NTSB Safety Recommendation P-10-004

NTSB safety recommendation P-10-004.

TO THE PACIFIC GAS AND ELECTRIC COMPANY: If you are unable to comply with Safety Recommendations P-10-2 (Urgent) and P-10-3 (Urgent) to accurately determine the maximum allowable operating pressure of Pacific Gas and Electric Company natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high consequence areas that have not had a maximum allowable operating pressure established through prior hydrostatic testing, determine the maximum allowable operating pressure with a spike test followed by a hydrostatic pressure test.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2011-01-03

Adopted Date: 2010-12-30

Overall Date Closed: 2023-09-06

Synopsis: On September 9, 2010, about 6:11 p.m. Pacific daylight time,1 a 30-inch-diameter natural gas transmission pipeline (Line 132) owned and operated by Pacific Gas and Electric Company (PG&E) ruptured in a residential area in the city of San Bruno, California. The accident killed eight people, injured many more, and caused substantial property damage. The rupture on Line 132 occurred near milepost 39.33, at the intersection of Earl Avenue and Glenview Drive in San Bruno. About 47.6 million standard cubic feet of natural gas were released as a result of the rupture. The rupture created a crater about 72 feet long by 26 feet wide. A ruptured pipe segment about 28 feet long was found about 100 feet away from the crater. The released natural gas was ignited sometime after the rupture; the resulting fire destroyed 37 homes and damaged 18.

Probable Cause: The National Transportation Safety Board determines that the probable cause of the accident was the Pacific Gas and Electric Company's (PG&E) (1) inadequate quality assurance and quality control in 1956 during its Line 132 relocation project, which allowed the installation of a substandard and poorly welded pipe section with a visible seam weld flaw that, over time grew to a critical size, causing the pipeline to rupture during a pressure increase stemming from poorly planned electrical work at the Milpitas Terminal; and (2) inadequate pipeline integrity management program, which failed to detect and repair or remove the defective pipe section.

Ntsbnumber: DCA10MP008

Report Number: PAR-11-01

Addressee Name: Pacific Gas and Electric Company

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2023-09-06

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2017-03-27

Communication Type: Official Correspondence

Communication Contents: We understand that, from 2011 to the date of your letter, you verified the maximum allowable operating pressure on approximately 1,106 miles of pipe, representing completion of approximately 98.7 percent of priority 1 pipe, and that approximately 24 miles of priority 1 pipe remain to be strength tested, verified, or replaced. We note that your analysis was facilitated by your new geographic information system, making records even more accessible and usable at a pipeline section and feature level. However, you wrote that the remaining miles of pipe are primarily short segments that include tie-in pieces, fittings, or smaller diameter off-takes from the larger transmission pipelines, and are on average less than 0.1 miles in length; therefore, you may not be able to complete the remaining work until 2022. We recognize the complexities and effort required to fully validate the remaining smaller pipe segments; however, we encourage you to expedite this essential validation process. Pending completion of these efforts, Safety Recommendation P-10-4 is classified OPEN--ACCEPTABLE RESPONSE.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2018-07-06

Communication Type: Official Correspondence

Communication Contents: We understand that, from 2011 to the end of 2017, PG&E verified the maximum allowable operating pressure of 1,360 miles of pipeline, representing completion of 97.9 percent of class 3, class 4, and class 1 and 2 HCA pipeline (priority 1). We note that your analysis of the new geographic information system identified an additional 7.2 miles of pipeline to be tested, and that a total of 29.3 miles of pipe remain to be strength tested, verified, or replaced. The priority 1 pipeline remaining is made up of 509 individual short segments that are, on average, less than 0.06 mile in length. In 2018, you plan to test 259.1 miles of pipeline, of which 2.3 miles (57 sections) are priority 1; therefore, you estimate the remaining work to be completed in 2022. Thank you for the information on PG&E’s safety and risk management topics. We are pleased to hear about the certification of your safety management system (SMS), Gas Safety Excellence, for the areas of asset management, process safety, and safety culture, and we note that you are developing a quantitative risk assessment program and an enterprise safety management system, which will provide a common framework and eventually add environmental management and occupational health and safety to your SMS. We recognize the complexities and effort required to fully validate the remaining smaller pipeline segments, and we encourage you to continue your efforts to complete this essential validation process. Pending completion, Safety Recommendation P-10-4 is classified OPEN--ACCEPTABLE RESPONSE.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2019-09-18

Communication Type: Official Correspondence

Communication Contents: We note that you continue to strength test transmission lines and verify strength test records as recommended, strength testing 286 miles of pipe in 2018. This brings the total miles of pipe completed, through either strength testing or verifying strength test records, to 1,645 miles. We further note that you expect to strength test approximately 102.6 miles of pipe in 2019, and you continue to expect pipe strength testing to be completed by approximately 2022. Pending completion of strength testing or records verification on all your natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high consequence areas, Safety Recommendation P-10-4 remains classified OPEN--ACCEPTABLE RESPONSE.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2020-11-24

Communication Type: Official Correspondence

Communication Contents: We note that you continue to strength test transmission lines and verify strength test records as recommended, testing 115 miles of pipe in 2019. This brings the total miles of pipe completed, either through strength testing or verifying strength test records, to 1,761 miles, leaving approximately 11.24 miles of Priority 1 pipe remaining to be tested, verified, or replaced. We further note that you anticipate that your efforts to satisfy this safety recommendation will extend through 2022. Pending completion of strength testing and records verification on all your natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high-consequence areas, Safety Recommendation P-10-4 remains classified OPEN--ACCEPTABLE RESPONSE. Please update us at ExecutiveSecretariat@ntsb.gov on your progress toward implementing this recommendation, and do not send both an electronic and a hard copy of the same response.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2021-10-26

Communication Type: Official Correspondence

Communication Contents: We note that, in 2020, you strength-tested another 39 miles of pipeline, bringing the total miles of pipe strength-tested or strength test records verified from 2011 to 2020 to approximately 1,800 miles. We further note that you have 7.67 priority 1 (class 3, class 4, and class 1 and 2 HCA) pipeline miles remaining to strength test as of December 31, 2020, with an anticipated completion date for priority 1 pipelines in 2022. Pending completion of your work to hydrostatically test your remaining natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 HCAs that have not had a maximum allowable operating pressure established through prior hydrostatic testing, Safety Recommendation P-10-4 remains classified OPEN-- ACCEPTABLE RESPONSE. Please update us at ExecutiveSecretariat@ntsb.gov on your progress toward implementing this recommendation, and do not submit both an electronic and a hard copy of the same response.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2022-07-26

Communication Type: Official Correspondence

Communication Contents: We note that, in 2021, PG&E strength-tested another 32 miles of pipeline, bringing the total miles of pipe strength-tested or strength test records verified between 2011 and 2021 to approximately 1,832 miles. We further note that, as of December 31, 2021, you have 5.56 priority 1 (class 3, class 4, and class 1 and 2 HCA) pipeline miles remaining to strength test, with an anticipated completion date for priority 1 pipelines in 2023. Pending completion of your work to hydrostatically test your remaining natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 HCAs that have not had a maximum allowable operating pressure established through prior hydrostatic testing, Safety Recommendation P-10-4 remains classified OPEN-- ACCEPTABLE RESPONSE.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2023-09-06

Communication Type: Official Correspondence

Communication Contents: We are aware that you have strength-tested or verified strength-test records for over 1,850 miles of pipeline to address this recommendation. We note that you have now mobilized the last three projects, consisting of a total of 0.56 miles of pipe, the last of which will be completed this October. Accordingly, Safety Recommendation P-10-4 is classified CLOSED-- ACCEPTABLE ACTION. We commend your effort to successfully address all 12 safety recommendations issued to PG&E after the 2010 pipeline rupture and fire in San Bruno, which are now all classified Closed—Acceptable Action.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2012-03-13

Communication Type: Official Correspondence

Communication Contents: The NTSB is encouraged that PG&E has tested over 163 miles of pipeline as recommended, including 144 of the 152 pipeline miles having characteristics similar to those of the line that failed in San Bruno. For these miles of pipeline, PG&E has hydrostatically tested, replaced, or verified strength-test pressure records. Also, over the next 3 years (2012-2014), PG&E plans to hydrostatically pressure test approximately 547 additional miles of pipeline. Pending completion of these efforts, Safety Recommendation P-10-4 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2012-08-29

Communication Type: Official Correspondence

Communication Contents: The NTSB notes PG&E’s progress to address this issue, which includes (1) testing a total of about 39.5 miles of Line 132 (about 37 miles of which were tested in 2011), (2) conducting strength tests at 1.7 times the maximum allowable operating pressure plus a 10 percent spike test where possible, and (3) providing the CPUC with monthly reports on the status of its strength testing program. PG&E will continue action on this issue in two phases. Phase 1 includes testing or verifying records of 185 miles in 2012, 204 miles in 2013, and 158 miles in 2014. Phase 1 strength testing will address the following types of pipes: • Pre-1970, low-frequency electric resistant welded, flash welded, single submerged arc welded, furnace butt welded, and lap welded pipe operating between 20 percent and 30 percent specified minimum yield strength (SMYS) in urban areas. • All urban-area pipes operating at or above 30 percent SMYS, unless it has been scheduled for replacement or an adequate strength test for the pipe exists. Phase 2, beginning in 2015, will include strength testing the following 1,700 additional miles of pipeline: • All urban area pipes operating below 30 percent SMYS, unless it has been scheduled to be replaced or an adequate strength test for the pipe exists. • All identified pipe not previously strength tested or replaced in Phase 1, which includes pipe located in Class 1 non-HCA, rural areas, unless an adequate pressure test exists for the pipe. Pending completion of these efforts, Safety Recommendation P-10-4 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2011-03-14

