NTSB Safety Recommendation P-11-023

NTSB safety recommendation P-11-023.

TO THE CALIFORNIA PUBLIC UTILITIES COMMISSION: Require the Pacific Gas and Electric Company to correct all deficiencies identified as a result of the San Bruno, California, accident investigation, as well as any additional deficiencies identified through the comprehensive audit recommended in Safety Recommendation P-11-22, and verify that all corrective actions are completed.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2011-09-26

Adopted Date: 2011-09-12

Overall Date Closed: 2023-09-29

Synopsis: On September 9, 2010, about 6:11 p.m. Pacific daylight time,1 a 30-inch-diameter underground natural gas transmission pipeline (which is identified by the company as Line 132), owned and operated by Pacific Gas and Electric Company (PG&E), ruptured in a residential area in San Bruno, California. The accident killed eight people, injured many more, and caused substantial property damage. The rupture on Line 132 occurred near mile point 39.28, 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 released natural gas was ignited after the rupture; the subsequent explosion created a crater about 72 feet long by 26 feet wide, and the resulting fire destroyed 38 homes and damaged 70. A ruptured pipe segment about 28 feet long was found about 100 feet away from the crater.

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. On April 9, 2015, the CPUC voted unanimously to approve Decision 15-04-024 which penalized PG&E $1.6 billion in connection with the investigations of PG&E's operations and practices related to gas transmission, including the pipeline rupture in San Bruno, Calif., in 2010. To comply with the deadlines provided by Ordering Paragraphs 18 and 19 of this Decision, on June 8, 2015, the CPUC's Safety and Enforcement Division submitted a compliance filing summarized in the table below that will test for PG&E's stated commitment to the corrective actions ordered as a result of the investigations and the independent audits ordered by the CPUC. In 2016, the CPUC issued a Request for Proposals (RFP), inviting consultants to bid on the MAOP Validation Audit ("MAOP Validation Audit RFP"). Unfortunately, no proposals were received in response to the MAOP Validation Audit RFP. The CPUC re-issued the MAOP Validation Audit RFP in 2017 and received only one bidder who was disqualified because of former employees who worked for PG&E. On December, 27, 2017, the Safety and Enforcement Division of the CPUC notified the Commissioners that both RFP attempts had been unsuccessful and asked for further details to define independent audits to help us attract a larger qualified candidate pool. An updated summary of the planned audits are shown below: Audit: MAOP Validation Start Date: Estimated to begin in 2018 Auditor: Independent Audit: Project Mariner Start Date: Post MAOP Audit Auditor: Independent Audit: Recordkeeping Audit (10YR) Start Date: Post MAOP Audit Auditor: Independent Audit: Comprehensive Audit Start Date: Completed Auditor: CPUC/SED Audit: Emergency Planning Start Date: Completed August 2016 Auditor: CPUC/SED Audit: Public Awareness Programs Start Date: Completed December 2016 Auditor: CPUC/SED Audit: Control Room Management Start Date: Completed March 2017 Auditor: CPUC/SED Audit: Integrity Management Start Date: Completed September 2017 Auditor: CPUC/SED In addition to the Safety and Enforcement -led comprehensive audits included above testing for corrective actions from the San Bruno related investigations which are listed below are also ongoing: • 1.11-02-016 - Investigation related to PG&E's recordkeeping practices as they relate to its natural gas pipeline systems. • I.11-11-009 - Investigation into the investigating the operations and practices of PG&E regarding natural gas transmission pipelines in locations with high population density. • 1.12-01-007 - Investigation and penalty proceeding into the operations and practices of PG&E to determine violations of Public Utilities Code Section 451, General Order 112-E, and other applicable standards, laws, rules and regulations in connection with the tragic San Bruno explosion and fire on September 9, 2010. In summary, the CPUC has directed PG&E to correct all the deficiencies identified in its investigatory proceedings and the Safety and Enforcement Division will test for compliance with all orders and verify that all corrective actions are completed through a rigorous combination of independent and staff-led audits. CPUC will update the NTSB upon competition of these audits.

