Report on PG&E Record Keeping

8/20/2019 Report on PG&E Record Keeping

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Investigation of PG&E Distribution System Recordkeeping

Investigation of PG&E Distribution System Recordkeeping

In Support of OII.14-11-008

Prepared for

The Safety and Enforcement Division

California Public Utilities Commission

Prepared by

P Wood Associates (PWA)

David Berger, John Gawronski and Paul Wood

September 30, 2015


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Investigation of PG&E Distribution System Recordkeeping i

TABLE OF CONTENTS

0. EXECUTIVE SUMMARY ....................................................................................................... 1

0.1 Scope of Investigation ......................................................................................................... 1

0.2 Facts Related to PG&E Recordkeeping ............................................................................... 1

0.3 Major Findings ..................................................................................................................... 2

0.4 Categories of Violations ...................................................................................................... 3

1. INTRODUCTION ..................................................................................................................... 5

1.1 Purpose and Scope ............................................................................................................... 5

1.2 Approach .............................................................................................................................. 5

1.3 Background .......................................................................................................................... 6

1.3.1 Incidents identified in the OII ............................................................................... 6

1.3.2 PG&E Response to the OII ................................................................................... 7

1.4 Impact of Records Gaps on Distribution System MAOP .................................................... 8

2. PREVIOUS PG&E AND CPUC INVESTIGATION OF RECORDS...................................... 9

2.1 Previous Consideration of Recordkeeping Issue ................................................................. 9

2.2 Findings of Duller and North’s Related to Recordkeeping at PG&E .................................. 9

2.3 Previous Studies of Records Adequacy at PG&E ............................................................. 11

3. PWA APPROACH TO THE INVESTIGATION ................................................................... 12

4. APPLICABLE REGULATIONS ............................................................................................ 25

4.1 Elements of a Safety Code Violation ................................................................................. 25

4.2

Applicable Pipeline Safety Requirements ......................................................................... 25

4.3 Records Necessary to Demonstrate Compliance ............................................................... 25

4.4 General Recordkeeping Requirements .............................................................................. 31

5. FACTORS CONTRIBUTING TO RECORDKEEPING-RELATED INCIDENTSAND VIOLATIONS ...................................................................................................... 34

6. EVIDENCE OF NON-COMPLIANCE .................................................................................. 36

6.1 Violations Associated with the Six OII Incidents .............................................................. 37

6.2 Additional PG&E Violations Identified during the Investigation ..................................... 40

6.2.1

Violations associated with additional incidents .................................................. 41

6.2.2 Violations associated with the relationship between incidents atMountain View and Carmel ................................................................................ 47

6.2.3 Violations associated with establishment of maximum allowableoperating pressure (MAOP) ................................................................................ 49


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Investigation of PG&E Distribution System Recordkeeping ii

7. CHANGES IMPACTING PG&E’S CONTROLS ON NATURAL GASDISTRIBUTION MAPPING AND RECORDKEEPING ............................................. 55

8. EVALUATION OF CORRECTIVE ACTIONS AND BACKSTOP MEASURES ............... 57

8.1 Recent SED Inspections Regarding the Effectiveness of PG&E Mapping ....................... 57

8.2 Design, Implementation and Effectiveness of PG&E’s Backstop Measures andCorrective Actions ............................................................................................................. 57

8.3

Adequacy of Training ........................................................................................................ 69

8.4 Observations on Root Cause Analysis ............................................................................... 71

9. CONCLUSIONS AND RECOMMENDATIONS .................................................................. 73

9.1 Conclusions ........................................................................................................................ 73

9.2 Recommendations .............................................................................................................. 75

Table 1 Relevant Details of the Six Incidents Described in the OII ........................................ 14

Table 2 Additional Incidents Evaluated for OII ...................................................................... 15

Table 3 Time Line for Map and Record Requirements ...........................................................27Table 4 Violations Associated with Additional Incidents Evaluated for OII .......................... 42

Table 5 Violations related to Incidents at Mountain View and Carmel .................................. 48

Table 6 PG&E MAOP Time Line ........................................................................................... 49

Table 7 List of available MAOP Correspondence ................................................................... 53

Table 8 SED-Identified Mapping Errors and Omissions ......................................................... 57

Table 9 Evaluation of PG&E Corrective Actions and Backstop Measures ............................. 59

Table 10 Evaluation of Training Adequacy ............................................................................. 69

Table E-1 Additional Incidents Derived from PG&E Responses to Data Requests ............. 125

FIGURE D-1 PRUDENT MANAGEMENT OF PIPELINE MAPS AND R ECORDS ............................... 123

Attachment A Qualifications of PWA Staff ............................................................................ 77

Attachment B Summary of DRs and Status of Responses (current on 09/18/15) ................... 84

Attachment C Compilation of Current Regulations Affecting Records and Maps ............... 111

Attachment D Standard of Care for Pipeline Maps and Records .......................................... 119

Attachment E Examples of Factors Contributing to Records and Mapping Issues ............... 124

Attachment F Observations on Root Cause Analysis ............................................................ 128

Attachment G Response to March 6, 2014 Gas Incident Violation Letter MountainView, California, Sumeet Singh (PG&E) to Michael Robertson, April 4, 2014 ............. 131


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Investigation of PG&E Distribution System Recordkeeping 1

0. EXECUTIVE SUMMARY1

0.1 Scope of Investigation2

The Safety and Enforcement Division (SED) of the California Public Utilities Commission (CPUC)3contracted with P Wood Associates (PWA) to:4

Investigate whether PG&E violated any provision of the CPUC code, Commission5general orders or decisions, applicable rules or requirements, or other state or federal6laws pertaining to safety recordkeeping for its natural gas distribution system.7

Identify recordkeeping violations that have occurred.8

Evaluate whether the actions the PG&E has planned and initiated to compensate for9known deficiencies in recordkeeping are reasonable, are taking hold in the field, and are10having the desired impact on safety.11

Provide a report and testimony in support of the PG&E Gas Distribution Records12

proceeding I.14-11-008.13

This section summarizes the facts and findings assembled from a series of presentations by PG&E14managers, structured interviews of PG&E staff, PG&E responses to an extensive set of data requests,15and evaluation of select CPUC incident and inspection reports.16

0.2

Facts Related to PG&E Recordkeeping17

Regulations describing requirements for records retention have been in place for decades, with the18earliest identified being issued by the California Railroad Commission in 1932.1 19

Over the years PG&E has developed policies and procedures intended to assure compliance with20these regulations.2 21

Violations related to recordkeeping were not the result of defective procedures, rather resulted from22failure to follow the procedures, including failure to keep the records secure. Early versions of23PG&E standard practice for mapping standards such as SP 410.21 effective April 1977 through24May 1980 appear to have adequate detail3 to capture accurate and sufficient information for maps25to be used by operating personnel. Requirements addressed security4 of original maps to prevent26their loss, and included an instruction to keep authorizations concerning installed mains27 permanently for reference.28

Inaccurate and missing records and maps have contributed to incidents, including those described29in the OII.30

PG&E has designed and implemented numerous measures intended to correct acknowledged31

imperfections5 in its maps and records and to provide backstops to minimize risks associated with32

1 Standards for Gas Service in the State of California, General Order No. 58-A, effective July 1, 1932. This wasthe third edition of this standard; the initial version was effective September 1, 1919.

2 See for example PG&E Mapping Standards, Standard Practice No. 410.21-1, 04/01/77.

3 See SP 410.21-1 page 9 for main pressure requirements, position of valves, page 11 for gas mains characterand history such as type of joint, size, location, kind of pipe, authorization, year installed, page 15 for insertmains, pages 16-19 for posting gas service information (house number, size, year installed, additionalmeasurements when service pipe is not at right angles to the main or property line, stub services, and insertservices.