Communication Type: Official Correspondence

Communication Contents: The NTSB is pleased with the following actions that PG&E is taking to implement these recommendations: • PG&E’s business lead for this records verification project reports directly to the Senior Vice President, Engineering and Operations. • PG&E has retained numerous leading external partners to lend specialized expertise and significant additional resources to this process in the areas of document management, process controls, engineering, pipeline pressure calculations, and auditing. • PG&E has leased new space to house the record verification operations and has built out space in its existing facilities to accommodate this activity. • PG&E has collected hundreds or boxes of original records from over 20 field office and other locations across the service territory, and document scanning and indexing operations are proceeding 24 hours a day, 7 days a week. PG&E further reports it is using the scanned and indexed records to verify the completeness of pressure test records and other applicable records used to establish each line’s maximum allowable operating pressure (MAOP) per industry standards and Federal code compliance. Over the next 6 weeks, PG&E will determine the total number of miles for which it has complete, verifiable, and traceable records of prior pressure tests, and will start the process of using all available verified records identified in the collection, scanning, and indexing process to compile a segment-by-segment pipeline features list. Where necessary, PG&E will perform excavations to verify pipeline features. In the end, as directed by the California Public Service Commission, the MAOP will be validated based on the weakest segment in the transmission pipeline sections of these Class 3 and 4 locations and Class 1 and 2 high consequence areas. In addition, PG&E reports it is taking all steps to ensure the safety and integrity of its gas pipeline systems, including verifying the underlying records of over 1,800 miles of pipeline by March 15, 2011. Because these actions, when completed, should satisfy Safety Recommendations P-10-2 through -4, the recommendations are classified OPEN -- ACCEPTABLE RESPONSE.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2011-11-23

Communication Type: Official Correspondence

Communication Contents: -From NTSB. –To: Christina Sames, Vice President Operations and Engineering, American Gas Association. NOT TO THE ADDRESSEE. NOT TO PGE. Thank you for your June 14, 2011, letter, regarding Safety Recommendations P-10-01 through -04, which the National Transportation Safety Board (NTSB) issued on January 3, 2011, regarding the San Bruno, California, pipeline accident. Safety Recommendation P-10-01 was issued to the Pipeline and Hazardous Materials Safety Administration (PHMSA), and Safety Recommendations P-10-02 through -04 were issued to the Pacific Gas and Electric Company (PG&E); all were urgent recommendations. The San Bruno pipeline accident report and the related safety recommendation issuance letters are posted on the NTSB’s website at http://www.ntsb.gov/doclib/reports/2011/PAR1101.pdf and http://www.ntsb.gov/recsletters/ DisplayLetters.aspx?FolderYR=2011, respectively. Your interpretations of our intent in issuing these recommendations, stated in your letter, are correct. To address another of your concerns, the NTSB does not intend for Federal or state agencies to codify the language from our safety recommendations directly into state and Federal rules and regulations. We believe that each agency should develop appropriate language for its own rules and regulations, to address and accomplish the intent of our safety recommendations. Of particular concern to you and your organization is the requirement for a postconstruction hydrostatic pressure test. For pipelines constructed before 1970 that were not required to be hydrostatically tested, 49 Code of Federal Regulations (CFR) 192.619(a)(3), commonly referred to as the “grandfather clause,” allows the maximum allowable operating pressure (MAOP) to be based on “the highest actual operating pressure to which the segment was subjected during the 5 years preceding … July 1, 1970.” In contrast to MAOP based on hydrostatic pressure testing, the grandfather clause does not specify a minimum amount of time that the historical pressure must have been held to be used as the basis for the MAOP. Studies have shown that hydrostatic pressure testing is most effective when it incorporates a spike test in which the pipeline is initially pressurized to a higher level for a short time. Accordingly, the NTSB recommended that PHMSA amend 49 CFR 192.619 to delete the grandfather clause and to require that all gas transmission pipelines constructed before 1970 be subjected to a hydrostatic pressure test that incorporates a spike test. Additional information regarding this safety recommendation can be obtained in our San Bruno pipeline accident report, at the address cited above. The NTSB considers the San Bruno accident report and the safety recommendations issued as a result of our findings, to be of the utmost importance to the gas pipeline industry and to the American people. We encourage all involved interests, including the AGA, to ensure that pipelines are maintained properly and are operated safely. Thank you for your interest in these very important pipeline safety issues. Should you require any additional information or clarification, please contact us.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2014-09-25

Communication Type: Official Correspondence

Communication Contents: On August 29, 2012, based on information you provided in your May 23, 2012, update, we classified Safety Recommendations P-10-4, and P-11-26 and -27 “Open—Acceptable Response.” To date, we have received no further update from you detailing any action you may have taken to implement these recommendations; we would appreciate receiving one soon. For your convenience, I have enclosed the correspondence history for each of these recommendations. Please reply regarding your progress in implementing Safety Recommendations P-10-4, and P-11-26 and -27.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2015-05-15

Communication Type: Official Correspondence

Communication Contents: We note that, from 2011 to the end of 2014, you completed verification of the maximum allowable operating pressure on 675 miles of pipeline by strength tests, and 162 miles of pipeline by strength test record verifications, for a total verification of 837 miles of pipeline. We further note your plans to test the remaining approximate 100 segment miles of pipeline in class 3 and class 4, and class 1 and class 2 high consequence areas, in 2015 and 2016. We understand that testing of the remaining pipeline segments will progress more slowly because many of these segments are short and will be tested within longer class 1 and class 2 Non-HCA segments. Pending notification that you have finished testing the remaining pipeline, Safety Recommendation P 10-4 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2015-12-01

Communication Type: Official Correspondence

Communication Contents: We note that, from 2011 to the date of your letter, you completed verification of the maximum allowable operating pressure on approximately 847 miles (80 miles expected to be tested by year’s end), for a total of 927 miles. We understand that, because the approximate 134 miles of pipe are primarily short segments that include tie-in pieces, fittings, or smaller diameter off-takes from the larger transmission pipelines, and are on average less than 0.1 miles in length, you may not be able to complete the remaining work until as late as 2025. We recognize the complexities and effort required to fully validate the remaining smaller pipe segments and encourage you to expedite this essential validation process. Pending completion of these efforts, Safety Recommendation P-10-4 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2015-10-28

Communication Type: Official Correspondence

Communication Contents: We classified this recommendation OPEN—ACCEPTABLE RESPONSE on May 15, 2015, (see enclosures) because of the considerable progress made by PG&E, although testing of the remaining pipeline segments is progressing slowly. We are aware that many of these segments are short and will be tested within longer class 1 and class 2 Non-HCA segments. We look forward to the anticipated completion of this project by the end of 2017.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2017-02-10

Communication Type: Official Correspondence

Communication Contents: -From Nickolas Stavropoulos, President, Gas: PG&E believes that substantial progress has been made to implement this remaining open recommendation. We have completed additional analysis on the remaining work needed to complete recommendation P-1 0-04, indicating that the remaining miles to be strength tested are less than previously anticipated, but that, as we have indicated in our prior update, completion will be later than 2017. Details of that analysis are included in this update.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2018-03-23

Communication Type: Official Correspondence

Communication Contents: -From Nickolas Stavropoulos, President and Chief Operating Officer: Pacific Gas and Electric Company (PG&E) continues to make progress in addressing the only remaining open safety recommendation of the twelve issued by the NTSB as a result of its investigation of the September 2010 San Bruno pipeline accident. The attached status report provides an update on PG&E's actions to address the remaining recommendation, P-10-04: Strength Testing, which is currently in "Open -Acceptable Response" status. Progress in implementing this remaining open recommendation has been ongoing since our last update. We continue to pursue additional detailed analysis on the remaining work needed to complete recommendation P-10-04. This work in 2017 indicates that the remaining miles to be strength tested are more than previously anticipated, and, as we have indicated in our prior update, completion will extend to approximately 2022. Details of that analysis are included in this update. We are available to provide additional information or answer any questions you may have by contacting me directly or Sumeet Singh. PG&E thanks the NTSB for its continuing guidance and leadership as the company continues to work towards our goal of making PG&E's gas system the safest and most reliable in the nation.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2019-07-15

