Interpretation Response #PI-10-0009 ([Pacific Gas and Electric Company] [Glen Carter])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Pacific Gas and Electric Company
Individual Name: Glen Carter
Location State: CA Country: US
View the Interpretation Document
Response text:
March 8, 2011
Mr. Glen Carter
Pacific Gas and Electric Company
375 N. Wiget Lane
Walnut Creek, CA 94598
Dear Mr. Carter:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated April 23, 2010, you requested an interpretation of the instructions to complete PHMSA Form F 7100.1-1. Your request also referenced a December 2008 letter from Pacific Gas and Electric Company (PG&E) to PHMSA seeking clarification on the wording in the instructions for reporting non-hazardous leaks on the operator annual report Form F 7100.1-1. You stated that PHMSA staff, Mr. Jamerson Pender, responded to the December 2008 letter request in a conference call with PG&E on January 13, 2009. You also stated that Mr. Pender explained that, despite use of the word "non-hazardous" in the instructions, PHMSA intended utilities to report any release of gas, regardless of how insignificant, excluding leaks that can be eliminated by lubrication, adjustment or tightening. You further stated that PG&E has modified its reporting for calendar year 2009 and brought to PHMSA's attention the resulting increase in reporting for leaks for PG&E that resulted from your change in reporting non-hazardous leaks and also your recent leak survey.
You stated that PG&E has historically included all leak repairs on gas distribution mains and service lines and hazardous above-ground leaks repaired in Form F 7100.1-1. Until last year, PG&E defined the criteria for reporting hazardous leaks as any leak below the service (shut-off) valve and had not historically reported above-ground leaks at the service (shut-off) valve or on the meter set unless the leak was deemed hazardous or potentially hazardous and required replacement of damaged, corroded, or non-operational equipment. You noted that PHMSA instructions direct that:
"A leak is defined as an unintentional escape of gas from a pipeline. A non-hazardous release that can be eliminated by lubrication, adjustment or tightening is not a leak. Include all leaks eliminated by repair, replacement or other reason during the reporting year."
As Mr. Pender had indicated in his guidance provided to PG&E during the January 2009 phone call, PHMSA points out that the instructions do not indicate that only hazardous leaks are to be reported but rather, they direct operators to report all leaks defined as "an unintentional escape of gas" except for "non-hazardous releases that can be eliminated by lubrication, adjustment, or tightening." In reporting these above-ground non-hazardous leaks, PG&E is leak reporting in line with the leak reporting of similar sized companies. PG&E should continue to report above-ground leaks including those at the shut-off valve and on the meter set unless the leak was non-hazardous and was remediated by simple lubrication, adjustment, or tightening.
PHMSA appreciates that PG&E brought this matter to its attention. PHMSA is considering how it can provide additional consistency and clarity in the use of the term "leak" across PHMSA regulations and guidance materials and will consider a revision to Form F 7100.1-1 in the future. PHMSA will involve stakeholder participation in evaluating the usefulness of the existing collection criteria. PHMSA will also evaluate potentially needed changes and will further assess the leak reporting criteria and guidance in the process.
I hope that this information is helpful to you. If I can be of further assistance, please contact me at 202-366-4046.
Sincerely,
John A. Gale
Director, Office of Standards and Rulemaking