CPUC Pipeline Safety Frequently Asked Questions Oct. 8, 2010
Q: Do first responders know where pipelines are in their area? A: Gas safety regulations require operators, including PG&E, to “establish and maintain liaison with appropriate fire, police, and other public officials…” It is intended that through this process both the operator and the officials can learn of each other’s abilities to respond to a gas pipeline emergency and plan how mutual assistance can help minimize hazards to life and property during an emergency.
Regulations do not require PG&E to provide maps of its gas facilities to the local agencies, but following the San Bruno explosion, PG&E is now offering more information to first responders.
Maps have typically not been provided due, to some degree, to security reasons. There are other challenges that have prevented the maps from being routinely provided, which include the following:
1) PG&E would have to provide updated maps to all agencies on an on-going basis. Every update would have to be communicated to every fire, law enforcement, and other official agencies with which PG&E maintains liaison. If the local agency did not update its maps as often as PG&E updated them, it could potentially respond to a scene with incorrect information.
2) Gas safety regulations require that anyone performing a covered task on a pipeline be qualified per the operator’s qualification program. This is not a one-time, but an on-going process by which the operator becomes responsible for the qualification of the individual and the work performed by that individual. If the responding agency were to use the maps to identify and close pipeline valves, it would require PG&E to fully equip and qualify any agency personnel to perform this task.
Q: What is a High Consequence Area (HCA)? A: The federal pipeline safety regulations, CFR 49, Part 192, Subpart O contains requirements for gas transmission pipeline integrity management. One of the elements of an integrity management program is the identification of all the high consequence areas. The regulations provide specific methods to identify high consequence areas. In general, these methods take into account the number of buildings intended for human occupancy and their proximity to the pipeline. The methodology is specified in Part 192, sections 192.903 and 192.905.
To determine which segments of an operator’s transmission pipeline system are covered by the gas transmission integrity management rules, an operator must identify the high consequence areas in its service territory. For each covered segment, an operator is required to identify the associated threats and risks, prioritize the segment for baseline assessment, and evaluate the merits of conducting additional preventative and mitigation measures.