieving GHG reductions. CARB will
collaborate with the Commission and provide GHG expertise throughout the
proceeding. The two agencies will ensure, on ongoing bases, that both the public safety
and the State's climate change goals will be achieved."'
This report describes the process and results of CPUC/CARB exploration of best
practices (BPs) for the reduction of methane leaks and emissions from utility gas
systems. Under the direction of the Assigned Administrative Law Judge and in
coordination with the Assigned Commissioner's Office, this process included several
staff-conducted public workshops and the convening of a technical working group
open to parties to the rulemaking.
Disclaimer: Despite the effort to be inclusive and collaborative during the
working group process, this document and its recommendations are not to be
considered a consensus report. Instead it represents CPUC/CARB staff proposals for
adoption, and will be subject to comments by Parties to the rulemaking before being
forwarded to the CPUC for consideration.
IDENTIFICATION OF BEST PRACTICES
In 2014 and 2015, Safety and Enforcement Division (SED) staff researched BPs for
the identification and mitigation of leaks from the utility gas system. The research
included intemet searches and personal contacts with vendors, utilities, research
organizations and regulators, in both the United States and overseas. On March 18,
2015, ALJ Kersten issued a ruling entering the SED staff report, titled "Survey of
3 Scoping Memo,p. 16.
Summary of Best Practices Working Group Activities - R.15-01-008 Page 3 of 22
Natural Gas Leakage Abatement Best Practices", dated March 17, 2015, into the record.
The purpose of this paper was to identify technologies and practices presently in use,
technologies and practices which are new and/or currently not in use in California, and
those which are in various stages of research and development (R&D)?
On July 24, 2015, the Scoping Memo for this rulemaking was issued. Two of the
questions included in the Scoping Memo were:
5. Should the Commission require specific methods and technologies to detect
and measure leaks? What BPs should be required?
6. How should preventive maintenance and operations and other efforts be
employed to prevent leaks and other emissions, including third-party dig-
ins?5
The Scoping Memo also established workshops,by stating, "This proceeding will
hold workshops to discuss the leakage issues and the types of activities and metrics that
are currently used or should be developed to detect, monitor, and repair such leaks. The
workshops could also discuss potential ratemaking treatments to facilitate minimizing
these leaks. These workshops will be led by the Commission's Safety and Enforcement
Division (SED), in cooperation with CARB."
The Scoping Memo further described the scope of the BPs workshop:
"2. Working Group Workshop on Best Practices
(Phase 1, Items 5 & 6) -Based on "target" emission sources, best practices to
identify, measure, avoid and repair leaks discuss:
• BPs to identify leaks;
'This report can be found on the CPUC Risk Assessment webpage at:
http://www.cpuc.ca.gov/riskassessment/
Scoping Memo at 13.
Summary of Best Practices Working Group Activities- R.15-01-008 Page 4 of 22
• Best protocols, methods and procedures to quantify methane emissions
and leaks;
• Best preventive maintenance and operations practices to avoid and
prevent leaks, emissions from blowdowns, operational emissions and
other emissions, including third-party dig-ins; and
• BPs to repair leaks (e.g. customer meters are a major source of leaks.
What is a cost effective way to repair those?)"
In compliance with the direction of the Scoping Memo, a workshop was held on
October 27, 2015, where several parties made the following presentations:'
• CPUC - Cost Effectiveness
• Professor Joseph C. von Fischer of Colorado State University- Leak
Quantification Using Mobile Sensors
• Environmental Defense Fund -SED Workshop on Best Practices
• Sempra- Natural Gas Leakage Workshop: Working Group Workshop
on Best Practices
• PG&E - Leak Abatement Best Practices Workshop: Implementing Best
Practices and Ongoing R&D Projects
• Southwest Gas - Best Practices Workshop R.15-01-008: Methane
Leakage
Subsequent to the workshop, meetings were held, by telephone and in person, to
further zero in on the specific BPs preferred by the parties to identify and mitigate leaks
and emissions. All parties were noticed and invited to participate in the working
6 All parties to the proceeding were invited to participate in the workshop and make
presentations. All presentations can be found on the CPUC Risk Assessment webpage
at: http://www.cpuc.ca.gov/riskassessment/
Summary of Best Practices Working Group Activities- R.15-01-008 Page 5 of 22
group. All teleconferences and meetings were well attended by the parties and their
representatives.' In general, the parties felt that the meetings were productive.
