Regulatory Compliance Management
Knowledgeable in both state and federal codes, GTS brings confidence to our clients in achieving pipeline safety regulatory compliance for natural gas pipeline transmission and distribution systems.
- Quality Control – Quality review protocols for operations and maintenance include leak survey, leak repair, valves, regulator stations, corrosion control, odorization, and instrument calibration.
- Pre-Audit Preparation – reviews of pipeline maintenance, facility maintenance, Public Awareness, Drug and Alcohol, Safety and Operator Qualification programs for compliance with the requirements of 49 CFR Part 192, API RP 1171 and API RP 1173
- Rate Case Strategy & Support – provides professional services through all phases of commission proceedings.
The project example below provides more detail on our Regulatory Compliance Management experience:
Key Project
Regulatory Compliance Support
In the aftermath of the San Bruno Incident, the California PUC mandated California’s investor owned utilities to submit individual plans; Pipeline Safety Enhancement Plans (PSEP) to address: pipeline modernization, valve automation, pipeline records integration and interim safety enhancements. GTS has been providing PSEP rate case preceding support services to a large utility client in California in support of their PSEP reasonableness review filing. The work includes preparing workpapers that substantiate and defend the projects recoverable costs, as well as written testimony and data request response. The workpapers are prepared with factual objective writing and verifiable project cost data utilizing project documentation analysis, information gained from project experience, or from project subject matter experts. The detailed technical data is tracked and archived for future reference and historical accuracy.
Creation of the workpaper is done with the understanding of the final workpaper, and may be reviewed by parties who may be unfamiliar with the technical and logistical challenges associated with completing these difficult pipeline safety enhancement projects. The contribution by GTS to the rate case preceding support included workpapers for 20 hydrotest, replacement, and valve enhancement projects that valued $228,000,000 of recoverable costs.