# Pacific Gas & Electric Company — Pipeline Safety Interpretation - **operation:** document - **citation:** PI-23-0001 - **title:** Pacific Gas & Electric Company — Pipeline Safety Interpretation - **source type:** guidance - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** guidance - **official:** true - **published on:** 2023-04-06 - **effective on:** Not available - **summary:** PI-23-0001 response to Pacific Gas & Electric Company concerning 199.1. - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-23-0001.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-23-0001.md - **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-23-0001 - **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/77451/pge-and-local-1245-pi-23-0001-04-06-2023-part199-1.pdf **body:** <<>> U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 February 14, 2023 Philip Simpkins Senior Counsel Pacific Gas & Electric Company Law Department 77 Beale Street San Francisco, CA 94105 Dear Mr. Simpkins: In your December 19, 2022, letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) you requested an interpretation of the federal pipeline safety drug & alcohol (D&A) regulations in 49 CFR Part 199 with respect to employees who perform back-up coverage of emergency dispatching job duties that are regularly performed by PG&E’s Work & Resource Dispatcher – Gas employees (“Gas Dispatchers”). You detailed the role of PG&E’s Gas Dispatchers in your letter with regards to emergency gas calls and, while not specifically stated, your letter implies that PG&E has determined its Gas Dispatchers are covered employees subject to PHMSA’s D&A Testing regulations. The D&A regulations in § 199.3 define “performs a covered function” to include “actually performing, ready to perform, or immediately available to perform a covered function. ” Moreover, PHMSA has issued several interpretations wherein we consistently explain that an employee who performs a covered function is a covered employee regardless of their job title or whether they perform those functions full-time, part-time, or as a back-up. The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or obligations, and are provided to help the specific requestor understand how to comply with the regulations. <<>> 2 Based on the information you provided, the PG&E Electric Dispatch employees who perform the back-up Gas Dispatch duties you described are covered employees as defined in § 199.3 and are subject to PHMSA’s D&A Testing regulations because PG&E has determined that their Gas Dispatchers are covered employees. If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523. Sincerely, John A. Gale Director, Office of Standards and Rulemaking The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or obligations, and are provided to help the specific requestor understand how to comply with the regulations. <<>> Pacific Gas and Electric Company TM Philip Simpkins Senior Counsel Mailing Address P.O. Box 7442 San Francisco, CA 94120 Street/Courier Address Law Department 77 Beale Street San Francisco, CA 94105 (415) 416-8960 Email: p3sr@pge.com Via U.S. and Electronic Mail December 19, 2022 John A. Gale Director, Office of Standards and Rulemaking U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 Re: Interpretation of 49 CFR § 199.1 re Back-up Dispatch for Gas Emergencies Dear Director Gale: The purpose of this letter is to request an interpretation regarding the applicability of PHMSA’s Drug and Alcohol Testing regulations, codified in 49 CFR Part 199, to specific classifications of employees working at Pacific Gas & Electric Company (“PG&E”) and represented by the International Brotherhood of Electrical Workers, Local 1245 (“Local 1245”). The pertinent classifications of employees perform back-up coverage of emergency dispatching job duties that are regularly performed by PG&E’s Work & Resource Dispatcher – Gas employees (“Gas Dispatchers”), as further explained below. PG&E and Local 1245 are jointly submitting this request in the hopes that a definitive response from your office will help the parties avoid the need to submit this issue of regulatory interpretation to a labor arbitrator who lacks specific expertise in PHMSA’s anti-drug and alcohol misuse prevention requirements. Under 49 CFR § 199.1, operators of pipeline facilities are required to test covered employees for the presence of prohibited drugs and alcohol. Covered employees include any employees who perform an emergency-response function as part of work regulated by Part 192 on a pipeline or on an LNG facility. As clarified by the Office of Pipeline Safety in its Interpretation Response PI-90-019 (a copy of which is attached as Exhibit A), “dispatch[ing] service personnel” to gas pipeline emergencies and “notifying