Report On PG&E Record Keeping

Investigation of PG&E Distribution System Recordkeeping
In Support of OII.14-11-008
Prepared for
The Safety and Enforcement Division
California Public Utilities Commission
Prepared by
P Wood Associates (PWA)
David Berger, John Gawronski and Paul Wood
September 30, 2015
TABLE OF CONTENTS
0. EXECUTIVE SUMMARY ....................................................................................................... 1
0.1 Scope of Investigation ......................................................................................................... 1
0.2 Facts Related to PG&E Recordkeeping ............................................................................... 1
0.3 Major Findings..................................................................................................................... 2
0.4 Categories of Violations ...................................................................................................... 3
1. INTRODUCTION ..................................................................................................................... 5
1.1 Purpose and Scope ............................................................................................................... 5
1.2 Approach.............................................................................................................................. 5
1.3 Background .......................................................................................................................... 6
1.3.1 Incidents identified in the OII ............................................................................... 6
1.3.2 PG&E Response to the OII ................................................................................... 7
1.4 Impact of Records Gaps on Distribution System MAOP .................................................... 8
2. PREVIOUS PG&E AND CPUC INVESTIGATION OF RECORDS...................................... 9
2.1 Previous Consideration of Recordkeeping Issue ................................................................. 9
2.2 Findings of Duller and Norths Related to Recordkeeping at PG&E.................................. 9
2.3 Previous Studies of Records Adequacy at PG&E ............................................................. 11
3. PWA APPROACH TO THE INVESTIGATION ................................................................... 12
4. APPLICABLE REGULATIONS ............................................................................................ 25
4.1 Elements of a Safety Code Violation................................................................................. 25
4.2 Applicable Pipeline Safety Requirements ......................................................................... 25
4.3 Records Necessary to Demonstrate Compliance ............................................................... 25
4.4 General Recordkeeping Requirements .............................................................................. 31
5. FACTORS CONTRIBUTING TO RECORDKEEPING-RELATED INCIDENTS
AND VIOLATIONS ...................................................................................................... 34
6. EVIDENCE OF NON-COMPLIANCE .................................................................................. 36
6.1 Violations Associated with the Six OII Incidents.............................................................. 37
6.2 Additional PG&E Violations Identified during the Investigation ..................................... 40
6.2.1 Violations associated with additional incidents .................................................. 41
6.2.2 Violations associated with the relationship between incidents at
Mountain View and Carmel................................................................................ 47
6.2.3 Violations associated with establishment of maximum allowable
operating pressure (MAOP) ................................................................................ 49
7. CHANGES IMPACTING PG&ES CONTROLS ON NATURAL GAS

DISTRIBUTION MAPPING AND RECORDKEEPING ............................................. 55
8. EVALUATION OF CORRECTIVE ACTIONS AND BACKSTOP MEASURES ............... 57
8.1 Recent SED Inspections Regarding the Effectiveness of PG&E Mapping ....................... 57
8.2 Design, Implementation and Effectiveness of PG&Es Backstop Measures and
Corrective Actions ............................................................................................................. 57
8.3 Adequacy of Training ........................................................................................................ 69
8.4 Observations on Root Cause Analysis............................................................................... 71
9. CONCLUSIONS AND RECOMMENDATIONS .................................................................. 73
9.1 Conclusions........................................................................................................................ 73
9.2 Recommendations.............................................................................................................. 75
Table 1 Relevant Details of the Six Incidents Described in the OII ........................................ 14
Table 2 Additional Incidents Evaluated for OII ...................................................................... 15
Table 3 Time Line for Map and Record Requirements ........................................................... 27
Table 4 Violations Associated with Additional Incidents Evaluated for OII .......................... 42
Table 5 Violations related to Incidents at Mountain View and Carmel .................................. 48
Table 6 PG&E MAOP Time Line ........................................................................................... 49
Table 7 List of available MAOP Correspondence ................................................................... 53
Table 8 SED-Identified Mapping Errors and Omissions ......................................................... 57
Table 9 Evaluation of PG&E Corrective Actions and Backstop Measures............................. 59
Table 10 Evaluation of Training Adequacy............................................................................. 69
Table E-1 Additional Incidents Derived from PG&E Responses to Data Requests ............. 125
FIGURE D-1 PRUDENT MANAGEMENT OF PIPELINE MAPS AND RECORDS............................... 123
Attachment A Qualifications of PWA Staff ............................................................................ 77
Attachment B Summary of DRs and Status of Responses (current on 09/18/15) ................... 84
Attachment C Compilation of Current Regulations Affecting Records and Maps ............... 111
Attachment D Standard of Care for Pipeline Maps and Records .......................................... 119
Attachment E Examples of Factors Contributing to Records and Mapping Issues ............... 124
Attachment F Observations on Root Cause Analysis ............................................................ 128
Attachment G Response to March 6, 2014 Gas Incident Violation Letter Mountain
View, California, Sumeet Singh (PG&E) to Michael Robertson, April 4, 2014 ............. 131
ii
0.
EXECUTIVE SUMMARY
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0.1
Scope of Investigation
The Safety and Enforcement Division (SED) of the California Public Utilities Commission (CPUC)
contracted with P Wood Associates (PWA) to:
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Investigate whether PG&E violated any provision of the CPUC code, Commission
general orders or decisions, applicable rules or requirements, or other state or federal
laws pertaining to safety recordkeeping for its natural gas distribution system.
Identify recordkeeping violations that have occurred.
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Evaluate whether the actions the PG&E has planned and initiated to compensate for
known deficiencies in recordkeeping are reasonable, are taking hold in the field, and are
having the desired impact on safety.
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Provide a report and testimony in support of the PG&E Gas Distribution Records
proceeding I.14-11-008.
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This section summarizes the facts and findings assembled from a series of presentations by PG&E
managers, structured interviews of PG&E staff, PG&E responses to an extensive set of data requests,
and evaluation of select CPUC incident and inspection reports.
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0.2
Facts Related to PG&E Recordkeeping
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Regulations describing requirements for records retention have been in place for decades, with the
earliest identified being issued by the California Railroad Commission in 1932.1
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Over the years PG&E has developed policies and procedures intended to assure compliance with
these regulations.2
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Violations related to recordkeeping were not the result of defective procedures, rather resulted from
failure to follow the procedures, including failure to keep the records secure. Early versions of
PG&E standard practice for mapping standards such as SP 410.21 effective April 1977 through
May 1980 appear to have adequate detail3 to capture accurate and sufficient information for maps
to be used by operating personnel. Requirements addressed security4 of original maps to prevent
their loss, and included an instruction to keep authorizations concerning installed mains
permanently for reference.
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Inaccurate and missing records and maps have contributed to incidents, including those described
in the OII.
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PG&E has designed and implemented numerous measures intended to correct acknowledged
imperfections5 in its maps and records and to provide backstops to minimize risks associated with
Standards for Gas Service in the State of California, General Order No. 58-A, effective July 1, 1932. This was
the third edition of this standard; the initial version was effective September 1, 1919.
2
See for example PG&E Mapping Standards, Standard Practice No. 410.21-1, 04/01/77.
See SP 410.21-1 page 9 for main pressure requirements, position of valves, page 11 for gas mains character
and history such as type of joint, size, location, kind of pipe, authorization, year installed, page 15 for insert
mains, pages 16-19 for posting gas service information (house number, size, year installed, additional
measurements when service pipe is not at right angles to the main or property line, stub services, and insert
services.
4
See SP 410.21-1 pages 31-32.
PG&E Initial Report in Response to the OII, December 22, 2014.
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these errors and omissions. However, ongoing map correction activities are typically opportunistic
(i.e., carried out in the normal course of maintenance) rather than proactive.
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PG&E is completing implementation of the Pathfinder Project to bring together available

information to identify and correct inconsistencies, to improve the accuracy of its maps and
records, and to provide easy field access to maps and records through the Gas Distribution
Geographic Information System (GD GIS) using the Pathfinder Viewer.
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PG&E has avoided implying that completeness and accuracy issues will be fully resolved through
completion of the Pathfinder Project.
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The US Department of Transportation Distribution Integrity Management Program (DIMP)6

regulation recognizes the existence of accuracy and completeness issues in distribution pipeline
maps and records.
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The DIMP regulation requires utilities subject to its provisions to implement measures to improve
the accuracy of maps and records based on numerous sources of information associated with
normal activities in the field.
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PG&E has implemented a program to, among other functions, address certain aspects of this
requirement the Corrective Action Program (CAP).
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PG&E has not implemented programs beyond CAP that are designed to identify and characterize
recognized imperfections in its maps and records associated with pipe inserts and stubs.
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PG&E has not fully addressed the root cause of damages to its gas lines resulting from the
elimination of retired and abandoned gas lines from maps. Information on the locations of retired
in place gas lines is needed to support locate and mark activities as well as other operating and
maintenance activities to help avoid confusion over live versus retired in place gas lines when
excavations in their proximity take place.
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PG&E has established the Maximum Allowable Operating Pressure (MAOP) for 243 of its 1,376
hydraulically independent distribution systems using an approach different from that prescribed in
the 1970 pipeline safety regulation Title 49 of the Code of Federal Regulations (49 CFR)
192.619(c).
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0.3
Major Findings
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Evidence from recent incidents gathered in support of this OII indicates that PG&E has failed to
follow the regulations and its procedures regarding record keeping - including both maps and
records.
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Factors contributing to accidents, incidents and third party damage included: lack of records, maps
not being updated in accordance with mapping procedures, and PG&E not maintaining control and
updating historical records of gas distribution mains and service lines.
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PG&Es approach to establishing the MAOP for 243 hydraulically independent distribution
systems is in violation of the 1970 requirement of 49 CFR 192.619(c) describing the bases on
which MAOP is to be established for so called grandfathered segments of its system. It is
probable that this violation resulted because of the absence of the distribution system pressure
records/charts associated with the five years (1965 through 1970) needed to comply.
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Refer to 49 CFR 192.1007 and 192.605(b)(4).
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We have seen no evidence that PG&E reviewed or requested approval of its approach to
establishing MAOP of its distribution systems with the CPUC7.
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Regulations such as 49 CFR 192.605(b)(4), 192.605(b)(8), 192.617, 192.1007, and 192.613,

have existed for many years requiring utilities to understand their systems, to evaluate the causes
and implications of incidents, and to incorporate the lessons from these investigations into utility
policies, procedures and programs.
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PG&Es handling of the incident at Mountain View (07/30/13), a clear precursor of the incident at
Carmel (03/03/14), supports the conclusion that PG&E has failed to comply with these learning
from experience regulations; until an incident is sufficiently high profile that action must be taken.
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California Government Code (CGC) 4216.3(a)(1) requires utilities either to locate and mark
(L&M) underground structures near identified excavation sites, or to agree with the excavator on a
delay in excavation until the L&M activity can be completed.
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An interview with
, Sr. Gas Compliance Representative an individual responsible for
locating and marking gas lines prior to excavation, supports the conclusion that PG&E has
substituted a permissive notification policy/practice (i.e., contact of the excavator when the L&M
cannot be completed on time can be as late as the night before the excavation and does not need to
include direct contact with the excavator a voice mail message is acceptable) for the requirement
to mutually agree with the excavator on a delay in the completion of the L&M activity. This
substitution, evidenced in the San Jose incident (11/07/14) described in Table 4 of this report,
violates CGC 4216.3(a)(1).
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Evidence gathered in CPUC inspections during July and August of 2015 shows that some of the
new processes and procedures PG&E has put in place to prevent inaccurate and incomplete
changes to maps and records are not yet working as intended.
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PG&E has established an Internal Audit (IA) program, which management is using to investigate
the completeness and effectiveness of the numerous changes in information systems, procedures
and practices it has implemented.
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0.4
Categories of Violations
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The CPUC adopted the 1958 edition of ASA B 31.8 code for transmission and distribution piping as
well as additional requirements for design, construction, testing, maintenance and operation in General
Order (GO) 112, effective January 17, 1961. The CPUC stated its intention in GO 112 Section 104.1
that all work performed within the scope of these rules shall meet or exceed the safety standards
expressed or implied herein. GO 112 Section 301.1 states the utility is responsible for maintenance of
necessary records to establish compliance with these rules. CPUC General Order112-E Section 101.2
incorporates 49 CFR Part 192.
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PWA found that PG&E lacked the necessary records to comply with code requirements, primarily as a
result of not maintaining its maps and records up to date. The following identifies the primary areas
of violations PWA identified as a result of its investigation into PG&Es distribution record-keeping
practices. Further details and information concerning these violations are provided in in Section 6 of
this report.
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Failure to follow written procedures to ensure operating maps and data are updated and
accurate. Not maintaining control and updating historical records of gas distribution mains and
In 1999 the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued guidance providing for
regulatory review of alternative approaches to the 1971 code requirement for establishing MAOPs of
distribution systems.
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service lines. Repeated failure to correct recordkeeping violations despite having adequate
knowledge for decades. 49 CFR 192.603(b), 192.605(a), 192.605(b)(3), 192.13(c) and
Public Utilities (PU) Code Section 451 and Section 961.
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Failure to mark out and inspect its gas lines in the area of excavation after receiving valid
Underground Service Alert notification in accordance with California Government Code
4216.3(a)(1), 49 CFR 192.614(c)(5) and 49 CFR 192.614(c)(6).
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Failure to carry out data gathering to evaluate the causes and implications of incidents, and to
incorporate the lessons from these investigations into utility policies, procedures and programs
in accordance with 49 CFR 192.605(b)(4), 192.605(b)(8), 192.613, 192.617, 192.1007
and PU Code Section 451 and Section 961.
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Failure to meet operating pressure restrictions contained in 49 CFR 192.619(a), or establish

the maximum allowable operating pressure (MAOP) for 243 hydraulically independent
distribution systems in accordance with 49 CFR 192.619(c).
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1.
INTRODUCTION
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1.1
In November 2014, the California Public Utilities Commission (CPUC) issued an Order Instituting
Investigation8 with the following purpose:
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Purpose and Scope
In response to several incidents, by this order, the California Public

Utilities Commission (Commission) institutes a formal investigation to
determine whether Pacific Gas and Electric Company (PG&E),
violated any provision or provisions of the California Public Utilities
Code (Public Utilities Code), Commission general orders or decisions,
other applicable rules or requirements pertaining to safety recordkeeping
for its natural gas distribution service and facilities, and/or other state or
federal laws. This investigation will review and determine whether
PG&Es recordkeeping practices for its gas distribution system have been
unsafe and in violation of the law.
In support of this investigation the Safety and Enforcement Division (SED) of the California Public
Utilities Commission (CPUC) contracted with P Wood Associates (PWA)9 to:
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Investigate whether PG&E has violated any provision of the CPUC code,
Commission general orders or decisions, or other state or federal laws or
applicable rules or requirements pertaining to safety recordkeeping for its natural
gas distribution system;
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Determine what recordkeeping violations, including those potentially associated

with PG&Es approach to establishing the maximum allowed operating pressure
(MAOP) for distribution lines in operation prior to 1970, have occurred;
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Evaluate whether the actions the operator has planned and initiated to compensate
for known deficiencies in recordkeeping are reasonable, are taking hold in the
field, and are having the desired impact on safety;
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Provide a report and testimony in support of the Gas Distribution Recordkeeping

proceeding I.14-11-008.
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1.2
Approach
In preparing this report, PWA consultants carried out the following activities:
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Reviewed the OII, the six Safety and Enforcement Division (SED) incident
evaluation reports referenced in the OII, and PG&Es initial response to the OII;10
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Reviewed the twelve data requests (DRs) prepared by the SED and submitted on
March 4, 2015 to PG&E - prior to the beginning of the PWA engagement;
Order Instituting Investigation and Order to Show Cause on the Commissions Own Motion into the
Operations and Practices of Pacific Gas and Electric Company with Respect to Facilities Records for its Natural
Gas Distribution System Pipelines, OII.14-11-008, November 20, 2014, San Francisco Office.
9
Collectively, the three P Wood Associates (PWA) subject matter experts bring (46+15+23) 84 years of gas
transmission and distribution pipeline experience, including experience as regulators, operators and consultants.
See Attachment A for a description of the background and experience of the PWA subject matter experts:
Berger, Gawronski and Wood.
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PG&E Initial Report in Response to the OII, December 22, 2014.
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Over the course of the investigation prepared an additional 102 DRs as well as 25
interrogatories under oath directed to four specific PG&E senior managers and
executives. These DRs and interrogatories are listed in Attachment B;
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Participated in two presentations (one by phone, one in person) by knowledgeable

PG&E managers on a number of records-related topics - these presentations were
designed to provide contextual information on ongoing PG&E activities;
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Visited the locations where the 6 incidents identified in OII 14-11-008 occurred,
and accompanied SED inspectors on a corrosion inspection in one of those
Divisions;
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Reviewed select incident reports, including those for the six OII incidents;
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Interviewed six working level PG&E employees, in a monitored environment, to

better understand how they discharge their responsibilities these six employees
were selected by PG&E. The purpose of these interviews was to gain insight into
the records handling process that PG&E currently uses and those used in the past;
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Screened and reviewed the over nine thousand documents PG&E provided in
response to the 114 DRs;
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Reviewed the PG&E executive responses to twenty-five (25) interrogatories

under oath;
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Made and reviewed the responses to eight (8) oral requests of PG&E for data
discussed during the presentations and interviews noted above;
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Conducted a search of past CPUC general orders and decisions that relate to
recordkeeping requirements, other state and federal recordkeeping requirements,
as well as reviewed recordkeeping issues identified during the San Bruno
investigation of PG&Es failed gas transmission line.
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The information gathering approach described above was designed to support investigation of the
consistency among management intentions and direction, procedures used in the field and for mapping,
and how working-level staff actually carries out the work.
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In an effort to supplement the information gathered as described above with actual results from PG&E
implementation of maintenance and related mapping activities, PWA consultants relied upon
inspections carried out by SED inspectors during July and August of 2015. These inspections included
a review of how consistently leak repairs involving insertion of plastic pipe resulted in correct changes
to the maps in the Gas Distribution Geographic Information System (GD-GIS) the field-accessible
system (using Pathfinder Viewer) in which distribution system maps along with supporting
information is stored.
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1.3
Background
1.3.1 Incidents identified in the OII
In the OII, the CPUC identified six incidents that have occurred during the past 5 years associated with
PG&Es record keeping practices. The six incidents include the following:
1. A release of gas from a 1 plastic gas service line in Castro Valley in September 2010
due to a mapping error that contributed to an erroneous locate and mark of the gas service
line. There were no injuries and minor property damage.
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2. A release of gas from a steel stub service line in Morgan Hill in June 2012 that was
not marked because it was not included on the current underground utility map. There
were no injuries and minor property damage.
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3. The loss of gas service to nearly 1,000 customers in Milpitas in October 2012 resulting in
part from a map showing a back-feed valve in the open position when it was closed. The
job work resulted in gas flow being curtailed during a planned main replacement project
for which an approved clearance existed. There were no injuries but many customers
were without gas service.
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4. The release of gas from a 2 plastic gas main in Milpitas in March 2013 resulting from
the locate and mark being more than 2 away from the pipe. There were no injuries and
only minor property damage.
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5. The release of gas resulting from welding on and tapping of a 1 steel service that had
an unknown 1 plastic insert in Mountain View in July 2013. There were no injuries but
property damage was estimated at $10,000.
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6. The release of gas and an explosion that destroyed a house resulting from tapping of a 2
steel main that had an unknown 1 plastic insert in Carmel in March 2014. There were
no injuries but significant property damage.
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In its 12/22/14 response, page 5 lines 3-4, PG&E states With the minor exceptions noted below,
PG&E does not disagree with the factual contentions and conclusions regarding its gas distribution
recordkeeping stated in the SED Reports. 11 PWA has evaluated these and other mapping-related
incidents, as well as additional information on the processes and procedures PG&E uses to assure the
accuracy of its maps and records, to determine whether violations have occurred and the nature of such
violations.
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1.3.2 PG&E Response to the OII

As part of the OII process, PG&E was given 30 days to respond to the Order Instituting Investigation
and Order to Show Cause(OII). PG&Es response12 to the OII makes several points, including:
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PG&E essentially agrees with the factual events in each of the six OII
incidents, but disagrees there were any related violations, or at least stated that
the violations cited by the CPUC in the OII are not valid;
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It contends that a company as large as PG&E cannot be expected to have

perfect records.13 Its distribution system records span 50 or more years and
comprise 77,000 miles of pipe, making the attainment of perfectly accurate
recordkeeping impossible;
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PG&E has long recognized that it has imperfections in its maps and records,
and has initiated major improvement projects to improve the completeness,
accuracy and accessibility of its maps and records, as well as other changes to
prevent the recurrence of incidents similar to the six noted in OII.
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As evidence of its ongoing efforts, PG&Es initial response to the OII enumerates approximately 24
activities in four categories:
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See PG&E Response to OII dated 12/22/14, page 5.
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See PG&E Response to OII dated 12/22/14..
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PG&E Response to OII dated 12/22/14, page 2.
o Efforts to improve accuracy,
o Efforts to improve map and record accessibility,
o Efforts to improve controls,
o Actions to improve operational safety.
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Consistent with our charge by SED, PWA has evaluated each of these 24 improvement activities in
Section 8.
1.4
Impact of Records Gaps on Distribution System MAOP
Subsequent to issuance of the OII, the SED decided to roll into the investigation consideration of the
fact that records gaps in the late 1960s led PG&E to establish the MAOP for 243 hydraulically
independent distribution systems using an approach different from that prescribed by 49 CFR
192.619(c). The PG&E response to Data Request #87 stated that in 2008, PG&E concluded that the
use of the method described in TD-4125S to establish MAOP does not pose a safety risk to the
distribution system. Therefore, PG&E has not implemented any additional compensatory measures
specifically applicable to the associated pipe. Since no compensatory measures have been used, only
the compliance aspects of the MAOP issue have been evaluated in this report.
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2.
Previous PG&E and CPUC Investigation of Records
2.1
Previous Consideration of Recordkeeping Issue
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The subject of generally accepted recordkeeping principles is not a new one for PG&E or the CPUC.
It was addressed in testimony by Duller and North as well as by Margaret Felts in Docket I. 11-02-016.
The findings of Duller and Norths work were based on Generally Accepted Record-keeping Principles
(GARP) Information Maturity Scores.14 The testimony of Duller and North found gas transmission
records and safety related documents were scattered, disorganized, duplicated, and were difficult if not
impossible to access in a prompt and efficient manner.15 Issued in connection with the same
proceeding, the testimony of Margaret Felts16 addressed how PG&Es record keeping practices
affected PG&Es transmission pipeline engineering.
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PWA did not evaluate PG&Es recordkeeping practices in relation to GARP. PWA did however
review and learn from the Duller and Norths findings as they relate to companywide and distribution
recordkeeping practices. PWA has checked the applicability of findings from these reports to PG&Es
distribution record keeping practices. In our evaluation we found that factors contributing to accidents,
incidents and third party damage included: the lack of records, maps not updated in accordance with
mapping procedures, and not maintaining control of and updating historical records of gas distribution
mains and service lines. The PWA report concentrates on the gas distribution engineering and
operations aspects of PG&E. Its findings complement the two transmission-focused reports noted
above, and point out deficiencies in record keeping practice that constitute violations of requirements
in the safety code.
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2.2
While Duller and North focused on transmission pipeline record keeping, many of the policies and
procedures it cited in its review included both transmission and distribution systems. For example, the
following quote includes both transmission and distribution systems:
PG&Es Internal Report17 goes on to state that even today related paper and
electronic records can be difficult to locate from office to office because of the
unique process each office has created to ensure the Mappers have access to the
information they need; the location and organization of physical records varies by
location and is often only known to a few individuals performing the filing; and
additionally, that maps are inconsistent between Gas Transmission and Gas
Distribution, as well as between divisions. The lack of process and controls for field
personnel submitting map corrections is cited, as a further cause for concern as the
map correction process varies by location, while the lack of controls over
contractors, is cited for completeness, consistency, and quality of work issues.
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Findings of Duller and Norths Related to Recordkeeping at PG&E
Duller and Norths report found:
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This report contains a review and assessment of PG&Es policies, procedures,

practices and records, as provided via data requests; technical reports, provided
by the NTSB, CPUC and other third parties; interviews with PG&E staff; and, a
14
Testimony of Duller and North, at p. 6-25, lines 30-32.
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Testimony of Duller and North, at p. 1-10, lines 15-24.
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Revised Report and Testimony of Margaret Felts, Docket I.11-02-016, March 16, 2012.
17
GasTransmissionSystemRecordsOII_DR_025-Q02(i) Supplement - Summary of Information Management