BPs meetings and topics of discussion were as follows:
• December 8, 2015, teleconference:
• Transmission Blowdowns and M&R Station Blowdowns
• December 22, 2015, teleconference:
• Compressor Stations-Leaks from Valves, Connections, Meters,
Vents, Packing, Blowdowns, etc.
• January 5, 2016, teleconference:
• Storage-Control Vents, Leaks, Blowdowns, Storage
Compressors, Casings, other sources of Leaks and Emissions.
• January 19, 2016, meeting at the offices of the Environmental Defense
Fund (EDF) at 123 Mission St., San Francisco:
• Customer Meter and PHMSA "minor" releases (threaded
connection leaks) AND Leak Surveys, Patrols, Leak Survey
Technology, Leak Prevention, Leak Reduction, Leak Repair and
Required Repair Times for Leaks.
• "Know Your Risers" presentation by the Utility Workers Union
of America, addressing the dangers of corroded anodeless
7 The parties who participated were Sempra Utilities,Pacific Gas and Electric (PG&E),
Southwest Gas,Central Valley Storage,Lodi Gas Storage,Wild Goose Gas Storage, the
Environmental Defense Fund (EDF), the Utility Workers Union of America (UWUA),
the Coalition of California Utility Employees (CCUE), the Utility Reform Network
(TURN), the California Air Resources Board (CARB), the CPUC Organization of
Ratepayers Advocates(ORA) and the CPUC Risk Assessment Group.
Summary of Best Practices Working Group Activities- R.15-01-008 Page 6 of 22
risers, a steel casing with a plastic pipe inside that carries the
gas to the stop valve and meter assembly.
• January 20, 2016, continuation meeting at the EDF offices:
• Selection of BPs for the Working Group Proposal.
• Cost Effectiveness-Discussion by Southern California Gas
regarding the cost effectiveness methodology presented in the
ICE Report titled, "Economic Analysis of Methane Emission
Reduction Opportunities in the U.S. Onshore Oil and Natural
Gas Industries", dated March 2014.
• "Best Practices/Effective Results -Safe Harbor Proposal"
presentation by the Independent Gas Storage Providers (ISPs)
These working group meetings led to the creation of a consolidated spreadsheet,
listing over 100 potential BPs for policies, practices and technologies that specifically
relate to the system components and operational areas mentioned above.,
The spreadsheet briefly describes the proposed BPs, which parties proposed
them, lists pros and cons, and -where information was readily available-
estimated emissions that may be avoided through the use of the best practice and the
potential costs of the measures. Additional comments about the proposed items that
came up during the working group meetings are included, as well as a link to the U.S.
Environmental Protection Agency Natural Gas STAR site in cases where the item is
already identified as a Best Practice by the U.S. EPA.
,See Notes on Appendix A at the end of this document.
Pa e 7 of 22
Summary of Best Practices Working Group Activities- R.15-01-008 g
BPs are further identified by functional categories: Operational, Monitoring,
Process/Program Development and Training, Existing/Standard Practices, Research&
Development, Crossover (may apply to several categories) and Maintenance.
Although there may be other ways to categorize the list, staff believes the
functional categorization is most useful at this point in the process.
The spreadsheet, which is proposed as an attachment to this document, is
available on the SED Risk Assessment web site?
