# NTSB Safety Recommendation P-10-006

- **operation:** document
- **citation:** P-10-006
- **title:** NTSB Safety Recommendation P-10-006
- **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 CALIFORNIA PUBLIC UTILITIES COMMISSION: If such a document and records search cannot be satisfactorily completed, provide oversight to any spike and hydrostatic tests that Pacific Gas and Electric Company is required to perform according to Safety Recommendation (P-10-4).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-10-006.json
- **markdown:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-10-006.md
- **app url:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-10-006
- **source url:** https://data.ntsb.gov/carol-main-public/sr-details/P-10-006
**body:**

NTSB safety recommendation P-10-006.

TO THE CALIFORNIA PUBLIC UTILITIES COMMISSION: If such a document and records search cannot be satisfactorily completed, provide oversight to any spike and hydrostatic tests that Pacific Gas and Electric Company is required to perform according to Safety Recommendation (P-10-4).

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2011-01-03

Adopted Date: 2010-12-30

Overall Date Closed: 2023-09-29

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: State of California, Public Utilities Commission

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2023-09-29

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2018-01-10

Communication Type: Official Correspondence

Communication Contents: -From Timothy J. Sullivan, Executive Director: This letter and the attached Status Report provide an update of the progress the California Public Utilities Commission (CPUC) has made in addressing the National Transportation Safety Board (NTSB) Safety Recommendations. The NTSB issued Safety Recommendations P- 10-5. P-10-6 and P-10-7 on January 2, 2011, and Safety Recommendations P-11 -22 and P-11-23 on September 26, 2011, as a result of its investigation of the September 9, 20 I 0, natural gas pipeline failure that occurred in a residential area in the City of San Bruno, California. As outlined in the attached Status Report 011 NTSB Recommendations to the CPUC (Status Report), the CPUC has completed several of the Safety Recommendations and plans in place to verify completed actions on NTSB recommendations P-1 1-23 and P-10-6 and will continue to update the NTSB on an annual basis. The table below summarizes the current status of all of the NTSB Safety Recommendations issued to the CPUC. Safety Recommendation P-10-5: closed on 9/9/14 with Acceptable Action Safety Recommendation P-10-6: Open- with Acceptable Action Safety Recommendation P-10-7: Closed on 3/29/11 with Acceptable Action Safety Recommendation P-11-22: Closed on 9/9/14 with Acceptable Action Safety Recommendation P-11-23: Open with Acceptable Action The CPUC looks forward to the continued partnership with the NTSB in its efforts to improve natural gas safety. The National Transportation Safety Board (NTSB) made several safety recommendations following the September 9, 2010 San Bruno pipeline incident. Among the safety recommendations directed to Pacific Gas and Electric Company (PG&E) and the California Public Utilities Commission (CPUC) was that the CPUC should develop an implementation schedule for the requirements of Safety Recommendation P-10-2 (Urgent) to PG&E. This required that the CPUC ensure, through adequate oversight, that PG&E has aggressively and diligently searched documents and records relating to pipeline system components, such as pipe segments, valves, fittings, and. weld seams, for PG&E 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 maximum allowable operating pressure established through prior hydrostatic testing. These records should be traceable, verifiable, and complete; should meet regulatory intent and requirements; and should have been considered in determining maximum allowable operating pressures for PG&E pipelines. To ensure the safety and reliability of gas pipeline systems in California, the CPUC has adopted several of the most stringent pipeline safety rules in the nation. Driving these rules is the CPUC's commitment to require a pressure test or replacement for any transmission pipeline operating under the grandfather clause. Specifically, CPUC Decision 11-06-017, and subsequently California Public Utilities (PU) Code Section 958 requires all California natural gas transmission operators to develop and file for CPUC consideration implementation plans for comprehensive pressure testing, also known as Pipeline Safety and Enhancement Plans (PSEP), to achieve the goal of orderly and cost effectively replacing or testing all natural gas transmission pipelines that have not been pressure tested. To ensure that PG&E properly hydrotests its pipelines, pursuant to NTSB Safety Recommendation P-10-4, the CPUC has been performing ongoing oversight of spike and hydrostatic tests performed by PG&E, including a field presence at numerous PG&E PSEP projects since inception as well as PG&E PSEP procedures, policies and records. Between January 1, 2011, and December 31, 2016, PG&E has verified approximately 5,850 miles of transmission pipeline; note, there are approximately 740 miles of transmission pipeline remaining to be strength tested or replaced per PU Code Section 958. PG&E has hydrostatically tested over 700 miles of pipeline to date. PG&E will update the NTSB on these numbers as of December 2017 in their 2018 update to the NTSB. On February 2, 2017, PG&E updated NTSB on Safety Recommendation P-10-4. PG&E stated that approximately 24 miles of priority 1 pipe remained to be strength tested, verified, or replaced. Also, PG&E stated that completion of testing and inspection of remaining pipe would occur in 2022. Between January 1 and November 30, 2017, PG&E mitigated 1.43 miles of the 24 miles of priority 1 reported pipe. PG&E is in the process of project scoping the remaining priority 1 pipe and will report the remaining mileage to the NTSB in early 2018. The remaining miles are primarily short sections or features. In order to complete these shorter sections or features, we expect that completion of priority 1 segments will extend to approximately 2022 or beyond. PG&E is currently on track to mitigate all priority 1 pipe by 2022.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2018-05-15