Communication Type: Official Correspondence

Communication Contents: -From Melvin Christopher, Vice President, Gas Operations: the only remaining open safety recommendation of the twelve issued by the National Transportation Safety Board (NTSB) as a result of its investigation of the September · 2010 San Bruno pipeline accident. The attached status report provides an update on PG&E's actions to address the remaining recommendation, P-10-4: Strength Testing, which is currently in "Open - Acceptable Response" status. Progress in implementing this remaining open recommendation has been ongoing since our last update provided on March 23, 2018. We continue to pursue additional detailed analysis on the remaining work needed to complete recommendation P-10-04. As indicated in our March 23, 2018 update, completion of the remaining Priority 1 miles to be strength tested will extend to approximately 2022. Further details are included in this update. We are available to provide additional information or answer any questions you may have by contacting me directly or Christine Cowsert. PG&E thanks the NTSB for its continuing guidance and leadership as the company continues to work towards our goal of making PG&E's gas system the safest and most reliable in the nation.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2020-10-15

Communication Type: Official Correspondence

Communication Contents: -From Christine Cowsert, Vice President, Gas Asset Management and System Operations: Pacific Gas and Electric Company (PG&E) continues to make progress in addressing the only remaining open safety recommendation of the twelve issued by the National Transportation Safety Board (NTSB) as a result of its investigation of the September 2010 San Bruno pipeline accident. The attached status report provides an update on PG&E’s actions to address the remaining recommendation, P-10-04: Strength Testing, which is currently in “Open – Acceptable Response” status. Progress in implementing this remaining open recommendation has been ongoing since our last update provided on July 15, 2019. We continue to expect that completion of the remaining Priority 1 miles associated with P-10-04 will extend to approximately 2022. Further details are included in this update. We are available to provide additional information or answer any questions you may have by contacting me. PG&E thanks the NTSB for its continuing guidance and leadership as the company continues to work towards our goal of making PG&E’s gas system the safest and most reliable in the nation. PG&E Update for P-10-4, through December 2019: PG&E is continuing to perform hydrostatic testing and records verification of gas transmission pipeline sections designated as Priority 1 (Class 3, Class 4 and Class 1 & 2 HCA) and also for pipeline sections in Class 1 & 2 non-HCA areas. The scope of these miles to be completed under Safety Recommendation P-10-4 was based on a June 4, 2015 snapshot in time. Mileage completed (including Class 1 and 2 Non-HCA pipeline segments) through 2019 is as follows: • In 2011, PG&E strength tested (164 miles) or verified strength test records (51 miles) for a total of 215 miles. • In 2012, PG&E strength tested (176 miles) or verified strength test records (28 miles) for a total of 204 miles. • In 2013, PG&E strength tested (199 miles) or verified strength test records (40 miles) for a total of 239 miles. • In 2014, PG&E strength tested (135 miles) or verified strength test records (55 miles) for a total of 190 miles. • In 2015, PG&E strength tested (79 miles) or verified strength test records (91 miles) for a total of 170 miles. • In 2016, PG&E strength tested 89 miles. • In 2017, PG&E strength tested 253 miles. • In 2018, PG&E strength tested 286 miles. • In 2019, PG&E strength tested 115 miles. This brings total miles of pipe strength tested or strength test records verified from 2011 to 2019 to approximately 1,761 miles. The totals listed above include not only Priority 1 pipeline sections, but also Class 1 and 2 Non-HCA pipeline sections. During 2019, PG&E continued to perform additional detailed analysis of Priority 1 (Class 3, Class 4, and Class 1 & 2 HCA) pipe to confirm remaining miles to be tested or verified. Attachment A, NTSB 12-19 Update: Priority 1 Strength Test Progress, summarizes the progress for these Priority 1 pipelines. As indicated in that attachment, as of December 31, 2019 there are approximately 11.24 miles of Priority 1 pipe remaining to be strength tested, verified, or replaced. The following summarizes the results as of December 31, 2019: • Priority 1 miles reported as of December 31, 2018: 23.33 miles • 2019 Priority 1 miles tested/replaced: 4.78 miles • 2019 Priority 1 miles verified: 7.31 miles • Remaining Priority 1 miles as of December 31, 2019: 11.24 miles The remaining Priority 1 miles are primarily short sections or features. Attachment B, NTSB 12-19 Update: Validation Tracker, provides a listing of each of the sections or features that remain to be tested, which will help provide an understanding of the characteristics of these remaining pipeline sections. Of the 11.24 Priority 1 miles remaining as of December 31, 2019, PG&E has reviewed 100 percent of them and has assigned a project to all but 0.02 miles. These 0.02 miles are currently being scoped for projects. In 2020, PG&E expects to strength test approximately 40.8 miles of pipe, including approximately 4.06 Priority 1 miles. PG&E expects that completion of strength testing of Priority 1 shorter sections of features will extend to approximately 2022. PG&E provides below additional information to augment the information provided in the 2019 update regarding the safety management system (SMS) within Gas Operations, which we named Gas Safety Excellence Management System. In 2019, PG&E continued to mature all three aspects of Gas Safety Excellence: Asset Management, Process Safety, and Safety Culture. Using the international Publicly Available Specification (PAS) 55-1, International Organization for Standardization (ISO) 55001 as guidance, PG&E’s asset management system focuses on identifying and reducing operational and enterprise risk; maintaining an asset management framework and directing organizational focus on the most important asset risks and opportunities; proactively managing the condition of gas assets; and meeting or exceeding the requirements of federal, state, and local codes, regulations and requirements in an environmentally sustainable manner. Process Safety focuses on preventing low frequency, high consequence incidents, and mitigating the consequences from these incidents. The Process Safety principles are used for engineering new facilities, modifying existing facilities, maintaining equipment, and ensuring safe operation. As indicated in the 2019 update, PG&E received certification for Responsible Care 14001 in 2014. This certification was replaced with the implementation of API RP 754, Process Safety Performance Indicators for Refining and Petrochemical Industries. In November 2019, PG&E was recognized, through a third-party assessment, for being in compliance with the intent of API RP 754 in so far as it meets its business operations. Gas Operations’ compliance with API RP 1173, Pipeline Safety Management Systems, was renewed in 2018 and confirmed annually thereafter through surveillance audits by a third-party assessor. API RP 1173 provides pipeline operators with safety management system requirements that when applied, provides a framework to reveal and manage risk, promote a learning environment, and continuously improve pipeline safety and integrity, underpinned by a healthy safety culture. In 2019, PG&E continued its efforts to advance its safety culture. PG&E continued its employee engagement efforts such as the Corrective Action Program, the Reach Every Employee initiative which enables all leaders to discuss safety with each direct report through one on one or small group discussions, and the Organizational Health Index (OHI), an annual employee survey that collects feedback regarding management behaviors and organizational outcomes.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2021-09-03

Communication Type: Official Correspondence

Communication Contents: -From Janisse Quinones, Senior Vice President, Gas Engineering, Pacific Gas and Electric: Pacific Gas and Electric Company (PG&E) continues to make progress in addressing the only remaining open safety recommendation of the twelve issued by the National Transportation Safety Board (NTSB) as a result of its investigation of the September 2010 San Bruno pipeline accident. The attached status report provides an update on PG&E’s actions to address the remaining recommendation, P-10-04: Strength Testing, which is currently in “Open – Acceptable Response” status. Progress in implementing this remaining open recommendation has been ongoing since our last update provided on October 15, 2020. As stated in the 2020 Update, we expect that completion of strength testing of the remaining Priority 1 miles associated with P-10-04 will extend to 2022. Further details are included in this update. We are available to provide additional information or answer any questions you may have by contacting me directly or Kristina Castrence. PG&E thanks the NTSB for its continuing guidance and leadership as the company continues to work towards our goal of making PG&E’s gas system the safest and most reliable in the nation.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2022-07-06

