IV. NTSB FINDING OF INACCURATE PG&E RECORDKEEPING

In conjunction with its investigation of the San Bruno explosion, the NTSB requested extensive records and other information from PG&E about its pipeline system. To date, the NTSB has not publicly released either its information requests addressed to PG&E or PG&E's responses to such information requests. The NTSB has indicated, however, that it will release such materials on March 1, 2011, at the commencement of the three-day public hearing. For the moment, however, we do not know the precise content of the information PG&E provided to the NTSB. But, on January 3, 2011, the NTSB issued its "urgent" Safety Recommendation, expressing the agency's concern about the adequacy of PG&E's records.

"According to PG&E as-built drawings and alignment sheets, Line 132 was constructed using 30-inch-diameter seamless steel pipe (API 5L Grade X42) with a 0.375-inch-thick wall. The pipeline was coated with hot applied asphalt and was cathodically protected. The ruptured pipeline segment was installed circa 1956. According to PG&E, the maximum allowable operating pressure (MAOP) for the line was 400 pounds per square inch, gauge.

"The NTSB's examination of the ruptured pipe segment and review of PG&E's records revealed that although the as-built drawings and alignment sheets mark the pipe as seamless API 5L Grade X42 pipe, the pipeline in the area of the rupture was constructed with longitudinal seam-welded pipe. Laboratory examinations have revealed that the ruptured pipe segment was constructed of five sections of pipe, some of which were short pieces measuring about 4 feet long. These short pieces of pipe contain different longitudinal seam welds of various types, including single- and double-sided welds. Consequently, the short pieces of pipe of unknown specifications in the ruptured pipe segment may not be as strong as the seamless API 5L Grade X42 steel pipe listed in PG&E's records. It is possible that there are other discrepancies between installed pipe and as-built drawings in PG&E's gas transmission system. It is critical to know all the characteristics of a pipeline in order to establish a valid MAOP below which the pipeline can be safely operated. The NTSB is concerned that these inaccurate records may lead to incorrect MAOPs." (NTSB January 3, 2011 Safety Recommendation, p.2, Appendix B).

A footnote in the January 3 report stated:

"PG&E's records identify Consolidated Western Steel Corporation as the manufacturer of the accident segment of Line 132. However, after physical inspection of the ruptured section, investigators were unable to confirm the manufacturing source of some of the pieces of ruptured pipe. Determining the identity of the manufacturer of these pieces of pipe is an ongoing part of the investigation." (Id., footnote 2).

Based on the above-quoted language from the NTSB's January 3 Safety Recommendation, it appears the NTSB has found that the state of PG&E's technical recordkeeping was not sufficiently accurate, complete and/or retrievable for PG&E to (1) correctly identify major characteristics of the type of pipe that was buried in the ground and ruptured on September 9, 2010, and (2) clearly identify the pipe's manufacturer.

The Commission takes note that the NTSB's January 3 Safety Recommendation directed PG&E to search for specified records about its transmission pipelines operating in "high consequence" (highly populated) areas. If PG&E cannot locate the transmission line records, the NTSB recommends that PG&E conduct hydrostatic pressure testing of all pipelines in populated areas. The NTSB directed PG&E to:

"[a]ggressively and diligently search for all as-built drawings, alignment sheets, and specifications, and all design, construction, inspection, testing, maintenance, and other related records, including all design, construction, inspection, testing, maintenance, and other related records....relating to pipeline system components, such as pipe segments...and weld seams.....these records should be traceable, verifiable, and complete" (NTSB January 3, 2011 Safety Recommendation, p. 3, Appendix B).

Shortly after issuance of the January 3 Safety Recommendation, the Chair of the NTSB made a public speech, expressing her concern about the safety implications of the PG&E record-keeping deficiencies the NTSB uncovered in the San Bruno investigation. She said:

"Our investigators were told [by PG&E] that the pipe

Involved in the explosion was a seamless factory manufactured

pipe.

But even a layperson could see the patchwork of welds marking

the pipe.

This misinformation was not a minor record-keeping oversight.

In the years since the pipe (San Bruno pipe) was put into service, decisions regarding inspections, operating pressures, and risk management plans were all based on facts that were just plain wrong" (NTSB Website Statement of Deborah Hersman, NTSB Chairman, January 26, 2011, Appendix D, pp 2 and 3).

From these NTSB statements, it is clear to the Commission that the NTSB has serious safety concerns about the adequacy of PG&E's recordkeeping, based on the documents and other materials PG&E has provided to NTSB in the San Bruno investigation. From this, we infer that the state of PG&E's records regarding critical infrastructure (in particular, its high-pressure gas transmission pipelines) may have been inadequate to make critically important, ongoing safety decisions about PG&E natural gas transmission pipelines, particularly welded pipelines

With such federal safety agency concerns and findings in mind, this Commission will now commence a formal investigation into whether PG&E's recordkeeping represents a deficient engineering practice that has fostered unsafe PG&E decision making about its transmission gas pipelines. The Commission will investigate and decide whether PG&E's recordkeeping pertaining to gas transmission lines, including San Bruno, has violated good and accepted engineering standards and practices, and thus whether PG&E violated Section 451 of the Public Utilities Code or other laws and regulations.

We also note that the NTSB has not yet commented on PG&E's maintenance and operating records, and their sufficiency, for the later years of the pipeline's existence and operation. Beginning in 1970, the Code of Federal Regulations 49 C.F.R. § 192.709 was amended to include an express requirement that gas pipeline operators keep and maintain for the life of the pipeline component various documents about pipeline repairs, and must keep for five years and longer other specified pipeline data. The Commission is empowered and committed to enforcing these federal rules. But the Commission's responsibilities for ensuring public safety further are defined by standards contained in the California Public Utilities Code, including in particular Section 451. PG&E's obligations to public safety are informed by federal standards, but they do not depend on federal safety rules alone.

In this investigation, the Commission intends to ascertain the adequacy of PG&E's recordkeeping for the entire life of the San Bruno pipeline that ruptured on September 9, 2010, under both state law and under federal standards and law that the Commission is specifically empowered to enforce. We also intend to ascertain recordkeeping adequacy for all PG&E gas transmission pipelines.

Ordinarily, the Commission issues an "order instituting investigation" after completion of a report by Commission staff. In such cases, the staff report typically comes after an extensive investigation by staff into the underlying facts, and based on allegations by staff of a violation of law revealed by such facts. In this instance, however, we are commencing this investigation based on information supplied by a federal safety agency, NTSB. The Commission invites interested parties to participate actively in this formal investigation, as it involves safety matters important on a local, state, and national basis. Participation by informed parties can facilitate the Commission reaching a decision that is both informed and fair.