NTSB Safety Recommendation P-11-026

NTSB safety recommendation P-11-026.

TO PACIFIC GAS AND ELECTRIC COMPANY: Equip your supervisory control and data acquisition system with tools to assist in recognizing and pinpointing the location of leaks, including line breaks; such tools could include a real-time leak detection system and appropriately spaced flow and pressure transmitters along covered transmission lines.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2011-09-26

Adopted Date: 2011-09-12

Overall Date Closed: 2015-05-15

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: Pacific Gas and Electric Company

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2015-05-15

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2012-03-13

Communication Type: Official Correspondence

Communication Contents: The NTSB understands that PG&E is currently evaluating approaches to revise work clearance procedures and to update its SCADA leak detection capabilities (such as information technology solutions, Lean Six Sigma improvement processes, emergency backup relocation exercises, and a new Data Historian system to assist operators and planning teams). Pending receipt of further information from PG&E on the completion of these efforts, Safety Recommendations P-11-24 and -26 are classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2012-08-29

Communication Type: Official Correspondence

Communication Contents: The NTSB understands that PG&E is implementing three significant projects that will expand the current SCADA capability to predict and then manage abnormal events on the transmission and distribution system. These three projects are (1) implementation of an automated valve program, (2) OSIsoft PI Data Historian integration with SCADA and a graphic information system, and (3) creation of a distribution control center; they are to be the foundation of the broad initiative PG&E has undertaken to build a comprehensive controls framework to move from monitoring and reacting to one that is predictive and proactive. Pending completion of these efforts, Safety Recommendation P-11-26 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2012-02-06

Communication Type: Official Correspondence

Communication Contents: Correspondence control 201200077 was closed administratively. 201200077 was combined with correspondence control 201100506. The reply to correspondence control 201200077/ 201100506 was mailed on 3/13/2012.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2014-09-25

Communication Type: Official Correspondence

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

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2015-05-15

Communication Type: Official Correspondence

Communication Contents: To address this recommendation, we understand that you developed, implemented, and/or tested the following measures: • SCADA display/alarming standards • Leak/rupture detection strategy document • Valve automation program design philosophy, including points of visibility • Documentation of other tools to enhance situational awareness and identify abnormal operations • Shutdown plans and governance document • Training materials and training records • Gas Transmission Control Center tabletop exercises for line shutdown These improvements will assist in recognizing and pinpointing the location of leaks and line breaks. Accordingly, Safety Recommendation P-11-26 is classified CLOSED—ACCEPTABLE ACTION. We understand that, in addition, you are developing a pipeline simulator tool for line break/large leak detection and that, if the pilot programs are successful, you will implement the tool systemwide. We further understand that you are developing a new and enhanced SCADA system that will incorporate and expand the use of the tools described above and that you plan to install over the next 2 years. We commend you for taking these actions, which exceed the scope of Safety Recommendation P-11-26 and will provide additional pipeline safety for your operation.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2012-01-27

Communication Type: Official Correspondence

Communication Contents: -From Christopher P. Johns, President: Pacific Gas and Electric Company (PG&E) fully embraces the safety recommendations outlined by the National Transportation Safety Board as part of the agencies review of the 2010 San Bruno pipeline accident. We recognize the importance of preventing a tragedy like this from occurring again and that is why we are committed to successfully implementing the NTSB's recommendations. To date, PG&E has taken numerous actions to make fundamental changes to our operations and management -all with a focus on putting public and employee safety first. In response to your September 26, 2011 letter, PG&E sent to you on December 22, 2011, an update on the progress we have made toward implementing the recommendations and the plans we have in place. This letter included an update on activities related to integrity management, emergency response, public awareness, threat assessment and recordkeeping, among other aspects of our operations and management. Since that time, members of our team have had the opportunity to meet with NTSB technical staff to discuss our submission and review our activities. We are grateful for the guidance and feedback provided at that meeting. As a result of those discussions, we recognize that it is incumbent upon us to provide a greater level of detail than was previously provided in the December 22, 2011 update. Therefore, we would like to take the opportunity to supplement our December 22, 2011 response by providing an amended response with the requisite detail within 45 days. PG&E will continue to meet with NTSB staff in the coming weeks to seek additional guidance to ensure that the update we provide is fully responsive and will allow the NTSB to more ably assess our progress and plans.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2015-03-23