fire and police officials” of the pipeline emergency are both emergency-response functions regulated by Part 192. More recently, the Office of Standards and Rulemaking in its Interpretation Response PI-22-0001 reaffirmed that “dispatching of personnel to the scene” of a gas leak (and presumably any other gas emergency concerning a pipeline) is an emergency response function regulated by Part 192 and performed on a pipeline. (Exhibit B.) Part 199 explains that a worker “performs a covered function” when that individual is “actually performing, ready to perform, or immediately available to perform a covered function.” This <<>> Joint Interpretation Request December 19, 2022 Page 2 definition, which we recognize was updated in 2001, appears to be consistent with prior explanations by George W. Tenley, Jr., Associate Administrator for Pipeline Safety, regarding the scope of work that will bring employees into coverage because they are considered to be performing emergency-response duties, in interpretations he authored on February 5, 1991 and May 9, 1991. (Exhibits C & D.) Those responses explained that employees who “seldom,” “infrequently,” “only temporarily,” or “rarely” perform emergency response duties are included within the scope of Part 199 and, even those whose assignments “have a potential to do a covered function…even if that person has not yet done a covered function” are still considered employees who perform emergency response functions. PG&E’s Gas Dispatchers take emergency calls routed to them by PG&E’s Customer Contact Centers, including calls reporting suspected gas leaks, which can include leaks inside the customer’s home or business, at the meter, or elsewhere on their property. They also take calls from 911 agencies (fire, police) reporting gas emergencies, such as gas leaks, dig-ins to pipelines, fires, vehicle impacts to gas facilities, exposed gas pipes, and even potential explosions. Calls from 911 agencies are first directed to a subset of Gas Dispatchers, called the Powerline Dispatch team, during the Powerline working hours of 6 a.m. to 6 p.m., Monday through Friday, and 8 a.m. to 6 p.m. on weekends. Outside of these regular service hours, or whenever Powerline Dispatch is non-operational because of a systems-down condition, then 911 agency calls are routed directly to all available Gas Dispatchers. 911 calls also will roll over to the Gas Dispatchers when there is an increase in call volume beyond what Powerline Dispatch is able to handle. For any emergency gas calls handled by a Gas Dispatcher, the individual is expected to manage the emergency response coordination. Because PG&E does not know, until it has personnel on the scene, how serious a potential gas emergency may be, all potential gas emergency calls are dispatched as “Priority Zero,” meaning that immediate response to the scene is required. (See Exhibit E.) Dispatcher’s coordination of this response includes using PG&E’s field automation system (FAS) dispatch application to report the incident and send a Gas Service Representative (GSR) to the scene of the incident. If the GSR needs assistance, the Gas Dispatcher notifies the GSR’s supervisor and command is transferred to the supervisor upon their arrival at the scene. Gas Dispatchers are also responsible for dispatching any other appropriate field responders to the scene of a gas emergency and serve as the primary link between all internal and external first responders. PG&E’s Work & Resource Electric Dispatchers (“Electric Dispatchers”), in turn, serve as back- up to the Gas Dispatch team. If Gas Dispatch is overloaded or if Gas Dispatch otherwise goes offline, due to technology issues, building evacuations (e.g., a fire alarm), or natural disaster (e.g., an earthquake), emergency gas calls – which may be routed from a Customer Contact Center or directly from 911 agencies – are sent to Electric Dispatch. When serving this back-up function, Electric Dispatchers perform all the same functions as their Gas Dispatch counterparts. Electric Dispatchers are specifically trained in how to handle Gas Dispatch work, including gas emergency calls. The utilize the FAS dispatch application to report the incident and to send a GSR and/or a GSR supervisor to the scene. The role of Electric Dispatchers as back-up to Gas Dispatch for gas emergencies is identified in PG&E’s “Gas Dispatch and Scheduling Handling 911 Calls – Emergency Response” and “Electric Operations Restoration Dispatch – Gas <<>> Joint Interpretation Request December 19, 2022 Page 3 Dispatch Tech Down” procedure bulletins, which are part of PG&E’s “Gas Emergency Response Plan” developed and maintained as required by Part 192. (See, respectively, Exhibits F, G, and H.) As mentioned above, PG&E and Local 1245 are