4 See SP 410.21-1 pages 31-32.

5 PG&E Initial Report in Response to the OII, December 22, 2014.


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these errors and omissions. However, ongoing map correction activities are typically opportunistic1(i.e., carried out in the normal course of maintenance) rather than proactive.2

PG&E is completing implementation of the Pathfinder Project to bring together available3information to identify and correct inconsistencies, to improve the accuracy of its maps and4records, and to provide easy field access to maps and records through the Gas Distribution5Geographic Information System (GD GIS) using the Pathfinder Viewer.6

PG&E has avoided implying that completeness and accuracy issues will be fully resolved through7

completion of the Pathfinder Project.8

The US Department of Transportation Distribution Integrity Management Program (DIMP)6 9regulation recognizes the existence of accuracy and completeness issues in distribution pipeline10maps and records.11

The DIMP regulation requires utilities subject to its provisions to implement measures to improve12the accuracy of maps and records based on numerous sources of information associated with13normal activities in the field.14

PG&E has implemented a program to, among other functions, address certain aspects of this15requirement – the Corrective Action Program (CAP).16

PG&E has not implemented programs beyond CAP that are designed to identify and characterize17recognized imperfections in its maps and records associated with pipe inserts and stubs.18

PG&E has not fully addressed the root cause of damages to its gas lines resulting from the19elimination of retired and abandoned gas lines from maps. Information on the locations of retired20in place gas lines is needed to support locate and mark activities as well as other operating and21maintenance activities to help avoid confusion over live versus retired in place gas lines when22excavations in their proximity take place.23

PG&E has established the Maximum Allowable Operating Pressure (MAOP) for 243 of its 1,37624hydraulically independent distribution systems using an approach different from that prescribed in25the 1970 pipeline safety regulation Title 49 of the Code of Federal Regulations (49 CFR)26

§192.619(c).270.3 Major Findings28

Evidence from recent incidents gathered in support of this OII indicates that PG&E has failed to29follow the regulations and its procedures regarding record keeping - including both maps and30records.31

Factors contributing to accidents, incidents and third party damage included: lack of records, maps32

not being updated in accordance with mapping procedures, and PG&E not maintaining control and33updating historical records of gas distribution mains and service lines.34

PG&E’s approach to establishing the MAOP for 243 hydraulically independent distribution35

systems is in violation of the 1970 requirement of 49 CFR §192.619(c) describing the bases on36which MAOP is to be established for so called “grandfathered” segments of its system. It is37 probable that this violation resulted because of the absence of the distribution system pressure38records/charts associated with the five years (1965 through 1970) needed to comply.39

40

6 Refer to 49 CFR §192.1007 and §192.605(b)(4).


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We have seen no evidence that PG&E reviewed or requested approval of its approach to1establishing MAOP of its distribution systems with the CPUC7.2

Regulations such as 49 CFR §192.605(b)(4), §192.605(b)(8), §192.617, §192.1007, and §192.613,3have existed for many years requiring utilities to understand their systems, to evaluate the causes4and implications of incidents, and to incorporate the lessons from these investigations into utility5 policies, procedures and programs.6

PG&E’s handling of the incident at Mountain View (07/30/13), a clear precursor of the incident at7

Carmel (03/03/14), supports the conclusion that PG&E has failed to comply with these “learning8from experience” regulations; until an incident is sufficiently high profile that action must be taken.9

California Government Code (CGC) 4216.3(a)(1) requires utilities either to locate and mark10(L&M) underground structures near identified excavation sites, or to agree with the excavator on a11delay in excavation until the L&M activity can be completed.12

An interview with , Sr. Gas Compliance Representative an individual responsible for13locating and marking gas lines prior to excavation, supports the conclusion that PG&E has14substituted a permissive “notification” policy/practice (i.e., contact of the excavator when the L&M15cannot be completed on time can be as late as the night before the excavation and does not need to16include direct contact with the excavator – a voice mail message is acceptable) for the requirement17

to mutually agree with the excavator on a delay in the completion of the L&M activity. This18substitution, evidenced in the San Jose incident (11/07/14) described in Table 4 of this report,19violates CGC 4216.3(a)(1).20

Evidence gathered in CPUC inspections during July and August of 2015 shows that some of the21new processes and procedures PG&E has put in place to prevent inaccurate and incomplete22changes to maps and records are not yet working as intended.23

PG&E has established an Internal Audit (IA) program, which management is using to investigate24

the completeness and effectiveness of the numerous changes in information systems, procedures25and practices it has implemented.26

0.4 Categories of Violations27

The CPUC adopted the 1958 edition of ASA B 31.8 code for transmission and distribution piping as28well as additional requirements for design, construction, testing, maintenance and operation in General29Order (GO) 112, effective January 17, 1961. The CPUC stated its intention in GO 112 Section 104.130that all work performed within the scope of these rules shall meet or exceed the safety standards31expressed or implied herein. GO 112 Section 301.1 states the utility is responsible for maintenance of32necessary records to establish compliance with these rules. CPUC General Order112-E Section 101.233incorporates 49 CFR Part 192.34

PWA found that PG&E lacked the necessary records to comply with code requirements, primarily as a35result of not maintaining its maps and records up to date. The following identifies the primary areas36of violations PWA identified as a result of its investigation into PG&E’s distribution record-keeping37 practices. Further details and information concerning these violations are provided in in Section 6 of38this report.39

Failure to follow written procedures to ensure operating maps and data are updated and40accurate. Not maintaining control and updating historical records of gas distribution mains and41

7 In 1999 the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued guidance providing forregulatory review of alternative approaches to the 1971 code requirement for establishing MAOPs ofdistribution systems.


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service lines. Repeated failure to correct recordkeeping violations despite having adequate1knowledge for decades. 49 CFR §192.603(b), §192.605(a), §192.605(b)(3), §192.13(c) and2Public Utilities (PU) Code Section 451 and Section 961.3

Failure to mark out and inspect its gas lines in the area of excavation after receiving valid4

Underground Service Alert notification in accordance with California Government Code54216.3(a)(1), 49 CFR §192.614(c)(5) and 49 CFR §192.614(c)(6).6

Failure to carry out data gathering to evaluate the causes and implications of incidents, and to7

incorporate the lessons from these investigations into utility policies, procedures and programs8in accordance with 49 CFR §192.605(b)(4), §192.605(b)(8), §192.613, §192.617, §192.10079and PU Code Section 451 and Section 961.10

Failure to meet operating pressure restrictions contained in 49 CFR §192.619(a), or establish11the maximum allowable operating pressure (MAOP) for 243 hydraulically independent12distribution systems in accordance with 49 CFR §192.619(c).13

14


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1. INTRODUCTION1

1.1 Purpose and Scope2

In November 2014, the California Public Utilities Commission (CPUC) issued an Order Instituting3Investigation8 with the following purpose:4

In response to several incidents, by this order, the California Public5Utilities Commission (“Commission”) institutes a formal investigation to6determine whether Pacific Gas and Electric Company (“PG&E”),7violated any provision or provisions of the California Public Utilities8Code (“Public Utilities Code”), Commission general orders or decisions,9other applicable rules or requirements pertaining to safety recordkeeping10 for its natural gas distribution service and facilities, and/or other state or11 federal laws. This investigation will review and determine whether12PG&E’s recordkeeping practices for its gas distribution system have been13unsafe and in violation of the law.14

In support of this investigation the Safety and Enforcement Division (SED) of the California Public15Utilities Commission (CPUC) contracted with P Wood Associates (PWA)9 to:16

Investigate whether PG&E has violated any provision of the CPUC code,17Commission general orders or decisions, or other state or federal laws or18applicable rules or requirements pertaining to safety recordkeeping for its natural19gas distribution system;20

Determine what recordkeeping violations, including those potentially associated21with PG&E’s approach to establishing the maximum allowed operating pressure22(MAOP) for distribution lines in operation prior to 1970, have occurred;23

Evaluate whether the actions the operator has planned and initiated to compensate24

for known deficiencies in recordkeeping are reasonable, are taking hold in the25field, and are having the desired impact on safety;26

Provide a report and testimony in support of the Gas Distribution Recordkeeping27 proceeding I.14-11-008.28

1.2 Approach29

In preparing this report, PWA consultants carried out the following activities:30

Reviewed the OII, the six Safety and Enforcement Division (SED) incident31

evaluation reports referenced in the OII, and PG&E’s initial response to the OII;10 32

Reviewed the twelve data requests (DRs) prepared by the SED and submitted on33March 4, 2015 to PG&E - prior to the beginning of the PWA engagement;34

8 Order Instituting Investigation and Order to Show Cause on the Commission’s Own Motion into theOperations and Practices of Pacific Gas and Electric Company with Respect to Facilities Records for its NaturalGas Distribution System Pipelines, OII.14-11-008, November 20, 2014, San Francisco Office.