Communication Type: Official Correspondence

Communication Contents: -From Nick Stavropoulos, Executive Vice President, Gas Operations: Pacific Gas and Electric Company (PG&E) continues to make significant progress implementing the safety recommendations outlined by the NTSB's investigation of the September 2010 San Bruno pipeline accident. The attached status report provides an update on PG&E's actions to address the remaining recommendations that are currently in "Open-Acceptable Response" status: 1. P-1 0-04: Strength Testing 2. P-11-26: Supervisory Control and Data Acquisition System Tools 3. P-11-27: Valve Automation Program PG&E believes that substantial progress has been made to implement these remaining open recommendations, and that one of the three is at the point that it may be considered for closure. We request that the NTSB review the information provided in this status report and consider closing recommendation P-11-26. In addition, we expect that recommendation P-11-27 will be ready to be considered for closure later this year, and the third recommendation, P-1 0-04, may be ready for consideration of closure in 2016. We are available to provide additional information or answer any questions you may have. PG&E thanks the NTSB for its continuing guidance and leadership as the company continues to work towards our goal of making PG&E's gas system the safest and most reliable in the nation. Update for P-11-26, March 2015: PG&E is committed to operating a robust gas control function and to enhance the SCADA information system to assist in recognizing and pinpointing the location of leaks, including line breaks. We have achieved several milestones in this effort: • Development of new SCADA Display/Alarming Standards for improved situational awareness was completed at the end of 2012. • A Leak/Rupture Detection Strategy Document was finalized in Q3 of 2014. • In coordination with the Valve Automation Program P-11-27 (VAP), installation of pressure and flow transmitters providing rupture detection alarming has been completed at all VAP installations. Spacing methodology for pressure and flow transmitters has been coordinated with the methodology used in determining automated valve spacing, and all future automated valve installations will include pressure sensing transmitters. • Completed the development and deployment of information technology applications making available near-real-time information outside of SCADA available in the Control Room for event analysis: o SAMI (Situational Awareness) tool live in Control Center, August 2013; and o TAMI (Tactical Awareness) tool live in Control Center, November 2013. • Shutdown Protocols were drafted by the end of 2013 for all segments bounded by Automatic Shutoff Valves (ASV)/ Remote Control Valves (RCV) at that time, and 17 protocols have been approved. Additional protocols will be drafted and approved as bounded segments are released for operation. • Gas Transmission Control Center table top exercises for Line Shutdown have been developed and tested; delivery of training to all operators is complete. Based on the actions completed to equip the SCADA system with tools to assist in recognizing and pinpointing the location of leaks, including line breaks, PG&E requests that consideration be given to closing this recommendation. We have attached the following documentation for the completed tasks described above: • SCADA Display/Alarming Standards • Leak/Rupture Detection Strategy Document • Valve Automation program design philosophy and added points of visibility • Documentation of other tools implemented to enhance situational awareness and identify abnormal operations • Shutdown plans and governance document • Training materials and training records PG&E has also undertaken two additional initiatives that are beyond of the scope of this recommendation, but may be of interest to you. The first is the development of a Pipeline Simulator tool for line break/large leak detection. Pilot installation of a Pipeline Simulator tool was completed and operational in mid-2013; an expanded pilot was completed in March 2014 which determined that use of an online simulator is feasible for use with PG&E's backbone transmission system. Implementation for the full backbone part of the transmission system is planned for the 2015 to 2017 period. PG&E has just selected a vendor to accomplish this implementation. The Pipeline Simulator is bleeding-edge technology that has shown significant promise in providing capability above anything we have been able to identify in the industry for achieving these goals. Upon successful full implementation on the backbone part of the transmission system, PG&E will then consider expanding implementation to the local transmission system. We have also attached some information describing the results of the pilots as well as the current status of this effort. In addition, we would like to note that PG&E is also working on the development of a new and enhanced SCADA system that will be installed over the next two years. It will incorporate and expand the use of the tools described above.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2013-01-31