Communication Type: Official Correspondence

Communication Contents: -From Janisse Quinones, PE, Senior Vice President, Gas Engineering: Pacific Gas and Electric Company (PG&E) continues to make progress in addressing the only remaining open safety recommendation of the twelve issued by the National Transportation Safety Board (NTSB) as a result of its investigation of the September 2010 San Bruno pipeline accident. The attached status report provides an update on PG&E’s actions to address the remaining recommendation, P-10-04: Strength Testing, which is currently in “Open – Acceptable Response” status. Progress in implementing this remaining open recommendation has been ongoing since our last update provided on September 3, 2021. We expect that completion of strength testing of the remaining Priority 1 miles associated with P-10-04 will primarily complete in 2022, with the potential for five projects to extend to 2023 due to permit concerns, timing and dependency on other projects. Further details are included in this update. We are available to provide additional information or answer any questions you may have by contacting me directly or Kristina Castrence. PG&E thanks the NTSB for its continuing guidance and leadership as the company continues to work towards our goal of making PG&E’s gas system the safest and most reliable in the nation. PG&E Update for P-10-4, through December 2020: PG&E is continuing to perform hydrostatic testing and records verification of gas transmission pipeline sections designated as Priority 1 (Class 3, Class 4 and Class 1 & 2 HCA) and also for pipeline sections in Class 1 & 2 non-HCA areas. The scope of these miles to be completed under Safety Recommendation P-10-4 was based on a June 4, 2015 snapshot in time. Mileage completed (including Class 1 and 2 Non-HCA pipeline segments) through 2021 is as follows: • In 2011, PG&E strength tested (164 miles) or verified strength test records (51 miles) for a total of 215 miles. • In 2012, PG&E strength tested (176 miles) or verified strength test records (28 miles) for a total of 204 miles. • In 2013, PG&E strength tested (199 miles) or verified strength test records (40 miles) for a total of 239 miles. • In 2014, PG&E strength tested (135 miles) or verified strength test records (55 miles) for a total of 190 miles. • In 2015, PG&E strength tested (79 miles) or verified strength test records (91 miles) for a total of 170 miles. • In 2016, PG&E strength tested 89 miles. • In 2017, PG&E strength tested 253 miles. • In 2018, PG&E strength tested 286 miles. • In 2019, PG&E strength tested 115 miles. • In 2020, PG&E strength tested 39 miles. • In 2021, PG&E strength tested 32 miles.1 This brings total miles of pipe strength tested or strength test records verified from 2011 to 2021 to approximately 1,832 miles. The totals listed above include not only Priority 1 pipeline sections, but also Class 1 and 2 Non-HCA pipeline sections. During 2021, PG&E continued to perform additional detailed analysis of Priority 1 (Class 3, Class 4, and Class 1 & 2 HCA) pipe to confirm remaining miles to be tested or verified. Attachment A, NTSB 12-20 Update: Priority 1 Strength Test Progress, summarizes the progress for these Priority 1 pipelines. As of December 31, 2020, there were approximately 7.67 miles of Priority 1 pipe remaining to be strength tested, verified, or replaced. The following summarizes the results as of December 31, 2021: • Priority 1 miles reported as of December 31, 2020: 7.67 miles • Priority 1 miles added from the June 4, 2015 list2: 0.15 miles • 2021 Priority 1 miles tested/replaced/retired: 2.26 miles • Remaining Priority 1 miles as of December 31, 2021: 5.56 miles The remaining Priority 1 miles are primarily short sections or features. Attachment B, NTSB 12-21 Update: Validation Tracker, provides a listing of each of the sections or features that remain to be tested, which will help provide an understanding of the characteristics of these remaining pipeline sections. Of the 5.56 Priority 1 miles remaining as of December 31, 2021, PG&E has reviewed 100 percent of them and has assigned a project to all. In 2022, PG&E expects to strength test approximately 58.2 miles of pipe, including approximately 2.36 Priority 1 miles. Although PG&E expected that all strength testing of Priority 1 miles would be completed in 2022, there are currently five projects totaling 3.21 miles that will or may extend into 2023. Three projects, DFM 1305-01, Lines 130 and 191-1, totaling 2.64 miles, are at risk due to permitting issues and the test completion may extend into 2023.3 Due to realized permit concerns, timing, and dependency on other projects, projects DFM 0630-01/DFM 0630-06 and DREG7096, totaling 0.57 miles, will begin in 2022 but complete in 2023. As part of our continuing commitment to pipeline safety, PG&E continues to maintain certification in the following industry standards: • PG&E currently holds industry certifications from Publicly Available Specification (PAS) 55 and International Organization for Standardization (ISO) 55001. These enable the development of an effective asset management system, which requires that a pipeline operator: know the condition of their assets; understand the risks to those assets; implement risk reduction strategies; maintain asset condition and performance; and balance asset cost, risk, and performance. • American Petroleum Institute (API) Recommended Practice (RP) 1173, Pipeline Safety Management Systems, provides pipeline operators with safety management system requirements that, when applied, provide a framework to reveal and manage risk, promote a learning environment, and continuously improve pipeline safety and integrity. API RP 1173 was developed for organizations that operate hazardous liquids and gas pipelines in response to major industry incidents. • API RP 754, Process Safety Performance Indicators for the Refining and Petrochemical Industries, provides a framework to identify leading and lagging process safety indicators useful for driving performance improvement. This recommended practice classifies process safety indicators into four tiers of leading and lagging indicators and provides a shift in viewing process safety from reactive and corrective to more predictive and preventive. In 2021, PG&E continued to advance its safety culture with the following employee engagement efforts: • Corrective Action Program - Ensures that notifications are categorized, assessed for risk, and assigned to the appropriate owner to resolve issues and implement effective corrective actions to help prevent recurrence; • Lean Management – Gas Operations continues to support and reinforce the importance of Operating Reviews throughout the organization. Operating Reviews are quick, structured conversations among team members that occur daily, weekly and monthly. Operating reviews provide a platform for employees to review visual management and understand the status of performance, prioritize opportunities, drive actions, and confirm effective countermeasures; • Safety Leadership Development - Beginning in 2017, the Leading Forward: Safety Leadership program was delivered to all operational leaders. The program included three workshops: Shaping a Safety Culture; Identifying and Controlling Exposure; and You Are Not Alone. In 2021, leaders continued to sustain the program by having periodic discussions in which best practices, lessons learned and collaboration for solving issues occurred; and • Leader in the Field - Continued focus on the supervisors and managers being in the field with their employees to assist in removing barriers and resolving safety concerns. In 2021, PG&E’s Gas Operations Managers spent approximately 25 percent of their time in the field with their employees.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2023-06-27

Communication Type: Official Correspondence

Communication Contents: -From Christine Cowsert, Senior Vice President, Gas Engineering: Pacific Gas and Electric Company (PG&E) continues to make progress in addressing the only remaining open safety recommendation of the twelve issued by the National Transportation Safety Board (NTSB) as a result of its investigation of the September 2010 San Bruno pipeline accident. The attached status report provides an update on PG&E’s actions to address the remaining recommendation, P-10-04: Strength Testing, which is currently in “Open – Acceptable Response” status. Progress in implementing this remaining open recommendation has been ongoing since our last update provided on July 6, 2022. We expect that completion of strength testing of the remaining Priority 1 miles associated with P-10-04 will be complete in 2023. Further details are included in this update. We are available to provide additional information or answer any questions you may have by contacting me directly, or Kristina Castrence. PG&E thanks the NTSB for its continuing guidance and leadership as the company continues to work towards our goal of making PG&E’s gas system the safest and most reliable in the nation. PG&E Update for P-10-4, through December 2022: PG&E is continuing to perform hydrostatic testing and records verification of gas transmission pipeline sections designated as Priority 1 (Class 3, Class 4 and Class 1 & 2 HCA) and also for pipeline sections in Class 1 & 2 non-HCA areas. The scope of these miles to be completed under Safety Recommendation P-10-4 was based on a June 4, 2015 snapshot in time. Mileage completed (including Class 1 and 2 Non-HCA pipeline segments) through December 31, 2022 is as follows: • In 2011, PG&E strength tested (164 miles) or verified strength test records (51 miles) for a total of 215 miles. • In 2012, PG&E strength tested (176 miles) or verified strength test records (28 miles) for a total of 204 miles. • In 2013, PG&E strength tested (199 miles) or verified strength test records (40 miles) for a total of 239 miles. • In 2014, PG&E strength tested (135 miles) or verified strength test records (55 miles) for a total of 190 miles. • In 2015, PG&E strength tested (79 miles) or verified strength test records (91 miles) for a total of 170 miles. • In 2016, PG&E strength tested 89 miles. • In 2017, PG&E strength tested 253 miles. • In 2018, PG&E strength tested 286 miles. • In 2019, PG&E strength tested 115 miles. • In 2020, PG&E strength tested 39 miles. • In 2021, PG&E strength tested 32 miles. • In 2022, PG&E strength tested 24 miles. Footnote: Out of the 24 miles strength tested, 4.03 miles were Priority 1 miles. This brings total miles of pipe strength tested or strength test records verified from 2011 to 2022 to approximately 1,856 miles. The totals listed above include not only Priority 1 pipeline sections, but also Class 1 and 2 Non-HCA pipeline sections. During 2022, PG&E continued to perform additional detailed analysis of Priority 1 (Class 3, Class 4, and Class 1 & 2 HCA) pipe to confirm remaining miles to be tested or verified. Attachment A, NTSB 12-22 Update: Priority 1 Strength Test Progress, summarizes the progress for these Priority 1 pipelines. As of December 31, 2021, there were approximately 5.56 miles of Priority 1 pipe remaining to be strength tested, verified, or replaced. The following summarizes the results as of December 31, 2022: • Priority 1 miles reported as of December 31, 2021: 5.56 miles • 2022 Priority 1 miles tested/replaced/retired: 4.72 miles • Remaining Priority 1 miles as of December 31, 2022: 0.84 miles The remaining Priority 1 miles as of December 31, 2022, are primarily short sections or features. Attachment B, NTSB 12-22 Update: Validation Tracker, provides a listing of each of the sections or features that remain to be tested, which will help provide an understanding of the characteristics of these remaining pipeline sections. Of the 0.84 Priority 1 miles remaining, PG&E has reviewed 100 percent of them, has assigned a project to all, and will be completely addressed through strength testing, replacement or retirement in 2023. As part of our continuing commitment to pipeline safety, PG&E continues to maintain certification in the following industry standards: • PG&E currently holds industry certifications from Publicly Available Specification (PAS) 55 and International Organization for Standardization (ISO) 55001. These enable the development of an effective asset management system, which requires that a pipeline operator: know the condition of their assets; understand the risks to those assets; implement risk reduction strategies; maintain asset condition and performance; and balance asset cost, risk, and performance. • American Petroleum Institute (API) Recommended Practice (RP) 1173, Pipeline Safety Management Systems, provides pipeline operators with safety management system requirements that, when applied, provide a framework to reveal and manage risk, promote a learning environment, and continuously improve pipeline safety and integrity. API RP 1173 was developed for organizations that operate hazardous liquids and gas pipelines in response to major industry incidents. • API RP 754, Process Safety Performance Indicators for the Refining and Petrochemical Industries, provides a framework to identify leading and lagging process safety indicators useful for driving performance improvement. This recommended practice classifies process safety indicators into four tiers of leading and lagging indicators and provides a shift in viewing process safety from reactive and corrective to more predictive and preventive. PG&E continues to advance its safety culture with the following employee engagement efforts: • Corrective Action Program - Ensures that notifications are categorized, assessed for risk, and assigned to the appropriate owner to resolve issues and implement effective corrective actions to help prevent recurrence; • Lean Management – Gas Operations continues to support and reinforce the importance of Operating Reviews throughout the organization. Operating Reviews are quick, structured conversations among team members that occur daily, weekly and monthly. Operating reviews provide a platform for employees to review visual management and understand the status of performance, prioritize opportunities, drive actions, and confirm effective countermeasures; • Safety Leadership Development - Beginning in 2017, the Leading Forward: Safety Leadership program was delivered to all operational leaders. The program includes three workshops: Shaping a Safety Culture; Identifying and Controlling Exposure; and You Are Not Alone. In 2022, leaders continued to sustain the program by having periodic discussions in which best practices, lessons learned and collaboration for solving issues occurred; • Leader in the Field - Continued focus on the supervisors and managers being in the field with their employees to assist in removing barriers and resolving safety concerns. In 2022, PG&E’s Gas Managers spent approximately 23 percent of their time in the field with their employees; • Role of the Supervisor - This initiative aims to elevate and redesign the role of the supervisor, encompassing brand reputation and meaningful experiences where supervision is an attractive, important, and supported position throughout the company, and coworkers aspire towards the role. In 2022, PG&E hosted supervisor engagement and listening sessions in multiple coworker town halls; grew participation in the Supervisor Advisory Council beyond Gas and Electric Operations by onboarding Gas Engineering, Customer Operations, and other functional areas; expanded the Supervisor Central Program beyond Gas by providing supervisors throughout the enterprise with a one stop shop for tools and resources and two quarterly community of practice calls; and establi

