Natural Gas Pipeline Safety
General Order 112
General Order 112 (GO 112) governs general gas system operations for utilities in California. GO 112 was last significantly revised in 1995.
In August 2013, the CPUC’s Safety and Enforcement Division circulated proposed rule changes to parties. In July 2014, the CPUC issued a Ruling with revisions to the GO 112 changes. The Ruling proposed a rule change which would double the amount of required inspections on some lines and identified the addition of:
- Encroachments on utility right-of-way
- A new emergency response standard
On January 23, 2015 the CPUC issued a Proposed Decision with the changes to GO 112, including:
- Expanding the definition of High Consequence Areas, with an effective date delayed until January 1, 2016.
- Requiring the doubling of transmission inspections from once to twice a year.
- Addressing encroachments on utility right-of-ways.
The CPUC held workshops on May 11 and 12, 2015 to gather input from stakeholders on changes to pressure testing requirements and how the Maximum Allowable Operating Pressure of pipelines should be set.
On June 25, 2015, the CPUC issued a Decision adopting General Order 112-F.
ORA Policy Position
ORA supports the CPUC’s objectives to update GO 112 in order to improve gas pipeline safety standards in California. ORA generally supports the CPUC’s proposed changes to GO 112, and provided minor requests for clarification. ORA also generally supports the new rules regarding encroachments on utility right-of-way.
However, ORA’s primary concern is that the CPUC has not yet included revisions to General Order 112 that reflect changes to pressure testing requirements that occurred as a result of the San Bruno pipeline explosion. The CPUC has required the utilities to pressure test pipeline installed prior to 1970 that had not been previously pressure tested, or for which records were missing. Currently this requirement exists only in a CPUC decision, whereas ORA recommends it should be specifically included in the General Order to ensure that all natural gas operators in California are clear on their requirements to operate pipelines.
Accordingly, on July 29, 2015, ORA filed an Application for Rehearing, requesting that the CPUC should clarify how the CPUC’s requirement to test or replace transmission pipeline interact with federal minimum safety codes.
See ORA’s February 2015 Briefing Document to the Commission, expressing its concerns about pressure testing and GO 112.
See ORA’s February 12, 2015 Comments on the Proposed Decision.
See ORA’s February 17, 2015 Reply Comments.
See ORA’s July 18, 2014 Comments on the CPUC’s proposed rule changes.
See ORA’s July 25, 2014 Joint Reply Comments with TURN.
See ORA’s September 27, 2013 Comments on the Safety and Enforcement Division’s proposed rule changes.
See the Proceeding docket.
The GO 112 Update is part of the Pipeline Safety Enhancement Plan Rulemaking.
ORA’s General Order 112 Briefing Document
ORA’s Pipeline Safety Enhancement Plans Portal