The SED Risk Group also proposed that the Best Practices Working Group adopt
the following Four Principles for Methane Leak Abatement Best Practices. The Four
Principles shown below incorporate parties' informal comments to the extent that Staff
agrees with them:
Four Principles for Methane Leak Abatement Best Practices
1. BPs go beyond technologies and tools to embody a new way of doing
things. Policies, practices and education are as important as new
technologies, and may provide additional methane reduction opportunities at
lower cost (e.g., The"Find it, fix it" policy for fixing leaks when found, in
some cases, may be more cost effective than monitoring or returning later to
fix the leak).
2. Industry standards for Safety and supplemental measures are needed to meet
the challenge of eliminating methane emissions to the extent necessary to
meet State goals.
Refer to the Risk Assessment website at: http://www.cpuc.ca.gov/riskassessment/
Summary of Best Practices Working Group Activities- R.1S-01-008 Page 8 of 22
3. If we can use the most advanced, technologically feasible, cost-effective
measures to further reduce methane emissions beyond established targets, we
should.
4. Improved methane detection by itself isn't enough; it should be coupled with
better quantification and accurate categorization, and matched with a
plan/timetable for mitigation in manners that are effective in minimizing the
release of methane.
It should be noted that these Principles represent a deeper iteration of one of six
statutory principles that were listed in SB 1371, in that they will guide the effort to "(4)
Establish and require the use of best practices for leak surveys, patrols, leak survey
technology, leak prevention, and leak reduction."10
RECOMMENDATIONS
At this time, after the exhaustive review of BPs described above, the CPUC and
CARB are prepared to make the following BP recommendations.
As stated in SB 1371, "The rules and procedures, including best practices and
repair standards, shall be incorporated into the safety plans required by Section 961 and
the applicable general orders adopted by the commission."" At this time, the only
applicable general order adopted by the commission is G.O. 112, Revision F and future
revisions. Whether and how these proposals, should they be adopted by the
Commission, would be incorporated into a general order, has not yet been determined.
10 PU Code Section 975(e)(4).
11 SB-1371 Natural Gas:Leakage Abatement,Section. 2., Article 3.,975(f)
Summary of Best Practices Working Group Activities- R.15-01-008 Page 9 of 22
Mandatory Requirements
There are mandatory minimum requirements proposed here that are intended to
ensure that the utilities and gas storage operators are using BPs to reduce Methane
leaks and emissions. Some of the minimum requirements are not BPs as identified in
the spreadsheet,but are the policies, procedures, programs, instructions and training
necessary to implement the BPs.
In addition, it should be mandatory for all utilities to create and file with the
CPUC and CARB, a compliance plan to compel the utilities to self-audit and certify
what specific BPs they are using to mitigate methane leaks and emissions.
There are also mandatory minimum BPs proposed that are aimed at mitigating
two of the largest categories of methane emissions and leaks. Those categories are
blowdowns and threaded connections". Further, there are several minimum required
BPs for the detection of graded and ungraded leaks, and to mitigate the uncontrolled
release of methane to the environment.
All of the mandatory requirements have been proposed because they are either
considered a crucial element to the success of the program (e.g., compliance, programs,
training, etc.) or because they will detect or mitigate the largest volume of methane
emitted and leaked (blowdowns, threaded fittings, graded and ungraded leaks,
uncontrolled releases of methane). They also appear to be cost-effective, based on
current utility experience or projected commercial cost (if still in R&D).
" As identified in the Methane Leak Abatement Proceeding Workshop on Cost-
Effectiveness and Best Management Practices (R.15-01-008),October 27, 2015. Refer to
the Risk Assessment website at: http://www.cpuc.ca.gov/riskassessment/
Pa e 10 of 22
Summary of Best Practices Working Group Activities- R.15-01-008 S
CPUC/ CARB Approval and Audits
The CPUC, in consultation with CARB, will approve the compliance plans and
mandatory procedures and practices described in this document using a process to be
determined later in this proceeding. Also, note that all components of this compliance
plan will be subject to audit by the CPUC in consultation with CARB and/or third-party
certifiers, using an audit process to be determined, including unannounced random
field inspections.