requesting a definitive answer as to whether Electric Dispatch employees who perform the above-described functions, in the above-described back-up role, should be considered covered employees under Part 199.3 and therefore subject to PHMSA’s Drug and Alcohol Testing regulations. If a definitive response cannot be provided, then PG&E and Local 1245 would appreciate any insight the Office of Standards and Rulemaking can provide regarding this issue. Sincerely, /s/Philip Simpkins Philip Simpkins cc (email only): Bob Dean, Business Manager, Local 1245 Bryan Carroll, Assistant Business Manager, Local 1245 Alex Pacheco, General Counsel, Local 1245 Matt Levy, Senior Director, Labor Relations, PG&E Robin Wix, Manager, Labor Relations, PG&E Missy Parry, Chief Counsel, PG&E <<>> EXHIBIT A <<>> May 18, 1990 Mr. Jay C. Rounds Director of Personnel Services City of Palo Alto P.O. Box 10250 Palo Alto, CA 94303 Dear Mr. Rounds: Your letter of April 20, 1990, to Cesar De Leon requests our assistance in determining whether positions called Communication Dispatcher, Chief Communications Dispatcher, and Manager Communications Operations, which have duties in connection with the City's natural gas distribution system, are subject to drug testing under 49 CFR Part 199. A person is subject to drug testing under Part 199 when that person performs on a gas pipeline an operation, maintenance, or emergency-response function that is regulated by 49 CFR Part 192. (See the Part 199 definition of "employee.") This jurisdictional test may be transformed into two questions, both of which must be answered affirmatively for Part 199 to require drug testing of a person working on a gas pipeline: (1) Does the function the person performs involve operation of a pipeline, maintenance of a pipeline, or response to a pipeline emergency? (2) Is the function the subject of a Part 192 regulation? The information you provided indicates that the Communications Dispatcher receives calls about pipeline emergencies and dispatches service personnel. These functions involve responses to a pipeline emergency that are regulated under § 192.615. Therefore, persons in the position of Communications Dispatcher are subject to drug testing under Part 199. Persons in the Chief Communications Dispatcher position and Manager Communications Operations position would not be subject to drug testing for directing the work of the Communications Dispatchers. However, if they perform either of the above functions of the Communications Dispatcher or any of the other emergency communications functions regulated by § 192.615, such as notifying fire and police officials, they would be subject to drug testing. dal/199.3 90-05-18.2 <<>> I trust this adequately responds to your inquiry. Sincerely, George W. Tenley, Jr. Director Office of Pipeline Safety dal/199.3 90-05-18.2 <<>> EXHIBIT B <<>> U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 March 03, 2022 Ms. Melissa Kurtz Business Representative I.B.E.W. Local Union 503 2657 Route 17M Goshen, NY 10924 Dear Ms. Kurtz: In your December 7, 2021, letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) you requested an interpretation of the federal pipeline safety regulations in 49 CFR § 192.615 with respect to customer service representatives (CSRs) working for Orange and Rockland Utilities, a subsidiary of Con Edison. Essentially, you asked if these CSRs are PHMSA drug and alcohol (D&A) “covered employees” subject to the Department of Transportation (DOT) drug testing. While 49 CFR Part 199 refers to Parts 192, 193, and 195 and knowledge of those federal pipeline safety regulations is essential to meet the D&A testing regulations in Part 199, the D&A regulations requiring interpretation are found in 49 CFR Part 199, not § 192.615. Specifically, in § 199.3, PHMSA defines a D&A “covered employee” and “covered function.” PHMSA promulgated the first drug testing regulations in 1988 wherein PHMSA required pipeline operators to have an “anti-drug program for employees who perform certain sensitive safety-related functions covered by the pipeline safety regulations.”1 While the original drug testing rule did not define covered employee or covered function, it was explained in the rule preamble that the drug testing regulations were limited to “those who perform regulated operation, maintenance, or emergency-response functions…on existing pipelines.” 2 PHMSA added the definitions of “covered employee” and “covered function” to Part 199 with Amendment 199-15 on March 17, 1998. In that amendment, PHMSA defined “covered function” to mean “an operations, maintenance, or emergency-response function conducted on the pipeline or LNG facility that is regulated by Part 192, 193, or 195.”3 PHMSA changed the definition of “covered function” to the current version with Amendment 199-19 on September 11, 2001. Covered function now means “an operations, maintenance, or emergency-response 1 53 FR 47084. 