Communication Type: Official Correspondence

Communication Contents: -From Alice Stebbins, CPUC Executive Director: On January 10, 2018 the California Public Utilities Commission (CPUC) provided our annual status report and update on the two remaining National Transportation Safety Board (NTSB) Safety Recommendations, P-11-23 and P-1 0-6 directed to the CPUC. On February 21, 2018, CPUC received the NTSB response dated February 2 1, 2018, which asked for additional oversight and monitoring of Pacific Gas and Electric Company's (PG&E's) progress in meeting their goal of replacing all Priority 1 pipe by year 2022. CPUC understands that Senior PG&E representatives met with NTSB in person in Washington D.C. in 2018 to accompany PG&E's annual update on NTSB Safety Recommendations. On April 19, 2018, CPUC Pipeline Safety Senior Management also met with PG&E specifically addressing the pace of PG&Es Priority 1 hydrostatic testing plan. PG&E explained that while the pace was slower than anticipated, they still plan to complete all remaining hydrostatic testing by year 2022. PG&E did mention that the pace for earlier completed Priority l miles was faster because they tested longer segments, whereas the remaining Priority I pipe are typically shorter segments. PG&E's explanation appears reasonable; however, CPUC will continue to conduct additional oversight of this remaining work. PG&E will also provide quarterly updates to the CPUC and meet twice yearly in person to discuss PG&E's progress in completing the Priority 1 pipe hydrostatic testing.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2011-02-02

Communication Type: Official Correspondence

Communication Contents: CC# 201100046: - From Paul Clanon, Executive Director: On January 3, 2011, the National Transportation Safety Board (NTSB) issued safety recommendations 10•5 , 10-6 and 10-7 to the California Public Utilities Commission (CPUC) concerning the San Bruno pipeline explosion of September 9, 2010. Immediately following the issuance of the NTSB recommendations the CPUC directed PG&E to undertake a plan of action to comply with NTSB Recommendation P-10-2, and to provide the CPUC with a status report on PG&E's efforts by February 1st, (Copy attached) Also, on January 3, 2011, the CPUC complied with NTSB Recommendation P-10-7 by informing all of California's intrastate natural gas transmission operators (Southern California Gas Company, San Diego Gas& Electric, and South West Gas Company) of the NTSB recommendations, directing the operators to undertake compliance with NTSB Recommendation 10-2 to PG&E, and to report on the status of their efforts by February 1st. (Copies attached) On February 1st all of the intrastate natural gas operatorsin California reported their implementation schedules to the CPUC. (Copies attached) The CPUC remains committed to aggressively and urgently implementing the NTSB Safety Recommendations P-10-5 thru P-10-7 (Urgent).