Communication Type: Official Correspondence

Communication Contents: -From Christopher P. Johns, President: Pacific Gas and Electric Company (PG&E) continues to make substantial progress implementing the safety recommendations outlined by the NTSB's investigation of the September 2010 San Bruno pipeline accident. This status report provides details on the actions we are taking to assure public safety remains the company's highest priority. In 2012, the NTSB evaluated PG&E's progress and closed four recommendations: 1. pe10-2: Search for Records 2. P-11-3: 911 Notifications 3. P-11-25: Emergency Response Procedures 4. P-11-28: Toxicology Testing In this report, we are submitting three additional recommendations for closure consideration by the NTSB: 1. P-10-3: MAOP Validation 2. P-11-24: Work Clearance Procedures 3. P-11-31: Public Awareness Program Continuous Improvement For recommendation P-10-3 (MAOP Validation), PG&E has completed the determination of the valid maximum allowable operating pressure (MAOP), based on the weakest section of the pipeline or component. The purpose of the MAOP validation is to ensure safe operation of natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high consequence areas (HCA) that have not had a MAOP established through prior hydrostatic testing. In total, MAOP validation was performed for all 2,088 miles of these transmission pipelines. In addition to completing NTSB Recommendation P-10-3, PG&E is validating all remaining transmission lines in non-HCAs by mid- 2013. In 2012, PG&E completed the MAOP validation of 4, 199 miles of non-HCA pipelines. For recommendation P-11-24 (Work Clearance Procedures), PG&E has completed the revision and issuance of work clearance procedures that include requirements for identifying the likelihood and consequences of failure associated with planned work. The development of contingency plans is now a part of this process. PG&E's new procedure ensures accurate and completed clearance forms and requires field crews, control room operators and individuals who have been assigned the clearance supervisor role to have complete knowledge of the intended work and written clearance procedure. PG&E has completed recommendation P-11-31 (Public Awareness Program Continuous Improvement) through the development and incorporation of written performance measurements and guidelines into our Public Awareness Plan (PAP) for evaluating the plan and for continuous program improvement. The primary objectives include awareness, damage prevention and emergency response readiness. PG&E has also completed two portions of recommendation P-11-29 (Integrity Management Program): Revisions to PG&E's Risk Model and Risk Analysis Methodology. Other recommendations with significant progress highlighted in the attachment include: • (P-10-4)-ln 2012, PG&E strength tested or verified an additional 202 miles for a total of 417 miles since 2011 • (P-11-2)-PG&E installed 46 valves in 2012 (for a total of 59 valves since 2010) • (P-11-29)-ln addition to revising the Integrity Management Risk Model and Risk Analysis Methodology, PG&E is continuing to revise other portions of its integrity management program PG&E thanks the NTSB for both its continuing guidance and leadership as the company works to address the remaining safety recommendations. Please contact me directly if you have any questions. PG&E is enhancing the SCADA information system to assist in recognizing and pinpointing the location of leaks, including line breaks by including additional information related to pipeline pressures, valve positions and gas flow rates as follows: Flow and Pressure Transmitters Upon completion of the Automated Valve Program as described in P-11-27 below, PG&E will have real-time knowledge of pipeline pressures at least every 5-8 miles on large diameter pipelines in Class 3 and 4 locations. PG&E plans