5. Evaluation of PG&E's Report Against NTSB Urgent Safety Recommendations and this Commission's Orders
As described above, PG&E states that it is engaged in a "Phased MAOP Validation" effort to determine whether it has records of pressure tests on High Consequence Area transmission pipelines and, for pre-1970 pipelines with MAOP set by historical high pressure, records of actual highest operating pressure between 1965 and 1970 as required by 49 CFR § 619(c).
As an initial matter, we note that PG&E appears to be in compliance with the Commission's directive to identify pipeline that has been subject to hydrostatic testing. PG&E's Report shows that it has some type of pressure test record for 1,210 miles out of the total 1,805 miles of pipeline in High Consequence Areas. Accordingly, the Commission is not including the requirement to identify pipeline that has been pressure tested within this Order to Show Cause.
This Order to Show Cause is directed at PG&E compliance with the portion of its order regarding the pipeline segments for which pressure test records can not be located.
In its order based on the NTSB's Safety Recommendations, the Commission directed PG&E, for pipelines without pressure test records, to:
3. "aggressively and diligently search for all as-built drawings, alignment sheets, specifications, and all design construction, inspection, testing, maintenance, and other related records" relating to pipeline system components, and based on those records; and
4. "determine the valid maximum allowable operating pressure, based on the weakest section of the pipeline or component to ensure safe operation."11
Based on these directives, the Commission ordered PG&E to locate and provide the Commission with as-built drawings or other documents showing pipeline components, followed by an analysis of each pipeline MAOP determination based on the weakest portion of the pipeline.
Rather than follow the ordered two-step, pipeline-component specific analysis, it appears that PG&E has instead opted to rely on the historical highest operating pressure. PG&E contends that its understanding of the Commission's intent was to provide valid pressure test records or "the determination of MAOP based on the historical high operating pressure."12 In its Report, PG&E provides no citation in support of its understanding that the Commission authorized the use of historical high operating pressure to validate MAOP, and the plain words of the Commission's order and the NTSB Safety Recommendations appear inconsistent with PG&E's interpretation.
The NTSB, alarmed at the discrepancies in PG&E's as-built drawings, issued urgent Safety Recommendations directed at review of "traceable, verifiable, and complete" as-built drawings and pipeline system components and, based on the reliable pipeline specifications, a determination of the valid MAOP. The Commission then adopted these Safety Recommendations and ordered PG&E to comply.
In light of this history, it appears that PG&E's interpretation is contrary to the NTSB Safety Recommendations and the Commission's order because PG&E relies on historical highest operating pressure as a substitute for actual pipeline component analysis.13 PG&E has provided no evidence that these historical pressure levels are the functional equivalents of the two-step process recommended by the NTSB. Similarly, PG&E's Report shows no evidence that it conducted an "aggressive and diligent search for as-built drawings" or that it attempted to determine a valid maximum allowable operating pressure based on the weakest component in each pipeline segment.
Therefore, we conclude that PG&E appears to have materially failed to comply with Commission Resolution L-410 and R.11-02-019.
11 Resolution L-410 at 2 - 3.
12 PG&E Report at 7.
13 The NTSB in its Safety Recommendation P-10-4 indicates that should PG&E be unable to comply with Safety Recommendations P-10-2(Urgent) and P-10-3(Urgent), then PG&E should "determine the maximum allowable operating pressure with a spike test followed by hydrostatic pressure test." PG&E's report contains no references to performing spike tests.