2 53 FR 47089. 3 63 FR 12998, 13000 (emphasis added). The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or obligations, and are provided to help the specific requestor understand how to comply with the regulations. <<>> 2 function regulated by [P]art 192, 193, or 195 of this chapter that is performed on a pipeline or on an LNG facility.”4 From the onset of the drug testing regulations in 1988, PHMSA has specified that the functions performed by employees subject to the regulations are operations, maintenance, and emergency- response functions performed on a pipeline. Your question relates to a natural gas pipeline facility regulated under Part 192, in which § 192.3 defines a “pipeline” to mean “all parts of those physical facilities through which gas moves in transportation, including pipe, valves, and other appurtenance attached to pipe, compressor units, metering stations, regulator stations, delivery stations, holders, and fabricated assemblies.” You also reference § 192.615, which, among other things, requires operators to establish written procedures and perform other actions to minimize the hazard resulting from a gas pipeline emergency. The D&A testing regulations do not necessarily cover all emergency-response functions listed in § 192.615. Only those functions in § 192.615 that are performed on a pipeline are “covered functions.” So, while “receiving, identifying, and classifying notices of events which require immediate response by the operator” [§ 192.615(a)(2)] is a required emergency-response function, it is not performed on a pipeline and is therefore not a D&A covered function. However, the “emergency shutdown and pressure reduction in any section of the operator's pipeline system necessary to minimize hazards to life or property” [§ 192.615(a)(6)] is a D&A covered function because it is performed on a pipeline. In your letter, you referenced PHMSA interpretation PI-20-0007 (April 24, 2020), which cited to an earlier interpretation (PL-90-003 dated February 13, 1990) that stated service clerks responsible for performing the following three things are “covered employees” subject to D&A testing: 1. receiving telephone notices of gas leaks, 2. identifying those notices that require immediate response by the company; and 3. dispatching personnel to the scene. PHMSA listed those three steps because the accomplishment of all three steps is necessary to meet the requirement that the emergency response function is being performed on a pipeline. In the absence of step three, the emergency response of the CSRs is not performed on a pipeline. You also explain in your letter that the CSRs working for Orange and Rockland Utilities receive telephone notices of gas leaks and identify those notices that require immediate response by the company, but they do not dispatch personnel to the scene. Instead they send gas emergency calls to the operator’s gas emergency response center (GERC), the hub for all gas leak dispatching. Without reviewing the operator’s CSR processes, and based only on the information you provided in your letter, the “dispatching of personnel to the scene” function (item # 3 above) is not performed by the CSRs but by the operator’s GERC. If that is correct, then the CSRs are not 4 66 FR 47114, 47118 (emphasis added). The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or obligations, and are provided to help the specific requestor understand how to comply with the regulations. <<>> 3 performing an emergency response on the pipeline and, therefore, are not “covered employees” subject to PHMSA drug testing. Notwithstanding the above, nothing in Part 199 prohibits an employer from D&A testing any of its employees using non-DOT procedures, including those employees already subject to D&A testing under PHMSA regulations. If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523. Sincerely, John A. Gale Director, Office of Standards and Rulemaking The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or obligations, and are provided to help the specific requestor understand how to comply with the regulations. <<>> I.B.E.W. L □ CAL UNl □ N S03 2657 ROUTE 17M GOSHEN, NY1O924 December 7, 2021 PHONE (845) 294.1337 FAX (845) 294.9754 EMAIL: IBEW5O3@1BEW5O3.COM Office of Pipeline Safety (PHP-30) PHM SA, U.S. Department of Transportation 1200 New Jersey Avenue SE. W ashington, DC 20590-0001 Good afternoon, M y name is M elissa Kurtz and I am the Business Representative for I.B.E.W. Local 503 located in Goshen NY. M y Local represents many of the workers at Orange and Rocklan. d Utilities which is a subsidiary of Con Edison. M any of the M embers that work in the Customer Service Department.have come to us with a concern that they are falsely being deemed "covered employees" for D &A testing.and should not be tested for marijuana. I am writing you today to request that PHM SA perform an interpretation of the. federal pipeline safety regulations in 49 CFR 192.615 with respect to the Customer Service Representatives (CSRs) working for Orange and Rockland Utilities. In interpretation response #Pl-20-0007, you state, "Under 49 CFR 192. 