Voluntary Use of Best Practices
All other BPs found in Attachment A of this document, or the March 18, 2015,
report found on the Risk Assessment website?are considered voluntary and may be
used as appropriate by the Respondents to meet the emission targets eventually
adopted by the CPUC. As technologies change and improve, additional best practices
may be added and/or made mandatory.
13 Refer to the Risk Assessment website at:http://www.cpuc.ca.gpv/riskassessment/
Summary of Best Practices Working Group Activities - R.15-01-008 Page 11 of 22
Mandatory Requirements and Best Practices
Mandatory Method 1 Logic Deadline
Category
Policies and Procedures
Written compliance plan identifying Regulatory Each company is of a different size January 31,2017
the policies,programs,procedures, Issue,Process and has a different business model.
instructions,documents,etc.used to and Program In most cases,they are given the
comply with the Final Decision in this Development flexibility to choose the BPs that are
Proceeding(R15-01-005). Exact &Training cost-effective for them.However,
wording TBD by the company and they must submit a compliance plan
approved by the CPUC,in for approval by the CPUC/CARB to
consultation with CARE. ensure that they are complying with
the emission targets and decisions of
this proceeding and SB 1371.
Written company policy stating that Process and Written company policies are December 15,2016
methane is a potent GHG that must be Program needed to direct company activities
prevented from escaping to the Development and hold employees accountable for
atmosphere. Exact wording TBD by &Training violations of the policy.
the company and approved by the
CPUC,in consultation with CARE.
Written company policy or procedure Process and 1 Written company policies are December 15,2016
stating that non-emergency venting of Program needed to direct company activities
transmission lines and distribution Development and hold employees accountable for
mains to atmosphere are only &Training violations of the policy.
permitted after pressure inside the Purging
lines has been reduced to the level
specified in Procedure XXX. Exact
wording TBD by the company and
approved by the CPUC,in
consultation with CARB.
'..Elm= Page 12 of 22
Summary of Best Practices Working Group Activities-R.15-01-006 B
Mandatory Method 1 Logic Deadline
Category
Policies and Procedures
Written company policy or procedure Process and Written company policies are December 15,2016
stating that any project that requires Program needed to direct company activities
evacuating methane must build time Development Sr and hold employees accountable
into the project schedule to reduce Training for violations of the policy.
methane by using one of the approved
BPs found in Procedure XXX.
Schedules of transmission line work
shall also be submitted to facilitate
audits,with line venting schedule
updates TBD.Exact wording TBD by
the company and approved by the
CPUC,in consultation with CARB.
Written company procedures Process and Written company procedures are December 15,2016
implementing the BPs approved for Program needed to direct company activities
use to evacuate methane and how to Development& and hold employees accountable
use them. Exact wording TBD by the Training for violations of the policy.
company and approved by the CPUC,
in consultation with CARB.
- Written company policy that requires Process and Written company procedures are December 13,2016
that for any projects requiring Program needed to direct company activities
evacuating methane,Work Planners Development& and hold employees accountable
shall clearly delineate,in procedural Training for violations of the policy.
•
documents,such as work orders used
in the field,the steps required to safely
and efficiently reduce the pressure in
the lines,prior to lines being vented.
Exact wording TBD by the company
and approved by the CPUC,in
consultation with CARB. December 15,2016
Written company policy requiring Process and Requires coordination and
bundling of work whenever possible Program awareness of construction,
to prevent multiple venting of the Development& operations and maintenance
same piping. Exact wording TBD by Training activities. Multiple blow-downs of
the company and approved by the lines cause excess methane
•
CPUC,in consultation with CARB. emissions.
Written company emergency Process and Storage facilities contain large December 15,2016
procedures which describe the actions Program volumes of methane. An
company staff shall take to prevent • Development& uncontrolled release will negate the
and/or stop the uncontrolled release of Training,IM methane reductions of other
methane from the gas system or Crossover utilities,increase greenhouse gases
storage facility. and endanger public health by .