9 Collectively, the three P Wood Associates (PWA) subject matter experts bring (46+15+23) 84 years of gastransmission and distribution pipeline experience, including experience as regulators, operators and consultants.See Attachment A for a description of the background and experience of the PWA subject matter experts:Berger, Gawronski and Wood.

10 PG&E Initial Report in Response to the OII, December 22, 2014.


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Over the course of the investigation prepared an additional 102 DRs as well as 251interrogatories under oath directed to four specific PG&E senior managers and2executives. These DRs and interrogatories are listed in Attachment B;3

Participated in two presentations (one by phone, one in person) by knowledgeable4PG&E managers on a number of records-related topics - these presentations were5designed to provide contextual information on ongoing PG&E activities;6

Visited the locations where the 6 incidents identified in OII 14-11-008 occurred,7

and accompanied SED inspectors on a corrosion inspection in one of those8Divisions;9

Reviewed select incident reports, including those for the six OII incidents;10

Interviewed six working level PG&E employees, in a monitored environment, to11 better understand how they discharge their responsibilities – these six employees12were selected by PG&E. The purpose of these interviews was to gain insight into13the records handling process that PG&E currently uses and those used in the past;14

Screened and reviewed the over nine thousand documents PG&E provided in15response to the 114 DRs;16

Reviewed the PG&E executive responses to twenty-five (25) interrogatories17under oath;18

Made and reviewed the responses to eight (8) oral requests of PG&E for data19

discussed during the presentations and interviews noted above;20

Conducted a search of past CPUC general orders and decisions that relate to21recordkeeping requirements, other state and federal recordkeeping requirements,22as well as reviewed recordkeeping issues identified during the San Bruno23investigation of PG&E’s failed gas transmission line.24

The information gathering approach described above was designed to support investigation of the25consistency among management intentions and direction, procedures used in the field and for mapping,26and how working-level staff actually carries out the work.27

In an effort to supplement the information gathered as described above with actual results from PG&E28implementation of maintenance and related mapping activities, PWA consultants relied upon29inspections carried out by SED inspectors during July and August of 2015. These inspections included30a review of how consistently leak repairs involving insertion of plastic pipe resulted in correct changes31to the maps in the Gas Distribution Geographic Information System (GD-GIS) – the field-accessible32system (using Pathfinder Viewer) in which distribution system maps along with supporting33information is stored.34

1.3 Background35

1.3.1 Incidents identified in the OII36In the OII, the CPUC identified six incidents that have occurred during the past 5 years associated with37PG&E’s record keeping practices. The six incidents include the following:38

1. A release of gas from a 1” plastic gas service line in Castro Valley in September 201039due to a mapping error that contributed to an erroneous locate and mark of the gas service40line. There were no injuries and minor property damage.41


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2. A release of gas from a ¾” steel stub service line in Morgan Hill in June 2012 that was1not marked because it was not included on the current underground utility map. There2were no injuries and minor property damage.3

3. The loss of gas service to nearly 1,000 customers in Milpitas in October 2012 resulting in4 part from a map showing a back-feed valve in the open position when it was closed. The5 job work resulted in gas flow being curtailed during a planned main replacement project6for which an approved clearance existed. There were no injuries but many customers7were without gas service.8

4. The release of gas from a 2” plastic gas main in Milpitas in March 2013 resulting from9the locate and mark being more than 2’ away from the pipe. There were no injuries and10only minor property damage.11

5. The release of gas resulting from welding on and tapping of a 1¼” steel service that had12an unknown 1” plastic insert in Mountain View in July 2013. There were no injuries but13 property damage was estimated at $10,000.14

6. The release of gas and an explosion that destroyed a house resulting from tapping of a 2”15steel main that had an unknown 1¼ plastic insert in Carmel in March 2014. There were16no injuries but significant property damage.17

18

In its 12/22/14 response, page 5 lines 3-4, PG&E states “With the minor exceptions noted below,19PG&E does not disagree with the factual contentions and conclusions regarding its gas distribution20recordkeeping stated in the SED Reports.” 11 PWA has evaluated these and other mapping-related21incidents, as well as additional information on the processes and procedures PG&E uses to assure the22accuracy of its maps and records, to determine whether violations have occurred and the nature of such23violations.24

1.3.2 PG&E Response to the OII25

As part of the OII process, PG&E was given 30 days to respond to the Order Instituting Investigation26and Order to Show Cause(OII). PG&E’s response12 to the OII makes several points, including:27

PG&E essentially agrees with the factual events in each of the six OII28incidents, but disagrees there were any related violations, or at least stated that29the violations cited by the CPUC in the OII are not valid;30

It contends that a company as large as PG&E cannot be expected to have31 perfect records.13 Its distribution system records span 50 or more years and32comprise 77,000 miles of pipe, making the “attainment of perfectly accurate33recordkeeping impossible”;34

PG&E has long recognized that it has imperfections in its maps and records,35and has initiated major improvement projects to improve the completeness,36

accuracy and accessibility of its maps and records, as well as other changes to37 prevent the recurrence of incidents similar to the six noted in OII.38

As evidence of its ongoing efforts, PG&E’s initial response to the OII enumerates approximately 2439activities in four categories:40

11 See PG&E Response to OII dated 12/22/14, page 5.

12 See PG&E Response to OII dated 12/22/14..

13 PG&E Response to OII dated 12/22/14, page 2.


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o Efforts to improve accuracy,1

o Efforts to improve map and record accessibility,2

o

Efforts to improve controls,3

o Actions to improve operational safety.4

Consistent with our charge by SED, PWA has evaluated each of these 24 improvement activities in5Section 8.6

1.4

Impact of Records Gaps on Distribution System MAOP7

Subsequent to issuance of the OII, the SED decided to roll into the investigation consideration of the8fact that records gaps in the late 1960’s led PG&E to establish the MAOP for 243 hydraulically9independent distribution systems using an approach different from that prescribed by 49 CFR10§192.619(c). The PG&E response to Data Request #87 stated that in 2008, PG&E concluded that the11use of the method described in TD-4125S to establish MAOP does not pose a safety risk to the12distribution system. Therefore, PG&E has not implemented any additional compensatory measures13specifically applicable to the associated pipe. Since no compensatory measures have been used, only14the compliance aspects of the MAOP issue have been evaluated in this report.15

16


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2. Previous PG&E and CPUC Investigation of Records1

2.1 Previous Consideration of Recordkeeping Issue2

The subject of generally accepted recordkeeping principles is not a new one for PG&E or the CPUC.3It was addressed in testimony by Duller and North as well as by Margaret Felts in Docket I. 11-02-016.4The findings of Duller and North’s work were based on Generally Accepted Record-keeping Principles5(GARP) Information Maturity Scores.14 The testimony of Duller and North found “gas transmission6records and safety related documents were scattered, disorganized, duplicated, and were difficult if not7

impossible to access in a prompt and efficient manner.”15 Issued in connection with the same8 proceeding, the testimony of Margaret Felts16 addressed how PG&E’s record keeping practices9affected PG&E’s transmission pipeline engineering.10

