4. Supporting Information Presented

To validate the strength and integrity of Lines 101, 132A, and 147, as well as the shorts associated with each, to operate at 365 psig PG&E stated that it:

1. Performed hydrostatic testing of gas transmission pipeline and associated components in accordance with 49 CFR 192 Subpart J in all Class 3 and 4 areas and the high consequence areas of Class 1 and 2, where a pressure test record could not be located. Each of the hydrostatic tests included a spike test;

2. Verified that all historical pressure test records for the pipelines and associated components located in Class 3 and 4 areas and the high consequence areas of Class 1 and 2, including shorts operating greater than or equal to 20% of Specified Minimum Yield Strength (SMYS), met the pressure test requirements for regulations existing when the facilities were installed;

3. Developed a pipeline features list showing each component and its characteristics, and completed maximum operating pressure validation for all pipelines and associated components, including shorts, whether they are located in high consequence areas or not;

4. Conducted 10 excavations in 2010 and 2011 to support the operating pressure validation. The excavations focused on obtaining or validating the specifications of pipeline components by performing direct inspection; and

5. Reviewed Leak Survey information and verified that all identified leaks have been repaired.

PG&E filed and served documentation of its testing, excavation, and records in six exhibits, labeled A through F. Confidential information was made available to the parties for inspection.

As required by D.11-09-006, the Commission's Consumer Protection and Safety Division (CPSD) reviewed the Supporting Information provided by PG&E. In a memorandum dated November 15, 2011, CPSD explained its detailed review of PG&E's Supporting Information and recommended that the Commission authorize PG&E to increase pressure in Lines 101, 132A, 147, and all related shorts, which at the increased pressure would be operating at or above 20% of SMYS, to 365 psig, with one additional requirement. CPSD recommended that PG&E pressure test short GCUST7013 which, because it serves a single large volume customer not down stream of a distribution center, is considered a transmission line even though it will be operating at only 18.5% of SMYS at the increased pressure level of 365 psig.