Exact wording TBD by the company releasing large amounts of odorant
and approved by the CPUC,in and other toxic natural gas by-
consultation with CARB. j products.
'tea Pa e 13 of 22
Summary of Best Practices Working Group Activities- R.1S-01-008 g
Mandatory Method 1 Logic Deadline
Category
Records
Written Company Policy directing the Regulatory It is impossible to accurately report December 15,2016
gas business unit to maintain records Issue methane releases without this
of all emissions and leaks,including information. It will also be used by
the calculations used to derive the regulators during audits to ensure
volume of methane released.Records compliance.
are to be maintained in accordance
with G.O.112 F and succeeding
revisions,and 49 CFR 192. Currently,
the record retention time in G.O.112 F
is at least 75 years for the transmission -
system. 49 CFR 192.1011 requires a
•
record retention time of at least 10
years for the distribution system. Exact
wording TBD by the company and
approved by the CPUC,in
consultation with CARB.
Training
Training to ensure that personnel Process and Storage facilities contain large December 15,2016
know how to use company emergency Program volumes of methane. An
procedures which describe the actions Development& uncontrolled release will negate the
staff shall take to prevent and/or stop Training,IM methane reductions of other
the uncontrolled release of methane Crossover utilities,increase greenhouse gases
from the gas system or storage facility. and endanger public health by
Training programs to be designed by releasing large amounts of odorant
the Company and approved by the and other toxic natural gas by-
CPUC,in consultation with CARE. products.
Ensure that training programs educate Process and Training programs are necessary to December 15,2016
workers as to why it is necessary to Program help employees understand why it
reduce,eliminate and/or prevent Development& is important to reduce methane
methane emissions and leaks. Training emissions and leaks. If they
Training programs to be designed by understand the issues,they are
the Company and approved by the more likely to comply with the
CPUC,in consultation with CARB. company's policies and
procedures.
Summary of Best Practices Working Group Activities- R.15-01-008 Page 14 of 22
Mandatory Method 1 Logic Deadline
Category
Training
Training/Mentoring/Knowledge Process and Alleviates knowledge gaps and January 31,2017
Transfer Programs to ensure Program improves safety. New workers
knowledge continuity as workers(cave Development MUST be trained for safety reasons,
and new workers are hired. Training, &Training in addition to limiting methane
mentoring and knowledge transfer emissions. Knowledge transfer
programs to be designed by the programs keep knowledge and
Company and approved by the CPUC, important information flowing
in consultation with CARB. through generations of employees.
Create and implement training Process and Training programs are necessary for January 31,2017
programs to instruct workers on how Program the safety of workers and the public.
to perform the BPs chosen,efficiently Development
and safely. Training,mentoring and &'I raining
knowledge transfer programs to be
designed by the Company and
approved by the CPUC,in
consultation with CARB.
Experienced,Trained
Personnel
Experienced,qualified people with Process and According to the Unions,there is a January 31,2017
field experience are needed. This is a Program significant need for experienced,
general comment for all BPs. Create Development qualified people working in the field,
new formal job classifications for &Training and also for participation in the
apprentices,journeyman,specialists, evaluation of existing practices and
etc where needed. Implement this development of better(best)
practice in cooperation with the practices. Experienced gas system
Unions. The CPUC,in consultation workers have first-hand knowledge
with CARB will review the number of how gas system equipment
and experience of employees in the operates,what the operation and
field,as well as training and mentoring maintenance problems are and how
programs,during audits. The audit to fix them resulting in less methane
process will be developed later in this leaks. These are not entirely
proceeding. hardware issues. Experienced
workers are needed to help train,
improve procedures,maintain and
operate equipment and in the
process,how to minimize methane
leaks and emissions.