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2012-05-07

Communication Type: Official Correspondence

Communication Contents: -Paul Clanon, Executive Director: The California Public Utilities Commission (CPUC) thanks the National Transportation Safety Board (NTSB) for its thorough and thoughtful analysis of the tragic rupture of the natural gas pipeline, Line 132 located in San Bruno, owned by Pacific Gas and Electric Company (PG&E). The CPUC is committed to implementing each of the NTSB recommendations directed at our agency. Our goals are simple: • Reform the CPUC to make safety its first priority; • Ensure the safety of existing natural gas pipeline infrastructure; • Upgrade and replace existing natural gas pipeline infrastructure to improve safety; and • Instill safety culture in the natural gas pipeline operators we oversee. This letter serves as an update on our progress. Urgent Recommendation NTSB P-10-6 required that the CPUC provide oversight to any hydrotesting required by NTSB Safety Recommendation P-10-4 (to PG&E). CPUC staff is actively monitoring the ongoing hydrotesting efforts. PG&E completed tes ting 152 miles in January 2012. CPUC staffs oversight responsibility will continue as the operators begin additional hydrotesting and pipeline replacement proposed in gas safety implementation plans currently under consideration. The CPUC has engaged consultant support to assist in our oversight as we build more expertise in this area. NTSB P-10-6 also required that the CPUC review PG&E's requests to increase pressure on lines facing pressure reductions. The CPUC has reviewed and approved requests by PG&E to restore pressure on Lines 101, 132A, and 147, as well as pressure restoration of facilities in the suction side of the Topock Compressor Station.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2013-06-03

Communication Type: Official Correspondence

Communication Contents: -From Paul Clanon, Executive Director, State of California, Public Utilities Commission: This letter serves as an update on the progress the California Public Utilities Commission (CPUC) has made in addressing Safety Recommendations P-10-5 and P-10-6, which the National Transportation Safety Board (NTSB) issued to the CPUC on January 2, 2011, and Safety Recommendations P-11-22 and P-11-23, which the NTSB issued to the CPUC on September 26, 2011, as a result of its investigaHon of the September 9, 2010, Pacific Gas and Electric Company (PG&E) natural gas pipeline rupture that occurred in a residential area in the City of San Bruno, California. As noted in our May 7, 2012, letter to the NTSB,ithe CPUC outlined four major goals in successfully implementing the NTSB recommendations. These goals are at the core of the CPUC's gas pipeline safety program and its commitment to protect the public and to promote gas pipeline safety throughout California: • Ensure the safety of existing natural gas pipeline infrastructure • Upgrade and replace existing natural gas pipeline infrastructure to improve safety • Reform the CPUC to make safety its first priority • Instill safety culture in the natural gas pipeline operators we oversee Californians deserve safe, reliable utility Services at reasonable rates. This is the core mission of the CPUC. In the two and a half years: since the tragic PG&E pipeline rupture the CPUC has made numerous improvements in safety rules,safety inspections, and safety enforcement. This letter provides a summary of not only the CPUC’s actions related to the NTSB's recommendations, but also of key activities of the CPUC's ambitious, two-pronged approach to meeting its safety goals, taking immediate actions to make California safer; and embarking on long-term changes to the internal safety culture at the CPUC and instilling a safety culture in the utility companies and other industries the CPUC regulates. To ensure the safety and reliability of gas pipeline systems in California, the CPUC has adopted several of the most stringent pipeline safety rules in the nation. Driving these rules is the CPUC's commitment to eliminate the grandfathering ofhistorical pressure levels by requiring jurisdictional operators to hydrostatically test or replace their pipelines. Specifically, CPUC Decision 11-06-017 directed all California natural gas transmission operators to develop and file for CPUC consideration implementation plans for comprehensive pressure testing, also known as Pipeline Safety Enhancement Plans (PSEP), to achieve the goal of orderly and cost effectively replacing or testing all natural gas transmission pipelines that have not been pressure tested. As of March 2013, PG&E has hydrostatically tested 340 miles and verified strength test records for 90 miles of pipeline. In addition, PG&E has replaced approximately 40 miles of pipeline. To ensure that PG&E properly hydrotests its pipelines, pursuant to NTSB Safety Recommendation P-10-4, the CPUC has engaged a consultant to assist it in its oversight responsibility of PG&E's hydrotesting. The CPUC staff will continue its oversight of PG&E's hydrotesting and the other operators as they continue hydrotesting and pipeline replacement efforts proposed in their PSEPs.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2014-08-14