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2011-02-02

Communication Type: Official Correspondence

Communication Contents: CC# 201100045: - From Christopher P. Johnson, President: On January 3, 2011, the National Transportation Safety Board (NTSB) issued several Safety Recommendations to PG&E and others arising out of its ongoing investigation into the tragic accident in San Bruno, California, on September 9, 2010. In your January 3 letter, you requested that PG&E respond within thirty days with the actions we have taken or intend to take to implement your recommendations. PG&E is fully committed to working expeditiously and cooperatively with the NTSB, the California Public Utilities Commission (CPUC) and other stakeholders to restore public confidence in the safety and integrity of our natural gas transmission system. Ensuring the completeness and the accuracy of PG&E's system records is absolutely fundamental to this effort. As you know, the same day that the NTSB issued these Safety Recommendations to PG&E and sent related Safety Recommendations P-10-5 through P-10-7 to the CPUC, the CPUC's Executive Director sent PG&E a directive to implement the NTSB's Safety Recommendations. The Executive Director's letter was subsequently ratified by CPUC Resolution L-410. On January 7, 2011, PG&E responded to the CPUC's letter, with a description of the scope of the task and the efforts already underway. Yesterday we provided the CPUC with a more detailed update on the work and the plan going forward. A copy of each of our letters is enclosed. PG&E is dedicated to taking all steps to ensure the safety and integrity of our gas pipeline systems, including the monumental effort of verifying the underlying records of over 1,800 miles of pipeline by March 15th. In the meantime, however, if you have any questions, please do not hesitate to contact me. A January 7, 2011 letters from Pacific Gas and Electric to the California Public Utilities Commission: PG&E is fully committed to working expeditiously and cooperatively with the Commission to restore public confidence in the safety and integrity of our natural gas transmission system. Ensuring the completeness and the accuracy of PG&E's system records is absolutely fundamental to this effort. Accordingly, our customers and the Commission have PG&E's pledge that verifying its gas system records is among PG&E's most immediate and highest priorities. As you know, following the San Bruno accident, we discovered a discrepancy in OUI' records. A discrepancy of this nature is not acceptable to us, We initiated a comprehensive records review for the approximately 150 miles of transmission pipeline on the San Francisco Peninsula, Your directive following this week's National Transportation Safety Board (NTSB) recommendations calls on us to extend this type of review to approximately 1,800 miles of transmission pipelines in class 3 and class 4 locations and class I and class 2 high consequence areas throughout our service area. Your January 3, 2011, letter directed PO&E to undertake specific actions in response to the NTSB recommendations and requested that we confirm by today whether this work could be completed by February 1, 2011. PG&E recognizes and supports the urgency surrounding this work and is moving forward aggressively. Our first step, already under way, is to gather all hydrostatic and other pressure test information to verify which pipeline segments have had their maximum allowable operating pressure established through pressure testing. Although we maintain a centralized data base that indicates that the majority of the 1,800 miles of pipeline have been pressure tested, we understand that your directive requires us to review and verify the original paper records, which currently are kept in local offices and records storage facilities. As pal1 of this process, we will also be collecting images of the original records in a centralized system, which is consistent with our understanding of your request. A February 1, 2011 letters from Pacific Gas and Electric to the California Public Utilities Commission: In our January 7, 2011, letter to you we committed to provide the California Public Utilities Commission (Commission) with an update of our progress in fulfilling the directives in your January 3, 2011 letter, ratified by the Commission through Resolution 1.,-410 on January 13, 2011. PG&E is aggressively and diligently working to meet the expectations of the Commission to perform our records review and verification work by March 15, 2011. This letter provides an update on PG&E's work and plan going forward. The Commission's directive applies to over 1,800 miles of gas transmission pipelines in Class 3 and Class 4 locations, and Class I and 2 high consequence areas throughout PG&E's service territory. Consistent with federal regulations, not all of these lines require a pressure test-established maximum allowable operating pressure (MAOP); nevertheless, we are in the process of verifying the number of these pipeline miles for we have records of pressure tests, containing the information required by 49 C.F.R. § 192.517(a). The foundational step and PG&E's initial focus have been collecting, scanning and indexing an estimated 1.25 million individual records associated with approximately 2,750 "job numbers" from PG&E's hard copy records into its electronic database. It is critical to the remainder of this records verification and validation effort that tbis first step provide comprehensive, high quality electronic documentation of PG&E's gas transmission system. Toward that end, the entire process is being subjected to detailed quality assurance oversight, as described in more detail below. As part of the first phase of this records verification project, PG&E has taken the following actions: • PG&E's business lead for this records verification project reports directly to the Senior Vice President, Engineering & Operations. The business lead oversees an internal team of over 50 engineers, estimators, mappers, information technology specialists and managers dedicated exclusively to the project; this team will continue to grow. • PG&E has retained numerous leading external partners to lend specialized expertise and significant additional resources to this process in the areas of document management, process controls, engineering, pipeline pressure calculations, and auditing. For example, Iron Mountain, Inc., a leading global document management company, is dedicating over 230 staff to assist PG&E in timely completing the document collection, scanning and indexing operation. • PG&E has leased new space to house the record verification operations as well as built out space in its existing facilities to accommodate this activity. Progress to date on this project includes: • Document scanning and indexing operations are proceeding 24 hours-a-day, seven days-a-week. • PG&E has collected hundreds or boxes of original records from over 20 field office and other locations across the service territory. • At this stage, PG&E is scanning and indexing tens of thousands of these documents each day. PG&E is using the scanned and indexed records to verify the completeness of pressure test records and other applicable records used to establish each line's MAOP per industry standards and federal code compliance. Over the next six weeks, PG&E will determine the total number of miles for which it has complete, verifiable and traceable records of prior pressure tests. At the same time, PG&E will start the process of using all available verified records identified in the collection, scanning and indexing process to compile a segment-bysegment pipeline features list (PFL). Where necessary, PG&E will perform excavations to verify pipeline features. In the end, as directed by the Commission, MAOP will be validated based on the weakest segment in these Class 3 and 4, and Class I and 2 HCA transmission pipeline sections. PG&E is dedicated to taking all steps to ensure the safety and integrity of our gas pipeline systems, including

