Risk Assessment and Safety Advisory (RASA) Section
The Risk Assessment and Safety
Advisory Section (RASA) consists of a team of senior engineers and senior
analysts, who serve many critical functions within the Safety and Enforcement
Division. RASA provides advisory support to Commissioner offices and
Administrative Law Judges on safety proceedings as well as any energy
proceedings that have safety implications. In 2015 and 2016, RASA identified safety concerns or considerations in
over 25 new regulatory proceedings. The RASA section also promotes safety by
improving the ways that energy utilities integrate risk analysis and risk
management into their operational, planning and other decision-making
processes. In addition, RASA suggests improvements in audits and inspections
performed by SED. RASA also identifies safety hazards and suggests improvements
to General Orders and safety inspection protocols. RASA regularly coordinates
with other Commission divisions and/or State agencies to promote safety in
regulated utility operations and research expenditures.
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