to install 300 new pressure transducers and 30 new flow transducers by the end of 2014. As of December 2012, PG&E has installed 49 new pressure transducers and 3 flow transducers since October 2010. Leak Detection Tools Recommendations from a 3'" party evaluation of PG&E SCADA rupture detection capability are being evaluated for incorporation into PG&E's rupture detection strategy. The recommendations incorporate expansion of the use of Rate of Change (ROC) alarming and complex alarming involving the evaluation of combinations of data from multiple sites for more accurate rupture detection. Additionally, PG&E has initiated a pilot to utilize pipeline simulation software in conjunction with SCADA for large leak and rupture detection on a section of Class 3 backbone gas transmission pipeline to further evaluate the effectiveness. OSISoft PI Historian and Alarm Management PG&E has completed development of a software application to create a bridge between the SCADA alarm system and the OSISoft PI Historian to improve situational awareness and provide greater capability to track and analyze alarm information.' This platform will rapidly provide near real-time information to all areas of the Gas Operations organization, including engineering, planning, maintenance, and operations. This will provide better guidance and input for remote monitoring and controls, as well as for real-time operations. The new application allows operators, engineers and planners to query, sort, associate and record comments on SCADA system alarms. The new tool also provides a method for quickly accessing historical data trends related to each specific alarm, and includes automatic reporting features to aggregate alarm information into key performance indicators. PG&E is using the new real-time OSlsoft PI Data Historian platform to support two large situational awareness screens. Billions of data records have been loaded into the OSlsoft PI Data Historian system representing more than a decade of historic SCADA information. New data is being added to the OSlsoft PI Data Historian system continuously, within seconds of being recorded in the SCADA system. In addition to the SCADA tools described above, PG&E is also implementing other improvements described below: SCADA Displays PG&E is working with industry experts to establish new SCADA display and navigation design standards which meet the requirements of API 1165 (Graphic Standard, Recommended Practice for Pipeline SCADA Display) and has completed evaluation of new data presentation methods to meet the requirements of API 1165,2 As a result of the work to date, new data presentation methods are being developed and deployed in the SCADA system. New display concepts will continue to be implemented for Gas Transmission displays with future SCADA upgrades, Control Center PG&E is continuing to move forward with building a new control center complex to co-locate transmission control, distribution control, gas dispatch, reliability planning and emergency response organizations, PG&E completed benchmarking activities; including site visits with more than .a dozen major North American gas and electric utilities, PG&E has selected an external control room design consultant that will work with its facilities architect team to build out the new facility by April 2013. The Transmission Control Center will be supported by a common SCADA system and the OSlsoft PI Data Historian system, an enhanced clearance process, and integration with the Gas Dispatch and Emergency Response organizations, PG&E's current SCADA system has been reviewed and will allow expansion to add several thousand monitoring and control points. The Distribution .Control Center opened for training in San Francisco in November 2012 and will continue to open in phases, Monitoring will begin in Q1 of 2013 and full operation is targeted for Q4 of 2013.