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. Regarding NTSB Safety Recommendation P-11-23 , the Safety and Enforcement Division (SED) of the CPUC formally updated the Commission in December of 2017. The update described that both Request for Proposal (RFP) attempts had been unsuccessful, which is why SED asked for further details to define independent audits to assist in attracting a larger qualified candidate pool. The CPUC expects to get this audit started in 2018 and will provide a detailed update in the January 2019 update to NTSB. Below is a table with an update of key milestones related to NTSB Safety Recommendation P-11-23: Audit Start Date Auditor Audit: MAOP Validation Start Date: Estimated to begin in 2018 Auditor: Independent Audit: Project Mariner Start Date: Post MAOP Audit Auditor: Independent Audit: Recordkeeping Audit (10YR) Start Date: Post MAOP Audit Auditor: Independent Audit: Comprehensive Audit Start Date: Completed Auditor: CPUC/SED Audit: Emergency Planning Start Date: Completed August 2016 Auditor: CPUC/SED Audit: Public Awareness Programs Start Date: Completed December 2016 Auditor: CPUC/SED Audit: Control Room Management Start Date: Completed March 2017 Auditor: CPUC/SED Audit: Integrity Management Start Date: Completed September 2017 Auditor: CPUC/SED The CPUC values to the continued safety partnership with the NTSB in addressing the Safety Recommendations and more generally in natural gas safety.

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 investigation 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. The CPUC is currently adjudicating three formal investigatory proceedings regarding PG&E's operations. The first proceeding, opened in February 2011, is considering PG&E's recordkeeping practices as they relate to its natural gas pipeline systems. The second proceeding, opened in November 2011, is investigating the operations and practices ofPG&E regarding natural gas transmission pipelines in locations with high population density. The third investigation, opened in January 2012, is the CPUC's investigation and penalty proceeding into the operations and practices of PG&E to determine violations of Public Utilities Code Section 451, General Order 112-E, and other applicable standards, laws, rules and regulations in connection with the pipeline rupture in San Bruno. On May 6, 2013, the CPUC's Safety and Enforcement Division recommended that the CPUC impose a total $2.25 billion penalty against PG&E for the three penalty cases. A CPUC decision is expected in late summer. I want to assure you that the CPUC will direct PG&E to correct all the deficiencies identified in its investigatory proceedings, the joint audits conducted with PHMSA, and other CPUC audits conducted by staff. The CPUC has also opened a Rulemaking focusing on forward-looking rule revisions to improve natural gas safety for all California operators. Further Safety Actions To ensure that the deficiencies on the part of PG&E are corrected and the NTSB Safety Recommendations are met, in addition to the work cited above, the CPUC has mounted an extensive effort in improving its Gas Pipeline Safety Program and has made other safety improvements, including: • Ordered tens of millions in fines for safety related issues: o Citation to PG&E for $16.8 million for failure to conduct pipeline leak surveys o Fined to PG&E for $38 million for a natural gas explosion in Rancho Cordova o Fine of telecommunications companies for $12 million for the 2007 wildfire in Malibu • Conducted a comprehensive audit of all aspects ofPG&E's gas operations, including control room, emergency planning, record-keeping, performance-based risk and integrity management programs, and public awareness. • Conducted 57 gas audits on transmission and distribution units for risk management and compliance with CPUC and federal regulations. The CPUC also conducts corporate audits for drug and alcohol testing and operator qualification on a system-wide basis for each major utility. • Published a Natural Gas Safety Action Plan (last update April2013). • Appointed a new safety leadership team at the CPUC, with the goal of changing the culture of safety in the CPUC and the industries we regulate. These appointments include a new director of the CPUC's Safety and Enforcement Division with extensive experience in leadership, culture change, and safety; 24 new field inspectors to perform safety work; and 16 additional engineers, which includes five engineering specialists to oversee the implementation of new gas safety legislation and the pipeline integrity management programs of the pipeline operators in California. • Created a Risk Assessment Section (RAS) with responsibilities including developing a new compliance model that sets, monitors, and enforces pipeline safety rules based on risk assessment and risk management. As part of the CPUC's Gas Safety Action Plan, RAS is currently developing performance metrics that examine pipeline safety beyond the typical realm of pipeline operations and reliability. RAS is examining potential safety blind spots and issues that if not adequately addressed may pose a risk to gas pipeline safety. • Ordered all natural gas utilities to develop enhanced safety plans; approved PG&E's 2012-2014 Pipeline Safety Enhancement Plan.