Key Themes: PG&E Gas Mapping Organization , Internal PG&E report produced by PwC. [Preliminary Draft
as of January 18, 2012].
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series of site visits to PG&Es facilities. While this review focuses on

organization, access, storage, preservation, and retention of Gas Transmission
records and related documentation, the findings are also referenced against
PG&Es corporate approach to records management.
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This report finds that PG&Es pipeline records were widely distributed and poorly
controlled across the Gas Transmission Division.
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This review has used the "Generally Accepted Record-keeping Principles" (GARP)18 and
the Information Maturity Model19 defined by ARMA International20 as the basis of an
assessment and evaluation of PG&Es records management activities.
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On the basis of the GARP criteria we find that records management within PG&Es
Gas Transmission Division prior to the San Bruno pipeline rupture and fire were SubStandard21 (Average Maturity Score = 1.2). PWA note, the highest possible score
was 5.
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PG&E failed to maintain the records management practices necessary to promote

the safety of its patrons, employees and the public. Examples of these failures include
the lack of company-wide strategy for record keeping: poor implementation of records
management standard practices; inappropriate disposal of pipeline history files;
inadequate management and control of job folders; poor metadata quality control; and
the uncontrolled distribution, duplication and storage of pipeline related job folders.
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24
25
As a result of these failures: PG&Es historical pipeline records would not have been
readily available, traceable, verifiable or complete; there was no single source of
trusted pipeline-related documents, records management was not optimized to support
operations, decision making, planning or safety; and inconsistent, incomplete and out
of date information would have been present in a significant number of its pipeline
related job folders, as well as those systems, such as GIS, which relied upon them.22
26
27
Duller and North did note in their testimony that PG&E has begun to address the records issues. These
changes are well underway, and PWA has included a discussion of the changes in Section 8.
28
29
30
31
32
In 2011 PG&E commissioned Pricewaterhouse Coopers (PwC) to undertake an

internal review of information management within its Gas Transmission Division.23
This internal review included records management, document management, and data
management. A preliminary draft was provided to Duller and North as of January
18, 2012.
18
www.arma.org/garp; Principles include: accountability, compliance, transparency, availability, integrity,

protection, retention, and disposition.
19
www.arma.org/garp/metrics.cfm .
20
ARMA International was previously known as Association of Records Managers and Administrators, and is
the authority on managing records and information in the USA (www.arma.org); Records management themes
include: strategy, responsibilities, training, policies/standards/procedures, records retention, business continuity
& vital records, records management processes, records management storage, and technology.
21
Level 1 (Sub-standard): An environment where record-keeping concerns are either not addressed at all, or are
addressed in a very ad hoc manner. Organizations that identify with these descriptions should be concerned that
their programs will not meet legal or regulatory scrutiny.
22
Duller and North report dated March 5, 2012 page 6-25 lines 5-18.
23
10
1
2
3
4
CPSD understands PG&E plans to make necessary changes to its records

management processes based on the findings from the PwC assessment. These
changes are likely to encompass new policies, procedures, practices, systems and
improved training.24
2.3
Previous Studies of Records Adequacy at PG&E
6
7
8
PG&E commissioned Bechtel Corporation to carry out two studies, one in 198425 and a follow-on
study in 199526, designed to evaluate pipe replacement priorities. This work was initially focused on
transmission pipelines, but ultimately included distribution mains.
The 1984 report contained the following observation:
10
11
12
13
P 13 During the data collection process, the area engineers were sometimes
confronted with the problem of missing records that prevented them from finding
variable values.
The follow-up 1995 report included the following observations:
14
15
P ES-1 There has been an ongoing effort to build and improve upon the data base of
information that goes into the prioritization program.
16
17
18
19
20
21
22
P 5-1 Transfer of the Distribution Feeder Mains (DFMs under 20% SMYS) from the
distribution subprogram to the transmission database necessitated research of company
records for the data required for evaluation under the transmission methodology.
Results of this research, conducted by PG&E personnel, were mixed at best due to the
absence of the underlying documents or due to recent organizational changes that have
made collection of data problematic. [The amount of pipe affected by incomplete or
missing data is not known at this time.]
23
24
25
26
P 5-1 The subject of data verification is one that deserves greater emphasis by PG&E.
Though time consuming, verification of pipe data should be a prerequisite to the
replacement decision to ensure that erroneous or missing data is not defaulting a
pipeline segment into a high replacement priority.
27
28
29
It seems clear these PG&E commissioned reports demonstrate that the utility has known of problems
related to its data and records for some time. The continuing presence of imperfect maps and records,
such as those discussed in Section 8.1, shows that the remediation efforts are incomplete.
30
24
25
Pipeline Replacement Program - Transmission Line Risk Analysis, Rev 0, Bechtel Corporation, January
1984.
26
Review of Transmission Priority Analysis (1995 Revision) for the Gas Pipeline Replacement and
Rehabilitation Program, Bechtel Corporation, May 1995.
11
3.
2
3
4
5
6
7
8
9
The PWA team used four means to carry out the evaluation. In addition to reviewing the
documentation prepared by the CPUC and PG&E in support of and in response to the OII, we learned
from (a) a series of presentations by PG&E managers, (b) a few structured interviews of PG&E staff,
(c) PG&E responses to an extensive set of data requests, and (d) review of numerous incident reports
and results from select SED inspections. This section briefly summarizes each of the first three
sources, then summarizes our review of recent map and records-related CPUC reportable incidents,
and finally discusses our investigation of the issue related to establishment of the maximum allowable
operating pressure (MAOP) for a large number of older distribution systems.
10
11
12
13
In response to our initial request to interview a number of its distribution pipeline executives, PG&E
offered two information briefings to help acquaint us with activities they are pursuing to update maps
and records and to help assure future errors do not occur. The first of these briefings was by telephone,
the second was face-to-face in PG&Es San Ramon offices.
14
15
16
To address our request for field interviews with key working-level employees at the four divisions in
which the OII incidents occurred, PG&E offered six employees they selected to be interviewed, in the
presence of PG&E monitors, in their offices in Salinas and San Jose.
17
18
19
20
The primary source of documentation used in support of our investigation was the over nine thousand
documents PG&E provided in response to our 114 DRs. In addition, PG&E provided responses to
eight oral requests made during the presentations and interviews, and responded to twenty-five (25)
interrogatories under oath made to PG&E executives.
21
22
23
24
25
26
27
Another primary information source in our evaluation of the impact of PG&Es mapping and
recordkeeping practices was reports on incidents prepared by the SED staff. Inspection findings are
discussed further in Section 8.1. The initial documents consisted of the incidents noted in the OII.27
From that start, the team then reviewed the incidents in the February 20, 2015 Notice of Probable
Violation (NOPV) letter28 and PG&Es response to that letter. Additional documentation, consisting of
the SED incident reports, was then reviewed, as were PG&E responses to SED inspections.29 Finally,
we visited several of the sites where incidents30 listed in OII occurred.
28
29
30
31
32
33
For all of the six (6) incidents listed in the OII either recordkeeping or mapping issues were significant
contributing factors. These six incidents are summarized in Table 1. Two of the six incidents involved
steel mains or services inserted with plastic which was not identified on the maps given to the field
crews. The crews performing the work, such as tie in or service transfer, were not aware that plastic
was inside of the steel and thus did not know that their actions had created an unsafe condition. In one
of the other incidents where stubs31 were not marked, a third party excavator hit one, thus releasing
27
PWA APPROACH TO THE INVESTIGATION
See OII I.14-011-08 pages 2 to 7.
28
See Letter of Ken Bruno dated February 20, 2015 and response of Larry Deniston dated March 24, 2015 pages
A-1 to A-22.
29
PG&E's letter of April 4, 2014, Sumeet Singh (PG&E) to Michel Robertson Safety and Enforcement Division
California Public Utilities Commission states: In its letter, the SED found PG&E in violation of Title 49 of the
Code of Federal Regulations Part 192.605(b). PG&E agrees with this violation.
30
General Order 112-E Section 122 (now GO 112-F) requires operators to report within a specified timeframe
incidents that resulted in loss of life, an injury, an estimated property damage of more than $50,000, attracted
public attention or given significant media attention. Incidents that are considered significant, even if they do
not meet any of these criteria, may also be reported and/or investigated by SED.
31
A stub is defined as a short service that was abandoned on a property or at the property line but not removed
all the way to the supply main. These capped stubs do have gas under the same pressure as the main and are
considered active.
12
1
2
3
4
gas. This stub was not on the map provided to the locating32 personnel. Another incident was the result
of a supply valve being shown on the map as open when it was actually closed; hence when the feed
from the other side of a tee was isolated to perform the tie in safely, almost 1,000 customers lost gas
service.
5
6
7
8
9
The final two incidents of the six listed in the OII involved mapping errors with one being on a plastic
service that was damaged by a third party excavator. This service had been inaccurately mapped and,
therefore, two earlier leak surveys had been carried out incorrectly before the listed incident. Each of
these documented incidents involved PG&E either not keeping accurate records or incorrectly mapping
the actual location of the underground facility.
10
11
12
These are not the only map or records-related incidents that have occurred over the last several years
that have resulted in damage, loss of supply or a release of gas. As discussed below, we have
evaluated a sampling of other map and record-related incidents in this report.
13
14
15
16
17
18
19
20
21
A sort of incidents for the period of 2010 to 2014 to identify those for which a valid locate ticket was
issued (Underground Service Alert - USA) and for which the incident cause was listed as a mark or
map error yielded in excess of 100 incidents. This total excludes any damages that listed no tracer
wire, no USA request was called in, poor excavation practice (such as digging with power equipment
near a known facility), and other causes or unknown causes. For just the first quarter of 2015 - after
PG&E instituted new procedures, implemented part of its database and records improvement program
known as the Pathfinder Program in many divisions and other database and operational improvements
and enhancements - there were still in excess of 25 incidents due to incorrect facility records/maps or
the facility was not properly located.
22
23
24
25
26
27
Table 2 presents a listing of some of the incidents occurring between 2010 and 2014 that the SED
investigated. Poor or inaccurate record keeping and/or miss-locating the PG&E facilities contributed
to each of these events. Some the incidents were not caused by outside excavation contractors but
rather by PG&E crews doing work on their own systems. There were many more incidents reported by
PG&E that may not have resulted in an SED investigation because they did not meet the incident
reporting criteria.33
28
29
30
31
32
33
34
35
36
37
38
Another records-related issue we have investigated is the approximately 243 hydraulically independent
distribution systems for which the maximum allowable operating pressure (MAOP) was not
determined by a recorded pressure test or a pressure certification during the regulation-mandated five
(5) year look back or grandfathered period between 1965 and 1970.34 During this period PG&E
procedures required that pressure records be retained for only two years. This retention time was the
same as that required by General Order 58A (effective 07/01/32) Sections 20(c) and 20(d). For many
of these systems the MAOP was set during a period from 1977 through 1979. By missing the
regulatory prescribed grandfathered period, PG&E failed to determine the MAOP for these systems
using the prescribed method. After the grandfathered period expired, only a valid pressure test per 49
CFR Part 192 Subpart J was allowed as the basis for establishing MAOP except where the operator
had obtained permission from its regulator to deviate along with a concurrence from PHMSA.
39
32
All marking and locating for PG&E gas distribution are performed by company personnel.
33
Per footnote 31, certain incidents require immediate reporting to the CPUC. General Order 112-E Section
122.2(d) requires quarterly reporting of all CPUC reportable and non-reportable gas leak related incidents,
including underground dig-ins.
34
Under the provisions of 49 CFR 192.619.
13
Table 1 Relevant Details of the Six Incidents Described in the OII

Location/Date
System Characteristics
Underlying Cause
Consequences
1 Castro Valley
09/17/10
(Mission
Division)
2 Morgan Hill
06/21/12
(San Jose
Division)
3 Milpitas
10/10/12
(San Jose
Division)
Plastic service line, 1 inch, 60

psig - MAOP
TPD, Mapping error, incorrect field documentation

from historical gas service records, violation of
procedures to maintain maps and records.
Steel service line, inch,

installed 1951, deactivated, 60
psig - MAOP
4 Milpitas
03/04/13
(San Jose
Division)
Plastic distribution main, 2 inch ,

60 psig - MAOP
5 Mountain View
07/30/13
(De Anza
Division)
Steel service line casing with

plastic liner, 60 psig - MAOP
TPD, Failure to follow procedures, service stub not

marked and not on 5 year review program,
violation of procedures to maintain maps and
records.
Error in data in analytical model, valve closed not
open, operating position of valve on map incorrect,
records, failure to verify valve position and
monitor pressure during main tie-in.
TPD, mapping error leading to ineffective locating
aid, mislocate, nearest ETS (1994) Electronic test
station for tracer wire not shown on map, violation
of procedures to maintain maps and records,
failure to resolve accuracy of locate signals or alert
excavation contractor of potential mark-out
inaccuracy.
Record error, no indication of inserted plastic pipe,
welding on 1 steel previously inserted with
plastic 1970, (OII indicates page 5 1972 vintage),
records.
Gas release & service interruption

(Note, incident reportable because of
presence of TV crew), hazard and
danger to the public, economic harm.
Evacuation, service loss, hazard and
danger to the public.
Replacing 6 inch main with 4 inch

plastic main, 60 psig - MAOP
14
Service loss to 987 customers, hazard

and danger to public, adverse impact
to the community being served.
Gas loss, hazard and danger to public,

economic harm.
Gas loss, hazard and danger to public.
Location/Date
6 Carmel 03/03/14
(Central Coast
Division)
Underlying Cause
Consequences
2 diameter steel main with an

unknown 1 plastic insert
PG&E welded on the 2 line
using a welded tapping tee, and
tapped through the 2 tee into the
1 plastic insert.
Welding on 2 steel main previously inserted with

1 plastic (manufactured 07-17-1997), PG&E
using SAP to manage jobs, poor reaction to AOCs
and emergencies GERP, violation of procedures to
maintain maps and records, failure to timely
investigate root cause of similar plastic insert
incident, failure to recognize significance of poor
mapping and recordkeeping practices.
Gas leak, migration & delayed

explosion, house destroyed, damage of
$302k, hazard and danger to public,
heightened public concern due to loss
of confidence in PG&E ability to
operate and maintain its gas lines in a
safe manner.
Table 2 Additional Incidents Evaluated for OII

Location/Date
Underlying Cause
Consequences
San Jose
(01/20/15)
1 Steel stub extending

from a 4 steel main
Directional boring TPD, valid USA, main

marked, steel stub longer than 12 ft. not on
maps, violations of procedures 49 CFR
192.605(a) for failure to update maps, to
maintain maps and stub records, 49 CFR
192.605(b)(3) failure to provide up to date
maps and records to L&M personnel, and
192.614(c)(5) failure to locate and mark
all its subsurface facilities within the
delineated excavation area.
Gas release, No injuries, major

traffic diversion, 12 businesses
in strip mall evacuated, hazard
and danger to the public,
economic harm.
15
Location/Date
Underlying Cause
Lafayette
(8/27/13)
steel service line and

service line valve
Location of service line removed from

Gas release, no injuries, hazard
PG&Es map based on an incorrect gas
and danger to the public.
service record which indicated the service
line was cut-off resulted in TPD.
Violations of 49 CFR 192.605(a) for
failure to follow GTS Standard S4129
(requires cutting off services as close to the
main as possible) and 192.727(b) for
failing to properly abandon or deactivate its
gas facilities. PG&E also is in violation of
49 CFR 192.614(c)(5) and California
Government Code 4216.3(a)(1) for failure
to provide temporary marking for its
subsurface facilities affected by the
excavation.
Consequences
16
Location/Date
Underlying Cause
Consequences
San Jose
(11/07/14)
2 plastic distribution main,

near 3-way tee, which
branches off a 4 plastic
distribution main, 60 psig
MAOP
Contractor erroneously thought PG&E had

marked out its gas lines in response to the
USA request and that a 2 steel electrical
conduit was the gas line; PG&E had not
marked out its 2 gas line. L&M crew had
attempted to contact the excavator one hour
prior to the scheduled start of excavation;
the communication was unsuccessful.
PG&E did not identify the significance in
not making positive effective
communication without marking out the
gas lines and complying with damage
prevention requirements and procedures.
PG&E did not dispatch a representative to
the excavation location to make contact
with the excavator or to monitor the
excavation to ensure the safety of the gas
lines.
Violations of 49 CFR 192.605(a) for
failure to follow procedures including
PG&Es damage prevention handbook TD
5811M, 49 CFR 192.614(c)(6) for failure
to dispatch a representative to the
excavation site, and violation of California
Government Code 4216.3(a)(1).
Gas release, significant hazard

and danger to the public, public
concern, economic harm and
negative impact on business in
downtown San Jose. 2,500
people evacuated from office
buildings, shops and restaurants.
17
Location/Date
Underlying Cause
Consequences
Kentfield
(4/1/11)
Goodhill Road &
Diablo Drive
2 plastic main 60 psig

MAOP
New 2 plastic main PG&E previously

installed without tracer wire on 12/23/10.
New plastic main was not updated on
PG&E maps. L&M crew lost signal, used
outdated map to mark out old retired steel
main. Plastic main not indicated on map.
49 CFR 192.605(a) for failure to update
maps in a timely manner per Mapping
Bulletin 05-01 dated 6/7/06
PG&E is in violation of:
49 CFR 192.13(c) failure to follow its
procedures not updating its maps
49 CFR 192.605(b)(3) failure to provide
employee with accurate maps to L&M the
facility and not following its procedures to
update its records and maps
49 CFR 192.321(e) - failure to install
tracer wire on 2 replacement plastic main.
49 CFR 192.614(c)(5) failure to mark
out 2 plastic main
Water contractor excavating for

City of Kentfield damaged 2
plastic main. Gas release, no
injuries, hazard and danger to
the public.
18
Location/Date
Underlying Cause
Consequences
Antioch
(3/15/10)
2 plastic main, 60 psig

MAOP

Colusa
(03/19/09)
2 steel main, 150 psig

MAOP
L&M crew incorrectly located 2 plastic

main, mark was 14 feet off of actual main
location resulting in TPD. Main was
located in a sweeping arc when the main
actually intersected at the intersection at
right angle. L&M crew failed to utilize
available map information to assist in
determining the location of the gas main.
PG&E is in violation of 49 CFR
192.614(c)(5) and of California
to provide accurate temporary marking for
its subsurface facilities.
3 steel main was marked, L&M crew
failed to mark the 2 steel main.
Violations of 49 CFR 192.605(a),
California Government Code 4216.3(a)(1)
19
Backhoe damage to a 2 steel

main by PG&E crew while
excavating to repair a valve on a
3 steel main
Location/Date
Underlying Cause
Consequences
Alameda
(09/28/10)

MAOP
TPD, valid USA, locate error

(disconnected locate wire, inaccurate
records, failure to follow procedures) The
locating wire was disconnected, led to a
stray locating signal; operating records did
not reflect field conditions; and the L&M
crew did not follow proper procedures for
determining location of pipeline or
communicating same to the excavator.
49 CFR 192.614(c)(5) and of California
49 CFR 192.614(c)(6) for failure to
dispatch a representative to the excavation
site.
employee with accurate maps to locate and
mark the gas line and not following its
procedures to provide updated records and
maps.
Gas release, gas odor in air,

hazard and danger to the public,
homes evacuated, streets closed,
Gas shut off to school, no
injuries,
20
Location/Date
Underlying Cause
Consequences
Roseville
(10/21/10)

MAOP
TPD by boring contractor due to inaccurate

mark-out, 2plastic main on plat map
shown in joint trench, was actually in offset
trench, L&M crew failure to mark the
offset, the mark and locate employee did
not follow PG&E procedures to contact
mapping for assistance once the locate did
not make sense in relation to the plat.
California Government Code 4216.3(a)(1)
due to inaccurate mark-out and 49 CFR
192.13(c) - PG&E also did not follow its
Work Procedure 4412-03 page 4, the L&M
crew did not contact mapping when the
field locate and map did not make sense.
employee with accurate maps to locate and
mark the gas line and not following its
procedures to provide updated records and
maps.
Six buildings evacuated, five

customers had service
interruptions, gas release,
economic harm, no injuries,
hazard and danger to the public.
21
Location/Date
Underlying Cause
Consequences
Sacramento
(10/31/11)
1 plastic service 60 psig

MAOP
The service line was not accurately

updated/mapped to reflect the presence of
two offsets in the line. L&M crew failure
to contact mapping per WP4412-03 when
signal was lost during locating of facilities
or to advise contractor of potential poor
service mark. PG&E is in violation of 49
CFR 192.614(c)(5) and of California
facility.
Horizontal boring contractor

damaged a mismarked 1
plastic service line. Gas release,
no injuries, hazard and danger to
the public
TPD, emergency locate, flooded surface,

couldnt locate line, available map didnt
have locate dimensions.
Gas release, no injuries
Alamo (07/24/13) plastic service and

adjacent steel service tee
60 psig MAOP
22
Location/Date
Underlying Cause
Consequences
San Francisco
(04/08/14)
1 plastic service line, 60

psig MAOP
TPD, valid USA, PG&E excavation pulled

1 service line from 8 steel main; active
main and service not marked in area of
excavation, inactive pipe (6 away)
marked, service between marked &
unmarked mains damaged. Violation of 49
CFR 192.614(c)(5) and California
to mark its gas lines and failure to use
information available in its records to mark
out its lines.
Damage by PG&E crew, Valid USA, L&M
crew mismarked 1 service, PG&E map
was not updated correctly when service
line offset was installed on 8/1/83 per
PG&Es Mapping Standard 410.21-1 in
effect during the time period which states
that offset in service within the street area
and/or adjacent to PL shall be shown to
scale with dimensions. Violations of
procedures to maintain maps, and failure to
provide up to date maps and records to
L&M personnel.
Gas release, No injuries, no

ignition, hazard and danger to
the public, one service
interruption.
35
Fresno (09/24/14) 1 plastic service line with

14 foot offset, 60 psig MAOP
35
PG&E report reflects both
and
for this incident.
23
Gas release, No injuries, no

interruption.
Location/Date
Underlying Cause
Consequences
San Ramon
(8/12/09)
2 plastic service line 60

psig MAOP
TPD due to unmarked and unmapped 2

diameter service to restaurant. PG&E was
unable to produce the original service order
and did not map the service line after
installation. The service line was serving
the restaurant since 10/14/97.
PG&E is in violation of 49 CFR
192.614(c)(5) and of California
facility.
49 CFR 192.723(b)(2) failure to
perform leak surveys of the service line
since installation prior to 10/14/97.
Gas release, no injuries, no

interruption, economic harm.
24
4.
APPLICABLE REGULATIONS
2
3
4
5
6
7
8
9
4.1
A pipeline safety code violation may be one of commission or omission. That is PG&E may be found
in violation of pipeline safety requirements when its actions deviate from or fail to address
requirements including those in California State Laws, California Public Utilities Commission General
Orders, Minimum Requirements contained in California State Safety Codes or Federal Pipeline Safety
Codes such as 49 CFR Part 192 Requirements for Transmission and Distribution by Pipeline. A
violation exists either when PG&E fails to follow its procedures or when procedures are inadequate to
support compliance.
10
11
12
13
14
Elements of a Safety Code Violation
4.2
Applicable Pipeline Safety Requirements
As a part of providing natural gas to end users, PG&E must also provide adequately for public safety.
To accomplish this PG&E is required, at a minimum, to comply with a number of pipeline safety
requirements. These include:
California State Laws such as:
15
o California Public Utilities Code Section 451 and Section 961
16
o California Government Code 4216
17
California Public Utilities Commission General Orders such as:
18
o Preservation of records of public utilities and common carriers GO28
19
o Standards of Gas Service GO58, 58A thru 58F
20
21
o Design, construction, testing, maintenance and operation of utility gas gathering,

transmission and distribution piping systems as described in GO112 A through F
22
23
CPUC/CA Natural Gas Safety Code incorporates by reference all of the USDOT Federal
Minimum Natural Gas Safety Code 49 CFR Part 192
24
Standards incorporated by reference such as:
25
o ASA B31.8 1958 edition
26
o Standards incorporated by reference in 49 CFR Part 192
27
General Rate Case requirements
28
29
30
PG&E Standards, Specifications, Plans, Standard Operating Procedures and Emergency Plans
developed to comply with the above State Laws, General Orders, State and Federal Pipeline
Safety Codes, and Standards Incorporated by reference
31
32
Advisory bulletins and findings from outside evaluation reports (e.g., those of the NTSB)
which are specifically required by the California legislature.
33
34
35
36
37
38
39
40
PG&E is required to comply with all of these requirements, generally by having procedures in place,
following its procedures, and documenting its actions to demonstrate it has complied with these
requirements.
4.3
Records Necessary to Demonstrate Compliance
Table 3 below details historical requirements related to maps and records. These requirements and
their subsequent revisions (see Attachment C for current requirements) must be met to demonstrate
compliance. Inaccurate information contained in required records or the lack of such records
constitutes non-compliance. Such non-compliance is considered a violation of pipeline safety
25
1
2
3
requirements. While the wording associated with some of the earliest of these requirements has
evolved over the years, changes to the requirements have typically been to provide clarification, to
update requirements to reflect new information, and to strengthen requirements.
4
5
6
7
We should note that, as PG&E has pointed out in its response to the OII,36 and as has been recognized
by the Pipeline and Hazardous Materials Safety Administration in 49 CFR 192.1007,37 there may
be gaps in the knowledge an operator has when it develops its initial IM plan. Following is a quote
from that regulation.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
This section requires that operators develop their understanding from

reasonably available information. The rule does not require operators to retrieve
many years of archived records or to conduct additional investigations (e.g.,
excavation) to discover information about the pipeline. Operators have
considerable knowledge of their pipeline to support routine operations and
maintenance, but this information may be distributed throughout the company, in
possession of groups responsible for individual functions. Operators must
assemble this information to the extent necessary to support development and
implementation of their IM program. PHMSA recognizes that there may be gaps
in the knowledge an operator has when it develops its initial IM plan. Operators
must identify these gaps and the additional information needed to improve their
understanding. Operators are required to provide a plan for gaining that
information over time through its normal activities of operating and maintaining
their pipeline (e.g., collecting information about buried components when
portions of the pipeline must be excavated for other reasons). Operators must
also develop a process by which the program will be periodically reviewed and
refined, as needed.
Therefore, as part of our investigation of PG&E records-related violations, PWA has included, based
on existing regulations and practice, a discussion of the Standard of Care the regulator and the public
has a right to expect from a prudent operator of gas distribution pipelines. This discussion is presented
as Attachment D to this report.
29
36
PG&E Initial Report in Response to OII (OII.14-11-008), December 22, 2014.
37
49 CFR 192 Subpart PGas Distribution Pipeline Integrity Management (IM), page 63906 Federal Register /
Vol. 74, No. 232 / Friday, December 4, 2009 / Rules and Regulations.
26
Table 3 Time Line for Map and Record Requirements