Summary of Best Practices Working Group Activities- R.15-01-008 Page 15 of 22
Mandatory Method 1 Logic Deadline
Category
Leak Detection
Conduct leak surveys of the gas Monitoring Transition from 5 year leak surveys Begin surveys on
distribution system outside business to 3 year leak surveys for the 3 year schedule by
districts,every 3 years instead of every following parts of the gas system: January 31,2017
5 years,using modern,digital data 49 CFR 192.723-Distribution
acquisition equipment(e.g.digital data systems:Leakage-surveys
loggers),which can be downloaded to (b)(2)states,"A leakage survey with
a central database. leak detector equipment must be
conducted outside business districts
as frequently as necessary,but at
least once every 5 calendar years at
intervals not exceeding 63 months."
Further,research cited by both
Colorado Air Quality Control
Commission and the EPA indicates
that more frequent inspections
result in greater reductions of
methane emissions". Leaks are
found sooner and have less time to
emit natural gas. The large gas
utilities all appeared to be in favor
of this change. More frequent leak
surve s are •mmitted b the CFRs.
Special Leak Surveys Monitoring Vintage Pipe is determined by Begin surveys by
Vintage Pipe, Distribution Integrity material and date manufactured. January 31,2017
Management Program Surveys- The intent is to find leaks on
conducted at least once per year and problematic infrastructure and
up to 4 times per year,depending on components such as Aldyl"A"
specific criteria. piping.
Leak surveys to be conducted using
modern,digital data acquisition
equipment(e.g.digital data loggers),
which can be downloaded to a central
database.
Pipe materials that are more
susceptible to leaks should be replaced
or modified to make safe(e.g.,cast iron
or certain type of plastic pipe,
unprotected steel.
14 In the ICF International Report,The Economic Analysis of Methane Emission Reduction
Opportunities in the U.S.Onshore Oil and Natural Gas Industries", .a:es 3-9 thou 3-11
Summary of Best Practices Working Group Activities- R.15-01-008 Page 16 of 22
Mandatory Method 1 Logic Deadline
Category
Leak Detection
Mobile methane mapping Monitoring Note: We are not requiring this Begin by
technology. technology to be used until January,2018, January 31,2018
to allow time for the technology to be
Strategic Mobile Methane Mapping perfected. It is very close to becoming
Leveraging Existing Vehicle Fleet commercially available. Technology
and/or use of mobile gas leak costs can also be considered in strategic
detection. Vehicles used for this implementation. .
purpose should be chosen in the
most cost effective way. Vehicles Pros:-Able to identify more leaks in a
that are rarely used are obviously given area,enabling the"Super Crew'
not candidates for this technology. method of fixing leaks en masse,resulting
in lower cost per repair.
Mobile mapping equipment must -Increase the number of leaks found in a
be capable of automatically very cost-efficient way. This new
downloading leak data to a central technology is more sensitive and therefore
database. finds more leaks.
-Leverage miles already being driven by
Leak maps shall be publicly Company vehicles.
available with leaks displayed by -No incremental vehicle cost or vehicle
zip code or other metric(number emissions.
and type of leaks per zip code) -For SCG,4,000 Company vehicles
driving 7,000 mi/yr—28 million miles
Note:PG&E uses Picarro to find driven annually.
and alert for leaks. If Picarro's -Develop an approach that is seamless to
equipment senses methane the vehicle operator.
concentration above 5 ppm,a -Use sensors on vehicle to gather and
survey is conducted on foot to communicate all data automatically
determine the source of the leak. -Develop methane/odorant detector to
This methodology would be similar differentiate Pipeline gas.
for all mobile gas leak detection , -Perform data analysis in centralized
technology. location.
-Large data volume may allow modeling
of atmospheric methane levels across
entire service territory.
-Company vehicles usually drive in areas
the companies have facilities.
-Centrally coordinate standard work
orders for Operations to investigate
locations of concern.
-Synergistic between Company
operations.
•
Cons:-Algorithms and methods are still
being improved to make the equipment
more accurate and efficient.