Communication Type: Official Correspondence

Communication Contents: -From Paul Clanon, Executive Director: This letter and the attached Status Report provide an update of the progress the California Public Utilities Commission (CPUC) has made in addressing National Transportation Safety Board (NTSB) Safety Recommendations. The NTSB issued Safety Recommendations P-10-5, P-10-6 and P-10-7 on January 2, 2011, and Safety Recommendations P-11-22 and P-11-23 on September 26, 2011, as a result of its investigation of the September 9, 2010, natural gas pipeline rupture that occurred in a residential area in the City of San Bruno, California. As outlined in the attached Status Report on NTSB Recommendations to the C PUC (Status Report), the CPUC has completed actions on NTSB recommendations P-10-5 and P-1)-~22 and requests for these Safety Recommendations to be considered closed with acceptable actio!i.• The activities to fully implement Safety Recommendations P-1 0-6 and P-11-23 are ongoing, with a progress update provided in the Status Report. Safety Recommendation P-1 0-7 was closed by NTSB on March 29, 2011. As noted in our June 3, 2013, letter-to the NTSB, the CPUC outlined-four major goals that would serve to successfully implement the NTSB recommendations. These goals are at the core of the CPUC's Gas Safety and Reliability Program and its commitment to protect the public and to promote gas pipeline safety throughout California: • Reform the CPUC to make safety its first priority • Ensure the safety of existing natural gas pipeline infrastructure • Upgrade and replace existing natural gas pipeline infrastructure to improve safety • Instill safety culture in the natural gas pipeline operators we oversee Californians deserve safe, reliable utility services at reasonable rates. This is the: core mission of the CPUC. It's been almost four years since the tragic PG&E pipeline rupture in San-Bruno, and the CPUC has made many improvements in safety rules, safety inspections, and safety enforcement during that time. On July 10, 2014, the CPUC adopted a Safety Policy Statement, which defines the rule of the Commissioners, binds together the agency in constantly strengthening our safety efforts, and provides a unifying vision and- guidance for the organization's multiple and disparate functions. The safety mission and goal of the CPUC is to assure that the regulated "utilities the state of California depends on for critical services are as safe and resilient as they can possibly be. The goal of the CPUC is not only to assure compliance with safety laws and regulations, but also to challenge itself and the utilities to excellence. Ultimately, the CPUC strives to achieve a goal of zero accidents and injuries across all the utilities and businesses we regulate, and within our own workplace. P-10-006: To ensure the-safety and reliability of gas pipeline systems in California, the CPUC has adopted several of the most stringent pipeline safety rules in the nation'. Driving these rules is the CPUC's commitment to eliminate the grandfathering of historical pressures levels by requiring jurisdictional operators to hydrostatically test or replace their pipelines. Specifically, CPUC Decision 11-06-0 1 7, directed all California natural gas transmission operators to develop and file for CPUC consideration implementation plans for comprehensive pressure testing, also known as Pipeline Safety and . Enhancement. Plans (PSEP), to achieve the goal of orderly and cost effectively replacing, or testing all natural gas transmission pipelines that have not been pressure tested. The CPUC approved PG&E PSEP in December, 201f, in decision D.12-l2-030. Subsequently, PG&E filed Application (A.) 13-10-017 on October 29, 2013 (PSEP Update Application), to update, PSEP .scope based on the results of the MAOP validation project. .The PG&E PSEP Update Application) is currently under CPUC review. As of April 2014, PG&E has hydrostatically tested over 565 miles and replaced approximately 90 miles of pipeline. To ensure that PG&E properly hydrotests its pipelines, pursuant to NTSB Safety Recommendation P-10-4, the CPUC has been performing ongoing oversight of spike and hydrostatic tests performed by PG&E, including: Field presence at over 65% of PG&E PSEP projects in 2013 Review of PG&E PSEP• procedures, policies; and records Review of quarterly PG&E PSEP progress reports PG&E currently estimates that work to address safety recommendation P-10-4 will be complete by 2017. CPUC will continue oversight of PG&E PSEP activities until the completion of the program.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2015-08-12