Date
Records-Related Event
07/01/1932 California Railroad

Commission GO 58A
(effective date of third
revision initial version
effective September 1, 1919)
1955
ASA B31.1.8-1955
1958
ASA B31.8-1958
Regulatory Requirement
3. System Maps and Records
a. Each gas utility shall keep on file with the Commission up-todate maps of the general territory, which it holds itself in readiness
to serve, outlining operating districts and showing major
transmission lines.
b. A suitable map or maps shall be kept on file in the principal
office of each division or district. Maps shall at all times show the
size, character and location of each street main, district regulator,
operating valve and drip, and when practicable, each service
connection in the corresponding territory served. In lieu of
showing service locations on maps, a card record or other suitable
means may be used.
c. In each division or district office there shall be available such
information relative to the distribution system which will enable
the local representatives at all times, to furnish necessary
information regarding the rendering of service to existing and
prospective customers.
20. Pressure Testing Equipment and Tests
(c) On low pressure distribution systems each gas utility shall
during the six months of the peak season of the year make at least
one 24-hour record of pressure each week at the outlet of
customer's meters for each one hundred (100) miles or less of
distribution main in each district or separate distribution system.
Such records shall be filed and retained as a continuous record
for a period of at least two calendar years in the principal office of
each district or division. there may be substituted an equal
number of twenty-four (24) hour records from recording pressure
devices permanently located at critical points on the distribution
system.
(d) On high pressure distribution systems gas utilities shall
maintain permanently located pressure gauges at critical points
and shall preserve in the district or division offices the charts from
these gauges as a continuous record for a period of at least two (2)
years.
850.3 Basic Requirements - Each operating company having gas
transmission or distribution facilities within the scope of this code
shall (a) Have a plan covering operating and maintenance
procedures in accordance with the purpose of this code. (b)
Operate and maintain its facilities in conformance with this plan.
(c) Keep records necessary to administer the plan properly.
850.3 Basic Requirements - Each operating company having gas
transmission or distribution facilities within the scope of this code
shall (a) Have a plan covering operating and maintenance
27
Date
01/17/1961 CPUC GO 112 (effective

07/01/1961)
01/17/1961 ASA B31.8-1958
08/19/1970 49 CFR Part 192
procedures in accordance with the purpose of this code. (b)
Operate and maintain its facilities in conformance with this plan.
(c) Keep records necessary to administer the plan properly.
Sec. 107 Compliance with ASA Code; 107.1 Gas transmission and
distribution facilities shall be constructed and operated in
compliance with the provisions of Section 8 of the American
Standard Code for pressure piping, known as the American
Standard Code for Gas Transmission and Distribution Piping
Systems, ASA B 31.8-1958, and in compliance with the further
requirements of the additional rules herein prescribed.
Sec. 301 General: 301.1 The responsibility for the maintenance of
necessary records to establish that compliance with these rules has
been accomplished rests with the utility. Such records shall be
available for inspection at all times by the commission or the
commission staff.
Sec. 302 Specifications: 302.1 Specifications for material and
equipment, installation, testing and fabrication shall be maintained
by the utility.
Sec. 303 Operating and Maintenance Procedures:
303.1 Plans covering operating and maintenance procedures,
including maximum actual operating procedures to which the line
is intended to be subjected, shall be maintained by the utility.
303.2 No pipeline shall be operated in excess of the maximum
operating pressure recorded by the company in accordance with
this section.
850. O&M; 850.3 Basic Requirements - Each operating company
having gas transmission or distribution facilities within the scope
of this code shall (a) Have a plan covering operating and
maintenance procedures in accordance with the purpose of this
code. (c) Keep records necessary to administer the plan
properly.
Incorporated by CPUC GO 112-C (01/12/71)
192.13 (a) No person may operate a segment of pipeline that is
readied for service after March 12, 1971, unless that pipeline had
been designed, installed, constructed, initially inspected, and
initially tested in accordance with this part.
(b) No person may operate a segment of pipeline that is replaced,
relocated, or otherwise changes after November 12, 1970, unless
that replacement, relocation, or change has been made in
accordance with this part.
(c) Each operator shall maintain, modify as appropriate, and
follow the plans, procedures and programs that it is required to
establish under this part.
192.517 Records - Each Operator shall make and retain for the
useful life of the pipeline a record of each test performed under
192.505 and 192.507 (strength testing). The record must
28
Date
12/04/2009 49 CFR Part 192 (DIMP-
contain at least the following information:
(a) Operator information (described)
(b) Test medium used
(c) Test pressure
(d) Test duration
(e) pressure recording charts or other records of pressure readings
(f) Elevation variations
(g) Leaks and failures noted and their disposition
192.603(b) Each operator shall establish a written operating and
maintenance plan meeting the requirements of this part and keep
records necessary to administer the plan.
192.605 Each operator shall include the following in its O&M
plan: (a) Instructions for employees covering operating and
maintenance procedures during normal operations and repairs.
192.613(a) Each operator shall have a procedure for continuing
surveillance of its facilities to determine and take appropriate
action concerning changes in class location, failures, leakage
history, corrosion, substantial changes in cathodic protection
requirements, and other unusual operating and maintenance
conditions.
192.613(b) If a segment of pipeline is determined to be in
unsatisfactory condition but no immediate hazard exists, the
operator shall initiate a program to recondition or phase out the
segment involved, or, if the segment cannot be reconditioned or
phased out, reduce the maximum allowable operating pressure in
accordance with 192.619 (a) and (b).
192.617 Investigation of Failures Each operator shall establish
procedures for analyzing accidents and failures, including the
selection of samples of the failed facility or equipment for
laboratory examination, where appropriate, for purpose of
determining the causes of the failure and minimizing the
possibility of a recurrence.
192.619(c) Notwithstanding the other requirements of this
section, an operator may operate a segment of pipeline found to be
in satisfactory condition, considering its operating and
maintenance history , at the highest actual operating pressure to
which the segment was subjected during the 5 years preceding
July 1, 1970, subject to the requirements of 192.611 (changes in
class location).
192.621(a) No person may operate a segment of a high pressure
distribution system at a pressure that exceeds the lowest of the
following pressures, as applicable:
(5) The pressure determined by the operator to be the maximum
safe pressure after considering the history of the segment;
particularly known corrosion and the actual operating pressure.
192.1007 What are the required elements of an integrity
29
Date
2006
related requirements)
management plan?
A written integrity management plan must contain procedures for
developing and implementing the following elements:
(a) Knowledge. An operator must demonstrate an understanding of
its gas distribution system developed from reasonably available
information.
(1) Identify the characteristics of the pipeline's design and
operations and the environmental factors that are necessary to
assess the applicable threats and risks to its gas distribution
pipeline.
(2) Consider the information gained from past design, operations,
and maintenance.
(3) Identify additional information needed and provide a plan for
gaining that information over time through normal activities
conducted on the pipeline (for example, design, construction,
operations or maintenance activities).
(4) Develop and implement a process by which the IM program
will be reviewed periodically and refined and improved as needed.
(b) Identify threats. The operator must consider the following
categories of threats to each gas distribution pipeline: corrosion,
natural forces, excavation damage, other outside force damage,
material or welds, equipment failure, incorrect operations, and
other concerns that could threaten the integrity of its pipeline. An
operator must consider reasonably available information to
identify existing and potential threats. Sources of data may
include, but are not limited to, incident and leak history, corrosion
control records, continuing surveillance records, patrolling
records, maintenance history, and excavation damage experience.
4216.3 (a) (1) Any operator of a subsurface installation who
receives timely notification of any proposed excavation work in
accordance with Section 4216.2 shall, within two working days of
that notification, excluding weekends and holidays, or before the
start of the excavation work, whichever is later, or at a later time
mutually agreeable to the operator and the excavator, locate and
field mark the approximate location and, if known, the number of
subsurface installations that may be affected by the excavation to
the extent and degree of accuracy that the information is available
either in the records of the operator or as determined through the
use of standard locating techniques other than excavating,
otherwise advise the person who contacted the center of the
location of the operator's subsurface installations that may be
affected by the excavation, or advise the person that the operator
does not operate any subsurface installations that would be
affected by the proposed excavation.
California Government Code

4216
30
1
2
3
Attachment C to this report provides a list of current requirements and provisions of the CPUC code,
Commission general orders, applicable rules or requirements or other state or federal laws pertaining to
pipeline safety recordkeeping that are applicable to PG&Es natural gas distribution system.
4.4
General Recordkeeping Requirements
5
6
7
8
9
10
11
12
The six incidents identified in the OII and listed in Table 1 all stem from PG&E or excavator actions
undertaken in the light of imperfect maps and records caused by deficient recordkeeping practices.
PG&E practices have been deficient given the requirements that a prudent operator is expected to
meet. (For a discussion of the concept of appropriate standard of care see Section 6 and Attachment
D.) This is supported by the report by Duller and North discussed above. Although focusing on
PG&Es Gas Transmission Line records, Duller and North in its report (dated March 5, 2012) on
records management following the San Bruno fire and explosion, states that the reports findings are
also referenced against PG&Es corporate approach to records management.38
13
14
15
16
17
18
19
20
21
22
23
24
Historically, mapping and recordkeeping requirements for utilities have been mandated by the CPUC
in General Orders 58 and 112. Over the years the recordkeeping requirements in these orders have
been periodically updated, with the most recent requirements provided in General Orders 58A and
112-E and 112-F. The Research and Special Programs Administration (RSPA) the federal agency
that preceded the Pipeline and Hazardous Materials Safety Administration (PHMSA) in regulating
pipeline safety - in addressing the need that gas company system maps and records be maintained
accurately to identify the locations, size, and operation[al] pressure of all their pipelines39 also requires
that all gas and hazardous liquid pipeline operators must maintain an operating and maintenance plan
that includes procedures for making construction records, maps, and operating history available to
appropriate operating personnel to enable them to safely and effectively perform their duties (49 CFR
192.605). CPUC General Orders are routinely updated to incorporate and often to exceed the most
recent federal requirements.
25
26
27
28
29
30
31
32
33
34
35
PWAs investigation, which has focused on evaluating recent incidents in which records imperfections
were the underlying causes, found that PG&E has had a series of procedures in place to comply with
CPUC mapping and recordkeeping requirements. Those procedures required each Division to
establish and maintain maps and records for its gas distribution lines.40 PG&E procedures required
each Division to maintain maps and records that provided details of its gas distribution lines on plat
maps, gas service records and file folders on sections of distribution mains. However, PG&E and
Division records management procedures inadequately detailed which records needed to be retained
and maintained to demonstrate compliance with general order requirements, California Laws, and gas
pipeline safety requirements. As a result an evolving set of PG&E record retention procedures focused
more on which records could be destroyed rather than on required records and their retention
requirements.
36
37
38
39
40
PG&Es records retention procedures were inconsistently followed, resulting in map plats becoming
outdated; containing incorrect and incomplete information. Key pipeline history records and files were
lost, misplaced and/or inadvertently destroyed. Plats maps have been found to be incomplete or
misleading because they do not contain up to date information on the location, nature, diameter and
material of current lines. Examples of such incomplete or misleading information are described in the
38
Docket: I. 11-02-016 Exhibit 2, page 1-7, lines 28-31.
39
Advisory Bulletin 02-03 - Federal Register Volume 67, Number 114 [Pages 40768-40770] (June 13, 2002) 2nd
paragraph Page 40769.
40
As discussed in the report by Duller and North, many of PG&Es current procedures and standards apply to
both gas transmission and gas distribution.
Page 31
1
2
3
4
discussion below concerning the six incidents in the OII as well as those in Tables 2 and 4. These
imperfections and missing or misleading information on maps and records include those associated
with inserted gas service lines and inserted gas mains, stub services, and records to substantiate the
MAOP of lines consistent with the initial 1970 requirements in 49 CFR Part 192.
5
6
7
8
9
Some plat maps have been found to contain lines that do not exist, and exclude gas lines that do exist.
Until recently, plat maps were the primary means by which field crews located gas lines in support of
marking to prevent excavation damage, leak detection and identification of needed repairs. PG&E is
currently pursuing a program to update maps and records as well as to make them more accessible to
crews in the field.
10
11
12
13
14
15
16
17
Current procedures used to locate and mark (L&M) gas lines use plat maps as secondary or tertiary
guidance rather than the primary source on line location by locate and mark (L&M) crews. The PG&E
procedures require L&M crew actions to rely on tracking frequencies techniques by electrically
directly connecting to gas lines and locating wire, or to indirectly induce a signal frequency to track,
locate and mark out gas lines within the scope of proposed excavations. Because of occasional
difficulty or inability to track such frequencies due to signal jumping, broken or missing locating wire,
or long distances from direct connections to the area to be marked, gas lines are occasionally
mismarked or not marked at all rather than basing markings solely on information in maps.
18
19
20
The following current General Orders and code sections were found to apply to the six incidents
identified in the OII. A more complete set of requirements to which PG&E records practices are
subject is shown in Attachment C.
21
22
23
24
25
26
27
1. General Order 58A (December 16, 1992) - Section 3. (b) A suitable map or maps shall be kept on
file in the principal office of each division or district. Maps shall at all times show the size,
character and location of each street main, district regulator, operating valve and drip, and when
practicable, each service connection in the corresponding territory served. In lieu of showing
service locations on maps, a card record, a computerized system, or other suitable means may be
used.
28
29
30
31
2. General Order 112-E (August 21, 2008) Section 101.4 The utilities shall maintain the necessary
records to ensure compliance with these rules and the Federal Pipeline Safety Regulations, 49 CFR
Part 192, that are applicable. Such records shall be available for inspection at all times by the
Commission or Commission staff.
32
33
34
3. 49 CFR 192.605(a) (November 11, 1970) - Each operator shall prepare and follow for each
pipeline, a manual of written procedures for conducting operations and maintenance activities and
for emergency response.
35
36
37
4. 49 CFR 192.605(b) (November 11, 1970) - Maintenance and normal operations. The manual
required by paragraph (a) of this section must include procedures for the following, if applicable, to
provide safety during maintenance and operations.
38
39
(3) Making construction records, maps, and operating history available to appropriate operating
personnel.
40
41
42
(8) Periodically reviewing the work done by operator personnel to determine the effectiveness, and
adequacy of the procedures used in normal operation and maintenance and modifying the
procedures when deficiencies are found.
43
44
5. 49 CFR 192.13(c) - Each operator shall maintain, modify as appropriate, and follow the plans,
procedures, and programs that it is required to establish under this part.
Page 32
1
2
3
4
5
6
7
8
6. Advisory Bulletin - ADB-02-03 Gas and Hazardous Liquid Pipeline Mapping - RSPA41
identified the need for accurate maps of pipeline systems in this Advisory Bulletin and stated that
pipeline operators should review their information and mapping systems to ensure that the operator
has clear, accurate, and useable information on the location and characteristics of all pipes, valves,
regulators, and other pipeline elements for use in emergency response, pipe location and marking,
and pre-construction planning. This includes ensuring that construction records, maps, and
operating history are readily available to appropriate operating, maintenance, and emergency
response personnel.
9
10
11
7. NTSB42 - Safety Recommendation P-87-34 urged RSPA to revise the pipeline safety regulations
to require that gas company system maps and records be maintained accurately to identify the
locations, size, and operating pressure of all their pipelines.
12
13
14
15
8. NTSB - Safety Recommendation P-97-19 emphasized the need for RSPA/OPS to ``develop
mapping standards for a common [pipeline] mapping system, with a goal to actively promote its
widespread use.'' NTSB recommends that pipeline mapping should consider the amount of detail
and the accuracy of information necessary for effective use.
16
17
18
The ADB and NTSB recommendations, though not included in actual gas safety code requirements,
are advice and indicative of what RSPA/OPS (now PHMSA) as well as NTSB expect operators to
achieve.
19
41
OPS, the Office of Pipeline Safety and RSPA, the Research and Special Programs Administration are both
predecessor agencies to PHMSA, the Pipeline Hazardous Materials Safety Administration of the US Department
of Transportation.
42
These NTSB recommendations resulted from a series of accidents in which a lack of accurate maps played a
role.
Page 33
1
2
5.
FACTORS CONTRIBUTING TO RECORDKEEPING-RELATED

INCIDENTS AND VIOLATIONS
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
The underlying cause of the six incidents in the OII are failures in record keeping, most commonly
related to PG&Es failure to include records of maintenance and other changes to its facilities
subsequent to the original installation. As discussed in Section 6.1 in this report, of the six incidents in
the OII, two were caused by not having accurate records of mains or services that that had plastic
inserted into existing steel or other pipe materials. One of the remaining four incidents was caused by
stubs not being mapped on existing maps and current records used by L&M43 technicians/personnel.
Since the stub was not on the maps the L&M crew was not seeking to mark out the unknown line and
the stub was not marked as part of the L&M process. Unmarked stubs represent a records issue due to
inaccurate or faulty mapping following a maintenance activity (e.g., partial removal or retirement of a
portion of a service which was then listed as totally retired to the main and removed from the map and
possibly from the records themselves). One of the remaining three incidents was caused by a field crew
doing a routine tie in not checking the position of an isolation valve. The valve was noted on the map
as open when in reality it was closed thus causing loss of gas supply to nearly 1,000.44 Of the
remaining two incidents, one was caused by a mismark and one incident was due to a faulty map that
did not show an electronic test station45 (ETS) close to a service that needed to be located. The L&M
technician used an ETS located a considerable distance away, and the signal used to locate the pipe
was either too weak or associated with the wrong facility. Thus, the locate was not accurate causing an
excavator to damage the service and leading to a gas release.
21
22
23
24
25
For the plastic inserted steel mains and service incidents, for which the plastic inserts were made in
the 1980s and 1990s based on the manufacturing date of the inserted plastic, the maps were never
updated to reflect the inserts. More recently46 a SED inspection discovered plastic mains and/or
services - inserted, in 2013 and 2014 that were not shown on maps as of August 2015. These
inspections are discussed in Section 8.1.
26
27
28
29
30
31
32
33
34
35
The incidents in the OII - consisting of mis-mapped or unmapped stubs off a main - highlights a major
source of marking errors that have caused damage by third parties (as well as PG&E crews) when
doing work adjacent to or on the existing mains. These unmarked stubs were initially thought by
PG&E to be rare but are located throughout the service territory.47 PG&E has recently completed
collecting available data in each of its 18 division regarding service stubs.48 Initially PG&E thought
that there were on the order of 17,000 stubs but checking records in additional divisions has increased
the known total of identified stubs to more than 71,000. These are just the known stubs and, as
indicated in recent incidents, there are certainly additional unknown stubs. The stub for the incident in
the OII was not shown on the map and it was thought that it had been cut off at the main and not at or
near the property line.
43
L&M stands for locate and mark, the people who complete USA tickets to identify gas line locations at
excavation sites and thereby help prevent outside force damage on underground facilities.
44
PG&E only started requiring clearances for distribution work in either late 2014 or early 2015, see the
responses to SED DR 004-Q79 through DR 004-Q82.
45
This particular test station is a location to attach a locating device onto a tracer wire or connect to the main.
46
In July and August of 2015 the SED performed a records/mapping audit in the San Jose and San Francisco
Divisions of PG&E and found over 9% of the services that had plastic inserts were not mapped in a reasonable
period of time that is several months.
47
See response to DR SED 003-Q52. 71,131 is the most recent count of stubs in the 18 PG&E districts as of
9/3/15.
48
PG&E supplementary 1 response to SED-003-Q52, 09/09/15.
Page 34
1
2
3
4
5
6
7
8
Until recently, PG&E had a policy that when a stub could not be located it would be eliminated from
the map and from the related records. An internal audit investigation49 in one division found that a
foreman/supervisor had reported doing excavations to locate a stub and not finding anything. These
excavations were never conducted, but since the policy was to remove the record of the stub from the
map based on locating it via excavation, the stub was apparently removed from the map. PG&E did not
check other foreman/supervisors and we are not sure whether it checked other records on the
individual who may have claimed to be unable to find other stubs. Since this may not be an isolated
occurrence,50 there could be more stubs that were erroneously removed from maps.
9
10
11
12
13
14
Another contributing factor in having unmapped stubs is that PG&Es policy on stubs contributes to
their existence in the first place. PG&E can essentially have a stub forever since known stubs are only
reviewed periodically and then if there is any chance of it being needed in the future, removal is not
scheduled. There does not appear to be a formal program to remove stubs (cut them back to the main)
after certain timeframe, thus stubs appear to be rarely removed although, as noted above, in at least one
instance, a stub has inappropriately been deleted from the maps.51
15
16
17
18
19
20
21
22
23
24
25
26
When federal regulations for pipeline safety were first proposed and issued for comment in the late
1960s, there were explicit requirements for how to determine the safe operating pressure on pipelines
and mains. These requirements included having valid pressure tests. Industry requested, and was
granted a so called grandfather provision, a five year window looking backward from the
implementation date of the regulations (1970 back to 1965) for those operators that did not have
records of a pressure test on which to base the MAOP. This grandfather provision was allowed based
on pressure records only for a onetime window. PG&E did not have all of the requisite pressure
records. Lacking records required by the new 49 CFR Part 192 regulations, PG&E developed its own
approach to establish the MAOPs of grandfathered systems. This approach included using either
certification by individuals or pressure records from the mid and late1970s as the basis. Using its
alternative approach, PG&E established the MAOP for approximately 243 of its 1,376 hydraulically
independently distribution systems by 1979.
27
28
29
30
31
32
33
34
35
Neither certification by individuals or use of pressure records from the 1970s was consistent with the
regulations. To date, PG&E has not identified any interaction with its regulator to discuss and request
approval to validate its alternative approach to establishing MAOP. A Data Request52 to obtain copies
of all correspondence relating to these systems shows that the SED only became aware of the issue
during an audit in 2014. PG&E has stated that they will continue to search their records to see whether
there is evidence of earlier correspondence with the CPUC on the issue and their approach to
addressing it. Additional discussion of the map and records issues contributing to incidents is
presented in Attachment E. The examples in Attachment E were derived from a review of PG&E CAP
reports provided in response to SED-001-Q12.
49
See responses to DR SED 001-Q12 Supplemental 01, Bates Nos. GDR 00007486 and 00007572 aka File 05047 and 05-052 (5B5-2650 and 1B5-1394) in San Rafael.
50
As reported in the SFGate, December 25, 2011 in an article titled PG&E incentive system blamed for leak
oversights, Jaxon Van Derbeken, several foreman/supervisors and others in the late 2000s were found to be
falsifying leak test and repair records.
51
Incident in San Francisco (04/08/14)