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. NTSB Recommendation P-11-23 directs the CPUC to require PG&E to correct all deficiencies identified as a result of the San Bruno accident investigation and verify that all corrective actions are completed. As you may know, in February 20 11, the CPUC opened an investigation into PG&E's recordkeeping practices. The reports analyzing PG&E's recordkeeping practices as they relate to natural gas pipelines, reviewing industry standards and engineering practices for recordkeeping, and evaluating PG&E's performance against that standard, were served on March 12, 2012. In addition, our staff conducted an investigation into the San Bruno rupture, in parallel with, and building on, the NTSB investigation. This investigation resulted in a report and initiation of an enforcement proceeding in January 2012. The results of these staff reports are informing the scope of the audit called for by the NTSB in Recommendation P-l l-22. In addition, these reports present significant critiques of PG&E's integrity management program and identify areas for enhancement which will assist PG&E in fulfilling NTSB Recommendation P-11-29. PG&E is also reporting progress on fulfilling the NTSB Recommendations directed at it to the CPUC staff on a regular basis. We intend to formalize what we have learned through implementation of the strongest policies and rules in the country surrounding natural gas pipeline operations. In February 2011, the CPUC opened a rulemaking that is focusing on forward looking rule revisions to improve natural gas pipeline safety. A cornerstone of our rulemaking was adoption of a pressure test or replace policy in June 2011. This policy eliminates grandfathering of historical pressure levels by requiring the operators under our jurisdiction to either produce a traceable, verifiable record that its pipelines have been pressure tested, or to conduct such a test or replace the pipeline. No longer will engineering assumptions substitute for test results. The utilities we regulate have submitted implementation plans pursuant to this policy, which the CPUC is currently reviewing through its administrative process. The plans include enhancing valve automation, additions to supervisory control and data acquisition systems, consistent with NTSB Recommendations P-11-26 and 27, as well as improved record management initiatives. On our website we have published several documents that provide the public with an update on our progress. At http://www.cpuc.ca.gov/PUC/events/sanbruno.htm you can find our January 2012 Overview and Detailed implementation Status, as well as a February 13, 2012 Update and a May 7, 201 2 Update. We intend to provide updates approximately every 75 days. As described above and in the referenced documents, the CPUC has made significant steps to improve our oversight over California ' s natural gas opera tors and to ensure that NTSB Recommendation P-II -23 will be fulfilled not only by PG&E, but all our operators. The CPUC is committed to improving our gas pipeline safety program. The CPUC is ready to provide additional information to you or your staff about any aspect of our gas safety activities. Please do not hesitate to contact our Consumer Protection and Safety Division Director.

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-11-023: The CPUC is currently adjudicating three formal investigatory proceedings regarding PG&E's operations. The first proceeding, opened in February 2011, is considering PG&E's recordkeeping practices as they relate to its natural gas pipeline systems. The, second 'Proceeding, opened in November 2011, is investigating the operations and practices of PG&E regarding natural gas transmission pipelines in locations with high population density~ The third investigation, opened in January, 2012, is the CPUC's investigation and penalty proceeding into the operations and practices of PG&E to determine violations of Public Utilities Code Section 451, General Order 112-E, and other applicable standards, laws, rules and regulations in connection with the tragic San Bruno explosion and fire on September 9, 2010. The CPUC will direct PG&E to correct all the deficiencies identified in its investigatory proceedings. On July 31, 2014, the Administrative Law Judges presiding over the investigations issued a ruling stating that the decisions in the San Bruno investigations will be issued within 60 days. Once the Administrative Law Judges' decisions are issued they become the decisions of the CPUC after 30 calendar days unless a party to the proceeding files an appeal or a Commissioner requests a review. Should either occur, the Administrative Law Judges will review the appeals and either make changes to their decisions or keep them the same, and the recommendations would then come before the Commissioners for a vote in open session at a Voting Meeting Commissioners also have the option of writing Alternate decisions for consideration.

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: On April 9, 2015, the CPUC voted unanimously to approve Decision 15-04-024 which penalized Pacific Gas and Electric Company (PG&E) $1.6 billion in connection with the investigations of PG&E's operations and practices related to gas transmission, including the pipeline rupture in San Bruno, Calif., in 2010. The penalty amount is includes an $850 million shareholder penalty toward gas transmission pipeline safety infrastructure, a $300 million fine, and a one-time $400 million bill credit spread across PG&E's gas customers. To comply with the deadlines provided by Ordering Paragraphs 18 and 19 of this Decision; on June 8, 2015, the Safety and Enforcement division submitted a compliance filing summarized in the table below that will test for PG&E's stated commitment to the corrective actions ordered as a result of the investigations and the independent audits ordered by the Commission. A summary of the planned audits are summarized below: Audit, Start Date, Auditor MAOP Validation, Early 2016, Independent Project Mariner, Shortly after completion of the MAOP Validation Audit, Independent Recordkeeping Audit (10YR), Not more than one year after the completion of the Project Mariner Audit, Independent Comprehensive Audit, 2016-2017, SED Control Room Management, 2016, SED Emergency Planning, 2016, SED Integrity Management, 2017, SED Public Awareness Programs, 2017, SED The SED led comprehensive audits include Control Room Management, Emergency Planning, Integrity Management, and Public Awareness Programs, and testing for corrective actions from the San Bruno related Oils which are listed below: • I.11-02-016- Investigation related to PG&E's recordkeeping practices as they relate to its natural gas pipeline systems. • I.11-11-009 - Investigation into the investigating the operations and practices of PG&E regarding natural gas transmission pipelines in locations with high population density. • I.12-01-007 - Investigation and penalty proceeding into the operations and practices of PG&E to determine violations of Public Utilities Code Section 451, General Order 112-E, and other applicable standards, laws, rules and regulations in connection with the tragic San Bruno explosion and fire on September 9, 2010. In summary the CPUC has directed PG&E to correct all the deficiencies identified in its investigatory proceeding and the Safety and Enforcement division with test for compliance with this order and verify that all corrective actions are completed through a rigorous combination of independent and staff led audits. With this planned course of action the CPUC respectfully submits for NTSB Recommendation P-11-23 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: Mr. Sullivan’s letter also said that, on June 8, 2015, the CPUC Safety and Enforcement Division submitted a compliance filing regarding corrective actions ordered as a result of your investigations and the associated independent audits. On October 28, 2015, we replied that, pending your verification that all corrective actions by PG&E had been completed, Safety Recommendation P-11-23 was classified OPEN--ACCEPTABLE RESPONSE. We have not received any further information regarding your actions to satisfy Safety Recommendation P 11-23; please update us regarding any actions that you have taken since 2015 to address this recommendation. Please reply electronically at correspondence@ntsb.gov regarding your progress toward addressing Safety Recommendations P-10-6 and P 11-23.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2018-02-21