PWA did not evaluate PG&E’s recordkeeping practices in relation to GARP. PWA did however11review and learn from the Duller and North’s findings as they relate to companywide and distribution12recordkeeping practices. PWA has checked the applicability of findings from these reports to PG&E’s13distribution record keeping practices. In our evaluation we found that factors contributing to accidents,14incidents and third party damage included: the lack of records, maps not updated in accordance with15mapping procedures, and not maintaining control of and updating historical records of gas distribution16mains and service lines. The PWA report concentrates on the gas distribution engineering and17operations aspects of PG&E. Its findings complement the two transmission-focused reports noted18above, and point out deficiencies in record keeping practice that constitute violations of requirements19in the safety code.20

2.2 Findings of Duller and North’s Related to Recordkeeping at PG&E21

While Duller and North focused on transmission pipeline record keeping, many of the policies and22 procedures it cited in its review included both transmission and distribution systems. For example, the23following quote includes both transmission and distribution systems:24

“PG&E’s Internal Report 17

goes on to state that even today “related paper and25electronic records can be difficult to locate from office to office because of “the26unique process each office has created to ensure the Mappers have access to the27

information they need”; the “location and organization of physical records varies by28 location and is often only known to a few individuals performing the filing”; and29additionally, that “maps are inconsistent between Gas Transmission and Gas30 Distribution, as well as between divisions”. The lack of process and controls for field31 personnel submitting map corrections is cited, as a further cause for concern as “the32map correction process varies by location”, while the lack of controls over33contractors, is cited for “completeness, consistency, and quality of work” issues.”34

Duller and North’s report found:35

“This report contains a review and assessment of PG&E’s policies, procedures,36 practices and records, as provided via data requests; technical reports, provided37by the NTSB, CPUC and other third parties; interviews with PG&E staff; and, a38

14 Testimony of Duller and North, at p. 6-25, lines 30-32.

15 Testimony of Duller and North, at p. 1-10, lines 15-24.

16 Revised Report and Testimony of Margaret Felts, Docket I.11-02-016, March 16, 2012.

17 GasTransmissionSystemRecordsOII_DR_025-Q02(i) Supplement - Summary of Information ManagementKey Themes: PG&E Gas Mapping Organization , Internal PG&E report produced by PwC. [Preliminary Draftas of January 18, 2012].


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series of site visits to PG&E’s facilities. While this review focuses on1organization, access, storage, preservation, and retention of Gas Transmission2records and related documentation, the findings are also referenced against3PG&E’s corporate approach to records management.”4

“This report finds that PG&E’s pipeline records were widely distributed and poorly5controlled across the Gas Transmission Division.”6

“This review has used the "Generally Accepted Record-keeping Principles®" (GARP®)18

and7

the Information Maturity Model19

defined by ARMA International20

as the basis of an8assessment and evaluation of PG&E’s records management activities.”9

“On the basis of the GARP® criteria we find that records management within PG&E’s10Gas Transmission Division prior to the San Bruno pipeline rupture and fire were ‘Sub-11Standard’21 (Average Maturity Score = 1.2).” PWA note, the highest possible score12was 5. 13

“…PG&E failed to maintain the records management practices necessary to promote14the safety of its patrons, employees and the public. Examples of these failures include15the lack of company-wide strategy for record keeping: poor implementation of records16management standard practices; inappropriate disposal of pipeline history files;17

inadequate management and control of job folders; poor metadata quality control; and18 the uncontrolled distribution, duplication and storage of pipeline related job folders.”19

“As a result of these failures: PG&E’s historical pipeline records would not have been20readily available, traceable, verifiable or complete; there was no single source of21trusted pipeline-related documents, records management was not optimized to support22operations, decision making, planning or safety; and inconsistent, incomplete and out23of date information would have been present in a significant number of its pipeline24related job folders, as well as those systems, such as GIS, which relied upon them.

22”25

Duller and North did note in their testimony that PG&E has begun to address the records issues. These26changes are well underway, and PWA has included a discussion of the changes in Section 8.27

“In 2011 PG&E commissioned Pricewaterhouse Coopers (PwC) to undertake an28internal review of information management within its Gas Transmission Division.

23”29

This internal review included records management, document management, and data30management. A preliminary draft was provided to Duller and North as of January3118, 2012.”32

18 www.arma.org/garp; Principles include: accountability, compliance, transparency, availability, integrity, protection, retention, and disposition.

19 www.arma.org/garp/metrics.cfm .

20

ARMA International was previously known as Association of Records Managers and Administrators, and isthe authority on managing records and information in the USA (www.arma.org); Records management themesinclude: strategy, responsibilities, training, policies/standards/procedures, records retention, business continuity& vital records, records management processes, records management storage, and technology.

21 Level 1 (Sub-standard): An environment where record-keeping concerns are either not addressed at all, or areaddressed in a very ad hoc manner. Organizations that identify with these descriptions should be concerned thattheir programs will not meet legal or regulatory scrutiny.

22 Duller and North report dated March 5, 2012 page 6-25 lines 5-18.



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“CPSD understands PG&E plans to make necessary changes to its records1management processes based on the findings from the PwC assessment. These2changes are likely to encompass new policies, procedures, practices, systems and3improved training.”

24 4

2.3 Previous Studies of Records Adequacy at PG&E5

PG&E commissioned Bechtel Corporation to carry out two studies, one in 198425 and a follow-on6study in 199526, designed to evaluate pipe replacement priorities. This work was initially focused on7

transmission pipelines, but ultimately included distribution mains.8The 1984 report contained the following observation:9

P 13 – “During the data collection process, the area engineers were sometimes10confronted with the problem of missing records that prevented them from finding11variable values.”12

The follow-up 1995 report included the following observations:13

P ES-1 – “There has been an ongoing effort to build and improve upon the data base of14information that goes into the prioritization program.”15

P 5-1 – “Transfer of the Distribution Feeder Mains (DFMs – under 20% SMYS) from the16

distribution subprogram to the transmission database necessitated research of company17records for the data required for evaluation under the transmission methodology.18 Results of this research, conducted by PG&E personnel, were mixed at best due to the19absence of the underlying documents or due to recent organizational changes that have20made collection of data problematic. [The amount of pipe affected by incomplete or21missing data is not known at this time.]22

P 5-1 – “The subject of data verification is one that deserves greater emphasis by PG&E.23Though time consuming, verification of pipe data should be a prerequisite to the24replacement decision to ensure that erroneous or missing data is not defaulting a25 pipeline segment into a high replacement priority.”26

It seems clear these PG&E commissioned reports demonstrate that the utility has known of problems27related to its data and records for some time. The continuing presence of imperfect maps and records,28such as those discussed in Section 8.1, shows that the remediation efforts are incomplete.29

30


25 “Pipeline Replacement Program - Transmission Line Risk Analysis, Rev 0”, Bechtel Corporation, January1984.

26 “Review of Transmission Priority Analysis (1995 Revision) for the Gas Pipeline Replacement andRehabilitation Program”, Bechtel Corporation, May 1995.