Communication Type: Official Correspondence

Communication Contents: -From Timothy J. Sullivan, Executive Director: To ensure the safety and reliability of gas pipeline systems in California, the CPUC has adopted several of the most stringent pipeline safety rules in the nation. Driving these rules is the CPUC's commitment to eliminate the grandfathering of historical pressures levels by requiring jurisdictional operators to hydrostatically test or replace their pipelines. Specifically, CPUC Decision 11-06-017, directed all California natural gas transmission operators to develop and file for CPUC consideration implementation plans for comprehensive pressure testing, also known as Pipeline Safety and Enhancement Plans (PSEP), to achieve the goal of orderly and cost effectively replacing or testing all natural gas transmission pipelines that have not been pressure tested. As of January, 2015, PG&E has hydrostatically tested over 675 miles of pipeline. To ensure that PG&E properly hydrotests its pipelines, pursuant to NTSB Safety Recommendation P-10-4, the CPUC has been performing ongoing oversight of spike and hydrostatic tests performed by PG&E, including: Field presence at over 60% of PG&E PSEP projects in 2014 Review of PG&E PSEP procedures, policies and records Review of quarterly PG&E PSEP progress reports PG&E currently estimates that work to address safety recommendation P-10-4 will be complete by 2017. CPUC will continue oversight of PG&E PSEP activities until the completion of the program. If there is any change in the expected completion date, the CPUC will promptly notify the NTSB of the updated plan. With this planned course of action the CPUC respectfully submits for NTSB Recommendation P-10-6 to be considered closed with acceptable action.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2017-11-17

Communication Type: Official Correspondence

Communication Contents: Our previous letter from the CPUC regarding Safety Recommendation P 10 6 was from Mr. Timothy J. Sullivan, Executive Director, and was dated August 12, 2015. Mr. Sullivan wrote that the CPUC was committed to eliminating the grandfathering of historical pressure levels by requiring jurisdictional operators to hydrostatically test or replace their pipelines. All California natural gas transmission operators were required to develop and file implementation plans for comprehensive pressure testing to CPUC. Mr. Sullivan reported that, as of January 2015, PG&E had hydrostatically tested over 675 miles of pipeline, and the CPUC was overseeing PG&E’s spike and hydrostatic tests. At that time, PG&E estimated that work to address Safety Recommendation P-10-4 would be completed by 2017, and that if there was any change in the expected completion date, the CPUC would notify us. On February 10, 2017, PG&E updated us on its progress in satisfying Safety Recommendation P-10-4. In that letter, PG&E said that since 2011, it had 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 remained to be strength tested, verified, or replaced. However, because 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 because they are on average less than 0.1 miles long, PG&E was unlikely to complete testing and inspection of the remaining pipe until 2022. On March 27, 2017, we classified Safety Recommendation P-10-4 to PG&E “Open—Acceptable Response” (see enclosure) because of the considerable progress PG&E had made. We would like to know if you are aware of PG&E’s new planned completion date, and we would appreciate an update on your activities related to overseeing the spike and hydrostatic tests that PG&E is performing. Pending completion of these tests, Safety Recommendation P-10 6 remains classified OPEN--ACCEPTABLE RESPONSE.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2018-02-21

Communication Type: Official Correspondence

Communication Contents: On February 10, 2017, PG&E updated us on its progress toward satisfying Safety Recommendation P-10-4. PG&E said that, since 2011, it had verified the maximum allowable operating pressure (MAOP) 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 remained to be strength tested, verified, or replaced. However, because 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 because they are, on average, less than 0.1 miles long, PG&E was unlikely to complete testing and inspecting the remaining pipe until 2022. On March 27, 2017, Safety Recommendation P-10-4 was classified “Open—Acceptable Response” because of the considerable progress PG&E had made. We note that you require all California natural gas transmission operators to develop and file implementation plans for comprehensive pressure testing and that, to ensure that PG&E properly hydrotests its pipelines, as requested in Safety Recommendation P-10-4, you have been overseeing its spike and hydrostatic tests. Further, you updated us on PG&E’s progress toward satisfying Safety Recommendation P-10-4. We were disappointed to learn that between January 1 and November 30, 2017, PG&E inspected only 1.43 miles of the 24 miles of priority 1 reported pipe. We note that PG&E is in the process of project scoping the remaining priority 1 pipe, and that it currently plans to mitigate all priority 1 pipe by 2022. We continue to believe that this testing should be completed as soon as possible. We ask that when you review PG&E’s implementation plans for comprehensive pressure testing, including the project scoping that PG&E is scheduled to complete for the remaining priority 1 pipe, you ensure that PG&E does not delay inspecting the last 24 miles of pipe. We believe you should consider actions such as requesting quarterly status updates (rather than annual ones) to ensure that PG&E is making progress. Pending PG&E’s timely completion of the activities requested in Safety Recommendation P-10-4, Safety Recommendation P-10-6 remains classified OPEN--ACCEPTABLE RESPONSE.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2018-11-27