Communication Type: Official Correspondence

Communication Contents: You previously told us 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. We note that, during 2016 and 2017, you completed a comprehensive audit that included control room management, emergency planning, integrity management, and public awareness programs, and that you are testing corrective actions in response to the findings from the San Bruno accident investigation. We further note that the remaining items are an MAOP validation audit and follow-up actions based on the results of that audit, including a 10-year evaluation of record keeping. Finally, we note that, in 2016, you issued a request for proposals (RFP), inviting consultants to bid on the MAOP validation audit, but you did not receive any proposals in response. In 2017, you re issued the RFP, but received only one bidder who was disqualified because the company employed former PG&E employees. You are currently reviewing the RFP and plan to revise it to attract qualified organizations to submit proposals. Pending completion of the MAOP validation audit, and the two follow-on actions described in your letter, Safety Recommendation P-11-23 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: You previously told us 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. We note that, during 2016 and 2017, you completed a comprehensive audit that looked at control room management, emergency planning, integrity management, and public awareness programs, and that you are testing corrective actions in response to the findings from the San Bruno accident investigation. We further note that the remaining items are an MAOP validation audit and follow-up actions based on the results of that audit, including a 10-year evaluation of record keeping. Finally, in 2016, you issued a request for proposals (RFP), inviting consultants to bid on the MAOP validation audit, but you did not receive any proposals in response. In 2017, you re issued the RFP, but received only one bidder, who was disqualified because the company employed former PG&E employees. You are currently revising the RFP to attract qualified organizations to submit proposals. Pending completion of the MAOP validation audit and follow-up actions based on the results of that audit, including a 10-year evaluation of record keeping, Safety Recommendation P-11-23 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: 2013-11-14

Communication Type: Official Correspondence

Communication Contents: As stated above, we support the CPUC’s progress in working with PG&E to correct PG&E deficiencies identified thus far and the CPUC’s plans to continue this effort. We note that the CPUC also initiated a rulemaking to improve natural gas safety for all California operators. Pending notification that all identified deficiencies from PG&E’s continuing audit have been corrected, Safety Recommendation P 11 23 is 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 notes the progress that CPUC has made thus far to ensure that all deficiencies identified in the PG&E audits are satisfactorily corrected. Accordingly, Safety Recommendation P-11-23 is classified OPEN—ACCEPTABLE RESPONSE, pending notification that that all identified deficiencies from PG&E’s continuing audit have been corrected.

Addressee Acronym: CPUC

Addressee Organization Type: S-State Government

Communication Date: 2014-09-19

Communication Type: Official Correspondence

Communication Contents: We note that CPUC is currently adjudicating three formal investigatory proceedings regarding PG&E’s operations: one considering PG&E’s record-keeping practices as they relate to its natural gas pipeline systems; another investigating the operations and practices of PG&E regarding natural gas transmission pipelines in locations with high population density; and a third investigating the operations and practices of PG&E to determine violations of Public Utilities Code Section 451, General Order 112-E, and other applicable standards, laws, rules, and regulations in connection with the San Bruno explosion and fire. We further note that CPUC’s determinations in these investigations will be issued by the end of September 2014 and that CPUC will direct PG&E to correct all the deficiencies identified in the investigations. In the meantime, pending the issuance of these decisions and completion of the recommended actions, Safety Recommendation P-11-23 is classified OPEN—ACCEPTABLE RESPONSE.

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.