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3. PWA APPROACH TO THE INVESTIGATION1

The PWA team used four means to carry out the evaluation. In addition to reviewing the2documentation prepared by the CPUC and PG&E in support of and in response to the OII, we learned3from (a) a series of presentations by PG&E managers, (b) a few structured interviews of PG&E staff,4(c) PG&E responses to an extensive set of data requests, and (d) review of numerous incident reports5and results from select SED inspections. This section briefly summarizes each of the first three6sources, then summarizes our review of recent map and records-related CPUC reportable incidents,7and finally discusses our investigation of the issue related to establishment of the maximum allowable8operating pressure (MAOP) for a large number of older distribution systems.9

In response to our initial request to interview a number of its distribution pipeline executives, PG&E10offered two information briefings to help acquaint us with activities they are pursuing to update maps11and records and to help assure future errors do not occur. The first of these briefings was by telephone,12the second was face-to-face in PG&E’s San Ramon offices.13

To address our request for field interviews with key working-level employees at the four divisions in14which the OII incidents occurred, PG&E offered six employees they selected to be interviewed, in the15 presence of PG&E monitors, in their offices in Salinas and San Jose.16

The primary source of documentation used in support of our investigation was the over nine thousand17

documents PG&E provided in response to our 114 DRs. In addition, PG&E provided responses to18 eight oral requests made during the presentations and interviews, and responded to twenty-five (25)19interrogatories under oath made to PG&E executives.20

Another primary information source in our evaluation of the impact of PG&E’s mapping and21recordkeeping practices was reports on incidents prepared by the SED staff. Inspection findings are22discussed further in Section 8.1. The initial documents consisted of the incidents noted in the OII.27 23From that start, the team then reviewed the incidents in the February 20, 2015 Notice of Probable24Violation (NOPV) letter 28 and PG&E’s response to that letter. Additional documentation, consisting of25the SED incident reports, was then reviewed, as were PG&E responses to SED inspections. 29 Finally,26we visited several of the sites where incidents30 listed in OII occurred.27

For all of the six (6) incidents listed in the OII either recordkeeping or mapping issues were significant28contributing factors. These six incidents are summarized in Table 1. Two of the six incidents involved29steel mains or services inserted with plastic which was not identified on the maps given to the field30crews. The crews performing the work, such as tie in or service transfer, were not aware that plastic31was inside of the steel and thus did not know that their actions had created an unsafe condition. In one32of the other incidents where ‘stubs’31 were not marked, a third party excavator hit one, thus releasing33

27 See OII I.14-011-08 pages 2 to 7.

28 See Letter of Ken Bruno dated February 20, 2015 and response of Larry Deniston dated March 24, 2015 pagesA-1 to A-22.

29 PG&E's letter of April 4, 2014, Sumeet Singh (PG&E) to Michel Robertson Safety and Enforcement DivisionCalifornia Public Utilities Commission states: “In its letter, the SED found PG&E in violation of Title 49 of theCode of Federal Regulations Part 192.605(b). PG&E agrees with this violation.”

30 General Order 112-E Section 122 (now GO 112-F) requires operators to report within a specified timeframeincidents that resulted in loss of life, an injury, an estimated property damage of more than $50,000, attracted public attention or given significant media attention. Incidents that are considered significant, even if they donot meet any of these criteria, may also be reported and/or investigated by SED.

31 A stub is defined as a short service that was abandoned on a property or at the property line but not removedall the way to the supply main. These capped stubs do have gas under the same pressure as the main and areconsidered active.


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gas. This stub was not on the map provided to the locating32 personnel. Another incident was the result1of a supply valve being shown on the map as open when it was actually closed; hence when the feed2from the other side of a tee was isolated to perform the tie in safely, almost 1,000 customers lost gas3service.4

The final two incidents of the six listed in the OII involved mapping errors with one being on a plastic5service that was damaged by a third party excavator. This service had been inaccurately mapped and,6therefore, two earlier leak surveys had been carried out incorrectly before the listed incident. Each of7these documented incidents involved PG&E either not keeping accurate records or incorrectly mapping8the actual location of the underground facility.9

These are not the only map or records-related incidents that have occurred over the last several years10that have resulted in damage, loss of supply or a release of gas. As discussed below, we have11evaluated a sampling of other map and record-related incidents in this report.12

A sort of incidents for the period of 2010 to 2014 to identify those for which a valid locate ticket was13issued (Underground Service Alert - USA) and for which the incident cause was listed as a mark or14map error yielded in excess of 100 incidents. This total excludes any damages that listed ‘no tracer15wire’, no USA request was called in, poor excavation practice (such as digging with power equipment16near a known facility), and other causes or unknown causes. For just the first quarter of 2015 - after17PG&E instituted new procedures, implemented part of its database and records improvement program18known as the Pathfinder Program in many divisions and other database and operational improvements19and enhancements - there were still in excess of 25 incidents due to incorrect facility records/maps or20the facility was not properly located.21

Table 2 presents a listing of some of the incidents occurring between 2010 and 2014 that the SED22investigated. Poor or inaccurate record keeping and/or miss-locating the PG&E facilities contributed23to each of these events. Some the incidents were not caused by outside excavation contractors but24rather by PG&E crews doing work on their own systems. There were many more incidents reported by25PG&E that may not have resulted in an SED investigation because they did not meet the incident26reporting criteria.33 27

Another records-related issue we have investigated is the approximately 243 hydraulically independent28

distribution systems for which the maximum allowable operating pressure (MAOP) was not29determined by a recorded pressure test or a pressure certification during the regulation-mandated five30(5) year look back or grandfathered period between 1965 and 1970.34 During this period PG&E31 procedures required that pressure records be retained for only two years. This retention time was the32same as that required by General Order 58A (effective 07/01/32) Sections 20(c) and 20(d). For many33of these systems the MAOP was set during a period from 1977 through 1979. By missing the34regulatory prescribed grandfathered period, PG&E failed to determine the MAOP for these systems35using the prescribed method. After the grandfathered period expired, only a valid pressure test per 4936CFR Part 192 Subpart J was allowed as the basis for establishing MAOP except where the operator37had obtained permission from its regulator to deviate along with a concurrence from PHMSA.38

39

32 All marking and locating for PG&E gas distribution are performed by company personnel.

33 Per footnote 31, certain incidents require immediate reporting to the CPUC. General Order 112-E Section122.2(d) requires quarterly reporting of all CPUC reportable and non-reportable gas leak related incidents,including underground dig-ins.

34 Under the provisions of 49 CFR §192.619.


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Table 1 Relevant Details of the Six Incidents Described in the OII

Location/Date System Characteristics Underlying Cause Co

1 Castro Valley

09/17/10

(Mission

Division)

Plastic service line, 1 inch, 60

psig - MAOP

TPD, Mapping error, incorrect field documentation

from historical gas service records, violation of

procedures to maintain maps and records.

Ga

(N

pre

dan

2 Morgan Hill

06/21/12

(San Jose

Division)

Steel service line, ¾ inch,

installed 1951, deactivated, 60

psig - MAOP

TPD, Failure to follow procedures, service stub not

marked and not on 5 year review program,

violation of procedures to maintain maps and

records.

Ev

dan

3 Milpitas

10/10/12

(San Jose

Division)

Replacing 6 inch main with 4 inch

plastic main, 60 psig - MAOP

Error in data in analytical model, valve closed not

open, operating position of valve on map incorrect,


records, failure to verify valve position and

monitor pressure during main tie-in.

Ser

and

to

4 Milpitas03/04/13

(San Jose

Division)

Plastic distribution main, 2 inch ,60 psig - MAOP

TPD, mapping error leading to ineffective locatingaid, mislocate, nearest ETS (1994) Electronic test

station for tracer wire not shown on map, violation

of procedures to maintain maps and records,

failure to resolve accuracy of locate signals or alert

excavation contractor of potential mark-out

inaccuracy.

Gaeco

5 Mountain View

07/30/13

(De Anza

Division)

Steel service line casing with

plastic liner, 60 psig - MAOP

Record error, no indication of inserted plastic pipe,

welding on 1 ¼” steel previously inserted with

plastic 1970, (OII indicates page 5 1972 vintage),


records.

Ga


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6 Carmel 03/03/14

(Central Coast

Division)

2” diameter steel main with an

unknown 1 ¼” plastic insert

PG&E welded on the 2” line

using a welded tapping tee, and

tapped through the 2” tee into the

1 ¼” plastic insert.

Welding on 2” steel main previously inserted with

1 ¼” plastic (manufactured 07-17-1997), PG&E

using SAP to manage jobs, poor reaction to AOCs

and emergencies GERP, violation of procedures to

maintain maps and records, failure to timely

investigate root cause of similar plastic insert

incident, failure to recognize significance of poormapping and recordkeeping practices.

