PACIFIC GAS & ELECTRIC CO — Integrity Assurance Notification

REASSESSMENT INTERVAL ABOVE 30% SMYSPacific Gas and Electric Company (PG&E) respectfully requests an extension of the reassessment interval for a covered segments of PG&E’s Line 300A at Milpitas Terminal for an additional six (6) months pursuant to General Order 112F §101.3 and 49 CFR §192.939. Under §192.939(a), PG&E is required to conduct a reassessment of a section of Line 300A located in a High Consequence Area (HCA) by December 31st, 2021; however, an operator may seek an extension of the reassessment interval if it demonstrates sufficient justification of the need for the extension. PG&E performs an engineering review to ensure that all covered segments due for integrity management assessments in the upcoming calendar year have a planned assessment to address the external corrosion threat by the assigned due dates. During the July 2021 review, PG&E identified that Line 300A within the Milpitas Terminal did not have a planned assessment to meet the December 31, 2021 reassessment deadline due to an error in the previous year’s review. At the time, PG&E incorrectly assigned assessment credit to this section of pipe from another External Corrosion Direct Assessment (ECDA) project performed within Milpitas Terminal, when in fact this pipe segment was not part of the assessment project. The review performed in July 2021 identified Line 300A as still needing an assessment by end of 2021. Stakeholders studied the project and concluded it would be a challenge to complete the assessment by December 31, 2021 due to insufficient time to safely plan and perform the ECDA, issues with Santa Clara Valley Transportation Authority (VTA) operating in the area, and obtaining a permit in time if an excavation is needed within a Caltrans right of way. The indirect inspection tool (IIT) survey is currently planned to be completed by October 2021.#