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2011-06-14

Communication Type: Official Correspondence

Communication Contents: From The American Gas Association, NOT FROM THE ADDRESSEEE. NOT FROM PGE. –From Christina Sames, Vice President, Operations and Engineering, American Gas Association: The American Gas Association (AGA) has reviewed the safety recommendations issued by the National Transportation Safety Board (NTSB) on January 3, 2011 (P-10-1 through P-10-7). As is our practice, AGA forwarded the recommendations to its member companies. AGA has received a number of questions from its members regarding the' NTSB recommendations and is therefore seeking clarification. Our members, who operate approximately 50,000 miles of transmission pipeline, have been actively engaged in following the developments of the investigation and have been considering how that information should be used to reduce the probability of similar incidents on their system. To that end, the NTSB's recommendations serve as prudent guidance regarding potential safety problems that operators may need to act on if it addresses a relevant factor on their system. Given these recommendations have not gone through the cost-benefit analysis, public notice and comment due process or analysis for potential adverse consequences, which are all normal steps in the rulemaking process, it is assumed these recommendations should not be considered a regulatory mandate nor should they be followed verbatim if the circumstances are not applicable for their system. To ensure appropriate response, AGA is seeking clarification from the NTSB that it did not intend for federal or state regulators to codify the exact language in the safety recommendations into state and federal pipeline safety codes which are applicable to all operators. In many cases, the safety recommendations appear to conflict with existing language, in other instances, the recommendations omit key provisions of the pipeline safety regulations. The clarification of the intended scope and applicability of the safety recommendations will allow operators nationwide to focus finite resources on appropriate areas that will provide real improvement in pipeline safety rather than diluting efforts in as that were never intended by the NTSB. Specific NTSB safety: recommendations that AGA believes should be clarified to achieve a consistent interpretation across the natural gas industry include P-10-1 to P-:-10-4 as follows. P-10-001: Please clarify the NTSB's intent relative to recommendation P-10-1. AGA believes the NTSB intended that PHMSA should inform pipeline operators of the circumstances and consequences surrounding the pipeline rupture in San Bruno and that, based on this information, operators should take appropriate action, if necessary, to conduct additional records searches based on the unique circumstances of their individual systems. AGA believes that the NTSB did not intend all natural gas transmission pipeline operators to implement an exhaustive records search or the other provisions detailed in recommendations P-10-2 to P-10-4 (below). P-10-002: Please clarify the NTSB's intent related to recommendation P-10-2. AGA believes that the NTSB intended that the recommendation to "aggressively and diligently search for all as-built drawings, alignment sheets, and specifications, and all design, construction, inspection, testing, maintenance, and other related records" applied exclusively to Pacific Gas and Electric Company or other operators who in individually determine the need to conduct a detailed records search for their natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high consequence areas that have not had a maximum allowable operating pressure (MAOP) established through prior hydrostatic or pressure testing. AGA also requests that the NTSB clarify its use of the term "hydrostatic testing." AGA believes the intent of the recommendation was to focus the record search on pipelines where MAOP has not been previously established through "pressure testing" in accordance with 49 CFR Part 192, Subpart J add 192.619 (see the request for clarification to P-10-4 below). AGA also requests clarification for transmission pipelines installed prior to the enactment of Subpart J. AGA believes the phrase "established through prior hydrostatic pressure testing" is meant to address the stability of transmission pipeline longitudinal seams through a post construction pressure test and no a requirement to have all pipelines be tested to Subpart J standards. Finally, AGA requests that the NTSB provide clarification to the phrase "traceable, verifiable and complete". AGA believes that the recommendation was intended to direct Pacific Gas and Electric to identify records confirming the strength of the line pipe and related components from the time of construction. In the event that the appropriate records are unavailable for any reason, AGA believes the N SB intended PG&E, or other operator who individually determines the need to conduct a detailed records search, to make a conservative default assumption relative to the strength of the respective pipe or components. P-10-003: Please clarify the NTSB's intent related to recommendation P-10-3. AGA believes that the NTSB intended the recommendation to use traceable, verifiable, and complete records located by implementation of P-0-2 to determine the valid MAOP of natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high consequence areas that have not had an MAOP established through prior hydrostatic or pressure testing to apply exclusively to Pacific Gas and Electric Company or those operators who individually determine the need to re-establish the MAOP of natural gas transmission lines based on the information contained in the PHMSA Advisory. As noted in the response to P-10-2 (above) and P-10-4 (below), please clarify NTSB's intent that the MAOP could have been previously established using "pressure testing" as defined by the provisions of 49 CFR Part 192, Subpart J and 1 2.619. P-10-004: Please clarify the NTSB's intent related to recommendation P-10-4. AGA believes that the NTSB intended for recommendation P-10-4, requiring natural gas transmission pipelines in class 3 and class 4 locations and class 1 and class 2 high consequence areas that have not had a maximum allowable operating pressure established through "prior pressure testing" to have the MAOP determined by a spike test followed by a hydrostatic pressure test, to apply exclusively to Pacific Gas and Electric Company. AS the NTSB noted in the safety recommendations, an operator may not be able to comply with safety recommendations P-10-2 and P-10-3. Operators have stated before the California Public Utility Commission (CPUC) that "traceable, verifiable and complete records for pipelines installed over 50 years ago was a very difficult, if not infeasible threshold to achieve." The phrase is not used in applicable regulations. As the NTSB noted, "Although hydrostatic testing is recognized to be a direct and effective methodology for validating an MAOP, its implementation requires that operating lines be shut down, which may adversely affect customers dependent on the natural gas supplied by the pipeline, particularly if the pipe fails during the test, which could necessitate a protracted shutdown." In addition, AGA notes that by placing water, a corrosive fluid, in a pipeline there is a very real possibility of introducing an unintended consequence of internal corrosion to the pipeline if the water is not eliminated completely after the hydro-test. Complete dehydration is extremely difficult for a pipeline that has already been placed into se ice and lines that include certain valves and laterals. Since the pipeline safety code, 49 CFR Part 192 -Transportation of Natural Gas by Pipeline: Minimum Federal Safety Standards, was established in 1970, operators and regulators have been very clear on the regulatory requirements for establishing the MAOP of new, r

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2013-09-04

Communication Type: Official Correspondence

Communication Contents: -From Christopher P. Johns, President: PG&E completed MAOP validation for all pipelines in class locations 3 and 4 and in high consequence areas in class locations 1 and 2 in January 2012 as reported to the CPUC and to the NTSB. The MAOP validation was based on the weakest section of the pipeline or component in class 3 and 4 locations and class 1 and 2 high consequence areas that did not have an MAOP established through prior hydrostatic testing. In addition to completing NTSB Recommendation P-1 0-3, PG&E has validated all remaining transmission lines in non-high consequence areas. On December 15, 2011 , the Commission issued a decision to PG&E's request to lift operating pressure restrictions authorizing PG&E to operate Lines 101, 132A and 147 to no higher than 365 psig. On July 3, 2013, PG&E submitted a document to the Commission that identified errors in some of the information previously filed to support lifting operating pressure restrictions. That document identified two types of errors in our previously-filed information: • Errors based on inaccurate pipe specifications. We have identified errors in our previously-submitted pipe specifications for a total of four segments of Line 147. Three of these lowered the maximum allowable operating pressure (MAOP) of Line .147 below the Commission-authorized 365 pounds per square inch gauge (psig) ; • Errors based on a corrected regulatory interpretation. We have recently concluded based on a conservative reading of the federal pipeline regulations that we inappropriately relied on a 1989 hydro test to set the MAOP for one segment of Line 1 01. Although we have acknowledged the need to correct our previously-submitted documentation for Line 147, all of the class 3 and 4 and class 1 and 2 high consequence area pipe have been strength tested to pressures well in excess of the 365 psig pressure we asked the Commission to authorize. In accordance with NTSB Recommendation P-10-2 (Records), we have undertaken an unprecedented effort to collect and organize our records to validate the MAOP of our entire gas transmission system. We recognize that our older, historic records are not complete. That is why we have embarked on a program, supported by the Commission in Decision 11-06-017, to strength test to modern standards or replace all transmission pipe for which we do not have complete, verifiable records of an appropriate strength test. The issues we identified in our Line 147 documentation revealed gaps in the early stages of our MAOP validation process, and we have continued to refine and improve this process over the year and a half since we filed our pressure restoration request. Examples of such enhancements include: (a) additional independent third-party review; (b) testing and validation of conservative engineering assumptions; and (c) implementing a computerized engineering data validation tool. These measures are part of our continuous improvement efforts, and raise our level of confidence in the rigor of our process and minimize the opportunity for errors going forward. We are continuing to strength test our transmission pipe so that the safety of all of our pipelines will ultimately be confirmed by a pressure test. Additionally, we continue to apply the findings from field excavations to confirm the accuracy of our existing records .and validate our conservative engineering assumptions. The inaccuracies identified also prompted us to review the way we were interpreting the federal code provisions related to class locations (i.e., the population density of areas in which pipelines operate). Specifically, we came to focus on a specific section of the federal code that was repealed over 15 years ago which gave pipeline operators a three-year window from 1971 to 1974 to determine the class locations in which their pipelines were operating and validate their respective MAOPs via strength tests. Historically, PG&E had interpreted 49 C.F.R. 192.611 to allow a pipeline to operate one class location above its original design ("one class-out") as long as it had been subjected to a valid Subpart J pressure test for eight hours in a different year than the install year. PG&E now believes that 192.611 (a) may preclude operators from relying upon a post-197 4 pressure test to operate a segment "one class-out" if that segment changed up in class before April15, 1971. Applying our revised interpretation of the one-class-out provisions and analyzing the pipeline, we determined that one segment of Line 101 had changed class prior to 1971 and was strength tested after 1974. That segment changed from a class 2 to class 3 in approximately 1952. The segment had a strength test to 650 psig in 1989, which would support an MAOP of 433 psig in a class 3 location. The MAOP validation records PG&E submitted to the Commission in October 2011 showed this segment of Line 101 capable of operating at 60 percent SMYS with a MAOP of 396 psig, and indicated it was "operating in class" in light of the strength test and per our historical application of the code. However, since the 1989 strength test cannot be used to allow the segment to operate one-class-out, class 3 requires an MAOP of 330 psig. The CPUC's Safety and Enforcement Division (SED) agrees that as long as properly conducted pressure tests were performed as represented, Lines147 and 101 can be operated consistent with state and federal regulations at the current reduced pressure. The SED emphasized the importance of pressure testing to guard against any record-keeping shortcomings, and agreed that all public safety issues have been addressed by PG&E's operational actions. On August 19, 2013, the Commission issued an Order to Show Cause why authority to increase operating pressure should not be stayed and directed PG&E to file a statement by August 30, 2013 setting forth the exact events, with dates, which revealed PG&E's errors, and PG&E's subsequent actions. PG&E's response on August 30 addresses in additional detail, the information that is provided above. Copies of both documents are attached for your review. We appreciate the guidance and leadership the NTSB has provided to PG&E as we continue to work to address the safety recommendations. I welcome an opportunity to provide additional details about any aspect of our pipeline safety enhancement program that you or your staff may find helpful.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2015-03-23