615, any person who performs on a gas pipeline a regulated operating, maintenance, or emergency response function is subject to POT mandated drug testing." This office also lists three tasks associated with being a "covered employee" subject to D &A testing: 1. 2. 3. Receiving telephone notices of gas leaks. The C SRs at O range and R ockland Utilities do perform this task. They routinely answer-both electric·ancl gas emergency ca!ls, as well as other billing inquiries. Identifying those notices that require immediate response by the Company. Through the use of a Company developed line of que$tidning the CSRs are trained to send the g as emergency calls to the G ERC. Dispatching personnel to the sceAe. This task is NEVER performed by our C SRs. Orange and Rockland has an established GERC (Gas Emergency R esponse Center) which is the hub for all gas leak dispatching, ti'l'!e reporting and . leak tracking,:At no tim e does a C SR dispatch any gas response personnel to any leak or location. Local 503 believes that due to the fact that the CSRs at Orange and Rockland Utilities do NOT perform all three functions making them "covered employees", that they ate wrongfully being. tested for marijuana using DOt procedures. This Local is not disputing that the Company has the right to drug and alcohol testing, we simply do not believe that the CSRs fijll into the DOT testing pool. • r' : • If any further information is needed, please feel free to contact me at (845) 294-1337. I look ft :>rw a ;d · t~ an interpretation response from PHM SA regarding this issue. -· ' · · · M elissa Kurtz Business Representative I.B.E.W Local Union 503 <<>> EXHIBIT C <<>> February 5, 1991 Mr. Patrick J. Clark Sr. Industrial Relations Representative Orange and Rockland Utilities, Inc. One Blue Hill Plaza Pearl River, NY 10965 Dear Mr. Clark: I am responding to your letters of November 21, 1990, and January 28, 1991, regarding our drug testing rules in 49 CFR Part 199. You asked whether personnel who relieve Orange and Rockland's customer service representative during severe storm conditions are subject to drug testing. Your November letter indicated that the customer service representatives are subject to drug testing under Part 199 because they record information customers report about gas leaks. In addition, you said that sever storm conditions occur rarely, and that relief personnel do not usually receive reports of leaks during the short span of their relief assignments. Recording information about gas pipeline leaks is a regulated emergency-response function to which Part 199 applies. When an operator engages a person to do this function, that person is subject to drug testing under Part 199. We conclude from your November letter that relief personnel are responsible for recording leak reports that come in while they are on duty during a severe storm. Although the relief personnel may seldom receive such reports, Part 199 does not except from coverage persons who do regulated emergency-response functions only temporarily or rarely. Therefore, the relief personnel are subject to drug testing under Part 199 as well as the customer service representative. I apologize for not answering your first letter sooner. We are always pleased to provide whatever information operators may need to understand the Part 199 drug testing requirements. Sincerely, George W. Tenley, Jr. Associate Administrator for Pipeline Safety <<>> EXHIBIT D <<>> May 9, 1991 Mr. Steven G. Rush Dorsey & Whitney 2200 First Bank Place East Minneapolis, MN 55402-1498 Dear Mr. Rush: I am responding to you letter of March 28, 1991, to Cesar De Leon regarding RSPA's drug testing regulations in 49 CFR Part 199. You asked whether persons who do a covered function infrequently or who have a potential to do a covered function are subject to all five types of drug testing. As you correctly noted, the persons subject to drug testing under Part 199 are those that come under the Part 199 definition of employee. Part 199 are those that come under the Part 199 definition of employees. Part 199 does not except from drug testing persons who serve infrequently as an employee, such as someone who substitutes for an employee on vacation or sick leave. Also, Part 199 does not allow