(See Table 2) active main and service not marked in
area of excavation, inactive pipe (6 away) marked, service between marked & unmarked mains was damaged.
Based on review of mapping standard 410.21-1 (effective 04/01/77) it appears (Section II.3) that PG&Es policy
was to remove abandoned mains from plat sheets, but that local variations in that policy may exist. Removal of
abandoned in place mains from their maps can lead to confusion of L&M personnel and excavators when they
uncover such facilities which they assume are the ones that were located and are accurate.
52
See response to SED DR 004-Q86.
Page 35
6.
2
3
4
5
The focus of the OII was on a specific set of six incidents. These incidents are summarized in Table 1.
PG&E has admitted that it violated title 49 CFR 192.605(b) regarding the Mountain View incident.53
In PG&Es letter dated April 4, 2014, Sumeet Singh of PG&E wrote the following to Michael
Robertson of the Safety and Enforcement Division:
6
7
EVIDENCE OF NON-COMPLIANCE
In its letter, the SED found PG&E in violation of Title 49 of the Code of Federal
Regulations Part 192.605(b). PG&E agrees with this violation.
8
9
10
11
12
13
In our investigation PWA considered violations associated with those six incidents, and looked further
at other records-related violations including: those associated with other incidents, those arising from
consideration of the relationship between two of the OII incidents, and those associated with the
acknowledged fact that PG&E lacking the necessary records - has established the MAOP for 243 of
its 1,376 hydraulically independent distribution systems using a procedure that is different from that
required by 49 CFR 192.619(c).
14
15
16
17
18
19
20
21
22
23
24
In its initial response to the OII,54 PG&E has acknowledged that its maps and records include errors
and omissions that they have referred to as imperfections.55 It also asserts that the problem of
imperfect maps and records exists throughout the pipeline industry, but is especially intractable at a
utility as large as PG&E. Furthermore, as also described in its initial response to the OII,56 PG&E has
undertaken major efforts both to correct these imperfections and to put in place backstop measures to
minimize the risk associated with these acknowledged imperfections. However, since PG&E has
avoided implying that these efforts will eliminate all imperfections,57 it is possible that incidents
caused by map and record imperfections will continue to occur. Given acknowledged imperfections in
PG&E distribution maps and records, which wording in the Distribution Integrity Management
Program regulation (DIMP)58 also acknowledges as existing throughout the industry, we will identify
the basis for citing non-compliances related to these imperfections.
25
26
27
28
29
30
31
32
33
34
As applied to pipelines, utilities are required to demonstrate compliance with applicable regulatory
requirements, and should adhere to industry best practices employed in assuring compliance. It could
be argued that violation of the standard of care for pipeline operators should include an incident or
accident directly linked to non-compliance with applicable regulatory requirements, or non-adherence
to industry best practices employed in assuring compliance. Because pipeline safety regulations
include a threshold for reporting of incidents and accidents to the safety regulatory authority, events
satisfying these thresholds provide one reasonable basis for evaluating operator conformance with the
standard of care. In addition, repeated non-compliance with regulatory requirements also may
demonstrate that the standard of care is not being met, even though there is not a reportable incident or
accident.
35
36
37
The reality that current maps and records may be inadequate to support effective integrity management
does not relieve the utility of its responsibility to operate its facilities safely. While many violations
are framed in terms of failure to comply with state and federal regulations, the actions underlying this
53
See letter Sumeet Singh (PG&E) to Michael Robertson (SED), April 4, 2014, Attachment G to this report.
54
55
PG&E managers responses to Interrogatories under Oath #3 (Response of John Higgins), #9 (Response of
Sumeet Singh), and #15 (Response of Raymond Thierry), August 24, 2015.
56
57
PG&E response to SED-003-Q50, July 1, 2015.
58
Subpart P of 49CFR Part 192, issued December 4, 2009.
Page 36
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2
failure also constitute violations of PG&Es obligation to furnish such services necessary to promote
the safety, health, comfort, and convenience of its patrons, employees, and the public.59
3
4
5
6
7
8
To understand how this might translate to pipeline operation we should consider the regulations, which
as noted in California Public Utilities Code Section 451, represent the minimum requirements for safe
operation. As it relates to maps and records, there are two elements to consider, both driven by
regulations: (1) what information should be retained in an accessible form to support operations and
maintenance, and (2) what process should be employed to address the acknowledged imperfections in
maps and records.
9
10
An operator is required to ensure the safety, health, comfort, and convenience of its patrons,
employees, and the public.60 This is demonstrated by three observables:
11
1. The absence of impactful events evidenced by the utilitys operation;
12
13
2. Rigorous application of root cause analysis to understand and support correction of

contributors to impactful events; and
14
15
3. Ongoing operation in which zero defects are evidenced in the utilitys maintenance of
maps and records.
16
17
This report has included all three of these observables in its evaluation of information to identify
violations.
18
6.1
Violations Associated with the Six OII Incidents
19
20
21
22
23
24
This section discusses violations associated with the initial six incidents. The following section
considers the other three sources of records-related violations: those associated with other incidents,
those arising from consideration of the relationship between two of the OII incidents, and those
associated with the acknowledged fact that PG&E lacking the necessary records - has established the
MAOP for 243 of its 1,376 hydraulically independent distribution systems using a procedure that is
different from that required by 49 CFR 192.619(c).
25
26
The initial focus of our evaluation of the six OII incidents is on investigating whether accurate
information necessary to prevent impactful events has been retained and is accessible.
27
28
29
30
31
32
33
34
35
1.
36
37
38
39
40
41
2. Main Street, Morgan Hill, 06/21/12 Third party contractor (directional bore installing a water
line) damaged a diameter 60 psig service stub not marked by locate and mark personnel. The
stub was on record map, not on 5 year stub review program, once identified as stub, to be removed
within a year per TD9500P-16. PG&E received a valid USA notification. The 1951 service line
was cut at property line in 1966, and in 46 years PG&E had not cut the stub off at the main. The
L&M crew noted service on plat map, did not find service riser, presumed service was previously
Castro Valley 09/17/10 Third Party Damage due to PG&E Mapping

error (contractor for municipality excavating for a new storm drain), PG&E locate and mark
(L&M) personnel did not accurately mark out the 1 diameter 60 psig service line, had incorrect
field documentation from historical gas service records, the maps and records did not indicate a
service should be at that location. PG&E did not follow: its standard UO S4460 to keep their maps
updated and accurate, 49 CFR 192.13(c), 49 CFR 192.605(a). Our review of the information
provided as well as CPUC SEDs investigation found PG&E in violation of not providing up to
date maps of its facilities, 49 CFR 192.605(b)(3). Following the damage to its service line,
PG&E corrected its map and gas service record.
59
Cal. Pub. Util. Code 451.
60
Page 37
1
2
3
4
5
6
7
8
9
10
cut off, did not mark stub in field; This is a violation of California Government Code 4216.3.(a)(1).
The L&M crew did not follow its mark-out procedure - Damage Prevention Handbook TD-5811M
did not communicate with excavator. L&M personnel stated he mentioned to supervisor that it was
difficult to manage current mark out workload, possible violation of California Public Utilities
Code Section 961 d(10). PG&E did not follow its standard to keep their maps and records updated
and accurate. Our review of the information provided as well as SEDs investigation found PG&E
in violation of: not providing up to date operating history of its facilities to appropriate personnel
(L&M personnel), 49 CFR 192.605(b)(3), and not following its procedures 49 CFR 192.605(a).
PG&E has reported a number of incidents and events involving stubs under its corrective action
program (CAP).61
11
12
13
14
15
16
17
18
19
20
21
22
23
3. Montague Expressway and Great Mall Parkway, Milpitas, 10/10/12 The operating position of a
2 diameter 60 psig valve on PG&Es map did not indicate it was closed. Field crews presumed
the valve was open and during the main shutdown process, crew did not verify the valve was in the
open position, relied on the map, resulting in pressure in the line dropping below that required for
safe operation of the system and a gas outage to 987 customers, a violation of 49 CFR 192.605(a).
PG&E was in violation of 49 CFR 192.605(b)(3) - for having a map with the incorrect valve
position (map indicated open and it had been previously closed). The Gas operating personnel did
not verify the position of the valve to ensure a gas supply from that direction. PG&Es pressure
and capacity SynerGEE model for that area shows back feed, which can only occur when the valve
is in the open position, would be sufficient to supply customer demand during the maintenance
activity. Who had closed the valve, when this occurred, and why it was left in the closed position
without notifying mapping to correct its map was not determined. At the time PG&E did not have
any type of clearance procedure for gas distribution.
24
25
26
27
28
29
PG&E standards A-93.1, D-S0454 - PG&E did not assign personnel to monitor the pressure to
verify minimum safe operating pressure was being maintained during the work activity (main
shutdown - isolation and tie-in associated with replacing 6steel with 4 plastic main). PG&E did
not follow the guidance concerning the nature of its valves on its maps as indicated in RSPA
Advisory Bulletin ADB-02-03 issued June 13, 2002. A summary of the advisory bulletin is
provided as follows.
30
ADB-02-03 Pipeline Safety: Gas and Hazardous Liquid Pipeline Mapping
31
32
33
34
35
36
37
38
39
40
SUMMARY: The Research and Special Programs Administration's (RSPA) Office

of Pipeline Safety (OPS) is issuing this advisory to gas distribution, gas
transmission, and hazardous liquid pipeline systems. Owners and operators
should review their information and mapping systems to ensure that the operator
has clear, accurate, and useable information on the location and characteristics
of all pipes, valves, regulators, and other pipeline elements for use in emergency
response, pipe location and marking, and pre-construction planning. This
includes ensuring that construction records, maps, and operating history are
readily available to appropriate operating, maintenance, and emergency response
personnel.
41
42
43
44
PG&E has developed a distribution clearance procedure as part of D-S0454 and A93.1 to ensure
such non-emergency valve positions are checked for their position and validated during shutdowns
or tie-ins. As part of its new gas distribution control center, the GDCC now monitors the process
for such tie-in activities and ensures valve positions are verified and actions taken to monitor
61
See PG&E response to SED Q-12 Supplement 3 Bates 30404, 30453, 30530, 30891.
Page 38
1
2
pressures during work activities. The use of gas clearance form WCD 8000 started in 2013-2014,
(no date is on the form) for taking out of service (shutting down) and hotting up a main.
3
4
5
Currently, a clearance decision is made by Gas Distribution Control Center in cooperation with
Field Engineer on what steps are required, approximately 10 days before application for gas
clearance. This was previously made at the Division level.
6
7
8
9
10
11
12
13
14
15
16
17
4. Great Mall Parkway, Milpitas, 03/04/13 Third party contractor installing a storm drain damaged
a 2 diameter 60 psig plastic main. The damage was caused by a PG&E mapping error; the map
had not been updated to show the nearest electronic test station (ETS) installed in 1994. Had the
ETS been known to the L&M personnel, they would have been able to connect their locate tool to
the nearby tracer wire thereby improving the accuracy of their locate signal to better locate the gas
main. As a result, the L&M crew mismarked the 2 diameter plastic main by 6 feet. L&M crew
did not use the map for locating and instead elected to use an ETS some distance away resulting in
the mismark and excavation damage. PWA determined that PG&E was in violation of 49 CFR
192.605(b)(3) - for not providing its construction records, maps and operating history to its L&M
crew (the map had not been updated with the location of the nearest ETS installed 1994).
Following the incident, PG&E processed a map change request to update the plat map to include
the missing ETS.
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
5. Charleston Road, Mountain View, 07/30/13 PG&E field crew welded a tapping fitting on a
vintage 1947 1 diameter service line casing. Unknown to the welding crew, the 1 service
line had previously been inserted with 1 diameter 60 psig plastic.62 The welding on the 1 steel
service casing line damaged and/or melted the plastic insert resulting in a gas leak and hazardous
condition. Neither the plat map nor construction documents indicated the 1947 1 service had
been previously inserted with plastic sometime during 1970-1972 (PG&E response indicated the
line was inserted sometime between 1972-1980). PWA determined that PG&E was in violation of
49 CFR 192.605(b)(3) - for not providing its construction records, maps and operating history to
its welding crew (the map had not been updated with the plastic insert information). USDOT
advisory bulletin June 13, 2002 ADB-02-03 states that operator maps should provide: diameter,
pipe grade, material wall thickness. Welding on a previously inserted line is a hazardous situation
that could easily have resulted in a fire, injuries or worse. Yet, according to the information
provided PWA, PG&E issued no stand down to its employees or even an advisory to its workers
companywide of the dangers that this lack of accurate map and or records could happen again, and
to check and verify whether the lines were inserted prior to working on them. PWA determined
that PG&E was in violation of 49 CFR 192.605(a) and 192.617 for not following its procedures
and failing to determine the cause of the failure and minimize the possibility of a recurrence. It is
unclear how many similar events had occurred prior to this incident in which service line or main
inserts were not accurately reflected on PG&Es maps and records, and yet PG&E took no
proactive actions to update its maps and or warn its workers.63 PG&E did indicate in response to
SED-004-Q70 that it fixed the specific problem and looked for other similar situations. Certainly
as part of PG&Es investigation of failures following the Mountain View incident, these issues
should have been identified and communicated as a caution to other gas operations personnel.
62
PG&E response to the OII, page 5 footnote indicates this was a plastic inserted in 1970. The plastic insert
was vintage 1972 plastic NIPAK TR 418, which leads one to believe it was installed sometime in 1972 or
thereafter.
63
Since the Mountain View and Carmel unknown plastic insert incidents, PG&E reported that other unmapped
service inserts have been reported under the corrective action program, see PG&E response to SED DR Q-12
Supplement 3 Bates 30499 for
, Selma.
Page 39
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
6. Guadalupe Street and 3rd Avenue, Carmel 03/03/14 In preparing to tie-in new plastic mains
installed in the area, a PG&E general construction field crew welded and tapped into a Mueller
tapping tee onto what they believed was a 2 diameter steel main. Unknown to the construction
crew, the 2 service line had previously been inserted with 1 diameter 52 psig plastic
(manufactured 07-17-1997). The general construction crew was not aware they had tapped into an
inserted plastic gas main causing a hazardous situation until the M-2 line stopper tapping tool
removed both metal and plastic coupons cut from the steel casing and live plastic gas main. PG&E
maps did not show that the line had been previously inserted, resulting in hazardous gas leaking
and migrating, including a house explosion. PG&E personnel reacted poorly to the abnormal
operating condition and emergency, and were ill-prepared to rapidly shut down or isolate the
damaged inserted main, especially since PG&E had outdated maps and did not know the extent of
the inserted gas mains in the area. PWA determined that PG&E was in violation of a number of
code requirements, but will cite here the ones associated with recordkeeping and its failure to
prevent a recurrence of creating an unsafe condition by welding on an inserted line. PWA
determined that PG&E was in violation of 49 CFR 192.605(a) for failure to follow its procedures
and update its maps and records following the 199764 1 plastic main insertion, and 49 CFR
192.617 for not following its procedures and failing to determine the cause of the Mountain View
accident and minimize the possibility of a recurrence. PWA determined that PG&E was also in
violation of 49 CFR 192.605(b)(3) for failure to provide its crews with accurate records and maps
in performing their duties.
21
22
23
24
25
Following the house explosion in Carmel associated with this event, PG&E implemented a several
week stand down of its workforce. Subsequently, the Gas Carrier Pipeline Checklist was
introduced at field crews tailboard meetings across the company. The field crews follow the Gas
Carrier Checklist to verify that field condition matches records. If not, the job is stopped. The
checklist was developed to check for presence of an inserted line not indicated on map.
26
27
28
29
30
31
Additionally, as part of the tie-in process and prior to welding on a gas line suspected of being
inserted, PG&E now requires installation and tapping of a bolt-on mechanical tapping tee. The tee
has a built in hard stop so it does not travel into the gas line far enough to pierce the plastic if the
line has previously been inserted and not mapped or not on record. The cutter, while not a drill bit,
can still damage the inserted plastic but does not result in a leak while allowing the crew to identify
the presence of inserted plastic.
32
6.2
Additional PG&E Violations Identified during the Investigation
33
34
35
36
37
Other potential records-related violations including: those associated with other incidents, those arising
from consideration of the relationship between two of the OII incidents, and those associated with the
acknowledged fact that PG&E lacking the necessary records - has established the MAOP for 243 of
its 1,376 hydraulically independent distribution systems using a procedure that is different from that
required by 49 CFR 192.619(c).
38
These are discussed below.
39
40
41
42
43
Additionally, inspections by SED personnel conducted in July and August of 2015 have identified
continuing mapping update violations and deficiencies. These are discussed further in Section 8.1.
Briefly summarized, SED audited maps and records for 42 service line insertion projects in San Jose
and San Francisco divisions, and found four (4) instances where the inserts were not mapped; a
violation of mapping requirements.
64
We conclude the 2 diameter steel main was inserted sometime in 1997 as that was the earliest it could have
been installed. The plastic pipe was manufactured on July 17, 1997.
Page 40
1
2
3
4
5
6.2.1 Violations associated with additional incidents

Several additional incidents were selected for evaluation as part of the OII. These incidents are
summarized in Table 4 below. These incidents were selected from SED NOPV letters, and a summary
of third party damage incidents provided by PG&E. In addition to a very brief summary of the
incident, the table describes potential violations associated with each incident.
Page 41
1
2
Table 4 Violations Associated with Additional Incidents Evaluated for OII

Location/Date
System
Characteristic
s
Comments/ Violation
San Jose (01/20/15)
1.25 steel
service stub
extending
from a 4 steel
main, 60 psig
MAOP
49 CFR 192.605(a) failure to follow mapping

standard 410.21-1 to update when stub service was
installed.
employee with accurate maps to L&M the facility
and not following its procedures to update its
records and maps of the presence of a stub service.
49 CFR 192.614(c)(5) - and failure to locate and
mark all its subsurface facilities within the
delineated excavation area.
Cal Gov. Code 4216.3 failure to provide L&M
staff with accurate records.
Failure to map stub resulted in TPD.
Lafayette
(8/27/13)
steel
service line
and service
line valve 60
psig MAOP
49 CFR 192.605(a) for failure to follow GTS

Standard S4129 (requires cutting off services as
close to the main as possible).
49 CFR 192.727(b) for failing to properly abandon
or deactivate its gas facilities.
49 CFR 192.614(c)(5) and California Government
Code 4216.3(a)(1) for failure to provide temporary
marking for its subsurface facilities in the area of
excavation.
Location of service line removed from PG&Es map
based on an incorrect gas service record which
indicated the service line was cut-off resulting in
TPD.
Page 42
Location/Date
System
Characteristic
s
Comments/ Violation
San Jose (11/07/14)
2 plastic
distribution
main, near 3way tee,
which
branches off a
4 plastic
distribution
main
Kentfield (4/1/11)
Goodhill Road &
Diablo Drive
2 plastic
main 60
psig MAOP
Contractor erroneously thought PG&E had marked

out its gas lines in response to the USA request and
that a 2 steel electrical conduit was the gas line.
PG&E had not marked out its 2 gas line.
L&M crew had attempted to contact the excavator
one hour prior to the scheduled start of excavation.
The communication was unsuccessful and PG&E
did not identify the significance in not making
positive effective communication without marking
out the gas lines and complying with damage
prevention requirements and procedures.
Violations of 49 CFR 192.605(a) for failure to
follow procedures including PG&Es damage
prevention handbook TD 5811M, 49 CFR
192.614(c)(6) for failure to dispatch a
representative to the excavation site, California
Government Code 4216.3(a)(1).
49 CFR 192.13(c) failure to follow its procedures
not updating its maps.
employee with accurate maps to L&M the facility
and not following its procedures to update its
records and maps.
49 CFR 192.321(e) - failure to install tracer wire
on 2 replacement plastic main.
49 CFR 192.614(c)(5) failure to mark out 2
plastic main
Water contractor excavating for City damaged 2
plastic main. Had exposed 2 steel main that had
previously been replaced on 12/23/10 without tracer
wire. L&M crew lost signal, used outdated map to
mark out old retired main. Plastic main not
indicated on map, not marked in area of excavation.
.
Page 43
Location/Date
System
Characteristic
s
Comments/ Violation
Antioch
(3/15/10)
Lonetree Way & James
Donlon Blvd.
2 plastic
main
60 psig
MAOP
PG&E is in violation of 49 CFR 192.614(c)(5) and

of California Government Code 4216.3(a)(1) for
failure to provide accurate temporary marking for its
subsurface facilities.
L&M crew incorrectly located 2 plastic main, mark
was 14 feet off of actual main location resulting in
TPD. Main was located in a sweeping arc when the
main actually intersected at the intersection at right
angle. L&M crew failed to utilize available map
information to assist in determining the location of
the gas main.
Colusa (03/19/09)
Grimes/Arbuckle Road
and First St.
2 steel main
150 psig
MAOP
Alameda (09/28/10)
4 plastic
main 60
psig MAOP
Violation of GO 112-E, 3 main was marked

accurately, 2main was not marked Violations of 49
CFR 192.605(a), California Government Code
4216.3(a)(1)
TPD due to incorrect map and mark-out.
The locating wire was disconnected, led to a stray
locating signal; operating records did not reflect
field conditions; and the L&M crew did not follow
proper procedures for determining location of
pipeline or communicating same to the excavator.
49 CFR 192.614(c)(5) and of California
Government Code 4216.3(a)(1) for failure to
provide accurate temporary marking for its
49 CFR 192.614(c)(6) for failure to dispatch a
representative to the excavation site.
employee with accurate maps to locate and mark the
gas line and not following its procedures to provide
updated records and maps.
Page 44
Location/Date
System
Characteristic
s
Comments/ Violation
Roseville (10/21/10)
2 plastic
main 60 psig
MAOP
Boring contractor struck a 2-inch plastic gas

distribution main at in Roseville. Six building were
evacuated as a precaution, including a nearby
restaurant, hotel, and DMV office. Baileys
Trenchless had a valid USA ticket. The cause of this
incident was inaccurately marked PG&E gas
facilities. PG&E is in violation of:
California Government Code 4216.3(a)(1) due to inaccurate
mark-out and 49 CFR 192.13(c) - PG&E also did not follow
its Work Procedure 4412-03 page 4, the L&M crew did not
contact mapping when the field locate and map did not make
sense.

gas line and not following its procedures to provide
updated records and maps
Page 45
Location/Date
System
Characteristic
s
Comments/ Violation
Sacramento (10/31/11)
1 plastic
service
Horizontal boring contractor damaged a mismarked

1 plastic service line. The service line was not
accurately updated/mapped to reflect the presence of
two offsets in the line. L&M crew failure to contact
mapping per WP4412-03 when signal was lost
during locating of facilities or to advise contractor
of potential poor service mark. PG&E is in
violation of 49 CFR 192.614(c)(5) and of
California Government Code 4216.3(a)(1) for
employee with accurate maps to L&M the facility.
San Francisco
(04/08/14)
1 plastic
service line,
60 psig MAOP
49 CFR 192.614(c)(5), California Government

Code 4216.3(a)(1) L&M crew failed to use available
mapping information to mark active gas main and
service line in the excavation area resulting in TPD.
1 plastic
service line,
60 psigMAOP
49 CFR 192.605(a) failure to follow mapping

standard 410.21-1 to update maps properly when
service was installed on 8/1/83;
facility accurately resulting in damage to gas line.
65
Fresno (09/24/14)
65
Both addresses are indicated for the damaged service line on PG&Es records.
Page 46
Location/Date
System
Characteristic
s
Comments/ Violation
San Ramon (8/12/09)
2 plastic
service line
60 psig
MAOP
TPD due to unmarked and unmapped 2 diameter

service to restaurant. PG&E was unable to produce
the original service order and did not map the
service line after installation. The service line was
serving the restaurant since 10/14/97.
PG&E is in violation of 49 CFR 192.614(c)(5) and
of California Government Code 4216.3(a)(1) for
employee with accurate maps to L&M the facility.
49 CFR 192.723(b)(2) failure to perform leak
surveys of the service line since installation prior to
10/14/97.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
6.2.2 Violations associated with the relationship between

incidents at Mountain View and Carmel
Table 5 below is a summary of identified violations related to the relationship between two of the OII
incidents that in Mountain View (07/30/13) and that in Carmel (03/03/14). These two incidents
occurred approximately seven months apart. The potential violations are associated with the fact that
mitigative actions on the scale undertaken following the incident at Carmel were not implemented
following the very similar incident seven months earlier at Mountain View. From a risk perspective,
the underlying cause of both events the failure to map plastic inserts in metal lines seemed to
warrant the same serious consideration following the Mountain View incident that it received
following the much more consequential (house explosion), and therefore more visible incident in
Carmel. The risk implications in both incidents include: unidentified/unmapped plastic inserts in metal
lines in PG&Es distribution system; breeching the metal casing in conjunction with maintenance
activities requiring drilling, welding or tapping can create both a rupture of the gas containment
boundary and a potentially unrestricted path for the gas to flow to inhabited locations. Thus a single
action - one that is required as part of frequent maintenance activities can cause both a release of gas
and a path through which the gas can flow to one or more unidentified locations. This seems to be a
clear example of the definition of high risk.
Page 47
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2
Table 5 Violations related to Incidents at Mountain View and Carmel

Violation
Requirement Violated
Evidence
Missed
Opportunities for
Corrective Actions
Failure to
implement
compensatory or
backstop measures
promptly in the face
of evidence of an
unanticipated high
risk situation.
49 CFR 192.617
Investigation of Failures - It is
not clear whether or not the
Charleston Road - Mountain
View incident was the first
time an unmapped plastic
insert was identified as being
present and not previously
mapped as well as records
inaccurately reflecting gas line
conditions and materials as per
PG&E mapping update
procedures.
49 CFR 192.605(b)(3)
Neither is it clear whether this
issue of maps not accurately
reflecting actual working
conditions (such as mains or
services having been inserted
and maps not being updated)
was shared as a concern or
warning to other gas
operations personnel to be
looking for such conditions
prior to performing work on a
gas line, especially welding or
tapping. Certainly as part of
PG&Es investigation of
failures following the
Mountain View incident, these
issues should have been
identified and communicated
to other gas operations
personnel following the
Mountain view incident.
The time between the

Mountain View incident and
that at Carmel was
approximately seven months.
PG&E had provided no
information that it actively
investigated the root cause of
the Mountain View incident
nor communicated a warning
to its employees that due to
mapping inaccuracies or nonupdated maps and records,
service lines and mains may
be previously inserted, and to
check for that condition prior
to working on any gas line.
Response to PHMSA
Advisory Bulleting
ADB-02-03
Failure to
address/ensure
maps and records
provide diameter,
grade, pipe type and
wall thickness per
PHMSA Advisory
Bulletin ADB-0203
Failure to identify and

take positively action
on precursor events in
which service line and
main inserts were not
accurately reflected on
PG&Es maps and
records.
Failure to issue an
advisory to workers
following the incident
at Mountain View.
3
4
5
6
Page 48
1
2
6.2.3 Violations associated with establishment of maximum

allowable operating pressure (MAOP)
3
4
5
6
7
8
9
10
11
The issue associated with distribution system MAOP is that PG&E acknowledges it has not complied
with the 1970 version of 49 CFR 192.619 (see Federal Register on August 19, 1970) in which the
approaches to establishing MAOP for pipelines installed prior to promulgation of that regulation were
specified. In particular, PG&E has indicated that, for 243 hydraulically independent distribution
systems, pressure records did not exist in 1970 to support the required five year pressure history
review. Hence it developed a procedure66 that relied on either certification of the maximum operating
pressure during the five years from 1965 through 1970, or use of pressure records during the mid to
late 1970s during leak surveys as the basis for the MAOP. Both approaches are an unapproved
alternatives to those described in the regulation.
12
13
In its evaluation of the MAOP issue, PWA developed a timeline of relevant events, which is shown
below as Table 6.
14
15
16
Table 6 PG&E MAOP Time Line