Communication Type: Official Correspondence

Communication Contents: -From Nick Stavropoulos, Executive Vice President, Gas Operations: Pacific Gas and Electric Company (PG&E) continues to make significant progress implementing the safety recommendations outlined by the NTSB's investigation of the September 2010 San Bruno pipeline accident. The attached status report provides an update on PG&E's actions to address the remaining recommendations that are currently in "Open-Acceptable Response" status: 1. P-1 0-04: Strength Testing 2. P-11-26: Supervisory Control and Data Acquisition System Tools 3. P-11-27: Valve Automation Program PG&E believes that substantial progress has been made to implement these remaining open recommendations, and that one of the three is at the point that it may be considered for closure. We request that the NTSB review the information provided in this status report and consider closing recommendation P-11-26. In addition, we expect that recommendation P-11-27 will be ready to be considered for closure later this year, and the third recommendation, P-1 0-04, may be ready for consideration of closure in 2016. We are available to provide additional information or answer any questions you may have. PG&E thanks the NTSB for its continuing guidance and leadership as the company continues to work towards our goal of making PG&E's gas system the safest and most reliable in the nation. PG&E Update for P-10-4, End of 2014: PG&E is continuing to perform hydrostatic testing and records verification of gas transmission pipeline sections designated as Priority 1 (Class 3, Class 4 and Class 1 & 2 HCA). Mileage completed (including some Class 1 and 2 Non-HCA pipeline segments intermingled as necessary with Priority 1 segments) through 2014 is as follows: • In 2011, PG&E strength tested (163 miles) or verified strength test records (51 miles) for a total of 214 miles. • In 2012, PG&E strength tested (177 miles) or verified strength test records (27 miles) for a total of 204 miles. • In 2013, PG&E strength tested (201 miles) or verified strength test records (40 miles) for a total of 241 miles. • In 2014, PG&E strength tested (134 miles) or verified strength test records (44 miles) for a total of 178 miles (validation of 2014 results is in the process of being completed). This will bring the total miles strength tested (675 miles) or strength test records verified (162 miles) from 2011 to the end of 2014 to 837 miles. Please note that totals for 2012 and 2013 have been updated from our previous submittal, reflecting full as-built documentation. As we begin 2015, PG&E has less than 100 segment miles of pipeline in class 3 and class 4, and class 1 and class 2 high consequence areas remaining to be tested or strength test records verified. PG&E plans to test these miles in 2015 and 2016. The remaining mileage in these categories is relatively low, however testing over the two years is necessary as many of the remaining segments are short and will be tested within longer Class 1 and class 2 Non-HCA segments.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2015-10-27

Communication Type: Official Correspondence

Communication Contents: -From Nick Stavropoulos, President, Gas: Pacific Gas and Electric Company (PG&E) continues to make significant progress implementing the safety recommendations issued by the NTSB as a result of its investigation of the September 2010 San Bruno pipeline accident. The attached status report provides an update on PG&E's actions to address the remaining recommendations that are currently in "Open-Acceptable Response" status: 1. P-1 0-04: Strength Testing 2. P-11 -27: Valve Automation Program PG&E believes that substantial progress has been made to implement these remaining open recommendations, and that one of the recommendations may be considered for closure. We request that the NTSB review the information provided in this status report and consider closing recommendation P-11-27. In addition, we are completing additional analysis on the remaining work needed to complete recommendation P-10-04, indicating that completion will be later than 2016. Details of that analysis are included in this update. We are available to provide additional information or answer any questions you may have. PG&E Update for P-10-4, through September 2015: PG&E is continuing to perform hydrostatic testing and records verification of gas transmission pipeline sections designated as Priority 1 {Class 3, Class 4 and Class 1 & 2 HCA). Mileage completed (including some Class 1 and 2 Non-HCA pipeline segments intermingled as necessary with Priority 1 segments) through 2014 and planned for 2015 is as follows: • In 2011, PG&E strength tested (164 miles) or verified strength test records (51 miles) for a total of 215 miles. • In 2012, PG&E strength tested (176 miles) or verified strength test records (28 miles) for a total of 204 miles. • In 2013, PG&E strength tested (199 miles) or verified strength test records (40 miles) for a total of 238 miles. • In 2014, PG&E strength tested (135 miles) or verified strength test records (55 miles) for a total of 190 miles. • In 2015, PG&E plans to strength test nearly 80 miles. This will bring total miles of pipe strength tested or strength test records verified from 2011 to 2015 to approximately 927 miles. Please note that totals for 2011 to 2015 have been updated from our previous submittal, reflecting full as-built documentation. Since our March, 2015 update, we have been able to perform more detailed analysis of the remaining segments in class 3 and 4 locations and class 1 and 2 HCAs to be strength tested or have records verified. This analysis has been enabled by the development of PG&E's new gas transmission GIS system, consolidating pipeline data from several sources into a centralized database and providing better investigation capability. In addition, completion of the pipeline centerline project, additional available data layers, and the use of LIDAR data has allowed for improved accuracy in class and HCA designations. There are approximately 134 miles of pipe associated with this recommendation that will remain to be strength tested after 2015. More granular data shows that these remaining miles are primarily short segments, including tie-in pieces, fittings, or smaller diameter off-takes from the larger transmission pipelines. While the average test length for 2011 to 2014 was approximately two miles, these remaining segments are on average less than 0.1 miles in length, which will require completing over 2,000 specific projects. Analysis to optimize grouping and scheduling these segments is ongoing, but may result in a scheduled completion of all projects in the 2020 to 2025 timeframe. We will provide a detailed plan and schedule for completion once our analysis is finished at the end of 2015.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2013-01-31