Ga

exp

$3

hei

of

op

saf

Table 2 Additional Incidents Evaluated for OII


San Jose

(01/20/15)

1¼” Steel stub extending

from a 4” steel main

Directional boring TPD, valid USA, main

marked, steel stub longer than 12 ft. not on

maps, violations of procedures 49 CFR§192.605(a) for failure to update maps, to

maintain maps and stub records, 49 CFR

§192.605(b)(3) failure to provide up to date

maps and records to L&M personnel, and

§192.614(c)(5) failure to locate and mark

all its subsurface facilities within the

delineated excavation area.

Ga

tra

in an

ec


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Lafayette

(8/27/13)

¾” steel service line and

service line valve

Location of service line removed from

PG&E’s map based on an incorrect gas

service record which indicated the service

line was cut-off resulted in TPD.

Violations of 49 CFR §192.605(a) for

failure to follow GTS Standard S4129(requires cutting off services as close to the

main as possible) and §192.727(b) for

failing to properly abandon or deactivate its

gas facilities. PG&E also is in violation of

49 CFR §192.614(c)(5) and California

Government Code 4216.3(a)(1) for failure

to provide temporary marking for its

subsurface facilities affected by the

excavation.

Ga

an


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San Jose

(11/07/14)

2” plastic distribution main,

near 3-way tee, which

branches off a 4” plastic

distribution main, 60 psig –

MAOP

Contractor erroneously thought PG&E had

marked out its gas lines in response to the

USA request and that a 2” steel electrical

conduit was the gas line; PG&E had not

marked out its 2” gas line. L&M crew had

attempted to contact the excavator one hour prior to the scheduled start of excavation;

the communication was unsuccessful.

PG&E did not identify the significance in

not making positive effective

communication without marking out the

gas lines and complying with damage

prevention requirements and procedures.

PG&E did not dispatch a representative to

the excavation location to make contactwith the excavator or to monitor the

excavation to ensure the safety of the gas

lines.

Violations of 49 CFR §192.605(a) for

failure to follow procedures including

PG&E’s damage prevention handbook TD

5811M, 49 CFR §192.614(c)(6) for failure

to dispatch a representative to the

excavation site, and violation of CaliforniaGovernment Code 4216.3(a)(1).

Ga

an

co

ne

do

pe bu


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Kentfield

(4/1/11)

Goodhill Road &

Diablo Drive

2” plastic main – 60 psig –

MAOP

New 2” plastic main PG&E previously

installed without tracer wire on 12/23/10.

New plastic main was not updated on

PG&E maps. L&M crew lost signal, used

outdated map to mark out old retired steel

main. Plastic main not indicated on map.49 CFR §192.605(a) for failure to update

maps in a timely manner per Mapping

Bulletin 05-01 dated 6/7/06

PG&E is in violation of:

49 CFR §192.13(c) – failure to follow its

procedures not updating its maps

49 CFR §192.605(b)(3) – failure to provide

employee with accurate maps to L&M the

facility and not following its procedures toupdate its records and maps

49 CFR §192.321(e) - failure to install

tracer wire on 2” replacement plastic main.

49 CFR §192.614(c)(5) – failure to mark

out 2” plastic main

W

Ci

pl

inj

th


22/136



Antioch

(3/15/10)

2” plastic main, 60 psig –

MAOP

L&M crew incorrectly located 2” plastic

main, mark was 14 feet off of actual main

location resulting in TPD. Main was

located in a sweeping arc when the main

actually intersected at the intersection at

right angle. L&M crew failed to utilizeavailable map information to assist in

determining the location of the gas main.

PG&E is in violation of 49 CFR

§192.614(c)(5) and of California


to provide accurate temporary marking for

its subsurface facilities.

Ga

an

Colusa

(03/19/09)

2” steel main, 150 psig –

MAOP

3” steel main was marked, L&M crew

failed to mark the 2” steel main.Violations of 49 CFR §192.605(a),

California Government Code 4216.3(a)(1)

Ba

mex

3”

Ga

an


23/136



Alameda

(09/28/10)

4” plastic main 60 psig –

MAOP

TPD, valid USA, locate error

(disconnected locate wire, inaccurate

records, failure to follow procedures) The

locating wire was disconnected, led to a

stray locating signal; operating records did

not reflect field conditions; and the L&Mcrew did not follow proper procedures for

determining location of pipeline or

communicating same to the excavator.


49 CFR §192.614(c)(5) and of California




49 CFR §192.614(c)(6) for failure todispatch a representative to the excavation

site.


employee with accurate maps to locate and

mark the gas line and not following its

procedures to provide updated records and

maps.

Ga

ha

ho

Ga

inj


24/136



Roseville

(10/21/10)

2” plastic main 60 psig –

MAOP

TPD by boring contractor due to inaccurate

mark-out, 2”plastic main on plat map

shown in joint trench, was actually in offset

trench, L&M crew failure to mark the

offset, the mark and locate employee did

not follow PG&E procedures to contactmapping for assistance once the locate did

not make sense in relation to the plat.


California Government Code 4216.3(a)(1)

due to inaccurate mark-out and 49 CFR

§192.13(c) - PG&E also did not follow its

Work Procedure 4412-03 page 4, the L&M

crew did not contact mapping when the

field locate and map did not make sense.49 CFR §192.605(b)(3) – failure to provide

employee with accurate maps to locate and

mark the gas line and not following its

procedures to provide updated records and

maps.

Si

cu

int

ec

ha


25/136



Sacramento

(10/31/11)

1 ¼” plastic service 60 psig

– MAOP

The service line was not accurately

updated/mapped to reflect the presence of

two offsets in the line. L&M crew failure

to contact mapping per WP4412-03 when

signal was lost during locating of facilities

or to advise contractor of potential poorservice mark. PG&E is in violation of 49

CFR §192.614(c)(5) and of California







employee with accurate maps to L&M thefacility.

Ho

da

pl

no

th

Alamo (07/24/13) ½“ plastic service and

adjacent ¾“ steel service tee

60 psig – MAOP

TPD, emergency locate, flooded surface,

couldn’t locate line, available map didn’t

have locate dimensions.

Ga


26/136



San Francisco

(04/08/14)35

1” plastic service line, 60

psig – MAOP

TPD, valid USA, PG&E excavation pulled

1” service line from 8” steel main; active

main and service not marked in area of

excavation, inactive pipe (6’ away)

marked, service between marked &

unmarked mains damaged. Violation of 49CFR §192.614(c)(5) and California


to mark its gas lines and failure to use

information available in its records to mark

out its lines.

Ga

ign

th

int

Fresno (09/24/14) 1” plastic service line with

14 foot offset, 60 psig -

MAOP

Damage by PG&E crew, Valid USA, L&M

crew mismarked 1” service, PG&E map

was not updated correctly when service

line offset was installed on 8/1/83 perPG&E’s Mapping Standard 410.21-1 in

effect during the time period which states

that offset in service within the street area

and/or adjacent to PL shall be shown to

scale with dimensions. Violations of

procedures to maintain maps, and failure to

provide up to date maps and records to

L&M personnel.

Ga

ign

th

int

35 PG&E report reflects both and for this incident.


27/136



San Ramon

(8/12/09)

2” plastic service line – 60

psig – MAOP

TPD due to unmarked and unmapped 2”

diameter service to restaurant. PG&E was

unable to produce the original service order

and did not map the service line after

installation. The service line was serving

the restaurant since 10/14/97.PG&E is in violation of 49 CFR

§192.614(c)(5) and of California







employee with accurate maps to L&M thefacility.

49 CFR §192.723(b)(2) – failure to

perform leak surveys of the service line

since installation prior to 10/14/97.