August 19, 1970 - FR Notice publishing 192.619.
17
18
19
o MAOP is the highest actual pressure to which the segment was subjected during the
five years preceding the applicable data (July 1, 1965 - July 1, 1970 for distribution
piping).
20
21
22
July 26, 1971 The CPUC granted PG&Es waiver request to allow an extension of time for
compliance with Section 192.619 (a)(3), Maximum allowable operating pressure; steel or
plastic pipelines, through July, 1971.
23
24
November 22, 1972 - PG&E internal letter to Division Gas Superintendents communicating
the ASME Committee interpretation of 192.619.
25
26
27
28
29
30
31
o Letter communicates the opinion of the ASME Committee on Gas Safety, PG&E, and
other unspecified utilities all of which concur that 192.619 covers all pipeline systems
and must be adhered to when determining the MAOP of distribution piping systems.
April 5, 1977 - PG&E internal letter to Division Managers disclosing that a recent systemwide audit disclosed that many of our distribution systems lack tangible documentation of
operating pressures for that five years period in 192.619 (July 1, 1965 - July 1, 1970 for
distribution piping).
32
33
34
35
36
37
38
o The letter described three alternative approaches to establishing the MAOP none of
which is consistent with those described in the regulations.
February 13, 1978 - PG&E issued Standard Practice 463-6 to Division Managers and the
Manager of Pipeline Operations prescribing a uniform procedure to establish, document,
review and revise MAOP for all distribution systems which contain plastic, cast iron,
wrought iron, or copper pipe and steel pipe which is operated below a hoop stress of 20%
SMYS.
39
40
41
o Allows certification of the highest operating pressure in the five year period
(July 1, 1965 - July 1, 1970 for distribution piping) as the basis for determination of
MAOP.
66
PG&E Standard Practice 463-6, February 13, 1978.
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o Allows alternative MAOP establishment not consistent with the regulations If

there is no pressure record available to document the operating pressure of the system
during the five years prior to July 1, 1970, the MAOP may be established as the
documented pressure of the system when the most recent leak survey demonstrated
the system to be safe while operating at the documented pressure (documented
pressure at the time of the survey or before and after the survey).
March 13, 1979 - PG&E internal letter to District Managers.
o Announcing the completion of establishment of MAOPs for the system consistent
with Standard Practice 463-6.
June 25, 1996 Transmittal of new PG&E DCS Standard.
o Transmits a revised standard effective 08/01/98 which purports to establish, revise,
confirm and document MAOP in compliance with applicable regulations. The new
DCS Standard is GTS S4125 which replaced Standard Practice 463-6.
April 22, 1998 - PHMSA published guidance on determination of MAOP.
o There is another way these regulations (192.619) can be used. If pipeline and/or
distribution system records are missing or incomplete, it may be impossible to
conclusively determine what the MAOP should be under the other criteria. In that
case, the operator must consult with the regulatory agency, and should look at the
normal operating pressure over the last five years, and select the highest pressure
which did not cause unusual safety or operational problems.
August 11, 2010 - Letter from John Gale (PHMSA Director, Office of Regulations) to Joe
Johnson, New Mexico PUC Pipeline Safety Bureau (PSB).
o Regarding PSB's alternative practice of accepting affidavits or other operating records
in lieu of pressure testing or uprating of pipelines in the absence of pre-July 1, 1970
pipeline operating pressure data, we would note that Part 192 has no regulatory
language to support the allowance of the PBS alternative practice. In order to
establish a MAOP in a manner other than pressure testing or uprating in accordance
with Subpart K of Part 192, an operator would have to seek a waiver and provide
justification for its proposed alternative approach.
August 16, 2010 Letter Glen Carter (PG&E) to Banu Acimis (SED).
o PG&E discusses the SED findings from an audit carried out from May 17 through 21,
2010. The SED finding related to PG&Es inability to locate MAOP documentation
and as-built installation records from 1961 for Zone 196 in the Colusa District.
PG&E responded that it believed the violation was actually of provisions in 192.619,
further that the correct reference system was #178 not #196. PG&E also indicated it
would establish the MAOP utilizing the procedure in TD-4125P-01.
37
38
39
October 20, 2014 - SED audit identified non-compliant establishment of the MAOP, later
determined to be for at least 240 of PG&Es 1,376 hydraulically independent distribution
systems.
40
November 11,2014 Letter Bill Gibson (PG&E) to Ken Bruno (SED).
41
42
43
o PG&Es response to the 2014 O&M Audit - AOC #23 stated:

PG&E has used this basis for establishing distribution systems MAOP since the late
1970s. During that period, PG&E realized that pressure records during the 5 years
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prior to July 1, 1970 for some distribution systems could not be found. PG&Es
standard practice provided an option to require a pressure record after July 1, 1970
with a subsequent leak survey in order to demonstrate safe operation and
establishment of a systems MAOP. PHMSAs instructions on the determination of
MAOP in natural gas pipelines (attached and currently available on PHMSAs
website:
7
8
9
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12
13
http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/maop_deter
mination.pdf ), dated April 22, 1998, describes considerations of missing records in
Section C. It is not known whether PG&E consulted the CPUC in the late 1970s in
specifying this option to establish distribution MAOPs. PG&E has reviewed
distribution system MAOP records and determined that of the 1376 hydraulically
independent systems, approximately 240 systems have had their MAOP established
using this basis.
14
15
August 14, 2015 - PG&E corrects the number of systems and states the number of systems
are actually 243. PG&E response to DR_SED-004_Q-86.
16
17
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19
20
September 14, 2015 In its response to SED-004-Q87, PG&E stated In 2008, PG&E
concluded that the use of the method described in TD-4125S to establish MAOP for the
subject 243 hydraulically independent distribution systems does not pose a safety risk.
Therefore, PG&E has not implemented any additional measures specifically applicable to the
associated pipe.
21
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23
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29
30
Review of this timeline shows that the earliest available correspondences discussing the issue were: an
internal PG&E letter dated November 22, 1972 to Division Gas Superintendents communicating the
ASME Committee interpretation of 49 CFR 192.619, and an internal PG&E letter dated April 5, 1977
that described three alternative approaches to establishing the MAOP none of which was consistent
with those described in 192.619. The primary inconsistencies were related to (a) PG&Es apparent
willingness to use certification of a knowledgeable manager concerning the pressure history as a
substitute for pressure records, and (b) PG&Es willingness to use pressure records for a five year
period much later than that stipulated in the regulation as the basis for establishing the MAOP.67
PG&E Procedure TD-4125S, p. 4 states:
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36
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40
41
For distribution systems operating at MAOP of 60 psig or less, if there is no

pressure record available to document the operating pressure of a system during the
5 years prior to July 1, 1970, establish the MAOP alternatively by the documented
pressure of the system during the most recent leak survey made in the period between
July 1, 1970 and March 1, 1979. The leak survey must demonstrate the system to be
safe while operating at the documented pressure (meaning the documented pressure
at time of survey or before and after survey). If a leak survey was made but there is
no record of the pressure at the time of survey (or before and after the survey),
establish the MAOP as the pressure of record, if knowledgeable personnel can certify
that the pressure at the time of the survey was the same as the pressure of record. The
next leak survey must verify MAOPs established in this manner.
42
43
PWAs review of the MAOP issue included issuing a data request (DR SED-004-086) for related
correspondence. In response to the DR, PG&E provided Table 7. The DR and PG&Es response are
67
Letter Kenneth Bruno to Sumeet Singh, General Order 112-E audit of PG&Es Operations and Maintenance
Plans, Item 23, October 20, 2014.
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shown below. Note that the discussion of the MAOP in 2006 referenced in the first entry in Table 7
was unrelated to the basis on which MAOPs were established by PG&E for the 243 hydraulically
independent distribution systems; rather it was referencing how the MAOP was established for two
systems with different historic MAOPs that were being integrated into a single hydraulically
independent distribution system. Available information shows that PG&Es activities to develop and
implement an alternative approach to assigning MAOP for the 243 Hydraulically Independent
Distribution Systems occurred in the 70s (1972-1979) which indicates they had not maintained
distribution system pressure charts to monitor the pressures on at least the 243 systems in question as
required by General Order 58A (effective 07/01/32) Sections 20(c) and 20(d). GO 58A Section 20(c)
required that (for low pressure distribution systems) such 24 hour pressure charts of the system
pressures be maintained for a minimum of 2 years, and Section 20(d) required that (for high pressure
distribution systems) such 24 hour pressure charts of the system pressures be maintained for a
minimum of 2 years.
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23
Following the promulgation of 49 CFR 192.619 Maximum allowable operating pressure for Steel
or plastic pipelines, published in the Federal Register on August 19, 1970, PG&E was required to
establish the maximum allowable operating pressures of their gas distribution lines in accordance with
its provisions. For pipeline segments not pressure tested in accordance with code requirements, this
code section 192.619(c) required that PG&E was to identify records that demonstrate the basis for a
pipeline segments MAOP. The code limited distribution operating pressures on segments of steel or
plastic pipeline to the highest actual operating pressure to which the segment was subjected during the
5 years preceding 1970 if installed prior to (Nov. 12, 1970). If installed after that date, pressure
restrictions apply unless the segment was tested according to the requirements in paragraph (a)(2) of
this section.
24
25
26
27
28
In summary, PG&E developed its approach to establishing the MAOP for the 243 hydraulically
independent distribution systems and implemented that approach without seeking either review or
approval by the SED. This is a violation of 49 CFR 192.619. Even in light of the 1998 PHMSA
guidance that the regulator needs to review and approve any alternative approach to establish MAOP
the earliest correspondence (2014) was sixteen years after PHMSA published its guidance.
29
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SED-004-Q086 - Please provide correspondence between PG&E and the CPUC

in which the approach PG&E took to establishing the MAOP for the subject 240
hydraulically independent distribution systems was described and approval was
sought for this approach.
PG&E Response:
PG&E is producing, as documents Bates numbered PGE_GDR_000022864 through
PGE_GDR_000022924 and PGE_GDR_000030028 through PGE_GDR_000030269, evidence
of joint meeting materials and correspondence located to date between PG&E and the CPUC
in which the approach PG&E took to establishing the Maximum Allowable Operating Pressure
(MAOP) for the subject 243 hydraulically independent distribution systems is discussed.
39
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Table 7 List of available MAOP Correspondence

Document
3
4
5
6
7
8
9
10
11
12
13
Bates No.
Begin
Bates No. End
1 September 22, 2006 letter from PG&E to Mr. Jadwindar Singh,

following an audit at which MAOP was discussed.
2 July 19, 2008 PG&E internal memo commenting that the CPUC
auditors would review PG&Es proposed process to resolve missing
MAOP documentation and get back to PG&E.
3 Agenda from July 29, 2008 regularly scheduled Regulatory
Liaison meeting between PG&E and the CPUCs Utility Safety
and Reliability Branch (USRB).
4 Hand-out from July 29, 2008 meeting documenting PG&Es
approach to establishing distribution MAOP.
GDR_000030028
GDR_000030039
GDR_000030040
GDR_000030045
GDR_000022880
GDR_000022880
GDR_000022864
GDR_000022873
5 PG&E internal memo attaching and documenting storage location

of materials from CPUC USRB/PG&E meetings, including July 29,
2008 meeting materials.
6 October 17, 2008 letter from Mr. Dennis Lee, CPUC, to PG&E,
observing that there have been ongoing discussions and that there
will be further communication between PG&E and the CPUC
regarding setting MAOP.
7 December 30, 2008 letter from PG&E to Mr. Sunil Shori, USRB,
further notifying the CPUC of PG&Es approach to setting
distribution MAOP.
8 February 13, 2009 correspondence from Mr. Sunil Shori, USRB, to
PG&E replying to PG&Es December 30, 2008
letter.
9 August 16, 2010 letter from PG&E to Ms. Banu Acimis, USRB,
providing detailed responses to 2010 audit findings, including a
May 17-21, 2010 audit with a response to an MAOP establishment
finding where PG&E commits to follow its procedure TD_4125P01, Establishing and Maintaining Distribution MAOP Records. The
letter also states that the procedure was attached as Attachment G.
GDR_000030046
GDR_000030236
GDR_000030237
GDR_000030239
GDR_000022881
GDR_000022886
GDR_000022874
GDR_000022879
GDR_000030240
GDR_000030269
PG&E is continuing to search its records for additional responsive correspondence and may
supplement this response.
In additional DR #87, PWA has asked about the risk represented by these 243 systems relative to other
grandfathered systems for which the MAOP was established in conformance with the regulations,
and about the measures PG&E proposes to address these risks. An indirect response was provided by
Raymond Thierry in response to Interrogatory under Oath #17 My understanding is that, in 2008,
PG&E concluded that the use of the method described in TD-4125S to establish MAOP does not pose
a safety risk to the distribution system. This position was reiterated in response to DR #87 that in
2008, PG&E concluded that the use of the method described in TD-4125S to establish MAOP does not
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pose a safety risk to the distribution system. Therefore, PG&E has not implemented any additional
measures specifically applicable to the associated pipe. PWA concludes that this PG&E workaround
necessitated by the associated recordkeeping deficiencies is a clear violation of 49 CFR 192.619(c).
Page 54
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7.
CHANGES IMPACTING PG&ES CONTROLS ON NATURAL GAS

DISTRIBUTION MAPPING AND RECORDKEEPING
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Since state and federal regulations were enacted, there have been requirements on natural gas
operators, both transmission and distribution, to keep some of their records for the life of the pipe.
PG&E has had procedures and standards to meet these requirements since before the enactment of the
federal standards in 1970.68 California has had public safety regulations for utilities since the early
1900s (the first edition of GO 58-A was effective on September 1, 1919). Industry has also had
standards such as ASA B31.1.8 which had recordkeeping requirements and provisions since at least
1955. The early safety regulations in California (i.e., CPUC GO 112 effective January 17, 1961)
required natural gas operators to comply with requirements in these industry standards. Thus PG&E
had procedures and standards in place to mandate that its underground facilities be properly mapped
and records of their testing, composition, and location be kept.69 These records are required to safely
operate a natural gas system. Therefore PG&E has violated federal safety regulations under 49 CFR
Part 192 and California regulations under GO 112 (A to E) and GO 58A [Section 3, effective
December 16, 1992] by failing to maintain such records and maps.
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Many of the early PG&E records retention procedures/standards were more geared to when records
needed to be purged70 than the identification and safe guarding of existing records. Additionally
records were being maintained and retained at various offices throughout the service territory and an
official copy was not centrally stored. Lose controls on records borrowing, some of which have yet to
be strengthened,71 and wide geographic diffusion of storage have caused many of the critical
retained for life records to be lost over time. Maps incorporating these critical records in as builts
including plastic inserts and the locations and characteristics of stubs were apparently not developed.
Hence field personnel, including those carrying out maintenance, leakage surveys, and those who
locate and mark underground facilities do not have accurate and complete maps of all company
underground facilities. Additional factors have exacerbated development of accurate maps, such as a
long lag time between when field personnel submitted updates to when they were mapped leading to
mapping backlog of months and not days, mapping updates were paper based and thus prone to being
lost, there was no formal quality control on map updates, and there was no verification that what was
mapped was actually installed.
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Since 2010 PG&E has started several recordkeeping and mapping improvement initiatives. These
include the Pathfinder Program which involves moving plat maps to the GD GIS. The program
integrates maps and records of all of the currently known information on the gas distribution system.
As part of this project, records and information in prior databases are being analyzed and integrated
with all of the other information on the system. Where miss matches are identified, a report of the
discrepancy is generated to be evaluated by an engineer and corrected. Thus, assuming continued
attention, we anticipate that many of the inaccurate records will be corrected. PG&E has also instituted
a tracking and correcting mechanism whereby field reported discrepancies are reported to mapping and
resolved. Maps are now available on an electronic format, called the Pathfinder viewer, to all field
68
See responses to SED DR 001-Q02Supp 01 (Bates Nos. 00006818 to and including 00006864, from 1959 to
1969)
69
PG&E Standard Practice No. 410.21-1, 04/01/77.
70
Paul Duller and Alison North, Records Management within the Gas Transmission Division of PG&E, March
5, 2012, page 6-33.
71
Interview notes from discussion with PG&E Mapping Principal
, week of August 3, 2015.
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crews with access to GD-GIS. Mapping is attempting to update changes from the field and to address
discrepancies in 30 days or less.72
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8
Another positive technology addition is using the SAP framework to track all work on the gas system,
all discrepant information, investigating all allegations of false record keeping, and having all new data
systems linked and the data verified and integrated with older data known to be reliable. Because of the
size of the undertaking, PG&E has also increased its commitment to quality assurance, including
performing quality control checks on existing and new data being entered into the database and records
of the actual field conditions.
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13
The Milpitas incident that cut off service to almost 1,000 customers was a direct result of ineffective
procedures and non-centralized controls. Subsequently PG&E has implemented a new gas distribution
control center, and implementing a new clearance control process where clearance decisions are made
and coordinated between field engineers and the control center in the light of more complete
information.
14
More details on recent and ongoing changes are discussed in Section 8.
15
72
Prior to the addition of more resources in the mapping area and splitting the common electric and gas the
mapping department, the backlog was 130 days or more.
Page 56
8.
EVALUATION OF CORRECTIVE ACTIONS AND BACKSTOP MEASURES
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3
8.1
Recent SED Inspections Regarding the Effectiveness of PG&E

Mapping
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11
During July and August of 2015, SED conducted inspections in the San Jose and San Francisco
Divisions of PG&E. These inspections included determining whether pipe repairs completed in 2013
and 2014, such as using plastic inserts, are adequately represented on current maps. The table below
shows four recent instances of the forty-two inspected (over 9%) in which map corrections were either
not completed or were inaccurate. Of these the San Jose inspection examined 27 leak repaired by
insertion of a plastic pipes of which two (2) had documentation problems. The San Francisco
inspection examined 15 leak repaired by insertion of a plastic pipes of which two (2) had some
documentation problems.
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13
Table 8 SED-Identified Mapping Errors and Omissions

Street
City
Work Description
Date Work
Completed
Date GDGIS
Checked
Time
Delay
San
Francisco
Inserted 1.5 steel service with PE.

Current GD-GIS map shows no insert. On
last page it is noted that posting not
required.
Inserted 1.25 steel service with PE and
installed plastic curb valve. Current GDGIS map shows no insert. Plat map does not
reflect insertion. On last page it is noted
that posting is required.
Inserted entire steel service with PE.
Current GD-GIS map shows no insert.
12/19/13
~08/07/15
~588
days
05/29/13
~08/07/15
~788
days
10/04/13
~07/17/15
~643
days
07/15/14
~07/17/15
~362
days
San
Francisco
San Jose
San Jose
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15
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18
8.2
Inserted entire steel service with PE.

Current GD-GIS map shows no insert.
Design, Implementation and Effectiveness of PG&Es Backstop

Measures and Corrective Actions
In its response to the OII, PG&E described at least twenty four system improvements, corrective
actions and backstop measures designed to accomplish four objectives:
19
To improve accuracy
20
To improve map and record accessibility
21
To improve controls
22
To improve operational safety
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Among these activities, PG&E discusses the specific steps it has taken to improve its records and
actions it has implemented to compensate for inaccurate or incomplete records.73 To this end PG&E
states that it has taken steps to improve its records using management practices which include
maintaining accurate, traceable, verifiable, and complete asset information.74 Some of these
improvements are updating systems to provide more accessibility to existing records, another - the
Pathfinder Project - will consolidate multiple sources of gas distribution asset records, including
paper records, into one integrated GIS data model called GD GIS. To increase map consistency and
accuracy, PG&E performs a comparison of existing records within the new GIS system, thereby
seeking out discrepancies and through a tool called the problem/action report (PAR), resolving these
discrepancies. Since 2012, 25,000 discrepancies have been resolved.75
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15
PG&E is also working to speed up the incorporation of capital work orders which change field assets
on gas distribution maps. They checked 61,000 open gas work orders and found that 18,000 had not
been updated on gas distribution maps.76 PG&E had reduced this back log to only several hundred by
the end of 2014. Currently PG&E has a target of mapping all capital jobs within 32 days of
completion, which it claims to have met in 2014 with a completion time of 29 days.77
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18
PG&E asserts it is performing other processes to improve its gas distribution records such as
electronically importing leak repair information and comparing the data base with the customer bill
data with distribution maps.
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26
PG&E recognizes that even if data is imported into a single data base quickly, if that data is incorrect,
the resulting data base will not be better. In their response, PG&E assert that a newly implemented
Quality Management group is charged with conducting quality reviews of many of the facets of the gas
distribution organization to ensure that new procedures and/or processes are being followed and do not
have any gaps. Since 2011, at the formation of this group, they have been reviewing as-built and gas
service record quality.78 In addition, PG&E executives are making use of the corporate Internal Audit
function (IA) to evaluate aspects of operation and changes to operation that have the potential for
difficulties.
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36
37
Since the Carmel incident, PG&E has instituted a gas carrier pipe checklist to backstop the lack of
records for inserted plastic. To address several of the other incidents, PG&E has instituted a new
Damage Prevention Handbook incorporating the updated procedures and processes for locating gas
facilities. In the 2014 rate case PG&E requested, and received, funding for its centralized gas control
center comprising both gas distribution and gas transmission which also includes the gas dispatch
operations.79 PG&E has also implemented clearance procedure changes to reduce the likelihood that
maintenance or construction activities will affect gas flow to customers in its distribution system.
There are a number of other improvements that PG&E presents in its response to the order. In Table 9,
we have listed the PG&E improvements described in its response to the OII and, based on what we
have learned, made an initial appraisal of the likely effectiveness of each of these improvements. Our
evaluation of the likely effectiveness uses the following set of ratings:
73
PG&E Response on page 5.
74
75
76
77
78
See Response on page 17.
79
See Response on page 23.
Page 58
Table 9 Evaluation of PG&E Corrective Actions and Backstop Measures

Judgment on Likely Effectiveness - Guidance
(BP) Best practice, widely viewed as effective
(IP) Innovative practice, potentially effective
(MV) Continuing management vigilance required to assure effectiveness
(PM) Performance measure(s) currently in place will support management monitoring of
effectiveness
(NPM) No performance measure(s) currently in place to support management monitoring of
effectiveness
(EI) Evidence of ineffectiveness exists, cause and pervasiveness not yet known
(UC) Potential for unanticipated consequences possibly associated with excessive focus on
improving performance measures
(II)
Insufficient information to make an informed judgment on effectiveness
Corrective Actions and Backstop
Measures
Efforts to improve accuracy include:

The Pathfinder Project through update
of the GD-GIS (scheduled for
completion in 2015) is attempting to
address the map accuracy issue; the
Problem/Action Reports (PAR) attempt
to identify and address inconsistencies
identified in Pathfinder.
Data captured from Gas Service

Records and integrated into GD-GIS
enabled PG&E to create an inventory of
28,000 (now71,000) service stubs in a
centralized database.
Evidence of Effectiveness
Judgment on Likely
Effectiveness (see
guidance preceding
the Table)
See PG&Es answer to SED-001-Q12

Bates No. GDR 000008364 - Internal
Audits found continuing problems with
as builts throughout the year (2014)
which reflects on the quality and
accuracy of information going into GD
GIS. Many incomplete as-builts have
been gathered at San Ramon and an
ongoing program to determine their data
accuracy and provide updates to GD GIS
is supposed to address the issue of
historical backlog of incomplete updates
to maps.
The fact that now over 71,000 stubs have
been identified indicates a problem.
Identification of these 71,000+ stubs is
just a start to what should be an
expedited program to eliminate or at
least fully characterize them. Whether
the identified 71,000+ stubs are due to
historical poor record keeping where
service lines were actually cut off at the
main, or a practice of cutting at the curb
line/ property line or a convenient
IP
MV
EI due to large backlog of
PAR reports to be
addressed
EI
II
Page 59

Measures
Training in and use of a new Field-AsBuilt-Handbook.
PG&Es Mapping Department

publishes a weekly report that provides
up-to-date performance information for
all as-builts, tracks every job that has
exceeded the target time for any phase
of the as-built process, and conducts
meetings with personnel to address
those jobs. Between June 2013 and
December 2013, PG&E mapped 100
percent of the jobs within 90 days.
unpaved area, the very number indicates

the issue of stubs has been neglected and
poorly managed in the past. Insufficient
information exists to evaluate the
effectiveness of PG&Es efforts
(described in TD-9500P-16) to eliminate
stubs, including verifying whether or not
a stub exists, and if one does exist, to
expedite cutting it off now since it
probably has existed more than 5 years.
The current program does not find stubs
that have been deleted from maps for
various reasons and thus may not be
fully effective since one of the six
incidents in the OII was for stubs that
may been erroneously deleted from the
system maps.
See PG&Es answer to DR SED 001Q12 Bates No. GDR 000008364
Internal Audits found continuing
problems with as builts throughout the
year (2014) which reflects on the quality
and accuracy of information going into
GD GIS. PG&E needs to perform a root
cause analysis on why there continue to
be errors in the information being input
into GD GIS via as built data, and
address identified causes.
The metric only covers jobs whose
construction was completed since July 1,
2013 (See Internal Audit Report dated
Feb 5, 2014 PG&Es answer to DR SED
001-Q12, footnote on Bates No. GDR
000008194.) SED inspections in July
and August of 2015 have shown that
there is a backlog of older jobs and asbuilts that the San Ramon mapping
group is either working on or unaware
of. The IA also identified one job whose
metric age was reported as 57 days and
in actuality was 87 days. One issue is
when the time clock starts for mapping
Judgment on Likely
Effectiveness (see
guidance preceding
the Table)
MV
EI
IP
PM
MV
Page 60

Measures
on those jobs where the sketch or asbuilt may be missing information. This
clock is currently reset when a job is
returned for better information.
(However, the time from job completion
to acceptance by mapping is also
tracked.) The current target of 30 days
to update maps is considered a best
practice. Another IA report (see Bates
No. GDR 000008364) states there
continue to be problems with map
update timeliness.
Updating pipeline records with leak
There still appears to be an issue with
repair records (A-Forms).
whether the nature of a leak repair
requires some type of map updating, or
just that the repair record needs to be
scanned into SAP and be available as a
job package. The A-form is initiated
when PG&E identifies a gas leak and
serves to document information about
the leak from identification through
recheck and or repair. Evidence from
recent SED inspections (see Section 6.1)
reveals repairs by insertion that were not
captured on maps.
Validated gas distribution asset data by We have not evaluated this programs
comparing distribution asset maps with effectiveness. This practice has been
meter locations in customer billing data. performed by other gas distribution
operators not just for checking maps but
for customer relations issues such as
billing, meter requirements, etc. PG&E
needs to check on the effectiveness of
this service/billing mis-match process.
A simple check might be to identify the
services being reported under the CAP
as not being mapped and found by leak
surveys, leak repairs, and other field
activities and inspections.
Efforts to improve map and record accessibility include:
Employees performing leak repair have Have not had the opportunity to evaluate
the effectiveness of this PG&E program.
been enabled to initiate A-Forms, take
pictures of completed work, document
Judgment on Likely
Effectiveness (see
guidance preceding
the Table)
IP
EI
MV
BP
II
IP
II
Page 61