Summary of Best Practices Working Group Activities- R.15-01-008 Page 17 of 22
Mandatory Method 1 Logic Deadline
Category
Leak Detection
Stationary Methane Detectors for Monitoring Early warning is essential to reducing February 28,2018
Compressor Stations,Terminals,Gas the amount of methane emitted or
Storage Facilities,or large leaked,especially at gas storage
concentrations of equipment or piping. facilities which are unmanned. This
is also a safety are especially useful at b'issue. Recent research
unmanned facilities.facilities. Methane conducted for the Environmental
detectors must alarm in manned Defense Fund(EDF)has identified
control rooms or manned facilities.For inexpensive(410000),reliable
underground storage facilities, stationary methane detectors.
requirements would be harmonized Although they are still considered in
with other monitoring requirements. R&D,it is anticipated that they will
he commercially available by Feb.
2018.
More frequent periodic possibly Monitoring Transmission facilities with a high February 28,2018
quarterly,leak detection and repair concentration of equipment and other
(LDAR)inspections at above ground components are more prone to leaks
transmission facilities with repair dates and vented emissions. In addition,
determined by leak size. Schedule and since they are in a more concentrated
scope to be determined. Use EPA area it is easier to perform leak
Method 21,optical gas imaging,or surveys. Quarterly leak detection
other methods for above ground and repair inspections are reasonable
facilities/leaks. and most likely will be cost-effective.
Use of hand-held detection devices to Monitoring, The most sensitive equipment finds February 28,2018
identify&quantify the sources of Existing/ the most leaks. There are many
leaks. Standard devices available. Refer to the March
Practices 18,2015 Best Practices Report,
Appendix A on the Risk Assessment
website under Recent Documents:
htt : www. ucca.my riskassessme
nt/. For example,a tunable laser
spectrometer is under development
by NASA. It is expected to be
commercially available for<$5000. It
will have a measuring sensitivity in
the parts per billion(ppb)range. The
newest equipment will be more
reliable,lower maintenance and more
sensitive compared to older
technologies.
Summary of Best Practices Working Group Activities- R.1S-01-008 Page 18 of 22
Mandatory Method 1 Logic Deadline
Category
Leak Repairs
Repairing Grade 2 and Grade 3 leaks Monitoring PG&E is already repairing these October 1,2018
within certain timeframe(TBD),rather and within the first 15 month cycle.
than keep monitoring. Maintenance PG&E has found this practice to be
Practices cost-effective.
"Find It Fix It Policy": Leak Repair
Timeline and Backlogs "There will be initial costs,however
once the program is in place,costs
The Leak repair time for Grade 2 and are expected to decrease because
Grade 3 leaks above a certain size
less leaks will be found to fix,and
threshold(TBD)are repaired on an less leaks will have to be monitored
within "Potential increase in capital for
one
accelerated timeline, Ye ar repairs and expense for labor.
from discovery,meaning the utilities
have one year from when they detect a
Grade 2 or above ground Grade 3 leak Note:Extended time is allowed for
to fix it. This would apply to all leaks those leaks which cannot be fixed on
found after December 15,2016. time due to permitting problems or
other problems beyond the utility's
Note:In no case shall the time to repair control.
a leak exceed the repair times specified
in G.O.112 F and succeeding revisions,
or as ordered by the CPUC Gas Safety
and Reliability Branch.
Backlogs—Utilities will be allowed
until October 1,2018 to eliminate their
backlog of above ground Grade 3 leaks
found prior to December 15,2016.
Note: Grading terminology varies
between utilities. Grade can also be
referred to as Code. Some utilities
may also have Grade 2+leaks. Grade
24 leaks shall be repaired within the
same time limit as Grade 2 leaks unless
required by the CFRs,G.O.112F,or the
CPUC Gas Safety and Reliability
Branch to be repaired sooner.
