{"operation":"document","citation":"P-10-004","title":"NTSB Safety Recommendation P-10-004","source_type":"guidance","agency":"National Transportation Safety Board","status":"guidance","official":true,"published_on":"2011-01-03","effective_on":"2011-01-03","summary":"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 throug","machine_formats":{"json":"https://regulus.evalyn.ai/document/ntsb-recommendation-p-10-004.json","markdown":"https://regulus.evalyn.ai/document/ntsb-recommendation-p-10-004.md"},"app_url":"https://regulus.evalyn.ai/document/ntsb-recommendation-p-10-004","source_url":"https://data.ntsb.gov/carol-main-public/sr-details/P-10-004","body":"NTSB safety recommendation P-10-004.\n\nTO 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.\n\nPriority: CLASS II\n\nOverall Status: Closed - Acceptable Action\n\nIssued Date: 2011-01-03\n\nAdopted Date: 2010-12-30\n\nOverall Date Closed: 2023-09-06\n\nSynopsis: 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.\n\nProbable 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.\n\nNtsbnumber: DCA10MP008\n\nReport Number: PAR-11-01\n\nAddressee Name: Pacific Gas and Electric Company\n\nAddressee Status: Closed - Acceptable Action\n\nAddressee Date Closed: 2023-09-06\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2017-03-27\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2018-07-06\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2019-09-18\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2020-11-24\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2021-10-26\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2022-07-26\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2023-09-06\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2012-03-13\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2012-08-29\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2011-03-14\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2011-11-23\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2014-09-25\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2015-05-15\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2015-12-01\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2015-10-28\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2017-02-10\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2018-03-23\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2019-07-15\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2020-10-15\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2021-09-03\n\nCommunication Type: Official Correspondence\n\nCommunication 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.\n\nAddressee Acronym: PG&E\n\nAddressee Organization Type: P-Private Industry\n\nCommunication Date: 2022-07-06\n\nCommunication Type: Official Correspondence\n\nCommunication 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 ","truncated":true,"body_characters":92686}