Communication Type: Official Correspondence

Communication Contents: On February 10, 2017, PG&E updated us on its progress toward satisfying Safety Recommendation P-10-4, saying that, since 2011, it had verified the maximum allowable operating pressure (MAOP) 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 remained to be strength tested, verified, or replaced. However, because the remaining miles of pipe were primarily short segments that include tie-in pieces, fittings, or smaller diameter off takes from the larger transmission pipelines, and because they were, on average, less than 0.1 miles long, PG&E was unlikely to complete testing and inspecting the remaining pipe until 2022. On March 27, 2017, Safety Recommendation P-10-4 was classified “Open—Acceptable Response” because of the considerable progress PG&E had made. Our February 21, 2018, letter to you regarding Safety Recommendation P 10 6 expressed our disappointment that, between January 1 and November 30, 2017, PG&E inspected only 1.43 miles of the remaining 24 miles of priority 1 piping. We noted that PG&E was in the process of project scoping the remaining priority 1 pipe, and that, as PG&E said in its February 10, 2017, letter, it planned to mitigate all priority 1 pipe by 2022. We emphasized that this testing should be completed as soon as possible, and we asked that when you reviewed PG&E’s implementation plans for comprehensive pressure testing, including the project scoping that PG&E was scheduled to complete for the remaining priority 1 pipe, you ensure that PG&E does not delay inspecting the last 24 miles of pipe. We suggested that you consider actions, such as requesting quarterly status updates (rather than annual ones), to ensure that PG&E is making progress. On March 6, 2018, PG&E and NTSB staff met to review PG&E’s progress toward satisfying Safety Recommendation P-10-4 and its plans for completing the recommended action. We note that, on April 19, 2018, your staff met with PG&E staff regarding the pace of PG&E’s priority 1 hydrostatic testing plan. At both of these meetings, PG&E said that it still planned to complete all remaining hydrostatic testing by 2022—a pace that was influenced by the large number of short pipe segments. We note that you believe PG&E’s planned schedule is reasonable, and you will continue to oversee this remaining work. We further note that PG&E will provide you with quarterly updates and meet twice yearly with you to discuss its progress toward completing the priority 1 pipe hydrostatic testing. Thank you for these additional steps that you are taking to ensure that PG&E will finish testing and inspecting the remaining priority 1 piping by 2022. Pending PG&E’s timely completion of the activities requested in Safety Recommendation P-10-4, Safety Recommendation P-10-6 remains classified OPEN--ACCEPTABLE RESPONSE.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2023-09-29

Communication Type: Official Correspondence

Communication Contents: On June 27, 2023, PG&E notified us that it had completed our recommended action, and, on September 6, 2023, we classified Safety Recommendation P-10-4 Closed—Acceptable Action. PG&E has now completed our recommended actions to address all 12 of the safety recommendations issued to the company as a result of the 2010 San Bruno pipeline accident. We issued Safety Recommendations P-10-6 and P-11-23 to the CPUC to oversee PG&E’s efforts in addressing Safety Recommendations P-10-4 and P-11-22, respectively. Because PG&E has successfully addressed the underlying safety recommendations, the recommendations issued to you to oversee PG&E’s progress can now be closed. Accordingly, Safety Recommendations P-10-6 and P-11-23 are classified CLOSED-- ACCEPTABLE ACTION. Thank you for your actions to address these recommendations.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2011-03-29