Summary of Best Practices Working Group Activities- R.15-01-008 Page 19 of 22
Mandatory Method 1 Logic Deadline
Category
Leak Prevention
Revise pipe fitting specifications to Design This is being added as a mandatory February 28,2017
require tighter tolerance/better quality practice because of the very large
pipe threads. number of threaded fittings and their
known propensity to develop leaks.
This is being recommended as a
mandatory BP,provided that further
research proves this to be a cost-
effective. If so,utilities will not be
required to replace all threaded
connections immediately,but rather
replace them as incidental work is
required to be performed on them.
This particular practice will be to use
ANPT pipe threads instead of NPT.
However,other types of threads or
connections may prove better. Leaks
from threaded connections are
usually not a result of initial
installation. Leaks are usually a
result of what happens later
(corrosion,things bumping into the
MSAs,customer abuse,etc.). Most
likely this practice will result in an
incremental reduction of emissions.
Methods,systems and components Design, Storage facilities contain large February 28,2017
used to prevent and/or stop the Process and volumes of methane. An
uncontrolled flow of methane from a Program uncontrolled release will negate the
gas system or storage facility. Development methane reductions of other utilities,
&Training,IM increase greenhouse gases and
This requirement should not be Crossover endanger public health by releasing
duplicative to the DOGGR's or CARB's large amounts of odorant and other
Oil&Gas Regulations. toxic natural gas by-products.
Dig-Ins-Public education program to Existing Dig-Ins are the major cause of gas Now.
alert the public and contractors to the Practice, line ruptures.
Call Before You Dig-811 program. In Process and
addition,utilities must provide Program
procedures for contractors to follow Development
when excavating to prevent damaging &Training
or rupturing a gas line.
Summary of Best Practices Working Group Activities-R.1S-01-008 Page 20 of 22
Dig-Ins-Utilities must provide ] Monitoring, This is necessary to ensure that Now
company monitors to witness all Existing people excavating around the line do
excavations near gas transmission lines Practice not damage it or rupture it. It is
to ensure that contractors are following possible to have an excavator nick or
utility procedures to properly excavate damage a transmission line causing it
and backfill around transmission lines. to rupture years later.
Dig-In Repeat Of fenders-Contractors Regulatory Repeat offenders of the 811 laws are Now
found to be at fault more than once by common. This must not be tolerated.
a CPUC investigation,for rupturing a
gas line,must be labelled Repeat
Offenders.They must be forbidden
from excavating near gas lines in the
future. In addition,the utility must be
report them to the California
Contractor's State License Board. The
Board has the authority to investigate
and punish dishonest or negligent
contractors. Punishment can include
sus ension of their contractor's license.
Summary of Best Practices Working Group Activities- R.15-01-008 Page 21 of 22
ATTACHMENTS
Attachment A -Best Practices Consolidated Spreadsheet
The Excel spreadsheet in Attachment A, found on the Risk Assessment website at
http:/Is ww.cpuc.ca.gov/riskassessment/ is the work product from the Best Practices
Working Group. All spreadsheets submitted by the parties have been merged together
(consolidated) and notes from all of the meetings have been added in Red into the
column titled "Additional Comments from Meeting.' PG&E participants agreed to
categorize the BPs for us, using the categories found in Method 1 and Method 2. The
spreadsheet that they developed was circulated by PG&E to the Service List. The staff
of the CPUC prefers Method 1; however parties are free to use whatever method they
choose to help them organize and categorize BPs for their purposes.
The staff of the CPUC modified Method 1 slightly. We have added two categories to
the Method 1 list. The categories are "Design" and "Regulatory Issue." The category
"Design" is needed because some BPs require design changes to gas system
infrastructure. In addition, the staff of the CPUC has color-coded, in light green, BPs
which are also recommended by the EPA Gas Star Program and added the list of BPs
meeting topics, in the yellow box, in the upper right-hand corner of the spreadsheet.
-END-
Summary of Best Practices Working Group Activities-R.15-01-008 Page 22 of 22