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2012-05-23

Communication Type: Official Correspondence

Communication Contents: -From Christopher P. Johns, President: Pacific Gas and Electric Company (PG&E) is making substantial progress to implement the safety recommendations outlined by the National\ Transportation Safety Board's (NTSB) investigation of the September 2010 San Bruno pipeline accident. This status report details the actions PG&E has taken and will continue to take to assure public safety remains the company's highest priority in the operation of our natural gas transmission system. We have made many fundamental changes to the operations and management practices throughout our gas organization. Some of the more critical actions include: completion of the Maximum Allowable Operating Pressure validation of all 2,088 miles of high consequence area (HCA) pipelines; validation of 1,032 miles of non -HCA pipelines through April 2012; and automation of 36 valves. In 2011, PG&E conducted strength tests and verified strength test pressure records for a total of approximately 214.5 miles of pipeline. Additionally, from January through April 2012, an additional 37.6 miles have been tested or verified. PG&E's Pipeline Safety Enhancement Plan (PSEP), currently before the CPUC for approval in R.11-02-019, outlines our plan for testing or verifying records of 547 miles in 2012 -2014. PG&E has modified its 911 Notification Process to respond to the NTSB's suggestion that SCADA real time operating data and alarms serve as triggers for 911 notifications. We have developed a comprehensive emergency response procedure for large-scale emergencies on transmission lines, which identifies a single person in charge, outlines specific protocols and provides for drills and training. PG&E has also incorporated performance measures and guidelines to assure continuous improvement in our public awareness program. PG&E has initiated a complete assessment of every aspect of our transmission integrity management program including threat identification and assessment. Much more work lays ahead, but the progress to date gives us confidence that PG&E is on track to achieving the goal of regaining the trust of the public and our regulators by demonstrating our steadfast commitment to safety. The attachment to this letter provides a more detailed summary of each NTSB recommendation and the steps we have taken and continue to take to act upon them. If you have any questions, please contact me directly. PG&E is implementing three significant projects that will expand the current SCADA capability to predict and proactively manage abnormal events on our transmission and distribution system. The three projects are: • Automated Valve Program implementation • OSlsoft PI Data Historian integration with SCADA and GIS • Distribution Control Center creation These projects are the foundation of the broad initiative PG&E has undertaken to build a comprehensive controls framework to move from monitoring and reactive, to predictive and proactive. Automated Valve Program Implementation PG&E has embarked on an aggressive program to increase SCADA visibility and control capability on its transmission pipeline focusing on the most densely populated areas in our service territory. Upon completion of the Automated Valve Program PG&E will have real-time knowledge of pipeline pressures at least every 5-8 miles on large diameter pipelines in Class 3 and 4 areas. The transmission automated valve field site installations include new pressure and flow data being transmitted to the SCADA system providing additional information that will be utilized by new SCADA control tools and technologies to provide PG&E's Control Room operators with better situational awareness of pipeline conditions. The increased number of new field transmitters will result in a 100 percent increase from PG&E's current number of pressure transmitters connected to SCADA. PG&E will implement the Valve Automation Program in two phases. The table below shows the planned and completed installations of new pressure and flow monitoring visibility and valve control capabilities that PG&E will attain through the two phases of the Automated Valve Program: In addition to the Valve Automation Program, the Control Room Management Alarm Management initiative will allow this large increase in system monitoring points to be incorporated into the Gas Control function while at the same time managing alarms from these points in a manner which better pinpoints the cause of the alarms and allow gas controllers to focus their efforts on the highest priority safety related conditions. Phase 1 Valve Automation work will additionally provide technology, tools, and training to allow our gas controllers to make optimal use of the increased pressure and flow data and new automated isolation valves in an emergency. PG&E has contracted with a process and controls engineering vendor to implement new screens and tools using the OSIsoft PI Data Historian platform to aid gas controllers in detecting, analyzing and taking action to isolate the pipeline if a rupture or major leak event were to occur. These tools will package the operational data on a pipeline system to more clearly identify deviations from normal operations. Each automated valve will be equipped with automatic and/or remote control capability designed to expedite the isolation of a section of pipeline. Each of these valve installation sites will send various alarm conditions to the SCADA system. Most importantly, an alarm indicating rapid pressure drop beyond the expected threshold will be received by the SCADA system and annunciated in the control room. Additionally, PG&E will be investigating and pilot testing various available and in development leak detection, pipeline damage and ground movement technologies that could be tied to the SCADA system, providing real-time information and proactive identification of developing risks. OSlsoft PI Data Historian Integration with SCADA and GIS PG&E has been evaluating information technology solutions to deliver the right information to gas operators to allow them to make prompt, informed decisions related to pipeline safety. PG&E has begun work to integrate its OSlsoft PI Data Historian (described below), SCADA, and GIS systems to achieve an electronic platform designed to support the Control Room operators. PG&E is incorporating Lean Six Sigma improvement processes from a variety of internal stakeholders and industry consultants to ensure a solution focused on interoperability and usability. Examples include: • PG&E has fully commissioned a new enterprise-wide OSlsoft PI Data Historian system that will be used to pull key relevant data together for operator and planning team use, and display material to operators on large screens in the control room. This platform will rapidly provide near real-time information to all areas of the Gas Operations organization, including engineering, planning, maintenance, and operations. This will provide better guidance and input for remote monitoring and controls, as well as for real-time operations. • PG&E is using the new real-time OSlsoft PI Data Historian platform to support two large situational awareness screens. Billions of data records have been loaded into the OSlsoft PI Data Historian system representing more than a decade of historic SCADA information. New data is being added to the OSlsoft PI Data Historian system continuously, within seconds of being recorded in the SCADA system. • In late December 2011, PG&E completed a SCADA enhancement that prioritizes alarms for appropriate operator action upon activation. This SCADA modification project provides PG&E's operating team the capability to filter alarms based on priority, data type, and geographic location. Alarm priorities can now be configured based on four categories: Emergency, High, Medium, and Low. • On January 23, 2012, PG&E implemented a geographical based operating system for the consoles used by