Ga

ign

th

int


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4. APPLICABLE REGULATIONS1

4.1 Elements of a Safety Code Violation2

A pipeline safety code violation may be one of commission or omission. That is PG&E may be found3in violation of pipeline safety requirements when its actions deviate from or fail to address4requirements including those in California State Laws, California Public Utilities Commission General5Orders, Minimum Requirements contained in California State Safety Codes or Federal Pipeline Safety6Codes such as 49 CFR Part 192 Requirements for Transmission and Distribution by Pipeline. A7

violation exists either when PG&E fails to follow its procedures or when procedures are inadequate to8support compliance.9

4.2 Applicable Pipeline Safety Requirements10

As a part of providing natural gas to end users, PG&E must also provide adequately for public safety.11To accomplish this PG&E is required, at a minimum, to comply with a number of pipeline safety12requirements. These include:13

California State Laws such as:14

o California Public Utilities Code Section 451 and Section 96115

o California Government Code 421616

California Public Utilities Commission General Orders such as:17

o Preservation of records of public utilities and common carriers GO2818

o Standards of Gas Service GO58, 58A thru 58F19

o Design, construction, testing, maintenance and operation of utility gas gathering,20transmission and distribution piping systems as described in GO112 – A through F21

CPUC/CA Natural Gas Safety Code incorporates by reference all of the USDOT Federal22Minimum Natural Gas Safety Code 49 CFR Part 19223

Standards incorporated by reference such as:24

o

ASA B31.8 1958 edition25

o Standards incorporated by reference in 49 CFR Part 19226

General Rate Case requirements27

PG&E Standards, Specifications, Plans, Standard Operating Procedures and Emergency Plans28developed to comply with the above State Laws, General Orders, State and Federal Pipeline29Safety Codes, and Standards Incorporated by reference30

Advisory bulletins and findings from outside evaluation reports (e.g., those of the NTSB)31which are specifically required by the California legislature.32

PG&E is required to comply with all of these requirements, generally by having procedures in place,33 following its procedures, and documenting its actions to demonstrate it has complied with these34requirements.35

4.3 Records Necessary to Demonstrate Compliance36

Table 3 below details historical requirements related to maps and records. These requirements and37their subsequent revisions (see Attachment C for current requirements) must be met to demonstrate38compliance. Inaccurate information contained in required records or the lack of such records39constitutes non-compliance. Such non-compliance is considered a violation of pipeline safety40


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requirements. While the wording associated with some of the earliest of these requirements has1evolved over the years, changes to the requirements have typically been to provide clarification, to2update requirements to reflect new information, and to strengthen requirements.3

We should note that, as PG&E has pointed out in its response to the OII,36 and as has been recognized4 by the Pipeline and Hazardous Materials Safety Administration in 49 CFR §192.1007,37 “…there may5 be gaps in the knowledge an operator has when it develops its initial IM plan.” Following is a quote6from that regulation.7

“This section requires that operators develop their understanding from8reasonably available information. The rule does not require operators to retrieve9many years of archived records or to conduct additional investigations (e.g.,10excavation) to discover information about the pipeline. Operators have11considerable knowledge of their pipeline to support routine operations and12maintenance, but this information may be distributed throughout the company, in13 possession of groups responsible for individual functions. Operators must14assemble this information to the extent necessary to support development and15implementation of their IM program. PHMSA recognizes that there may be gaps16in the knowledge an operator has when it develops its initial IM plan. Operators17must identify these gaps and the additional information needed to improve their18

understanding. Operators are required to provide a plan for gaining that19information over time through its normal activities of operating and maintaining20their pipeline (e.g., collecting information about buried components when21 portions of the pipeline must be excavated for other reasons). Operators must22also develop a process by which the program will be periodically reviewed and23refined, as needed.”24

Therefore, as part of our investigation of PG&E records-related violations, PWA has included, based25on existing regulations and practice, a discussion of the “Standard of Care” the regulator and the public26has a right to expect from a prudent operator of gas distribution pipelines. This discussion is presented27as Attachment D to this report.28

29

36 PG&E Initial Report in Response to OII (OII.14-11-008), December 22, 2014.

37 49 CFR 192 Subpart P—Gas Distribution Pipeline Integrity Management (IM), page 63906 Federal Register /Vol. 74, No. 232 / Friday, December 4, 2009 / Rules and Regulations.


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Table 3 Time Line for Map and Record Requirements

Date Records-Related Event Regulatory Requirement

07/01/1932 California Railroad

Commission GO 58A

(effective date of third

revision – initial versioneffective September 1, 1919)

3. System Maps and Records

a. Each gas utility shall keep on file with the Commission up-to-

date maps of the general territory, which it holds itself in readiness

to serve, outlining operating districts and showing majortransmission lines.

b. A suitable map or maps shall be kept on file in the principal

office of each division or district. Maps shall at all times show the

size, character and location of each street main, district regulator,

operating valve and drip, and when practicable, each service

connection in the corresponding territory served. In lieu of

showing service locations on maps, a card record or other suitable

means may be used.

c. In each division or district office there shall be available such

information relative to the distribution system which will enable

the local representatives at all times, to furnish necessary

information regarding the rendering of service to existing and

prospective customers.

20. Pressure Testing Equipment and Tests

(c) On low pressure distribution systems each gas utility shall

during the six months of the peak season of the year make at least

one 24-hour record of pressure each week at the outlet of

customer's meters for each one hundred (100) miles or less of

distribution main in each district or separate distribution system.

Such records shall … be filed and retained as a continuous record

for a period of at least two calendar years in the principal office ofeach district or division. …there may be substituted an equal

number of twenty-four (24) hour records from recording pressure

devices permanently located at critical points on the distribution

system.”

(d) On high pressure distribution systems gas utilities shall

maintain permanently located pressure gauges at critical points

and shall preserve in the district or division offices the charts from

these gauges as a continuous record for a period of at least two (2)

years.

1955 ASA B31.1.8-1955 850.3 Basic Requirements - Each operating company having gas

transmission or distribution facilities within the scope of this code

shall (a) Have a plan covering operating and maintenance

procedures in accordance with the purpose of this code. (b)

Operate and maintain its facilities in conformance with this plan.

(c) Keep records necessary to administer the plan properly.

1958 ASA B31.8-1958 850.3 Basic Requirements - Each operating company having gas

transmission or distribution facilities within the scope of this code

shall (a) Have a plan covering operating and maintenance


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procedures in accordance with the purpose of this code. (b)

Operate and maintain its facilities in conformance with this plan.

(c) Keep records necessary to administer the plan properly.

01/17/1961 CPUC GO 112 (effective

07/01/1961)

Sec. 107 Compliance with ASA Code; 107.1 Gas transmission and

distribution facilities shall be constructed and operated in

compliance with the provisions of Section 8 of the American

Standard Code for pressure piping, known as the AmericanStandard Code for Gas Transmission and Distribution Piping

Systems, ASA B 31.8-1958, and in compliance with the further

requirements of the additional rules herein prescribed.

Sec. 301 General: 301.1 The responsibility for the maintenance of

necessary records to establish that compliance with these rules has

been accomplished rests with the utility. Such records shall be

available for inspection at all times by the commission or the

commission staff.

Sec. 302 Specifications: 302.1 Specifications for material and

equipment, installation, testing and fabrication shall be maintained

by the utility.

Sec. 303 Operating and Maintenance Procedures:

303.1 Plans covering operating and maintenance procedures,

including maximum actual operating procedures to which the line

is intended to be subjected, shall be maintained by the utility.

303.2 No pipeline shall be operated in excess of the maximum

operating pressure recorded by the company in accordance with

this section.

01/17/1961 ASA B31.8-1958 850. O&M; 850.3 Basic Requirements - Each operating company

having gas transmission or distribution facilities within the scope

of this code shall (a) Have a plan covering operating andmaintenance procedures in accordance with the purpose of this

code. … (c) Keep records necessary to administer the plan

properly.

08/19/1970 49 CFR Part 192 Incorporated by CPUC GO 112-C (01/12/71)

§192.13 (a) No person may operate a segment of pipeline that is

readied for service after March 12, 1971, unless that pipeline had

been designed, installed, constructed, initially inspected, and

initially tested in accordance with this part.