Measures
geo-spatial location of repairs, and

record required information
electronically.
Providing crews with mobile access to
digital gas distribution system maps,
streets and electric cables via laptops.
Have not had the opportunity to evaluate

the effectiveness of this PG&E program.
Success will depend on map data,
accuracy and quality. 49 CFR
192.605(b)(3) requires PG&E to
provide maps to its personnel.
Locate-and-mark (L&M) personnel
From interview with L&M personnel,
moved from older mobile technology to the technology and capabilities appear to
tablets to access L&M tickets and
support and enhance the L&M function
relevant maps, and to record completion effectively. 49 CFR 192.605(b)(3)
of these tickets.
requires PG&E to provide maps to its
personnel. Downside is the L&M
personnel use maps as a guide and do
not appear to use them as a primary
source when marking out locations of
gas lines, or even as a third option to
frequency driven locate tools. Still, as
evidenced by the incidents in Tables 2
and 4, many gas lines are not being
marked or being marked inaccurately
resulting in TPD. Until L&M personnel
become confident in the accuracy of the
maps they use, they will continue their
primary reliance on frequency based
tools and disregard information on maps
which they cannot verify. Also, the
apparent misinterpretation of the
acceptability of a positive contact
(rather than establishment of a mutually
agreeable L&M reschedule) if timely
mapping is not possible is inconsistent
with California law. In addition to
incidents in which failure to complete a
timely L&M and failure to establish a
mutually agreeable date for the L&M are
80
a significant contributor, excavator
80
Judgment on Likely
Effectiveness (see
guidance preceding
the Table)
BP
II
BP
EI
MV
See the incident in San Jose on 11/07/14 Described in Table 4 of this report.
Page 62

Measures
In November 2014, PG&E also began

an effort to use mobile technology and
GD GIS to identify situations where
PG&E personnel need to stand by when
third parties are excavating or
performing other work adjacent to
PG&Es critical facilities.
Make gas service and distribution
records accessible electronically.
Application in 2015 implementation of
its Gas As-Built Collection initiative to
collect, scan, and make available
electronically all of the gas distribution
as-built job records to anyone with
access to PG&Es web viewer system.
Efforts to improve controls include:

In October 2013, Gas Operations
launched the Corrective Action
Program (CAP), a universally
available system that records issues
submitted by employees or contractors.
These issues are tracked and resolved
from entry by an employee or
contractor to resolution. To date, CAP
has aided the generation, receipt, and
processing of mapping corrections
because of its accessible platform, builtin training, and availability to report
and track issues. PG&E has
implemented a procedure listing the
steps that employees must follow to
address a gas map correction submitted
through CAP.
In 2013, Gas Operations published two
81
81
complaints are an additional source of
information on the sufficiency of L&M
staff.
We have not evaluated this aspect of
PG&Es program, or to determine how
often PG&E personnel actually stand by.
PG&E needs to develop a metric to
determine the effectiveness of this
activity, including whether sufficient
resources are being provided.
PG&Es program. It is unclear how the
backlog of as built packages that had not
been previously updated due to potential
errors or lack of data and information is
being addressed, and how the associated
accuracy and data quality have been
addressed. Providing electronic
accessibility to field personnel is always
useful.
Judgment on Likely
Effectiveness (see
guidance preceding
the Table)
BP
MV
BP
II
The CAP process has been integrated

into the map correction process. CAP
has replaced other approaches used in
the past and is the practice for mapping
corrections in certain work activities. It
is also being used for employees to
identify mapping corrections during field
work practices. Corrections to improve
mapping accuracy could be made more
effective if PG&E implemented a
program to take advantage of third party
excavations where gas facilities are
exposed to verify their locations.
IP in pipelines, although
standard practice in
nuclear plant operation
II The program appears
promising with the
number of CAP suggested
corrections increasing
yearly. It is too early to
tell how well the
corrective action process
will work.
Standard TD-4017S is the standard to be
MV
Email, PG&E Gas Line Locate, William Heinselman (excavator) to PG&E, August 4, 2015.
Page 63

Measures
standards - the Records and Information

standard (TD-4016S) and the Vital
Records Management standard (TD4017S) - strengthening the operational
protocols for identifying, maintaining,
organizing, and retaining records.
followed for third parties records

EI
management, while TD-4016S is the
requirements for in house records
82
requirements. TD-4016S identifies
simple limited requirements for the
record owners together with Gas
Operations Records and Information
Management in requiring company
authorized record repositories. Limited
details are included in the standard.
Control of records still may be an issue.
MV
PG&Es program. Based on widespread II
records problems at PG&E, this training
was necessary. PG&E should evaluate
the need to develop a metric to
determine the effectiveness of the
training.
A key element of the records

management initiative is employee
engagement. In 2014, nearly all (98%)
of the Gas Operations workforce
received records and information
management training, which included
information about defining a record,
provided examples of the difference
between a record and a non-record, and
described electronic and paper records.
Gas Operations achieved certification in
the best practice asset management
certification offered by the British
Standards Institute, Publicly Available
Specification (PAS) 55, and the
International Standards Organization
certification (ISO-55001) in May 2014.
In 2011, PG&E Gas Operations

established a Quality Management

PG&Es program. In its response to
SED-002-Q15, PG&E provided the
initial Lloyds register evaluation and a
follow-up audit. These described
inspections of practices and records that
were made to achieve certification. SED
audits still are finding records and
mapping issues that PAS certification
83
inspectors did not identify. This result
brings into question how significant or
valuable was the PAS certification and
inspections if CPUC audits continue to
find map and record issues.
The QM group by means of targeted
audits has been useful in identifying
82
Provided by PG&E as Bates Nos. GDR 000000054 and 000000033.
83
See Tables 2 and 8 in this report.
Judgment on Likely
Effectiveness (see
guidance preceding
the Table)
IP
II
MV
BP
MV
Page 64

Measures
(QM) group to conduct quality

assurance reviews of work activities
and key processes, including
engineering, design, construction,
maintenance, and operations, to validate
adherence to new procedures and
processes and identify gaps and areas
for improvement.
problem areas for improvements. 49

CFR 192.605(b)(8) requires PG&E to
periodically review personnel work to
determine effectiveness and adequacy of
its procedures.
Actions to improve operational safety include:

Addressing unmapped plastic pipe
The checklist appears to be an effective
inserts through use of a Gas Carrier
backstop approach to PG&Es
Pipe Checklist.
unmapped or unrecorded plastic inserted
lines. Based on risk considerations,
PG&E should also evaluate the value of
implementing a program to proactively
correct its maps and records to
accurately depict its gas lines including
material, diameter, and age of
installation as required by General Order
58A Section 3.
In March 2014, PG&E issued a new
To better treat this subject, PG&E issued
Damage Prevention Handbook (TDRev 1 of the handbook seven months
5811M, Rev 1) that contains all
after initial publication. PG&E still has
applicable, up-to-date work steps for
too many damages associated with
locating and marking PG&Es gas and
unmarked, delays in marking, or
electric facilities.
inaccurately marked PG&E gas lines
which call into questions the
effectiveness of the training for the
L&M personnel and others on this new
handbook. Job time constraints may also
play a role in L&M effectiveness. L&M
personnel continue to have a problem
when they cannot meet mark-out
deadlines on making positive contact
with excavators and gaining agreement
on delaying excavation start dates.
Having received a notice to excavate,
PG&E must ensure it is meeting its
deadline commitments. Not being able
to meet these deadlines should be a rare
Judgment on Likely
Effectiveness (see
guidance preceding
the Table)
MV
II
IP
MV
Page 65

Measures
The Golden Shovel and Habitual

Offender programs for excavating
companies.
PG&E is developing a Pre-Dig
Verification Form, which was created
in response to dig-in incidents
involving PG&E employees or
contractors working for PG&E.
The Gas Distribution Control Center

(GDCC) in the Gas Operations
Headquarters in San Ramon further
enables PG&E to respond to emergency
conditions in a timely manner. It
represents a shift away from a monitorand-respond philosophy to a monitorand-prevent philosophy, with an
emphasis on predictive assessment and
proactive control.
PG&E has recently implemented a gas
distribution clearance process to permit
the GDCC to oversee safety monitoring
and risk mitigation from the inception
of a project through its completion.
PG&E has recently implemented an

enhanced gas mapper manual and
mapping apprenticeship program.
PG&E has established via multiple

leadership messages an expectation that
all employees and contractors stop a job
exception.
PG&Es program.
PG&Es program. PG&Es workforce
should not be experiencing an undue
number of damages to its gas lines. A
number of damages appear to be caused
by PG&E failure to hand dig to expose
its gas lines as required by its procedures
and damage prevention code.
Integration and control via the GDCC
represents a shift away from a monitorand-respond philosophy to a monitorand-prevent philosophy, with an
emphasis on predictive assessment and
proactive control. While this is laudable,
we have not evaluated whether and how
GDCC enables PG&E to respond to
emergency conditions in a timely
manner.
Additional centralized oversight should
add rigor and consistency to the
clearance process thereby helping to
prevent unsafe situations from
developing. PG&E has stated that this
new GDCC has allowed it to start
issuing clearances for work on the
distribution system, a practice that
should have been instituted well before a
central control became a reality.
Gas mapper manual and the mapper
apprenticeship program should help
improve map quality. However,
unmapped plastic inserts are still being
identified more than a year after
initiation of new programs.
PG&Es program, nor have we
determined how often or consistently
Judgment on Likely
Effectiveness (see
guidance preceding
the Table)
BP
MV
MV
II
BP
MV
BP
MV
II
EI
IP
MV
II
Page 66

Measures
if they discover a recordkeeping

inconsistency.
jobs are stopped when record

inconsistencies are identified.
Judgment on Likely
Effectiveness (see
guidance preceding
the Table)
Page 67
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
While, as shown in Table 9, PG&E has undertaken a number of improvement initiatives, other
opportunities, as yet untapped, may offer opportunities to address factors contributing to recent
incidents that are as yet unexplored. It appears from a response to a DR84 that PG&E is
opportunistically seeking out unmapped plastic inserts and stubs. That is, when a discrepancy appears
between what is shown on maps and records and actual or apparent conditions in the field, the
corrective action program is used to record and initiate resolution of the discrepancy. Additionally,
when a maintenance crew comes across an area with suspected inserts, a newly designed and revised
checklist is being used to determine if the main has been inserted.85 The number of known inserted
services is currently over 300,00086 and at least 3.9 million feet of main have been inserted.87 While
the work around procedure for addressing suspected inserts not shown on maps, by using a special
device to tap steel mains without damaging the suspected plastic inserts is a very useful backstop
measure, PG&E should consider implementation of systematic programs to identify and correct
mapping imperfections. Such programs could focus on identifying plastic inserts and stubs in addition
to incorrect location and gas line attribute data at third party excavation sites, which have contributed
to recent incidents, and will likely continue to contribute until they have been identified, characterized
and mapped.
17
18
19
20
21
22
23
Other than promoting greater awareness and improved locate practices, PG&E does not appear to have
developed a work around for stubs that are not on the maps.88 This will likely mean that damage will
continue to occur during excavation near existing mains, such as water and sewer main work. Of the
corrective actions that PG&E has proposed to address this concern, the Damage Prevention
Handbook89 which provides guidance on hard to locate or find facilities is noteworthy. However, it
seems to assume that the locator knows that a stub is present and decides to apply the difficult to locate
procedure.
24
25
26
For hard to locate conditions or locates that identify apparent discrepancies with the map, PG&E has
provided its locating staff with job aid TP 5811P-103-JA0190 in addition to the normal procedure TP
5811P-103 both of which appear to have been issued in 2013 based on their copy write date.
27
28
29
30
31
32
Until very recently91 there was no corporate procedure for obtaining a gas clearance to work on gas
distribution main, this contributed to the OII incident that interrupted service to almost 1000 customers
due to a valve being in the closed instead of open position. It appears that no one was tasked to verify
the valve position, or to monitor pressure in the line to ensure flow to customers. We believe that this
sort of event should not happen again since clearances, involving the gas distribution control center,
are now required for main work.
33
34
Overall Observations on the Effectiveness of PG&E Corrective Actions and Backstop Measures Based on continuing problems and the short time many of these backstops and corrective actions have
84
See response to DR SED 004-Q76 which includes a checklist on Bates No 00009180.
85
See response to DR SED 004-Q76 and is included in Form 61-0604 Job Site Safety Analysis form, Bates No.
000018820.
86
See responses to DR SED 003-Q60 and DR SED 001-Q11 as of 2013, respectively.
87
See response to DR SED 003-Q60.
88
89
90
See response to DR SED 001-Q09 Attachment 02.
91
See response to DRs SED 004-Q79.
Page 68
1
2
3
4
5
6
7
8
9
10
11
12
been in place, it is extremely difficult to determine the effectiveness or the possible unintended
consequences of these actions.
PG&E Management use of Internal Audits - PG&Es reliance on internal and external audits of its
programs, processes, and procedures is commendable. We were not, however, able to ascertain
whether the corrective actions that resulted from these audits were appropriate, timely and effective.
The corrective action forms were prepared and apparently closed out for many IA audits, but we did
not see evidence that internal audit performed a follow up to determine these qualities. Responsibility
for understanding the IA findings and following up on their implementation and effectiveness lies with
management. Ultimately, PG&Es Vice President of Gas Operations and/or CEO must assume
responsibility for follow through and assure that the high level vision translates into effective operation
on the ground.
8.3
Adequacy of Training
13
14
15
16
17
PWA has based its evaluation of the adequacy of training received by the PG&E staff that have an
impact on the completeness and accuracy of maps and records on interviews with six people in two
Divisions Central Coast and San Jose. These people were selected by PG&E as representative of
several key positions having records-related responsibilities. Table 10 below summarizes the
positions, responsibilities and training regimen which they must navigate to be qualified for their jobs.
18
19
Table 10 Evaluation of Training Adequacy

Position
Typical Responsibilities
Minimum Training, Oversight &

Update
Working
Foreman B,
General
Construction
Manages a crew of up to 5 people

working projects up to a year in length
Work covers excavation, installation, tieins, through backfill & patch
A single service installation requires
completion of from 6 to 10 forms
Gas Crew
Foreman,
Division
Construction
Manages leak repairs

If map corrections are identified as
necessary, a CAP (Corrective Action
Program) is filed, Gas Service Record
(GSR) and map correction form are
completed as part of the CAP process
On-job training (OJT) for three years;

from Utility Worker to Foreman B
requires at least 4 years
Retest/requalification every three years
Promotion based on training and
recommendation of supervisor
2 days training in use of application for
gas clearance form
Information needed on a job is
discussed at a tailboard
Field Engineer or other supervisor is
always accessible to help
Progression to foreman typically takes
about seven years, including a formal 30
month apprenticeship
Periodic one day workshops at which
procedures are reviewed and changes
suggested
Page 69
Position

Update
Sr Distribution
Engineer
Gas Associate
Distribution
Engineer
Mapping
Principal
Serves as a consultant on customer

inquiries
Supports the estimating group in
planning projects
Provides guidance on appropriate
standards for job or refers to expert
Supervises two estimators (estimators
checks the site, determines whether
buildable, develops drawings, generates
estimate, if/as required generates map
showing utilities in the vicinity, applies
for required permits)
Manages residential and small
commercial projects
May be responsible for projects up to
1,000 ft. of main replacement
Upon project completion a new as built is
prepared
Manages Gas Service Record (GSR)/Job
Packages in group that updates maps
Part of responsibility is to verify map
accuracy
Monitored job steps in mapping include:
o Completeness check to start
mapping;
o Start to map completion;
o Completion to end internal
review
Trained in job functions, e.g., preclearance endorsements using webbased training (WBT)
On-job training (OJT)
A three year apprenticeship program

with testing at six month intervals to
allow continuation, OJT card signed by
supervisor after six month test
Training included visits to job sites to
observe work in progress
Supervisor looks for training needs of
staff, use Web Based Training (WBT);
periodic update of qualifications for
individuals
Map Advancement Program (MAP) is

the training program, includes learning
procedures, tools, job aids and systems
There is a Mapper Manual, has access to
procedures electronically
Training requires two years, including
learning modules, OJT
Supervisor approves completion of
modules
When GD-GIS was initially introduced
in October 2014 for San Jose &
DeAnza - mappers received:
o 1 week Boot camp training
o 1 week on-site support from
developers
o Subsequent refresher courses
o Subsequent access to support to
address questions
o No formal qualification required
in use of the new system
Page 70
Position

Update
Gas Compliance
Representative
Locate & Mark
Has assigned service region (called a

Folder)
GCR has full responsibility for folder
from prioritization of L&M activities
through communication with excavator
Workload varies considerably with ease
of locate 4 to 5 per day in Milpitas; 20
to 30 per day in the Southern area (more
open)
Training required 1 month as trainee

(shadow L&M person), 1 month
shadowing a field construction crew, 2
weeks in L&M school (now 1 week),
then formal qualification and
assignment to the field as an
independent L&M person
1
2
3
4
Based on interview information it appears that training for the people we interviewed - which included
apprenticeships, OJT and qualification testing - was adequate. Additionally, if individuals have any
difficulty with their assignments, an expert is available to offer advice or assistance.
5
6
However, in response to DR SED 001 Q12 (see Attachment B), PG&E provided a recent internal audit
report92 in which it was noted:
7
8
9
10
11
12
We noted that the Utility hasn't designed its training program to ensure that all users
are identified and trained before they use the new systems and processes. Based on
our analysis of training records and leak repairs, approximately 700 users haven't
completed one or more of the training courses offered, and approximately 600 leak
repairs recorded after deployment showed that 212 of them (35 percent) were
recorded by users who haven't completed the related training.
13
8.4
14
Observations on Root Cause Analysis
In our experience a root cause analysis can be performed for many reasons, including:
15
16
a. Identifying a cause or contributing factor that, if corrected, will prevent future similar
accidents;
17
b. Identifying lessons that may promote the achievement of better consequences;
18
19
20
c. Identifying a set of contributing factors that inform both corrective actions and identification of
similar vulnerabilities (physical, operational, and cultural characteristics) for elimination or
change;
21
22
d. Evaluation of whether negligence contributed to the occurrence of or to adverse consequences such as economic loss, death or injury - from an event.
23
24
25
26
27
28
29
PG&E has a long-established root cause analysis program, including seeking outside expertise when
needed. Our concern here is twofold: (1) that PG&E failed to adequately identify and respond to the
causes of the incident at Mountain View, and (2) that a root cause analysis, such as that performed by
Exponent following the incident at Carmel (see Attachment F), whose scope focuses on the first of the
four reasons, potentially misses opportunities to identify important corrective actions. Additionally, a
root cause analysis focused on addressing the first three reasons cited above might also contribute
information of use in addressing the fourth reason (negligence related to liability). Thus, liability
92
PGE_GDR_000008321, Review of Leak Repairs and Rechecks Under Mariner Bundled Deployment,
Internal Auditing, January 30, 2015.
Page 71
1
2
concerns have the potential to seriously limit the value of a root cause investigation. Avoiding this
limitation seems critical to learning as much as possible from consequential events.
Page 72
9.
CONCLUSIONS AND RECOMMENDATIONS
9.1
Conclusions
3
4
Based on the information we have been provided, we have concluded the following regarding PG&E
violations:
5
6
1. Using the current and historic regulations and the standard of care we have proposed in Attachment
D, we have identified numerous violations.
2. Our investigation has assembled evidence of safety code violations of four types:
8
9
10
11
12
13
a. Evidence from recent incidents gathered in support of this OII indicates that PG&E has
failed to follow written procedures to ensure operating maps and data are updated and
accurate. Not maintaining control and updating historical records of gas distribution mains
and service lines. Repeated failure to correct recordkeeping violations despite having
adequate knowledge for decades. 49 CFR 192.603(b), 192.605(a), 192.605(b)(3),
192.13(c), and PU Code Sections 451 and 961.
14
15
16
b. PG&E has failed to mark out and inspect its gas lines in the area of excavation after
receiving valid Underground Service Alert notification in accordance with California
Government Code 4216.3(a)(1), as well as 49 CFR 192.614(c)(5) and 192.614(c)(6).
17
18
19
20
21
22
23
c. PG&Es approach to establishing the MAOP for 243 hydraulically independent distribution
systems is in violation of the 1970 requirement 49 CFR 192.619(c) describing the bases on
which MAOP is to be established for so called grandfathered segments of its system.
This approach disregarded the regulatory process. It is probable that this violation resulted
because of the absence pressure records during the years 1965 through 1970, needed to
comply. Note that General Order 58A (effective 07/01/32) Sections 20(c) and 20(d)
required retention of pressure records for a period of two years.
24
25
26
27
As yet we have seen no evidence that PG&E reviewed its alternative approach to
establishing MAOP with the CPUC until 2014, well after the 1970 regulation and the 1998
instructions provided by the Pipeline and Hazardous Materials Safety Administration
(PHMSA)93 identifying the need for regulatory review of alternative approaches.
28
29
30
Failure to meet operating pressure restrictions contained in 49 CFR 192.619(a), or

establish the maximum allowable operating pressure (MAOP) for 243 hydraulically
independent distribution systems in accordance with 49 CFR 192.619(c).
d. Regulations94 have existed for many years requiring utilities to understand their systems, to
evaluate the causes and implications of incidents, and to incorporate the lessons from these
investigations into utility policies, procedures and programs.
31
32
33
34
35
36
37
PG&Es handling of the incident at Mountain View (07/30/13), a clear precursor of the
incident at Carmel (03/03/14), supports the conclusion that PG&E has failed to comply with
these learning from experience regulations; until an incident is sufficiently high profile
that action must be taken.
38
39
Failure to carry out data gathering, to evaluate the causes and implications of incidents, and
to incorporate the lessons from these investigations into utility policies, procedures and
93
See PHMSA web site http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/maop_determination.pdf.

94
See for example 49 CFR 192.605(b)(8), 192.617, 192.1007, and 192.613.
Page 73
1
2
programs in accordance with 49 CFR 192.605(b)(4), 192.605(b)(8), 192.613, 192.617,