Communication Type: Official Correspondence

Communication Contents: -From Christopher P. Johns, President: Pacific Gas and Electric Company (PG&E) continues to make substantial progress implementing the safety recommendations outlined by the NTSB's investigation of the September 2010 San Bruno pipeline accident. This status report provides details on the actions we are taking to assure public safety remains the company's highest priority. In 2012, the NTSB evaluated PG&E's progress and closed four recommendations: 1. pe10-2: Search for Records 2. P-11-3: 911 Notifications 3. P-11-25: Emergency Response Procedures 4. P-11-28: Toxicology Testing In this report, we are submitting three additional recommendations for closure consideration by the NTSB: 1. P-10-3: MAOP Validation 2. P-11-24: Work Clearance Procedures 3. P-11-31: Public Awareness Program Continuous Improvement For recommendation P-10-3 (MAOP Validation), PG&E has completed the determination of the valid maximum allowable operating pressure (MAOP), based on the weakest section of the pipeline or component. The purpose of the MAOP validation is to ensure safe operation of natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high consequence areas (HCA) that have not had a MAOP established through prior hydrostatic testing. In total, MAOP validation was performed for all 2,088 miles of these transmission pipelines. In addition to completing NTSB Recommendation P-10-3, PG&E is validating all remaining transmission lines in non-HCAs by mid- 2013. In 2012, PG&E completed the MAOP validation of 4, 199 miles of non-HCA pipelines. For recommendation P-11-24 (Work Clearance Procedures), PG&E has completed the revision and issuance of work clearance procedures that include requirements for identifying the likelihood and consequences of failure associated with planned work. The development of contingency plans is now a part of this process. PG&E's new procedure ensures accurate and completed clearance forms and requires field crews, control room operators and individuals who have been assigned the clearance supervisor role to have complete knowledge of the intended work and written clearance procedure. PG&E has completed recommendation P-11-31 (Public Awareness Program Continuous Improvement) through the development and incorporation of written performance measurements and guidelines into our Public Awareness Plan (PAP) for evaluating the plan and for continuous program improvement. The primary objectives include awareness, damage prevention and emergency response readiness. PG&E has also completed two portions of recommendation P-11-29 (Integrity Management Program): Revisions to PG&E's Risk Model and Risk Analysis Methodology. Other recommendations with significant progress highlighted in the attachment include: • (P-10-4)-ln 2012, PG&E strength tested or verified an additional 202 miles for a total of 417 miles since 2011 • (P-11-2)-PG&E installed 46 valves in 2012 (for a total of 59 valves since 2010) • (P-11-29)-ln addition to revising the Integrity Management Risk Model and Risk Analysis Methodology, PG&E is continuing to revise other portions of its integrity management program PG&E thanks the NTSB for both its continuing guidance and leadership as the company works to address the remaining safety recommendations. Please contact me directly if you have any questions. PG&E is continuing to perform hydrostatic testing or records verification of gas transmission pipeline sections designated as Priority 1 (those segments located within urban areas (Class 4, 3 and 2) operating above 30% without record of a pressure/strength test). In 2011, PG&E hydro tested (163.5 miles) or verified (50.9 miles) a total of 214.4 miles. In 2012, PG&E strength tested (175 miles) or verified (28 miles) an additional 202 miles. PG&E expects to complete pressure testing or records verification of a total of 783 miles by the end of 2014.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2012-05-23

Communication Type: Official Correspondence

Communication Contents: -From Christopher P. Johns, President: Pacific Gas and Electric Company (PG&E) is making substantial progress to implement the safety recommendations outlined by the National\ Transportation Safety Board's (NTSB) investigation of the September 2010 San Bruno pipeline accident. This status report details the actions PG&E has taken and will continue to take to assure public safety remains the company's highest priority in the operation of our natural gas transmission system. We have made many fundamental changes to the operations and management practices throughout our gas organization. Some of the more critical actions include: completion of the Maximum Allowable Operating Pressure validation of all 2,088 miles of high consequence area (HCA) pipelines; validation of 1,032 miles of non -HCA pipelines through April 2012; and automation of 36 valves. In 2011, PG&E conducted strength tests and verified strength test pressure records for a total of approximately 214.5 miles of pipeline. Additionally, from January through April 2012, an additional 37.6 miles have been tested or verified. PG&E's Pipeline Safety Enhancement Plan (PSEP), currently before the CPUC for approval in R.11-02-019, outlines our plan for testing or verifying records of 547 miles in 2012 -2014. PG&E has modified its 911 Notification Process to respond to the NTSB's suggestion that SCADA real time operating data and alarms serve as triggers for 911 notifications. We have developed a comprehensive emergency response procedure for large-scale emergencies on transmission lines, which identifies a single person in charge, outlines specific protocols and provides for drills and training. PG&E has also incorporated performance measures and guidelines to assure continuous improvement in our public awareness program. PG&E has initiated a complete assessment of every aspect of our transmission integrity management program including threat identification and assessment. Much more work lays ahead, but the progress to date gives us confidence that PG&E is on track to achieving the goal of regaining the trust of the public and our regulators by demonstrating our steadfast commitment to safety. The attachment to this letter provides a more detailed summary of each NTSB recommendation and the steps we have taken and continue to take to act upon them. If you have any questions, please contact me directly. 2011 Progress Overall in 2011, PG&E conducted strength tests on 163.5 miles of gas transmission pipeline and verified strength test pressure records for an additional 50.9 miles of pipeline, for a total of approximately 214.5 miles. In 2011, PG&E successfully strength tested, tied in, replaced or had strength test pressure records verified for 144.5 of the 152 miles of IIPriority 1" pipeline (those segments identified to be similar to the pipeline segment that failed in San Bruno). (About 1.1 miles of the 152 Priority 1 miles has been abandoned in the area of the San Bruno rupture and will not be strength tested.) PG&E has tested a total of about 39.5 miles of Line 132 (about 37 miles tested in 2011). An additional 12.6 miles is planned for testing in 2012. By the end of 2012, PG&E expects that all 52.1 miles of Line 132 (with the exception of the out of service segment that ruptured on September 9, 2010) will have been strength tested. PG&E is conducting strength tests at 1.7 times the MAOP plus a 10°1'0 spike test where possible. In some locations where a pipe is operating at 72% of SMYS, the strength test may be limited to 1.25 times the MAOP plus a 10% spike to avoid exceeding 100% of SMYS. Also, when significant elevation changes cause the spike test pressure to exceed 100% of SMYS, PG&E has not conducted the spike test. This occurred on about 12 tests out of 97 tests completed in 2011. Additional information regarding 2011 test levels is shown in Attachments P-10-4A and Attachment P-10-4B. PG&E provided the CPUC with monthly reports on the status of its strength testing progran1. Attachment ?-10 4C shows the Report of Pacific Gas and Electric Company on Status of Hydrostatic Pressure Testing as of December 30, 2011. 2012-2015 Progress and Plan PG&E's proposed Pipeline Safety Enhancement Plan (PSEP), currently before the CPUC for approval in R.11 02-019, outlines a 2-phase approach for strength testing. Phase 1 of the plan calls for testing or verifying records of 185 miles in 2012, 204 miles in 2013, and 158 miles in 2014. Phase 1 strength testing addresses the following types of pipes: • Pre-1970, low-'frequency electric resistant weld (ERW), flash welded, single submerged arc weld (SSAW), furnace butt welded, and lap welded pipe operating between 20% and 30% SMYS in urban areas. • All urban-area pipes operating at or above 30% SMYS, unless it has been scheduled for replacement or an adequate strength test for the pipe exists. During Phase 2 (which will begin in 2015), PG&E forecasts the need to strength test an additional 1,700 miles of pipeline. Including: • All urban area pipes operating below 30% SMYS, unless it has been scheduled to be replaced or an adequate strength test for the pipe exists. • All identified pipe not previously strength tested or replaced in Phase 1, which includes pipe located in Class 1 non-HCA (rural areas), unless an adequate pressure test exists for the pipe. If approved by the CPUC, PSEP progress reports will be provided to the CPUC every six months and will include updates on strength testing. Attachment P-1 0-4D shows the schedule for strength testing in 2012 and Attachment P-10-4E is the list of projects to be scheduled in 2013 and 2014. Through April 2012, nine tests have been completed for 18.9 miles and an additional 18.7 miles of records have been verified.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2011-12-22

Communication Type: Official Correspondence

Communication Contents: -From Christopher P. Johns, President: Pacific Gas and Electric Company (PG&E) has fully embraced the safety recommendations outlined by the National Transportation Safety Board (NTSB) as part of the agency's review of the September 2010 San Bruno pipeline accident. We at PG&E recognize the importance of preventing a tragedy like this from ever happening again, and we are grateful for the NTSB's guidance toward that goal. As requested in your September 26, 2011 letter, we are providing an update on the actions PG&E is taking, and the plans that are in place to implement the NTSB's thoughtful and thorough recommendations. These recommendations have prompted PG&E to take significant actions on many fronts, including pipeline leak and break identification, emergency response, integrity management, threat assessments, public awareness of pipeline safety measures, and recordkeeping. The NTSB's recommendations have helped propel PG&E to make fundamental changes to our operations and management-all intended to underscore our commitment to putting public and employee safety first. For example, we've completed Maximum Allowable Operating Pressure validation of more than 1,600 miles of high consequence area pipelines, with plans to complete all 2,000 miles by the end of January 2012. We are implementing a new data management system intended to address the NTSB's recommendations for traceable, verifiable and complete records. Additionally, PG&E has automated 11 shutoff valves in 2011. As part of the company's Pipeline Safety Enhancement Plan, which was presented for approval to the California Public Utilities Commission this year, PG&E has proposed automating a total of 228 valves through 2014. We've also updated our emergency response plans to reflect industry best practices and have begun training employees, public officials and first responders. In an effort to improve public gas safety awareness, we've mailed more than two million safety information letters to customers who live within 2,000 feet of a transmission pipeline. We realize we still have much to learn and do in the wake of the tragic San Bruno accident. As you'll see in the attachment, we have completed several of the recommendations and are in mid-stream on the remainder. We're working with urgency to complete all of the recommendations and we remain steadfast in our commitment to safety and to regaining the trust of the public and our regulators. The attachment to this letter provides a more detailed summary of each NTSB recommendation and the steps we are taking to act upon them. If you have any questions, please contact me directly. • In 2011, PG&E hydrostatically tested, replaced or verified strength test pressure records for about 144 of the 152 Priority 1 transmission pipeline miles with similar characteristics to the line that failed in San Bruno. • A total of 163.6 miles was tested in 2011. • PG&E plans to hydrostatic pressure test approximately 185 miles in 2012, 204 miles in 2013 and 158 miles in 2014.