3. Pressure Test Results
To validate the strength and integrity of the Topock piping and components without prior complete pressure test records, PG&E stated that it pressure tested one-half of the station piping at a time, while maintaining minimum pipeline flows through the other half. PG&E explained that all segments were successfully tested to a pressure above the minimum required to confirm the safe operation of the Topock station at the established MAOP with an additional measure of safety in compliance with the requirements of 49 Code of Federal Regulations (CFR) Part 192, Subpart J. PG&E provided the complete pressure test results for each test segment in its Supporting Information.1
As required by D.11-09-006, the Commission's Consumer Protection and Safety Division (CPSD) reviewed the pressure test information provided by PG&E. In a memorandum dated September 12, 2011, CPSD listed several deficiencies in PG&E's pressure test protocols and records, but determined that the tests conducted by PG&E had demonstrated adequate assurance of the fitness for operation of these facilities at the restored MAOP.2 CPSD directed PG&E to remedy the listed deficiencies for future testing.
CPSD also informed the Commission that PG&E's pressure test data showed that PG&E was pressure testing facilities to a MAOP of 735 psig, and certain vessels to a MAOP of 900 psig, rather than the previously existing 660 psig. Thus, these pressure test results not only supported lifting the Commission's operating pressure restrictions but also, as provided in 49 CFR, Part 192, Subpart K, § 192.555, PG&E's pressure test results could be used as part of an operator's review to justify a higher MAOP when conditions later permit.
1 PG&E redacted certain critical infrastructure details including maps and drawings of stations components from its public filing. At the direction of the Administrative Law Judge (ALJ), PG&E provided a full set to CPSD under seal and offered parties an opportunity to inspect the full documents.
2 The memorandum is included in the record as part of Exhibit E to PG&E's Supporting Information filed on September 12, 2011.