Communication Type: Official Correspondence

Communication Contents: The NTSB understands that the CPUC directed PG&E and the other California intrastate natural gas transmission operators to undertake a plan of action to comply with P-10-2 by March 15, 2011, and then to complete all steps necessary to ensure the safety and integrity of their gas pipeline systems, as requested. In addition, the CPUC is monitoring or overseeing the PG&E spike and hydrostatic tests required by Safety Recommendation P-10-4. Accordingly, pending completion of these efforts, Safety Recommendations P-10-5 and -6 are classified OPEN – ACCEPTABLE RESPONSE.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2012-05-09

Communication Type: Official Correspondence

Communication Contents: This letter was closed administratively, no response was sent on 5/8/2012 under correspondence control #201200253. See the response to correspondence control #201200239, a letter dated 8/2/2012.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2012-08-02

Communication Type: Official Correspondence

Communication Contents: The NTSB understands that CPUC continues to monitor PG&E’s hydrostatic testing of the pipeline identified in Safety Recommendation P-10-5, of which 152 miles were completed in January 2012. We note that CPUC oversight will continue as PG&E identifies more pipeline destined for replacement and that CPUC has engaged a contractor to assist in this oversight. Pending completion of the recommended action, Safety Recommendation P-10-6 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2013-11-14

Communication Type: Official Correspondence

Communication Contents: As stated above, we recognize the ongoing action by PG&E and the CPUC to address Safety Recommendation P 10 5. We note that the CPUC has adopted several stringent pipeline safety rules that will eliminate the grandfathering of historical pressure levels by requiring jurisdictional operators to hydrostatically test or replace their pipelines. Specifically, CPUC Decision 11 06 017 directed all California natural gas transmission operators to develop and file for CPUC consideration implementation plans, also known as pipeline safety enhancement plans (PSEP), for comprehensive pressure testing to replace or test, in an orderly and cost-effective manner, all natural gas transmission pipelines that have not been pressure tested. We further note that, as of March 2013, PG&E has hydrostatically tested 340 miles, verified strength test records for 90 miles, and replaced approximately 40 miles of pipeline, and that the CPUC engaged a consultant to assist in its oversight of the testing. Pending completion of the recommended testing, Safety Recommendation P-10-6 is classified OPRN—ACCEPTABLE RESPONSE.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2014-09-19

Communication Type: Official Correspondence

Communication Contents: We note that you continue efforts to address Safety Recommendation P-10-6 by providing field inspectors at over 65 percent of PG&E Pipeline Safety and Enhancement Plans (PSEP) projects in 2013; through review of PG&E PSEP procedures, policies, and records; and through review of PG&E’s quarterly PSEP progress reports. We also note that PG&E expects to complete its action to address Safety Recommendation P-10-4 by 2017, and that, with the assistance of a contractor, you will monitor PG&E’s associated hydrotests and pipeline replacements. Pending completion of these efforts, Safety Recommendation P-10-6 is classified OPEN—ACCEPTABLE RESPONSE. In consideration of the long-term efforts required to satisfy Safety Recommendation P 10 6, the recommendation is no longer classified as urgent.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2015-10-28

Communication Type: Official Correspondence

Communication Contents: We understand that, as of January 2015, you had conducted oversight of spike and hydrostatic tests performed by PG&E on more than 675 miles of its pipelines. Your work has included field presence at more than 60 percent of PG&E’s Pipeline Safety and Enhancement Plan (PSEP) projects in 2014; review of its PSEP procedures, policies, and records; and review of its quarterly PSEP progress reports. We appreciate your commitment to continuing your oversight of activities related to the PG&E PSEP until the completion of this significant improvement program in 2017. Because we recognize the long-term effort required, we removed the “Urgent” designation from Safety Recommendation P-10-6 on September 19, 2014. Pending completion of the tests described, Safety Recommendation P-10-6 remains classified OPEN—ACCEPTABLE RESPONSE. We note that on June 8, 2015, your Safety and Enforcement Division submitted a compliance filing regarding corrective actions ordered as a result of your investigations and the associated independent audits. Pending your verification that all corrective actions have been completed by PG&E, Safety Recommendation P-11-23 is classified “Open—Acceptable Response.”
- **truncated:** false
- **body characters:** 36447