Pacific Gas and Electric Co. adopted some key recommendations from safety advocates while rejecting a host of others in a compliance plan that it was ordered to submit after a state investigation into the utility’s gas distribution system.
The California Public Utilities Commission began looking into the utility’s gas distribution record keeping in light of several incidents. The regulator ultimately fined PG&E $25.6 million and ordered it to come up with a plan to fix numerous issues.
After consultations with a number of stakeholders, including The Utility Reform Network and the CPUC’s Office of Ratepayer Advocates, PG&E agreed with recommendations that the company do a systemic records review, validate its geographic information system data, determine which metal pipes have plastic inserts, and put in place a records and information management training program.
The utility nixed several other stakeholder suggestions, though, including that the company apply federal regulators’ “traceable, verifiable and complete,” or TVC, record-keeping standard to distribution pipes. The U.S. Pipeline and Hazardous Materials Safety Administration has used that phrasing for transmission pipelines, defining the terms back in 2012, but PG&E pointed out that the terminology has not been used for the smaller-diameter, lower-pressure distribution systems that span millions of miles.
PG&E has more than 42,000 miles of natural gas distribution pipelines, which bring gas at relatively low pressure to end users, and more than 6,400 miles of transmission pipelines, which move gas at higher pressures across longer distances.
PG&E said that not applying TVC to the distribution system is more a matter of legal semantics than safety, though, and agreed to treat distribution system records with the same level of rigor as transmission system records.
“Establishing a TVC standard for gas distribution is a rule-making activity, not a compliance plan activity, and should involve all stakeholders state-wide,” PG&E said in response to the recommendations. “PG&E’s gas distribution record-keeping compliance plan contains the appropriate elements to effectively address the elements of TVC — record retention, standard elements for a job file, and what action to take when records are missing and cannot be replaced including the application of conservative assumptions.”
The company also did not adopt recommendations to do a maximum allowable operating pressure risk assessment, arguing that this kind of analysis would not address any of the violations the CPUC found. Because of cost and resource limitations, PG&E additionally decided against directing employees to do records validation work during all routine maintenance.
“Personnel performing routine maintenance are not qualified to perform suggested tasks and do not use as-built records when performing tasks,” the PG&E Corp. subsidiary noted, adding that workers are supposed to report any clear disconnects they find between reality and records.
The CPUC opened the investigation into PG&E’s record-keeping failures in November 2014 after a house explosion in Carmel, Calif., revealed notable records gaps, prompting the regulator’s Safety and Enforcement Division to look more deeply into the utility’s history with distribution system documentation. The investigation turned up multiple instances in which the company’s inaccurate records or lack of documentation contributed to incidents, some of which involved outages or property damage.
The commission had already investigated the utility’s flawed gas pipeline record keeping after the fatal 2010 San Bruno pipeline rupture exposed critical gaps in documentation for the gas transmission system. The CPUC disciplined the company for these shortcomings as a part of a broader $1.6 billion penalty for all the investigations related to the San Bruno incident.