pipeline operators to conduct only some types of drug testing with respect to persons used infrequently as employees. However, persons to remain continuously under a Part 199 drug testing program would be subject to pre-employment testing only the first time they are engaged to perform a covered function. As for persons who have a potential to do a covered function, each person an operator engages as a Part 199 employee is subject to drug testing, even if that person has not yet done a covered function. For example, a person an operator employs for an emergency-response function may not have to do the function until sometime in the future. Meanwhile, the person is subject to each type of drug testing to assure that prohibited drugs do not impair the person's capacity to do the function should an emergency occur. Thank you for your inquiry. Please let me know if you need any more information about our drug testing requirements. Sincerely, George W. Tenley, Jr. Associate Administrator for Pipeline Safety <<>> EXHIBIT E <<>> Utility Procedure: TD-6700P-02 Publication Date: 11/17/2021 Effective Date: 02/01/2022 Rev: 2a Gas Dispatch and Scheduling Procedure for Priority Zero Gas Field Orders SUMMARY This utility procedure describes how Pacific Gas and Electric (PG&E or Company) work and resource (W&R) gas dispatch personnel process immediate response (IR) Priority Zero gas field orders (FOs) on a 24-hour, 365-day basis. Level of Use: Informational Use TARGET AUDIENCE Gas W&R dispatch personnel For information only: Field Services personnel SAFETY Potential hazards associated with gas dispatch and scheduling work include ergonomic risks from general office activity. BEFORE YOU START Successfully complete the dispatcher-in-training (DIT) program or (if currently in the DIT program) work under the direction of fully-trained gas W&R dispatchers, relief dispatchers, or supervisors. TABLE OF CONTENTS SUBSECTION TITLE PAGE 1 Overview ........................................................................................................... 2 2 Dispatching an IR Priority Zero Gas Field Order ................................................ 2 3 Dispatching Field Orders to Personnel Currently Working on Another Field Order ................................................................................................................. 4 4 Dispatching Multiple IR Priority Zero Field Orders for the Same Area ............... 4 5 Pipeline Ruptures and Explosions ..................................................................... 5 6 Area Odor Events .............................................................................................. 5 7 Potential Grade One Leak ................................................................................. 5 8 Potential Cross Bore ......................................................................................... 6 PG&E Internal Printed copies of this document might be out of date. The Technical Information Library (TIL) has the current version. ©2021 Pacific Gas and Electric Company. All rights reserved. Page 1 of 9 <<>> Utility Procedure: TD-6700P-02 Publication Date: 11/17/2021 Effective Date: 02/01/2022 Rev: 2a Gas Dispatch and Scheduling Procedure for Priority Zero Gas Field Orders PROCEDURE STEPS 1 Overview 1.1 Respond to each gas IR Priority Zero gas field order (IR FO) in a timely manner. 2 Dispatching an IR Priority Zero Gas Field Order 2.1 Determine the appropriate field service person to receive the IR FO as follows: 1. Using mapping tools as needed, assess location of field resources to identify field service personnel who can best respond to the IR FO location. 2. Minimize dispatching multiple IR FOs to one field service person. a. Attempt to identify to the closest field service person not assigned an IR FO before dispatching multiple IR FOs to the same field service person. b. Consider the nearest alternative available field service personnel in, but not limited to, the headquarters or division. 3. If necessary, use the appropriate 212 list. 2.2 Contact the identified field service person as follows: 1. Use the approved process of cell phone as the primary means of contact and radio as secondary (except in areas where the exception has been implemented). 2. Get verbal acceptance to respond to the IR FO (e-page only when radio and phone call not possible) and note their estimated time of arrival (ETA). 3. IF attempts to contact the field service person are unsuccessful (there is no mandated wait time), THEN direct the IR FO to the available field service person with the next shortest ETA. 4. Repeat Step 2.2.3 as needed until a field service person is contacted, or the list of shift personnel is exhausted. 