and 192.1007, and PU Code Sections 451 and 961.
3
4
5
Regarding the efforts by PG&E to correct and provide backstops for recognized imperfections in maps
and records and deficiencies in their maintenance, we have concluded, based on the information we
have been provided, the following:
6
7
8
1. PG&E maps and records have suffered from years of neglect, leading to a situation in which maps
are inaccurate and records are incomplete; the inaccuracy and incompleteness has contributed to
numerous incidents, some serious.
9
10
11
2. PG&E has recognized the need to improve its maps and records, has sought funding in the 2014
general rate case, and is proceeding (through the Pathfinder Project) to complete many needed
improvements to its maps and records.
12
13
14
15
16
17
18
3. Through the Pathfinder Project, PG&E is undertaking a major consolidation and quality
improvement effort of its maps and records in GD-GIS and SAP. While this effort will
significantly improve their quality and accessibility, PG&E has given no assurance that the
resulting maps and records will be completely accurate. Therefore measures will continue to be
needed both to backstop work procedures and to continuously improve and maintain the accuracy
of maps and records. PG&E has put many such measures in place, but vigilance will be required to
ensure their effectiveness.
19
20
21
22
23
4. Other than a corrective action program (CAP) to allow inconsistencies between maps and field
observations to be resolved and maps corrected, PG&E has not yet undertaken a systematic
program to identify and correct two of the major sources of incidents resulting from mapping errors
and gaps: unmarked or incorrectly marked stubs, and unmapped plastic inserts in steel mains and
services.
24
25
26
27
5. To address the fact that its maps and records will not be completely accurate, PG&E has instituted
numerous backstop measures to minimize the impact of map and records inaccuracies on public
and worker safety. Management vigilance will be required to assure the effectiveness of these
measures.
28
29
30
31
6. While PG&E has root cause analysis procedures and processes to identify and address root causes,
evidence from the Mountain View and Carmel incidents (which occurred seven months apart)
indicates that these procedures and practices have not addressed underlying issues on a time frame
consistent with their risk significance.
32
33
34
35
36
37
7. While the advertised time for incorporating changes from new construction and certain
maintenance activities (those classified as capital) in the maps and records is less than thirty days,
evidence exists from SED inspections carried out in July and August of 2015 that some updates
require much longer, potentially leading to a false sense of confidence in the accuracy of maps and
records residing in the GD-GIS - that have been processed in the Pathfinder Project. Recent
evidence also suggests a disconnect between quality expectations and results.
38
39
40
41
42
43
44
45
8. The improvements being undertaken by PG&E include basic changes to the way operations,
maintenance and construction activities are carried out. These changes, together with more
focused improvements on activities affecting incident frequency such as locate and mark practices,
all require changes in implementing procedures and related training. To develop these procedures,
PG&E has involved the performers of related activities, thereby increasing the likelihood that basic
content and implementation issues will be effectively addressed. However, the rate of introduction
of and change to these procedures imposed unprecedented training demands and has the potential
to cause confusion, indifference and to increase error rates.
Page 74
1
2
3
4
5
6
9. PG&E has implemented a system of internal audits based on identified management concerns and
the level of risk among other factors. In addition, it has implemented a quality management
program, including quality assurance and quality control involving periodic routine audits. Based
on our review of IA reports and follow-up action plans, we believe PG&E management is making
good use of these processes to monitor the impact, as well as potential unintended consequences of,
its improvement programs.
7
8
9
10
10. In our experience, successful navigation of the transition PG&E is undertaking will require
constancy of executive attention and visible behavior supporting the desired changes over a period
of at least a decade. This magnitude of sustained commitment has historically been difficult for
PG&E to achieve.
11
12
13
14
15
16
11. PG&E does not have a program to reduce and eventually eliminate unused service stubs. With all
18 divisions moved to the Pathfinder Program, a small known problem has escalated to a much
larger one with over 71,000 known stubs on the gas distribution system. Recent incidents have
highlighted that PG&E has problems not only with the accurate mapping of known service stubs
but also with unmapped stubs. This problem has grown over decades, and an aggressive removal
program may be necessary to stem the tide.
17
18
19
20
21
22
23
12. Weak safety culture has been an historic problem at PG&E. Inconsistent and destructive
management behaviors, underpinned by inappropriate safety values, have apparently contributed to
this state of affairs. Current management seems to recognize and to be equipped to address this
serious concern however PG&Es Vice President of Gas Operations and/or CEO must assume
responsibility for recordkeeping quality expectations and meeting pipeline safety compliance.
Strengthening the safety culture is a long-term job, requiring visible management-level attention
and demonstration of the behaviors characteristic of the values the organization wished to promote.
24
9.2
Recommendations
25
26
27
28
29
30
31
32
1. There are two map and records-related issues that PG&E has decided to address through
opportunistic approaches, that is, make map corrections as the need is identified through
normally scheduled work in the field. These issues are unmapped or incorrectly mapped stubs, and
plastic inserts that are not shown on GD-GIS maps. While PG&E has initiated practices to
minimize the risk associated with unmapped plastic inserts, identifying unmapped and incorrectly
mapped stubs is left to the skills of the L&M staff. PG&E should examine the costs and benefits
associated with undertaking a systematic identification and correction effort for these features,
relying on the experiences of other utilities in dealing with these issues.
33
34
35
36
2. Even stubs currently shown on maps have been a source of locate errors and resultant excavation
damage. While PG&E has a policy for addressing these mapped, but often inappropriately
characterized stubs, it should, again considering risk tradeoffs, reexamine the wisdom of more
aggressively eliminating existing stubs.
37
38
39
40
41
42
43
44
45
3. Documentation provided by PG&E has revealed that the utility has established the MAOP for 243
hydraulically independent distribution systems using an approach that deviates from that required
by the 1970 version of 49 CFR 192.619, and for which formal CPUC approval was neither sought
nor granted. These systems are part of a group of grandfathered systems for which the MAOP
was established using approaches other than pressure testing. Often older systems are part of a
long-term systematic replacement program. PG&E should reexamine the risk characteristics on
which priorities for replacement of these older systems are based to assure that the adequacy of
MAOP establishment is appropriately considered. PG&E should also evaluate whether the
alternative approach to establishing MAOP for these systems, for example by certification of the
Page 75
1
2
highest pressure attained during the required five year window, contributes to the risk represented
by these systems, and if so, propose measures to deal with this higher risk.
3
4
5
6
7
8
9
4. In our review we have observed that PG&E management uses the Internal Audit (IA) function as
an ingredient in its vigilance to evaluate aspects of new systems and programs about which it has
concern. In each case following an IA report, the responsible PG&E operating division develops
an action plan to address the IA findings. The CPUC should take advantage of these insights into
potential soft spots in the massive change effort being undertaken by PG&E to help focus its
inspections, perhaps on the adequacy of the action plan given the IA findings on the effectiveness
of implementation, and on the impact of corrective actions.
10
11
12
13
5. Several recent SED inspections included reviewed to determine whether plastic pipe inserted in
existing steel lines have been adequately mapped. This is a useful approach, and should be
extended to focus on the results of major maintenance activities undertaken subsequent to full
implementation of the new GD-GIS and its associated practices and procedures.
14
15
16
17
18
19
20
21
22
23
6. In our view, an effective root cause analysis program focused on incidents, on close calls, and on
repetitive violations of regulatory requirements is a critical part of strengthening PG&Es safety
culture. Clearly, the nature, scope and effectiveness of corrective actions resulting from identified
root cause analyses will communicate management commitment to strengthening safety culture to
the organization. Our belief is that the Exponent Report95 on the underlying causes of the incident
at Carmel missed the mark in demonstrating this commitment, principally by imposing an
excessively narrow definition of root cause If the removal of a contributing cause prevented
the occurrence of the problem, this cause was considered a root cause. PG&E should consider
reexamining both how it defines root cause and how it integrates corrective actions related to those
root causes into existing management practices. Objectives of a root cause analysis might include:
24
25
a. Identifying a cause or contributing factor that, if corrected, will prevent future similar
accidents;
26
b. Identifying lessons that may promote the achievement of better consequences;
27
28
29
c. Identifying a set of contributing factors that inform both corrective actions and
identification of similar vulnerabilities (physical, operational, and cultural
characteristics) for elimination or change.
30
95
Carmel Gas Incident, Exponent, Failure Analysis Associates, April 2014, Doc. no. 1401752.000 6877.
Page 76
ATTACHMENT A
QUALIFICATIONS OF PWA STAFF
Overview
Paul Wood, currently a principle in P Wood Associates, was a founder and partner in Cycla
Corporation which over the last 15 years has assisted the US Department of Transportation in writing
and evaluating pipeline safety regulations for gathering lines, gas distribution systems and gas
transmission systems. He has also previously done work for the CPUC in evaluating the PG&E 2014
GRC proposals.
John Gawronski a professional engineer with over 46 years of experience is expert in all matters
affecting public safety due to the operation of natural gas, petroleum, and steam pipeline systems. He
specializes in pipeline safety inspection processes, code compliance and enforcement policies for
inspections, and evaluating risks associated with gas distribution systems. For over 25 years, he was
the Chief of Gas & Petroleum Safety, for the New York Public Service Commission, addressing all
matters affecting public safety due to operation of the States natural gas, petroleum, and steam
pipeline systems. Prior to joining the Commission, John served at a forerunner of National Grid
(Brooklyn Union Gas Company) as a Field Engineer, Senior Engineer, and Section Manager. John
Gawronski has provided consulting service on gas and steam system issues for the last 12+ years for
various State and Federal clients.
David Berger has also been doing gas system and pipeline system consulting for 10+ years for various
federal and state clients including incident investigations and expert testimony. Prior to becoming a
consultant, he worked in gas operations for 15+ years in a forerunner of National Grid (KeySpan
Energy which was the combination of the gas operations of Brooklyn Union, Boston Gas and Long
Island Lighting).
Resumes for these three individuals follow.
Page 77
Paul J Wood
Summary
Employment
Mr. Wood has over 35 years experience in developing risk management and process safety programs
for industrial facilities ranging from nuclear power and fuel processing plants to pipeline facilities. He
has worked with regulators and operators to identify common goals as the basis for implementing
mutually agreeable approached to managing health and safety risk.
2015 Present
P Wood Associates
Executive Consultant
Naples, FL
1990 2014
Cycla Corporation
Alexandria, VA
Senior Partner
CoFounder of Cycla Corporation
A key manager for multiyear prime contracts with Department of Energy and Department of
Transportation
Education
19721973
Massachusetts Institute of Technology
ScD Nuclear Engineering
Cambridge, MA
19661968
Massachusetts Institute of Technology
S.M. Nuclear Engineering
S.M. Chemical Engineering
Cambridge, MA
19621966
Purdue University
B.S. Chemical Engineering
West Lafayette, IN
Major Projects P i p e l i n e and Hazardous Materials Safety Administration

Over twelve years experience in the development and implementation of a riskbased regulatory
program for the pipeline industry, including supporting development of Integrity Management
regulations for the natural gas transmission and distribution pipeline industries, development of
standards for evaluating the qualifications of pipeline operators, and expansion of the pipeline
R&D program. Also, participated in developing the technical basis for the NACE recommended
practice on external corrosion direct assessment; and consulted with the Alaska Department of
Environmental Conservation in determining how to characterize the risk of Alaskas pipelines.
Recently completed an evaluation of the safety elements of the 2014 PG&E Gas Distribution General
Rate Case filing for the CPUC.
Department of Energy
Developed and implemented a riskbased resource management systems used to gain regulatory
acceptance for resumption of operation of a research reactor in an environment of great political
uncertainty. The systems were later expanded to support a Department-wide strengthening of
safety management practices. Also, managed the process leading to acceptance by the US Nuclear
Regulatory Commission of the operational readiness of the uranium enrichment complex
following decades of superficial internal regulation.
United States Nuclear Power Industry
Managed application-oriented probabilistic risk assessments at several nuclear facilities, both in
design and in operation. Developed and implemented riskbased resource management systems at
numerous commercial nuclear power plants. These systems were instrumental in guiding a more
orderly safety improvement process following the accident at the Three Mile Island nuclear plant.
Page 78
DavidB.Berger,Principal
DavidBergerAssociates
AreasofSpecialization
Mr.Bergerspecializesinpipelineandsystemintegritymanagement,corrosioncontrol,gasinfrastructureasset
management,andgassystemoperationandsecurity.
RelevantExperience
Mr.Bergerhasbeeninvolvedinratemakingcasesforgasdistributioncompaniesformanyyearsfromboth
theoperatorandregulatoryperspective.MostrecentlyheadvisedtheMainePUConaratecaseforthe
largestgasdistributioncompanyinthestateandinparticularontheirproposedinfrastructurereplacement
program.Previouslyhehadperformedasafetyandmanagementauditonthiscompanyforthecommission
staffaspartofsettlementagreement.WhenMr.BergerwaswithKeySpanEnergy(nowpartofNationalGrid)
hewasinvolvedinseveralratecaseswithregardtogasmeteringandcorrosioncontrolissuesalongwith
infrastructureimprovements(systemintegrityakaDIMP).
Mr.BergerperformedtwomanagementauditsfortheNewYorkPSConthreegasdistributioncompanieson
theirrecentlyapprovedratecaseswithregardtosafetyprogramsandmainandservicecapitalreplacement
programs.Theseauditsincludedthestateslargestutilityandalsoamoreruralutility.
Mr.Bergerwasthetaskarealeaderfortheareasofcorrosioncontrolandemergencyplansinaninvestigation
ofoperationalsafetyfortheIllinoisCommerceCommission.TheauditreviewedandevaluatedanLDCsoverall
operationsandmaintenanceactivitiesanditsgassafetyprogramstodeterminethedegreetowhichtheyare
incompliancewithfederalandstateregulationsandconformanceofthoseactivitiesandprogramwith
industrybestpracticesandthebestpracticesdeterminedbytheICCStaffinconsultationwiththeLDC.
HeisconsultingfortheVermontPublicServiceDepartmentonevaluatingthesafety,constructionand
operatingissuesonproposedexpansionwhichrequiresacertificateofpublicgood.Thisexpansionwillinvolve
bothtransmissionanddistributionpipelinesandmains.
Hewasthetaskarealeaderforgasoperationsinaninvestigationofoperationalsafetyandmanagement
practicesofasmallgasoperatorfortheNewJerseyBoardofPublicUtilities.
Heprovidedexpertreviewandpossibletestimonyregardingasafetyissueonmechanicalcouplingsforthe
DistrictofColumbiaPublicServiceCommission.
Mr.BergerisundercontracttoUnitedStatesDepartmentofTransportation(DOT)PipelineandHazardous
MaterialsSafetyAdministration(PHMSA)toassistindevelopingandimplementingagasandliquidpipeline
integritymanagementprogramandtoassistininspectingoperatorsofpipelinesthroughCyclaCorporation.He
istheauthorandinstructoratPHMSAsTrainingandQualificationsSection(T&Q)ondirectassessment
trainingmodulesforExternalCorrosionDirectAssessment(ECDA)(includingacourseonECDAindirect
Page 79
inspectiontechniques)InternalCorrosionDirectAssessment(ICDA),StressCorrosionCrackingDirect
Assessment(SCCDA),andConfirmatoryDirectAssessment(CDA).Inaddition,heisaconsultanttoPHMSAon
integritymanagementnotifications,specialpermits(suchasalternateMAOPandclasslocationchanges)and
corrosioncontrolissuesforbothgasandliquidpipelines.
HeconsultswiththeWashingtonUtilitiesandTransportationCommissionforcorrosioncontrolandintegrity
issuesandprovidesexpertadviceregardingcommissioninvestigationsandconsentorderspertainingtogas
infrastructureissues.Heisatechnicalconsultantforariskmodelregardingdistributionintegrityissues.
Currentlyheisperformingavalidationauditontheimplementationofauditrecommendationsastheoutcome
ofconsentorder.
MostrecentlyMr.BergerhasbeenretainedbytheCaliforniaPUCtoassistinaninvestigationofanincidenton
atransmissionpipelineinNorthernCalifornia.Hehasassistedcommissionstaffwithpreparingrelevant
documentsandreviewedandcommentedondocumentsprovidebytheutility.
Mr.BergerisalsoundercontractasatechnicalexpertandpossibleexpertwitnessfortheUSDepartmentof
Justice.Heiscurrentlyworkingonacasethathasbeenproposedforlitigationinvolvingfatalitiesand
significantpropertylosses.
HeisworkingfortheFloridaDepartmentofTransportationasanexpertwitnessinalitigationconcerninga
rightofwayissuewithgaspipelinealongtheFloridaTurnpike.
UntilJuly2004,Mr.BergerwastheDivisionManager,AssetManagement,forKeySpanEnergy(nowpartof
NationalGrid).Inthiscapacity,hemanagedagroupofengineers,clerks,technicianassistants,supervisors,and
fieldlabortoassess,maintainandimprovetheassetsofthegasinfrastructure(bothdistributionand
transmissionfacilities)andthecathodicprotectionsystemsonallKeySpanEnergygasandelectricfacilities
(LongIsland,NewYorkCity,NewEngland).HewastheprocessownerofKeySpanEnergysgastransmission
systemanddirectedtheoverallcorrosioncontrolprogramsforallKeySpanEnergysassets(gas,electric,
electricgeneration).Manyoftheissuesheprovidedguidanceonrelatedtoimplementationofimprovements
inthegasdistributionassetsoneofwhichincludedworkonamechanicalcouplingissuerelatingtochangein
gasquality.Heprovidedguidancetocorporatesecurityongasoperationalsecurityissuesandimplemented
securityplansforthegasinfrastructureinallserviceareas.Hewasadeveloperofthedirectassessment
methodofdetermininggaspipelineintegrity.
InthepositionofsectionheadoftheEnvironmentalEngineeringDepartmentforKeySpan,Mr.Berger
managedagroupofengineersthatwasresponsibleforallofthehazardouswaste,industrialwasteand
petroleumstoragefacilitiesforthecompany.Henegotiatedpermitsandcompliancescheduleswithalllevels
ofregulatoryofficials(local,county,stateandfederal).Hepreparedandsubmittedallsuperfundandother
legalnotifications.Heprovidedsupporttooperatingorganizations,legaldepartment,andfuelmanagement
personnelforenvironmentalmatters.
PriortohisemploymentatKeySpan,Mr.BergerwastheDirectorofOperationsforRussellPlasticsTechnology
Inc.andaPlantManagerforICIAmericas,Inc.AerospaceandChemicalDivisions
Education
UniversityofDelaware,coursework(32+credits)forM.S.inEnvironmentalEngineering
NewYorkUniversity,B.Ch.E.(ChemicalEngineering)
OtherHonors,Societies,andPapers
Page 80

MemberA.I.Ch.E.
MemberNACE
AuthorandcoauthorofpapersinWPCF,AGA,NACE
AGACorrosionControlCommitteeChairperson2000to2004
AGADistributionEngineeroftheYear,2002
CIS,PCMandACVGCorrosionTools
AGAAchievementAwards,2003,2004
BassTrigonCorrosionControlDataBase
NumerouspapersinvariouspipelinetechnicaljournalsandNACEpublications
NewYorkStateRegentsScholarship(College)andIncentiveAward
Page 81
John E Gawronski
AreasofSpecialization
Mr.Gawronskispecializesinpipelinesystemintegritymanagement,leakmanagement,naturalgas
infrastructureassetmanagement,gassystemoperationandsecurity.
RelevantExperience
Mr.Gawronskihasbeeninvolvedinratemakingcasesinvolvinggasdistributioncompaniesformanyyears
fromtheregulatoryperspective.Priorto2004whenMr.GawronskiwaswiththeNewYorkStateDepartment
ofPublicService,hewasresponsibleforgassafetyoversightofthepublicandmunicipalgasdistribution
companiesoperatinggaspipelinesthroughouttheState.Inthatcapacityhehasreviewedtheengineering,
assetplanningandoperationsofallmajorNewYorkcombinationcompaniesandgasutilities,includingsenior
supervisoryresponsibilityforstaffinvestigationsofsignificantincidentsandaccidents,andotherunusual
events.HewasthesenioradvisortothePublicServiceCommissiononallmattersinvolvingpipelinesafety,
includingevaluatingratecaseproposals,operationsandmaintenanceactivitiesandvulnerableinfrastructure
replacementprogram,aswellaswellasthedevelopmentofkeypipelinesafetymetricsforutilityoperators.
HehasadvisedtheMainePUCaspartofasettlementagreementinperformingasafetyandmanagement
auditonthelargestgasdistributioncompanyinthestateprimarilyevaluatingrecords,leakmanagement
activitiesandinfrastructurereplacement.
HehasparticipatedinTransmissionIntegrityManagementPlanreviewsandinspectionswiththeUSDOTof
transmissionpipelineoperators,andhasassistedtheUSDOTindevelopingsecurityinspectionprotocols
regardinggasoperatorsinfrastructure.
Mr.Gawronskiwasthetaskarealeaderfortheareasofleakmanagement,managementandmaintenanceof
systemassetsincludingevaluationofvulnerableinfrastructurereplacementprograms,systemsupport,and
recordsinaninvestigationofoperationalsafetyfortheIllinoisCommerceCommission.Theauditreviewedand
evaluatedanLDCsoveralloperationsandmaintenanceactivitiesanditsgassafetyprogramstodeterminethe
degreetowhichtheyareincompliancewithfederalandstateregulationsandconformanceofthoseactivities
andprogramwithindustrybestpracticesandthebestpracticesdeterminedbytheICCStaffinconsultation
withtheLDC.
FortheDistrictofColumbiaOfficeofPeoplesCounsel,Mr.Gawronskiiscurrentlyparticipatinginagas
distributionoperatorsratecaseevaluatingproposedreplacementprogramsofbaresteel,unprotectedcoated
steel,castironmainsandvulnerableservicelinesandmechanicalcouplings.AlsofortheOfficeofPeoples
Counsel,hepreviouslyevaluatedthesafetyandmaintenancepracticesofthissamegasdistributionoperator
regardingvulnerablevintagesofmechanicalcouplingsresultinginthedevelopmentofamechanicalcoupling
replacementprogram.
InaratecaseproposalbyamajorConnecticutgasdistributionoperator,Mr.Gawronskiadvisedthe
ConnecticutOfficeofConsumerCounselinevaluatingtheutilitysleakratesandproposedcastironand
unprotectedsteelinfrastructurereplacementprograms.
Page 82
MostrecentlyinCaliforniaonbehalfoftheCityandCountyofSanFrancisco,Mr.Gawronskiwasthetask
leaderinevaluatinganddevelopingtestimonyonPacificGasandElectricsGasTransmissionPipeline
ModernizationandTestingProgram,hesubmittedtestimonyinproceedingsinvolvingPG&Estransmission
facilitiesrecords,andviolationsinconnectionwiththeSanBrunoexplosionandfireonSeptember9,2010.
PriortocomingtoworkfortheNewYorkStatePublicCommissionin1977,Mr.Gawronskiheldpositionswith
amajorgasutilityintheNewYorkCityarea.ThosepositionsincludedFieldEngineer,SeniorEngineer,and
SectionManager.AsSectionManagerhemanagedafieldsectionconsistingof170+employeesand
contractors.AsSeniorEngineerfordistributionoperations,providedoversightofthedesignofmajorpipeline
systems,ensuredupdatedmappingsystems,andinterfacedandcoordinatedactivitieswithpermitting
agencies.AsFieldEngineer,heprovidedoversightoftheconstructionofnewpipelines,aswellasthe
maintenanceandemergencyresponseandleakrepairactivitiesofcompanyandcontractorcrews.
Education
M.S. MechanicalEngineering,TheCityCollegeofNewYork(CUNY),1974
B.S.
MechanicalEngineering,TheCityCollegeofNewYork(CUNY),1969
OtherHonors
Mr.GawronskiservedasChairoftheUSDOTTechnicalPipelineSafetyStandardsCommittee.
Page 83
ATTACHMENT B
SUMMARY OF DRS AND STATUS OF RESPONSES
STATUS AS OF SEPTEMBER 28, 2015
The table below shows that PG&E has submitted one or more responses to all SED questions except
the three that were deleted by mutual agreement.
DR #
Date
Request
Submitted
PG&E Responses
to Date
Comment on
Response
March 4,
2015
Provide all PG&E policies and

procedures published and
implemented related to
underground gas distribution
facilities mapping since 1970.
March 4,
2015
Provide all PG&E record-retention

policies and procedures related to
gas distribution assets since 1970.
March 4,
2015
Provide a list of all PG&E policies

and procedures, including
identification of the forms used
and record retention
requirement(s), that address the
installation of distribution mains
as required in Subpart G
(construction requirements for
mains) of Part 192 since 1970.
These include PGEGDR-5458 thru 5920;

PGE-GDR 5925 thru
6113; PGE-GDR 12621
thru 15348;
PGE-GDR 15349 is
index
Att01 thru Att10
include PGE-GDR0001 thru 0050;
Supp01 includes PGEGDR-6118 thru 7485
These include PGEGDR-5921, PGE-GDR6114, PGE-GDR15350
March 4,
2015
March 4,
2015

installation of service lines as
required in Subpart H (customer
meters, service regulators, service
lines) of Part 192 since 1970.
SED-001-Q01;
SED-001-Q01 (Att
001 thru Att 086);
SED-001-Q01
Supp01;
SED-001-Q01
Supp02
SED-001-Q02; SED001-Q02 Att01 thru
Att10;
SED-001Q02Supp01;
SED-001-Q03;
SED-001-Q01Q03Atch001;
SED-001Q03Supp01;
SED-001-Q03Supp02
SED-001-Q04;
SED-001Q04Atch001 (PGEGDR-5922);
SED-001Q04Supp01;
SED-001-Q04Supp02
Resubmit (PGEGDR-6115)
SED-001-Q05;
SED-001Q05Atch001 (PGEGDR-5923);
SED-001-
These include PGEGDR-5922, PGE-GDR6115, PGE-GDR15351
These include PGEGDR-5923, PGE-GDR6116, PGE-GDR15352;

SED-001-Q05Atch002
Page 84
DR #
Date
Request
Submitted
March 4,
2015
March 4,
2015
March 4,
2015
March 4,
2015
10
March 4,
testing of distribution facilities as

required in Subpart J (test
requirements) of Part 192 since
1970.
Provide a list of all historical and
current forms used to document
compliance with the requirements
of Subpart M (maintenance) of
Part 192 related to gas distribution
facilities. For each form, provide
the effective date and the
corresponding PG&E procedure
that references the use of the form.
Provide a list of all historical and
current database programs used by
PG&E that contain data related to
the construction, operations, and
maintenance of gas distribution
assets. For each database
program, provide a description of
the type of gas distribution asset
data contained.
Provide a list of excavation
damages caused by PG&Es
mismarking of underground gas
distribution facilities from January
1, 2004 to December 31, 2014.
On the list, please provide the date
the incident occurred, address
where the excavation damage
occurred, excavator or damaging
party, and description of
distribution facility material
damaged by the excavation
including type of material (steel,
PE, etc.), size and operating
pressure at the time of the incident.
What is PG&Es procedure for
documenting and tracking locate
and mark requests where PG&E
field locators indicate difficulties
or challenges in locating the
subsurface distribution facilities?
Describe how PG&E monitors and
PG&E Responses
to Date
Comment on
Response
Q05Supp01; SED001-Q05Supp02
is PGE-GDR-6116
SED-001-Q06;
SED-001Q06Atch001 (PGEGDR-5924)
SED-001Q06Supp01; SED001-Q06Supp02;
SED-001Q06Atch002
SED-001-Q07; SED001-Q07Supp01
SED-001-Q06Supp01
is PGE-GDR-6117
See also PGE-GDR5924 and PGE-GDR15353
SED-001-Q08; SED001-Q08, Rev 1;

SED-001Q08Atch01CONF
(this is PGE-GDR0060); SED-001Q08Atch02CONF
(this is PGE-GDR5457); SED-001Q08Supp01; SED001-Q08Supp02 (this
is PGE-GDR-5457)
SED-001-Q08Supp02
includes PGE-GDR12399 thru PGE-GDR12466;
18 reportable in 2010
thru 2014;
7 reportable in 2004
thru 2009
SED-001-Q09; SED001-Q09Atch01 thru

Atch05
See PGE-GDR-0061
thru 0091
SED-001-Q10; SED-
SED-001-
List is in PGE-GDR0060;
Page 85
DR #
Date
Request
Submitted
PG&E Responses
to Date
Comment on
Response
2015
001Q10Atch01CONF;
SED-001Q10Atch02CONF;
SED-001Q10Atch03CONF
thru Atch608
Q10Atch03CONF thru
Atch609 is an index of
the 608 Attachments
See PGE-GDR-0098
thru 4651
SED-001-Q11
352,479 inserted of
2,155,290 PE services
SED-001-Q12;
SED-001-Q12Supp01
SED-001-Q12Supp02
SED-001-Q12Supp03
SED-001-Q12Supp04
Include documents with

