10. Findings of Fact

1. In Resolution L-410 and R.11-02-019, the Commission ordered PG&E to:

a. Aggressively and diligently search for all as-built drawings, alignment sheets, and specifications, and all design, construction, inspection, testing, maintenance, and other related records, including those records in locations controlled by personnel or firms other than Pacific Gas and Electric Company, relating to pipeline system components, such as pipe segments, valves, fittings, and weld seams for Pacific Gas and Electric Company natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high consequence areas that have not had a maximum allowable operating pressure established through prior hydrostatic testing. These records should be traceable, verifiable, and complete. (P-10-2) (Urgent)

b. Use the traceable, verifiable, and complete records located by implementation of Safety Recommendation P-10-2 (Urgent) to determine the valid maximum allowable operating pressure, based on the weakest section of the pipeline or component to ensure safe operation, of Pacific Gas and Electric Company natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high consequence areas that have not had a maximum allowable operating pressure established through prior hydrostatic testing. (P-10-3) (Urgent)

2. In R.11-02-019, the Commission ordered PG&E to file its report complying with Resolution L-410 in this proceeding.

3. PG&E presented substantial evidence that it searched for and obtained records of pressure testing for 1,210 miles of pipeline.

4. It appears that PG&E presented no evidence that it aggressively and diligently searched as-built drawings and other records to obtain traceable, verifiable, and complete pipeline records upon which to determine a valid maximum allowable operating pressure for pipeline without records of pressure testing.

5. PG&E's March 15, 2011 Report filed with the Commission does not appear to comply with the Commission's directives in Finding of Fact 1 of Resolution L-410.

6. The public interest requires that the hearing in this matter be held on less than 10 days notice.

7. There is a need to take immediate action on this matter and that need for action came to the attention of the Commission subsequent to the agenda being posted as specified in California Government Code § 11125. 3(a)(2).