5. IF list of shift personnel is exhausted, THEN determine, based on customer service representative’s remarks, whether IR FO should be issued to field service personnel already working on an IR FO (stacking). a. IF stacking is appropriate, THEN obtain dispatch supervisor approval to issue IR FO to field service personnel already working on an IR FO. PG&E Internal Printed copies of this document might be out of date. The Technical Information Library (TIL) has the current version. ©2021 Pacific Gas and Electric Company. All rights reserved. Page 2 of 9 <<>> Utility Procedure: TD-6700P-02 Publication Date: 11/17/2021 Effective Date: 02/01/2022 Rev: 2a Gas Dispatch and Scheduling Procedure for Priority Zero Gas Field Orders 2.2 (continued) 6. IF NO field service personnel are available, THEN follow the callout procedures. 7. IF NO field service personnel are available through callout, THEN contact the field service personnel supervisor for further instructions AND notify the dispatch supervisor. 2.3 After verbal or electronic acceptance of IR FO is received, dispatch the IR FO as follows: 1. Confirm whether the field service person is in available status in field automation system (FAS). 2. Dispatch the IR FO. a. Attempt to have all IR FOs dispatched in 4 minutes or less. 3. Use one of the following means to verify that the field service person arrives at the IR site by the ETA:  Verify via FAS (if available).  Make contact by the approved process of radio and/or phone. 4. IF field service personnel do not arrive at the IR site by the ETA provided, THEN perform steps below as needed. a. IF the delay will continue to prevent a timely arrival of the field service personnel, THEN dispatch additional or alternate field service personnel as needed. b. IF no other field service personnel are available THEN ask the nearest fire department or law enforcement agency to stand by AND request an emergency response escort to the location. When requesting police escort, state, “PG&E is requesting police escort for a serious gas leak.” c. IF a 911 agency is on-site and there is a delay on the original ETA provided, THEN provide the agency with the updated ETA. PG&E Internal Printed copies of this document might be out of date. The Technical Information Library (TIL) has the current version. ©2021 Pacific Gas and Electric Company. All rights reserved. Page 3 of 9 <<>> Utility Procedure: TD-6700P-02 Publication Date: 11/17/2021 Effective Date: 02/01/2022 Rev: 2a Gas Dispatch and Scheduling Procedure for Priority Zero Gas Field Orders 2.4 Record the following information in the dispatcher remarks on the IR FO (for additional guidance, refer to Utility Procedure TD-6700P-01, Attachment 1, “Dispatcher Remarks”):  All contact attempts. For unanswered calls, note “Tech ID RDNA/DNA (radio did not answer)” and time called.  The ETA to the IR FO site. Record the estimated arrival time, not the amount of time needed to reach the site (e.g., 13:40, not 30 min.).  The actual time of arrival (unless recorded in FAS). 3 Dispatching Field Orders to Personnel Currently Working on Another Field Order 3.1 IF an IR FO is dispatched to field service personnel currently planning or conducting a non- priority Company-generated FO, THEN the gas W&R dispatcher may reschedule or reassign the Company-generated field order (not emergency work) to the same or other field service personnel for completion. 3.2 IF an IR FO is dispatched to gas field service personnel currently working a customer- generated FO, THEN, if necessary, the dispatcher may reassign the customer-generated FO to other field service personnel to complete. 4 Dispatching Multiple IR Priority Zero Field Orders for the Same Area 4.1 When notified by field service personnel that an IR site has been made safe, perform the following steps: 1. Create a make-safe turn-on FO (4196) in customer care and billing (CC&B). a. Note “IRMS” (IR made safe) as the first characters, then copy and paste the original remarks of the made-safe FO in the Office Remarks. 2. Note “IRMS (IR made safe) + Tech ID of Make Safe GSR + LAN ID of Dispatcher” in DSP Remarks. Example: IRMS D2GD0M9 SAC4 PG&E Internal Printed copies of this document might be out of date. The Technical Information Library (TIL) has the current version. ©2021 Pacific Gas and Electric Company. All rights reserved. Page 4 of 9 <<>> Utility Procedure: TD-6700P-02 Publication Date: 11/17/2021 Effective Date: 02/01/2022 Rev: 2a Gas Dispatch and Scheduling Procedure for Priority Zero Gas Field Orders 5 Pipeline Ruptures and Explosions 5.1 IF an IR is due to an explosion or suspected transmission pipeline rupture, and field service personnel notify Gas Dispatch of a delay in response or ETA, THEN perform the following steps: 1. Update the ETA on the IR FO. a. IF the updated time exceeds communicated on-site time response limits, THEN gas W&R dispatch personnel may attempt to dispatch other field service personnel. (1) IF other field service personnel are not available, THEN ask the nearest fire department or law enforcement agency to stand by AND request an emergency response escort to the location. 