Addressee Acronym: PG&E

Addressee Organization Type: P-Private Industry

Communication Date: 2011-12-22

Communication Type: Official Correspondence

Communication Contents: -From Christopher P. Johns, President: Pacific Gas and Electric Company (PG&E) has fully embraced the safety recommendations outlined by the National Transportation Safety Board (NTSB) as part of the agency's review of the September 2010 San Bruno pipeline accident. We at PG&E recognize the importance of preventing a tragedy like this from ever happening again, and we are grateful for the NTSB's guidance toward that goal. As requested in your September 26, 2011 letter, we are providing an update on the actions PG&E is taking, and the plans that are in place to implement the NTSB's thoughtful and thorough recommendations. These recommendations have prompted PG&E to take significant actions on many fronts, including pipeline leak and break identification, emergency response, integrity management, threat assessments, public awareness of pipeline safety measures, and recordkeeping. The NTSB's recommendations have helped propel PG&E to make fundamental changes to our operations and management-all intended to underscore our commitment to putting public and employee safety first. For example, we've completed Maximum Allowable Operating Pressure validation of more than 1,600 miles of high consequence area pipelines, with plans to complete all 2,000 miles by the end of January 2012. We are implementing a new data management system intended to address the NTSB's recommendations for traceable, verifiable and complete records. Additionally, PG&E has automated 11 shutoff valves in 2011. As part of the company's Pipeline Safety Enhancement Plan, which was presented for approval to the California Public Utilities Commission this year, PG&E has proposed automating a total of 228 valves through 2014. We've also updated our emergency response plans to reflect industry best practices and have begun training employees, public officials and first responders. In an effort to improve public gas safety awareness, we've mailed more than two million safety information letters to customers who live within 2,000 feet of a transmission pipeline. We realize we still have much to learn and do in the wake of the tragic San Bruno accident. As you'll see in the attachment, we have completed several of the recommendations and are in mid-stream on the remainder. We're working with urgency to complete all of the recommendations and we remain steadfast in our commitment to safety and to regaining the trust of the public and our regulators. The attachment to this letter provides a more detailed summary of each NTSB recommendation and the steps we are taking to act upon them. If you have any questions, please contact me directly. • Developing Comprehensive Controls Framework PG&E is currently evaluating information technology solutions to deliver the right information to operators to allow them to make prompt, informed decisions related to pipeline safety. PG&E is incorporating Lean Six Sigma improvement processes from a variety of internal stakeholders and industry consultants to ensure a solution focused on interoperability and usability. Examples include: o Beginning the establishment of a new Distribution Control Center to expand visibility and control capability of the distribution system. o The new Distribution Control Center will work in tandem with the existing Transmission Control Center function. o PG&E will take best practices and findings from internal assessments and external benchmarking to create a leading class distribution control center that oversees planning and execution of critical distribution system enhancements, and monitors work on the distribution system. It will also include low-power consumption solutions for gathering SCADA data from remote gas distribution assets. o Ensuring that both the Transmission and Distribution control centers will be supported by a common SCADA and real-time Data Historian platform, an enhanced clearance process, and integration with the Gas Dispatch and Emergency Response organizations. o Nearing completion of a SCADA modification project as a major step in implementing an alarm management process. o This SCADA enhancement will prioritize alarms for appropriate operator action upon activation. o In conjunction with the new alarm management strategy, PG&E is working with human factors consultants to develop a new SCADA visual coding design, including use of color, text and symbols in graphic displays to present alarm status and data quality. The new design will meet the requirements of API 1165 (Graphic Standard, Recommended Practice for Pipeline SCADA Display) by August 2012. This modification will prioritize alarms on Operators' operating screens.