(b) No person may operate a segment of pipeline that is replaced,

relocated, or otherwise changes after November 12, 1970, unless

that replacement, relocation, or change has been made in

accordance with this part.

(c) Each operator shall maintain, modify as appropriate, and

follow the plans, procedures and programs that it is required to

establish under this part.

§192.517 Records - Each Operator shall make and retain for the

useful life of the pipeline a record of each test performed under

§§192.505 and §192.507 (strength testing). The record must


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contain at least the following information:

(a) Operator information (described)

(b) Test medium used

(c) Test pressure

(d) Test duration

(e) pressure recording charts or other records of pressure readings

(f) Elevation variations(g) Leaks and failures noted and their disposition

§192.603(b) Each operator shall establish a written operating and

maintenance plan meeting the requirements of this part and keep

records necessary to administer the plan.

§192.605 Each operator shall include the following in its O&M

plan: (a) Instructions for employees covering operating and

maintenance procedures during normal operations and repairs.

§192.613(a) Each operator shall have a procedure for continuing

surveillance of its facilities to determine and take appropriate

action concerning changes in class location, failures, leakage

history, corrosion, substantial changes in cathodic protection

requirements, and other unusual operating and maintenance

conditions.

§192.613(b) If a segment of pipeline is determined to be in

unsatisfactory condition but no immediate hazard exists, the

operator shall initiate a program to recondition or phase out the

segment involved, or, if the segment cannot be reconditioned or

phased out, reduce the maximum allowable operating pressure in

accordance with §192.619 (a) and (b).

§192.617 Investigation of Failures – Each operator shall establish

procedures for analyzing accidents and failures, including theselection of samples of the failed facility or equipment for

laboratory examination, where appropriate, for purpose of

determining the causes of the failure and minimizing the

possibility of a recurrence.

§192.619(c) Notwithstanding the other requirements of this

section, an operator may operate a segment of pipeline found to be

in satisfactory condition, considering its operating and

maintenance history , at the highest actual operating pressure to

which the segment was subjected during the 5 years preceding

July 1, 1970, subject to the requirements of §192.611 (changes in

class location).

§192.621(a) No person may operate a segment of a high pressure

distribution system at a pressure that exceeds the lowest of the

following pressures, as applicable:

(5) The pressure determined by the operator to be the maximum

safe pressure after considering the history of the segment;

particularly known corrosion and the actual operating pressure.

12/04/2009 49 CFR Part 192 (DIMP- §192.1007 What are the required elements of an integrity


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related requirements) management plan?

A written integrity management plan must contain procedures for

developing and implementing the following elements:

(a) Knowledge. An operator must demonstrate an understanding of

its gas distribution system developed from reasonably available

information.

(1) Identify the characteristics of the pipeline's design andoperations and the environmental factors that are necessary to

assess the applicable threats and risks to its gas distribution

pipeline.

(2) Consider the information gained from past design, operations,

and maintenance.

(3) Identify additional information needed and provide a plan for

gaining that information over time through normal activities

conducted on the pipeline (for example, design, construction,

operations or maintenance activities).

(4) Develop and implement a process by which the IM program

will be reviewed periodically and refined and improved as needed.

(b) Identify threats. The operator must consider the following

categories of threats to each gas distribution pipeline: corrosion,

natural forces, excavation damage, other outside force damage,

material or welds, equipment failure, incorrect operations, and

other concerns that could threaten the integrity of its pipeline. An

operator must consider reasonably available information to

identify existing and potential threats. Sources of data may

include, but are not limited to, incident and leak history, corrosion

control records, continuing surveillance records, patrolling

records, maintenance history, and excavation damage experience.2006 California Government Code

4216

4216.3 (a) (1) Any operator of a subsurface installation who

receives timely notification of any proposed excavation work in

accordance with Section 4216.2 shall, within two working days of

that notification, excluding weekends and holidays, or before the

start of the excavation work, whichever is later, or at a later time

mutually agreeable to the operator and the excavator, locate and

field mark the approximate location and, if known, the number of

subsurface installations that may be affected by the excavation to

the extent and degree of accuracy that the information is available

either in the records of the operator or as determined through the

use of standard locating techniques other than excavating,

otherwise advise the person who contacted the center of the

location of the operator's subsurface installations that may be

affected by the excavation, or advise the person that the operator

does not operate any subsurface installations that would be

affected by the proposed excavation.


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Investigation of PG&E Distribution System Recordkeeping Page 31

Attachment C to this report provides a list of current requirements and provisions of the CPUC code,1Commission general orders, applicable rules or requirements or other state or federal laws pertaining to2 pipeline safety recordkeeping that are applicable to PG&E’s natural gas distribution system.3

4.4

General Recordkeeping Requirements4

The six incidents identified in the OII and listed in Table 1 all stem from PG&E or excavator actions5undertaken in the light of imperfect maps and records caused by deficient recordkeeping practices.6

PG&E practices have been deficient given the requirements that a prudent operator is expected to7meet. (For a discussion of the concept of appropriate “standard of care” see Section 6 and Attachment8D.) This is supported by the report by Duller and North discussed above. Although focusing on9PG&E’s Gas Transmission Line records, Duller and North in its report (dated March 5, 2012) on10records management following the San Bruno fire and explosion, states that the reports’ findings are11also referenced against PG&E’s corporate approach to records management.38 12

Historically, mapping and recordkeeping requirements for utilities have been mandated by the CPUC13in General Orders 58 and 112. Over the years the recordkeeping requirements in these orders have14 been periodically updated, with the most recent requirements provided in General Orders 58A and15112-E and 112-F. The Research and Special Programs Administration (RSPA) – the federal agency16that preceded the Pipeline and Hazardous Materials Safety Administration (PHMSA) in regulating17 pipeline safety - in addressing the need that gas company system maps and records be maintained18accurately to identify the locations, size, and operation[al] pressure of all their pipelines39 also requires19that all gas and hazardous liquid pipeline operators must maintain an operating and maintenance plan20that includes procedures for making construction records, maps, and operating history available to21appropriate operating personnel to enable them to safely and effectively perform their duties (49 CFR22§192.605). CPUC General Orders are routinely updated to incorporate and often to exceed the most23recent federal requirements.24

PWA’s investigation, which has focused on evaluating recent incidents in which records imperfections25were the underlying causes, found that PG&E has had a series of procedures in place to comply with26CPUC mapping and recordkeeping requirements. Those procedures required each Division to27

establish and maintain maps and records for its gas distribution lines.40

PG&E procedures required28each Division to maintain maps and records that provided details of its gas distribution lines on plat29maps, gas service records and file folders on sections of distribution mains. However, PG&E and30Division records management procedures inadequately detailed which records needed to be retained31and maintained to demonstrate compliance with general order requirements, California Laws, and gas32 pipeline safety requirements. As a result an evolving set of PG&E record retention procedures focused33more on which records could be destroyed rather than on required records and their retention34requirements.35

PG&E’s records retention procedures were inconsistently followed, resulting in map plats becoming36outdated; containing incorrect and incomplete information. Key pipeline history records and files were37lost, misplaced and/or inadvertently destroyed. Plats maps have been found to be incomplete or38

misleading because they do not contain up to date information on the location, nature, diameter and39material of current lines. Examples of such incomplete or misleading information are described in the40

38 Docket: I. 11-02-016 Exhibit 2, page 1-7, lines 28-31.

39 Advisory Bulletin 02-03 - Federal Register Volume 67, Number 114 [Pages 40768-40770] (June 13, 2002) 2nd paragraph Page 40769.

40 As discussed in the report by Duller and North, many of PG&E’s current procedures and standards apply to both gas transmission and gas distribution.


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Investigation of PG&E Distribution System Recordkeeping Page 32

discussion below concerning the six incidents in the OII as well as those in Tables 2 and 4. These1imperfections and missing or misleadi

Report on PG&E Record Keeping

Documents

Transcript of Report on PG&E Record Keeping