2. Notify Electric Dispatch personnel of an explosion or suspected transmission pipeline rupture report AND provide an address for the creation of an electric IR tag. 6 Area Odor Events 6.1 Gas W&R dispatcher may dispatch IR FOs related to the same area odor event to the same responding field service personnel. 6.2 Take appropriate actions as needed based on field service personnel findings per Utility Procedure TD-6700P-03, Attachment 5, “Area Odor Guideline. ” 7 Potential Grade One Leak 7.1 IF field service personnel determine a subsurface gas leak is hazardous, as directed in Utility Procedure TD-6100P-02, “Gas Leak and Odor Investigations, ” THEN create a work order in the Event Management Tool (EMT), requesting that qualified gas maintenance and construction (M&C) field personnel repair the leak per Utility Procedure TD-4470P-01, “Gas Crew Tracking Process for Gas Leak or Odor Investigation.” PG&E Internal Printed copies of this document might be out of date. The Technical Information Library (TIL) has the current version. ©2021 Pacific Gas and Electric Company. All rights reserved. Page 5 of 9 <<>> Utility Procedure: TD-6700P-02 Publication Date: 11/17/2021 Effective Date: 02/01/2022 Rev: 2a Gas Dispatch and Scheduling Procedure for Priority Zero Gas Field Orders 7.2 IF a field resource that is not qualified for leak grading encounters a subsurface gas leak that is non-hazardous, as described in TD-6100P-02 THEN perform the following steps: 1. Dispatch FO request to operator-qualified gas field personnel to grade the subsurface leak. a. IF no qualified field personnel are available, THEN create a work order in EMT (per TD-4470P-01), requesting leak grade- qualified gas M&C field personnel to investigate and grade leak per TD-TD- 4110P-09. 2. IF a gas leak source is identified as another utility’s gas main or service, THEN ask the responsible utility to respond. 8 Potential Cross Bore 8.1 IF Gas Dispatch receives 911 call or FO from contact center for a cross bore event, THEN dispatch a gas service representative (GSR) and advise the M&C supervisor-in-charge of a potential cross bore. 1. Gas M&C supervisor may dispatch an M&C crew. 2. Gas dispatcher creates an EMT record identifying the incident as a “cross bore.” a. IF identified as cross bore, THEN Gas Distribution Control Center (GDCC) will handle event, OTHERWISE Gas Dispatch will handle event 3. Create EMT event on initial cross bore field order END of Instructions PG&E Internal Printed copies of this document might be out of date. The Technical Information Library (TIL) has the current version. ©2021 Pacific Gas and Electric Company. All rights reserved. Page 6 of 9 <<>> Utility Procedure: TD-6700P-02 Publication Date: 11/17/2021 Effective Date: 02/01/2022 Rev: 2a Gas Dispatch and Scheduling Procedure for Priority Zero Gas Field Orders DEFINITIONS Cross bore: An intersection of an existing underground facility or structure by a second facility installed using trenchless technology resulting in direct contact between the facilities, compromising the integrity of the facility or underground service. Priority Zero: Immediate response (IR) emergency field order. IMPLEMENTATION RESPONSIBILITIES The supervisors responsible for dispatch and scheduling will ensure that personnel who perform dispatch and scheduling work are trained and knowledgeable about this utility procedure. GOVERNING DOCUMENT Utility Standard TD-6700S, “Gas Dispatch and Scheduling Operating Practices” COMPLIANCE REQUIREMENT / REGULATORY COMMITMENT Records and Information Management: Information or records generated by this procedure must be managed in accordance with the Enterprise Records and Information (ERIM) program Policy, Standards and Enterprise Records Retention Schedule (ERRS). REFER GOV-7101S, “Enterprise Records and Information Management Standard” and related standards. Management of records includes, but is not limited to:  Integrity  Storage  Retention and Disposition  Classification and Protection REFERENCE DOCUMENTS Developmental References: Pacific Gas and Electric Company, “Code of Conduct for Employees” Pacific Gas and Electric Company/IBEW Labor Agreement Utility Manual TD-9660M, Tariff Application Guide PG&E Internal Printed copies of this document might be out of date. The Technical Information Library (TIL) has the current version. ©2021 Pacific Gas and Electric Company. All rights reserved. Page 7 of 9 - **truncated:** true - **body characters:** 350158