4. PG&E's March 15 Submission
On March 15, 2011, PG&E filed and served a report it characterized as a "status report on the first phase of its efforts to validate its gas transmission records and the maximum allowable operating pressure of each of its gas transmission pipelines."6 PG&E stated that Phase 1 of its MAOP validation effort was focused on collecting and reviewing pipeline records to determine whether PG&E possesses records that demonstrate MAOP by either:
1. pressure tests, or
2. For pipelines installed prior to 1970 where MAOP was set pursuant to 49 CFR § 192.619(c), the pipeline's highest actual operating pressure from July 1, 1965, through June 30, 1970.7
Specifically, on page 7 of its March 15 Report, PG&E stated as follows:
Neither the NTSB nor the Commission defined "traceable, verifiable and complete." Nor is that phrase contained in the applicable regulations. PG&E understands the intent to be to identify reliable records confirming the performance of a pressure test or the determination of MAOP based on the historical high operating pressure.
(PG&E March 15 submission, at 7 (emphasis added).)
In keeping with this purported "understanding" of the Commission's order and the NTSB's safety recommendation, PG&E stated that of the total 1,805 miles of transmission pipeline, 455 miles had MAOP determined by highest operating pressure from 1965 to 1970.8 Of those 455 miles, PG&E has located records to support the highest historical operating pressure for about 95% or 432 miles. PG&E stated that it plans to continue its MAOP verification efforts in Phase 2 where it will complete the verification of the documents supporting the 619(c) MAOP determinations, which may include excavations and field testing of pipeline systems "as appropriate."9 PG&E intends to complete Phase 2 by the end of 2011.
As a result of its record review, PG&E identified 152 miles of pipeline for which it has not located pressure testing records and the segments contain either pre-1962 24 to 36 inch double submerged arc welded pipe or pre-1974 seamless pipe greater than 24 inches in diameter. PG&E explained that it selected pipeline with these characteristics due to similarities to the ruptured segment of Line 132 in San Bruno. PG&E stated that it intended to either hydro test or replace this pipeline during 2011.
PG&E's Report showed that it had pressure test records or historical maximum pressure data to support its MAOP for 92% of its pre-1970 pipeline and 93% of its post-1970 pipeline. PG&E's Report raises additional questions because PG&E is unable to locate records to support the MAOP it is using for 8% of its pipeline installed prior to July 1, 1970, and even more troublingly for 7% of its pipeline installed after that date. In sum, after a multi-month search effort, PG&E is currently operating 8% of its natural gas transmission system without documents supporting the purported MAOP. Further, undermining confidence in the Strength Test Pressure Reports that it has found, PG&E admits that for 270 miles out of 1,018 miles it claims to have complete pressure test records, the Strength Test Pressure Report footage tested does not correspond to the pipeline High Consequence footage.10 Again, the lack of consistency between these data raises additional questions.
6 PG&E Report at 1.
7 PG&E Report at 7.
8 Pipeline with MAOP set via subsection 619(c) is often referred to as "grandfathered" pipeline because it is exempted from MAOP regulations adopted after 1970.
9 PG&E Report at 12.
10 PG&E Report at 13.