Bates numbers (Internal
Audits) PGE-GDR7486 thru 8372; (CAP)
PGE-GDR-9228 thru
12398;
(QA reviews) PGEGDR-15354 thru
17277;
(CAP) PGE-GDR21063 thru 21377,
21383, 21519, 21524
thru 22083, and 23104
thru 23591;
(3rd Party Assessments)
PGE-GDR-30270 thru
30899; (CAP Items)
PGE-GDR-33479 thru
36211
11
March 4,
2015
12
March 4,
2015
13
May 29,
2015
inspects applicant-installed
distribution facilities. Please
provide copies of all such policies
and procedures, including forms
used by PG&E to do final
inspection(s) prior to serving gas
to applicant- installed distribution
facilities.
In PG&Es Gas Distribution
System Annual Report for
Calendar Year 2013, PG&E
reports 2,155,290 Plastic PE
services. Please identify the
number of these PE services that
are inserted into an existing
conduit such as a deactivated steel
service line.
Provide each and every document
in your possession that references
PG&Es gas distribution recordkeeping problems. Include all
audit records regarding PG&Es
gas distribution recordkeeping,
and indicate the dates of such
audits, the personnel involved, and
any corrective actions taken.
Please provide documentation on

the bases of internal PG&E
requirements (policies and
procedures) in data requests #1and
#2 (e.g., regulations, consensus
standards, rate case commitments,
lessons from operating
experience).
SED-002-Q13
Page 86
DR #
Date
Request
Submitted
PG&E Responses
to Date
14
May 29,
2015
SED-002-Q14
15
May 29,
2015
Please identify the purpose for

records and mapping
documentation policies and how
have PG&Es control requirements
in data requests #1and #2 (e.g.,
support design, installation,
operations and maintenance needs,
allow accurate pipe location)
Please provide all internal and
external audits or consultant
reports addressing records or
mapping issues for the gas
distribution system from 1985 to
current date.
SED-002-Q15
SED-002-Q15Supp01
SED-002-Q15Supp02
SED-002-Q15Supp03
SED-002-Q15Supp04
SED-002-Q15Supp05
SED-002-Q15Supp06
Comment on
Response
PGE indicates this is

redundant to SED-001Q12; Lloyds Register
documentation
provided as PGE-GDR12467 thru 12506
(Stage 1) and PGEGDR-12507 thru 12548
(Stage 2); Lloyds
Register surveillance
visit documentation
provided as PGE-GDR12549 thru 12584 and
PGE-GDR-12585 thru
12620
GTS Records Reviews
PGE-GDR-18735 to
18743, 18745 to 18774,
25310 to 26162
SED GO 112-E audits
(1996 2014) PGEGDR-18861 to 21062
Responsive External
Audits PGE-GDR24546 to 25112
Internal Leak Surveys
and repair audits PGEGDR-25113 to 25264;
PGE-GDR-31906 thru
33007; (GO112-E
Audits) PGE-GDR36818 to 36867;
PGE-GDR-36950 to
36987; PGE-GDR37038 to 37060;
PGE-GDR-37551 to
Page 87
DR #
Date
Request
Submitted
16
May 29,
2015
17
May 29,
2015
18
May 29,
2015
19
May 29,
2015
For 2000, 2005, 2010 and 2015,

please provide organization charts
for those departments or sections
that were tasked with providing,
receiving, verifying, and recording
records relating to the safe
maintenance and operation of the
gas distribution system These
should include but not be limited
to: initial construction, operations,
maintenance, leaks, repairs, capital
improvements, replacements,
review of operating experience
including evaluation of exposed
pipe reports - to identify
deficiencies and the need for
broader mapping and records
requirements, and modification.
Please provide a list of individuals
who headed the gas distribution
records section since 01/01/2000
to the present date and their tenure
in the position.
Please provide a list of all
distribution system events and
near misses from 01/01/2000 to
the present that meet any of the
following criteria: a) reported to a
regulatory authority under code; b)
self-reported; c) identified as a
close call, d) led to evaluations of
inconsistencies between records
and field experience that identified
lessons resulting in changes to
records or mapping practices or
procedures, e) resulted in the
unplanned release of gas.
Please provide all reports,
regulatory citations, root cause
analyses, and other documentation
relating to the events and near
PG&E Responses
to Date
SED-002-Q16
SED-002-Q16Supp01
SED-002-Q16Supp02
Comment on
Response
38340;
PGE-GDR-38349 to
38938
Includes PGE-GDR8583 and a table
describing PGE-GDR
documents (by Bates
number) containing
various Departments;
Tables of documents
highlighting
organizations based on
the type of utility
supported;
On 07/13/15 Mr. Nick
Stavropoulos became
President Gas
Operations;
PGE-GDR-38348 &
38939
SED-002-Q17
Since late 2012 this

function has been
consolidated and has
had four (4) managers
SED-002-Q18
SED-002-Q18Supp01
SED-002-Q18Supp02
References document
in response to SED002-Q19 and Q20, as
well as SED-001-Q08
and Q12; also refer to
SED-002-Q19Supp01;
also refers to response
to SED-002Q19Supp02
SED-002-Q19
SED-002-Q19Supp01
SED-002-Q19Supp02
Referenced documents
in response to SED001-Q08 and Q12;
Additional CAP data
Page 88
DR #
Date
Request
Submitted
PG&E Responses
to Date
misses in data request #18.
20
May 29,
2015
21
May 29,
2015
22
May 29,
2015
23
May 29,
2015
Please provide documentation

describing the corrective actions
identified following events having
records-related contributing
factors; records of completion of
corrective actions and evaluation
of their effectiveness.
Please provide a list of the
locations where gas distribution
system records needed to support
pipe design, operation,
maintenance, location and pipe
modification are kept and
specifically what records are at
each location. If the records are
digital, please provide a list of
where/how access to those records
can be obtained.
Custody of records please
describe how and where
responsible individuals obtain
historical maps and asset records,
and historical responsibility for
archiving.
Please describe the procedural
requirements for accessing asset
records in support of operational
and maintenance activities.
SED-002-Q20
SED-002-Q20Supp01
SED-002-Q20Supp02
Comment on
Response
base PGE-GDR-18302
thru 18466
Additional selfidentified noncompliances as PGEGDR-22739 to 22825
Excel of events & nearmisses (2004 thru
07/08/15) PGE-GDR23098 thru 23103 and
30022 thru 30027;
PGE-GDR-26163 thru
30021
Refers to response to
SED-002-Q19;
also refer to SED-002Q19Supp01; refers to
response to SED-002Q19Supp02
SED-002-Q21
Refers to PGE-GDR9188 (Excel

spreadsheet)
SED-002-Q22
Response references
earlier submittals in
response to SED-001Q02 and Q02Supp01;
Lists Bates numbers of
specific procedures
SED-002-Q22;
Also refers to response
to SED-001-Q09 or
SED-002-Q32 listing
Bates Stamp (GDR)
Numbers
SED-002-Q23
Page 89
DR #
Date
Request
Submitted
PG&E Responses
to Date
Comment on
Response
24
May 29,
2015
SED-002-Q24
25
May 29,
2015
If PG&E is going to change how

and where records are currently
stored please provide a timetable
and an explanation of the changes.
Please provide a listing of
currently known missing
document types and how PG&E
proposes to obtain the necessary
information.
26
May 29,
2015
Please provide descriptions of

programs and personnel assigned
each year for the past 10 years to
correct and update recognized
asset record deficiencies and gaps,
and verification initiatives.
SED-002-Q26; SED002-Q26, Rev 1
27
May 29,
2015
SED-002-Q27
28
May 29,
2015
Please provide information

describing the basis on which
records are prioritized for ongoing
upgrade programs and the current
listing of priorities.
If events occurred on pipe systems
that were acquired, please provide
records describing the
characteristics, location and
configuration either obtained in
the acquisition or reconstructed by
PG&E post-acquisition.
29
May 29,
2015
Please provide a description of the

compensatory (backstop) measures
SED-002-Q29
Refers to pages in PGR

response to OII I.1411-008; Lists years for
transition of storage
Response references
initial response to the
OII and subsequent
response to SED-002Q29;
Noted De Anza
Division paper leak
repair records missing
1979 thru 1991,
available in predecessor
leak repair system
Refers to numerous
PGE-GDRs, provided
as part of the response
to SED-001-Q01 and
SED-001-Q02;
Good description of
evolution (timeline) of
mapping and correction
process
Provides a very highlevel planning process
description; refers to
pages in PGR response
to OII I.14-11-008
Supp01 narrowed the
request to the City of
Tehama acquisition,
but misinterpreted the
request as relating to
incidents occurring
prior to the acquisition;
misinterpretation not
important since PG&E
seems to have been
responsible for the
system O&M since its
initial design
Response references
PGR response to OII
SED-002-Q25
SED-002-Q25Supp01
Page 90
DR #
Date
Request
Submitted
30
May 29,
2015
31
May 29,
2015
32
May 29,
2015
33
May 29,
2015
34
May 29,
2015
currently in place to address

recognized deficiencies in system
records, along with a description
of how PG&E assures itself these
measures are effective and the
time when each of these measures
was fully implemented.
Please provide a listing of the
types of data and information
PG&E identified as necessary for
its maps, asset records, data bases
and engineering information.
For the types of data and
information PG&E identified as
necessary in data request #30,
please identify PG&E's
need/reason/purpose for collecting
and establishing such data and
information.
Please provide copies of
procedures PG&E used during the
past 10 years to locate and markout (L&M) its gas facilities in
response to one call mark-out
requests. Please include details of
instructions provided to L&M
personnel regarding what to do
when asset data was unclear or
when assets were difficult to
ascertain the exact location.
Please provide internal PG&E
requirements on asset records and
maps (in the form of procedures,
check lists, etc.), including
requirements for initial preparation
and modification to reflect
engineered changes as well as
lessons from operation.
Please provide a narrative on how

system changes (maintenance,
PG&E Responses
to Date
SED-002-Q30
Comment on
Response
I.14-11-008 and lists
ongoing initiatives;
Discussed how
effectiveness of
corrective measures is
evaluated : QA/QC;
Internal Audit; CAP
PGE references its
earlier response to
SED-001-Q01, Q03
thru Q06
SED-002-Q31
Response references
PGR response to OII
I.14-11-008 and to
SED-002-Q29
SED-002-Q32
Table summarizes
L&M and map
correction procedures,
including Bates
numbers
SED-002-Q33
PGE tabulates
procedures (PGEGDR) and references
its earlier response to
SED-001-Q01, Q03
thru Q06;
New documents to be
provided include: PGEGDR-8430 thru GDR8443 as well as PGEGDR-8467 thru GDR8582
Refers to pages in PGR
response to OII I.14-
SED-002-Q34
Page 91
DR #
Date
Request
Submitted
35
May 29,
2015
36
May 29,
2015
37
May 29,
2015
38
June 17,
2015
39
June 17,
2015
modification, etc.) have been and

are updated into the master record
database and what quality control
procedures are used to ensure that
all the records are updated and are
correct.
Please provide procedures for
upgrading records to reflect asset
changes, correcting maps and
records based on field verifications
and lessons from operating
experience.
Please provide a narrative on how
gas distribution system upgrades
are tracked and the time required
from when the work is completed
until the maps and all databases
are updated with the new quality
controlled data.
Please provide information on
historic acquisition of distribution
systems location, approach to
evaluation, incorporating data,
information, maps and records and
modification of records of
acquired distribution systems.
Please provide the

process/procedure/policy
used to make map
corrections prior to TD4460P-11 from 2000 to
10/17/14.
For each CPUC reportable
incident recorded from 2000
to present, please provide
copies of all map corrections
submitted before and after
each incident in the general
area of the incident.
PG&E Responses
to Date
Comment on
Response
11-008 for description
of quality protocols
SED-002-Q35
Response references
PGR response to SED002-Q33
SED-002-Q36
SED-002-Q36Supp01
Good summary
narrative;
Expensed jobs (vs.
capital) require an
average of 30 days to
map.
PG&E respectfully
objects; PGE described
recent acquisition in
response to SED-002Q28
SED-003-Q38; SED003-Q38, Rev 1
Response references
PGR response to SED002-Q26; Rev 1
includes map correction
tracking process
description & forms
SED-003-Q39
SED-003-Q39Supp01
SED-003-Q39Supp02
SED-003-Q39Supp03
Maps provided as PGEGDR-17556 thru

18301; index provided
as PGE-GDR-17555;
PGE-GDR-22925 thru
23087; (Gas
Distribution Pipeline
Safety Reports) PGEGDR-30933 thru
31737; PGE-GDR38341 thru 38347
Page 92
DR #
Date
Request
Submitted
40
June 17,
2015
41
June 17,
2015
42
June 17,
2015
PG&E Responses
to Date
Please describe the processes SED-003-Q40

and procedures used when a
steel or cast iron/ductile iron
main is inserted with another
material or different diameter
main: currently, in 2010, in
2005 and in 2000. List all
forms that must be
completed, by whom, and
submitted to whom, and the
timing for submissions and
record updating.
Please provide a list of dGIS SED-003-Q41
Change forms, TD-4010P-01
Attachment 1 and its
predecessor forms submitted
from 2005 to present for
Divisions where 6 incidents
in OII are located. The list
should be in an Excel
Spreadsheet format have the
date submitted, a description
of the change, the date the
change was verified, and the
date the database was
updated.
SED-003-Q42
Under current policies and
procedures, how many
procedures must be utilized
and followed to properly
document a change or an
error in a gas distribution
asset such as a main or
service and what is the order
that these policies or
procedures must be
Comment on
Response
Response references
and reiterates PGR
response to SED-002Q10 and SED-003Q42; gas design
standards enumerated
and Bates numbers
provided; table
provided describing
forms to be used
PGE will revise

response to SED-001Q01 to delete
transmission
references; PGE
submitted spreadsheet
PGE-GDR-17554 for
the period since 2012
(GD-GIS inception
date)
Response references
earlier PGR responses
to SED-002-Q01, Q09
and Q10
Page 93
DR #
Date
Request
Submitted
43
June 17,
2015
44
June 17,
2015
45
June 17,
2015
46
June 17,
2015
PG&E Responses
to Date
completed. Who is
responsible for verifying that
all of these policies and
procedures are followed?
SED-003-Q43
Which organization is
charged with performing the
quality control function on
the dGIS system? Please
provide any and all reports
on the actual quality of the
data in the system.
SED-003-Q44
Since 2005 how many
SED-003-Q44Supp01
distribution leak surveys
were performed at an interval
greater than those listed in
TD-4110P-01 (and its
predecessor procedures)
Table 1? Please describe
each by location, number of
services, and length of main.
Please provide copies of each SED-003-Q45

self-report of a leak survey
that exceeded the required
time frame since 2000.
SED-003-Q46
Please provide copies of all
mapping standards in use
since 2000 excluding TD
4460S.
Comment on
Response
Response references
PGR response to SED003-Q53;
Two people involved in
map changes
implementer and
verifier
Initial submittal PGEGDR-18467 thru 18479
references earlier
submittal in response to
SED-001-Q12, SED002-Q19, and SED003-Q45;
Final pre-audit leak
surveys PGE-GDR24444 thru 2497;
Responsive internal
reviews PGE-GDR23592 thru 23607;
Responsive SED GO
112E Audits PGEGDR-23608 thru
24443;
Also see response to
SED-002-Q15Supp02
and to SED-003Q48Supp01
Self-reporting program
has been in place since
December 2011;
reports provided
See Bates Documents
PGE-GDR-17296 thru
17297 and PGE-GDR5925 thru 5930
Page 94
DR #
Date
Request
Submitted
47
June 17,
2015
48
June 17,
2015
49
June 17,
2015
50
June 17,
2015
51
June 17,
2015
PG&E Responses
to Date
SED-003-Q47
Please provide an
explanation on how PG&E
implemented TD-01 for its
gas distribution workforce.
Please provide the results of SED-003-Q48
SED-003-Q48Supp01
PG&E's quality control
activities to correct any
deficiencies in its gas
distribution records on: plat
maps, as built drawings,
repair records, leak repair
forms and gas service records
from 2005 to the present in
Divisions where 6 incidents
in OII are located.
What is the difference

between GD GIS and dGIS?
Please provide a narrative on
exactly how the Pathfinder
project proposed in the 2014
GRC will correct the data
and record inaccuracies and
lapses.
SED-003-Q49
Please provide any and all

reports, audits, and quality
control investigations
designed to determine
whether the PAR method is
finding and correcting all
data anomalies. Also,
describe how the PAR
methodology populates the
GD GIS system with
accurate data when data sets
SED-003-Q51
SED-003-Q50
Comment on
Response
Distinguished between
QA and QC;
Lists records requested
by QC;
References as-Built
Drawing Handbook and
Training;
Internal quality
improvement reports
PGE-GDR-25265 thru
25309;
Refer to response in
SED-003-Q44Supp01
and SED-00Q15Supp02
References discussion
in testimony supporting
the 2014 GRC (PG&E3);
Testimony does not
state pathfinder is
focused on correcting
potential data and
records inaccuracies
References Internal
Audit Department 2015
audit of Pathfinder
implementation,
provided in response to
SED-001-Q12Supp01;
Problem Action
Resolution (PAR) is
not designed to find
and correct all data
anomalies
Page 95
DR #
Date
Request
Submitted
are missing.
Are there any additional
service stubs other than the
28,000 that PG&E has
recently migrated into GD
GIS?
PG&E Responses
to Date
Comment on
Response
SED-003-Q52
SED-003-Q52Supp01
Response references
PGR response to OII
I.14-11-008 and
provides additional
information; Following
deployment of GD-GIS
to all 18 Divisions, the
total stub service
inventory is 71,131
Measures provided as
PGE-GDR-17298 thru
17319; also see
response to SED-003Q43; results of 2013
internal audit provided
as PGE-GDR-17484
thru 17486; results of
PGE 2015 internal
audit were provided in
response to SED-001Q12Supp01 (see PGEGDR-8370 thru 8372)
PGE references
response to SED-001Q12 and SED-002-Q15
52
June 17,
2015
53
June 17,
2015
SED-003-Q53
Please describe how PG&E
is ensuring the data quality of Resubmit
the data sets being imported
into the new Pathfinder/ GD
GIS data bases.
54
June 17,
2015
55
June 17,
2015
56
June 17,
2015
SED-003-Q54
reports, audits (from both
internal and external sources)
on data quality in both legacy
and current gas distribution
databases and records since
2000.
Please provide a narrative on SED-003-Q55
how PG&E will correct its
database for work orders,
maintenance orders, and leak
repairs that were never
inputted and for which there
currently may not be a paper
trail.
Please provide the number of SED-003-Q56
records that have been
Refers to PG&E
response to SED-003Q48 and PG&E
Page 96
DR #
Date
Request
Submitted
57
June 17,
2015
58
June 17,
2015
59
June 17,
2015
60
June 17,
2015
61
June 17,
corrected by comparing A
Form data to data base
records. Also provide the
time frame from when this
process has been in effect.
Please provide a list of the
number of CAP submissions
by year since the program
started, the number
outstanding at each year end,
the average time it takes to
implement the requested
correction, what were the
monthly and yearly numbers
of CAP submissions PG&E
anticipated, and if PG&E
considers it a success.
PG&E Responses
to Date
Comment on
Response
response to OII
SED-003-Q57

Lloyd's Register
recommendations from the
initial audit and all
subsequent audits.
Please provide copies of the
new Gas Distribution QM
group audit activity schedule
since its inception.
How many feet of steel main
does PG&E believe was
inserted with plastic, how
many feet were not updated
on maps, how many services
were inserted with plastic,
how many services were not
updated on maps?
SED-003-Q58
Please provide the yearly
SED-003-Q61
Of 2,110 CAPs
submitted from Oct
2013 thru 06/18/15,
609 were outstanding
on 06/18/15;
Number of CAPs
submitted is
significantly
increasing;
Time to implement
corrective actions is
being reduced;
Inventory (as a
percentage of CAPs
submitted) is shrinking
PGE references
response to SED-002Q15Supp01
SED-003-Q59
PGE refers to responses

PGE-GDR-17482 and
17483 (for 2014)
SED-003-Q60
SED-003-Q60Supp01
PGE response notes its

belief that all known
inserts have been
mapped ;
There are
approximately 353,371
inserts in a population
of about 3.3 million
plastic services;
4,786,311 ft. of plastic
main inserts
Since 2012 more than
Page 97
DR #
Date
Request
Submitted
2015
62
June 17,
2015
63
June 17,
2015
64
June 17,
2015
65
July 22,
2015
66
July 22,
2015
67
July 22,
2015
PG&E Responses
to Date
Comment on
Response
quality ratings that the QM

group has found in auditing
the L&M personnel for each
year since its inception in
2011 (Percentage of L&M
within 2' of the actual gas
facility and if the facility was
located).
SED-003-Q62
Please explain how the
proposed Continental Steel
bolt on piercing tool will
prevent future incidents like
the one at Carmel in 2014.
98% of tickets passed

the audit by QC
(criterion mark within
2 ft. of actual location)
In PG&Es view, were any of the

self-reported non-compliances the
result of incorrect, missing, or
other record issue?
Please provide documentation
describing PG&Es position
regarding how the requirements of
the PAS 55 and ISO 55001
standards have been applied to
PG&Es safety management
system, PG&E's management of
its physical assets, and its record
keeping practices.
Please provide the Damage
Prevention Handbook: TD-5811M
Rev 1.
Please provide the procedures used
prior to the 7/30/2013 Mountain
View and 3/3/2014 Carmel
incidents for tapping a steel main
that is known to be inserted with a
plastic line.
Please provide the standards and
procedures related to the Gas
Event Reporting Program & Tool
(GDR-8044).
SED-003-Q63
PG&E offered no
opinion, no analysis to
evaluate
SED-003-Q64
Certification results
were provided as part
of PGE response to
SED-002-Q15Supp01
SED-004-Q65
Provided
SED-004-Q66
Provided, primarily in
response to SED-001Q10 and SED-003Q40; additional
procedures provided
SED-004-Q67
No longer utilized,
provided anyway;
CAP implemented in
March of 2013, prior to
the at OII referenced
Mountain View
Page 98
DR #
Date
Request
Submitted
68
July 22,
2015
69
July 22,
2015
70
July 22,
2015
71
July 22,
2015
72
July 22,
2015
73
July 22,
2015
74
July 22,
2015
State whether the mains and/or

services in the six incidents
identified in the OII were updated
in SAP and GD-GIS at the time of
each incident, as well as after each
incident.
Identify and provide information
on each map and records related
incidents that have occurred on
distribution lines for which records
had been updated and incorporated
in SAP and GD-GIS prior to the
incident.
What specific backstop and
mitigating measures were
implemented in response to the
7/30/2013 Mountain View
Incident? Please provide dates as
to when the specific backstop and
mitigating measures were
implemented.
What are PG&E standards for the
accuracy of locate and marks
relative to pipe location?
Please provide the procedures used
by field personnel in preparing for
and performing a tie-in of a new
main replacing an existing main.
Please provide a description of
how a PG&E crew would have
determined which procedures to
use on a job, including supporting
documents, at the time of the
10/10/2012 Milpitas incident.
Please provide the individual work
packages used to conduct work for
each of the six incidents identified
in the OII, including AOCs.
PG&E Responses
to Date
SED-004-Q68
Comment on
Response
incident
The six OII incidents
preceded
implementation of the
GD-GIS
SED-004-Q69
PG&E does not track;

information provided
earlier would support
our analysis
SED-004-Q70
Fixed specific problem,

looked for other similar
situations, no general
solution implemented
until after the OII
incident at Carmel
SED-004-Q71
Listed standards and

references
SED-004-Q72
Good summary of
procedures provided in
response to earlier data
requests
General discussion, no
reference to valve
position verification in
procedures
SED-004-Q73
SED-004-Q74
PG&E states that it

does not maintain
copies of the preconstruction work
packages as issued;
verbal information
obtained during the
week of 08/03/15
indicated that PG&E
Page 99
DR #
Date
Request
Submitted
75
July 22,
2015
76
July 22,
2015
77
PG&E Responses
to Date

PG&Es program to identify and
correct data gaps in the GD GIS
and SAP.
PG&Es ongoing activities to
identify inserted lines that are not
properly identified on maps.
SED-004-Q75
July 22,
2015

PG&Es ongoing activities to
identify stubs that are not properly
identified on maps.
SED-004-Q77
78
July 22,
2015
SED-004-Q78
79
July 22,
2015
80
July 22,
2015
81
July 22,
2015
82
July 22,
2015

how PG&E is assuring long-term
corrosion protection on special
bolted fittings being used to tap
lines where there is suspected
plastic inserts not identified on
maps.
instructions and/or procedures for
completing clearances on the gas
distribution system from 2010 to
date.
clearances provided and the
documentation they contained for
all of the six incidents listed in the
OII.
Please provide any changes that
have been made to the clearance
procedures during the time frame
of and subsequent to the six
incidents listed in the OII.
Please provide the titles of each
individual who initiated, reviewed
and signed the clearances for the
six incidents listed in the OII.
SED-004-Q76
Comment on
Response
has retained completed
work packages in SAP
for 8 years.
Lists previously
provided responses of
relevance
Summarizes careful
opportunistic approach;
no focused program
cited; Use of Gas
Carrier Pipe Checklist
Looking for new
technologies;
otherwise, uses
opportunistic approach
dependent on the nature
of activities
Provided procedure:
PGE-GDR-18480
SED-004-Q79
Listed procedures and

Bates numbers
SED-004-Q80
References earlier
SED-004-Q81
References earlier
SED-004-Q82
References earlier
Page 100
DR #
Date
Request
Submitted
PG&E Responses
to Date
Comment on
Response
83
July 22,
2015
Deleted by agreement
with SED
84
July 22,
2015
85
July 22,
2015
86
July 22,
2015
Please identify when PG&E will

complete its response to the CPUC
O&M AOC #23 Data Request.
Based on our records we have yet
to receive information on pipe
specifications, year of installation
and date system was placed in
service.
Please provide the number and
grade of distribution main leaks on
each of the subject 240
hydraulically independent
distribution systems for each of the
last 15 years.
Please provide the same data as
requested in the O&M AOC #23
Data Request for other
distribution systems for which the
MAOP was established consistent
with the requirements using
operating pressure records prior to
1970.
Please provide correspondence
between PG&E and the CPUC in
which the approach PG&E took to
establishing the MAOP for the
subject 240 hydraulically
independent distribution systems
was described and approval was
sought for this approach.
SED-004-Q86
The earliest entry in the

correspondence list
PG&E provided was
09/22/06. PG&E
developed and
implemented an
alternative approach to
establish MAOP for the
subject 243
hydraulically
independent
distribution systems in
the 70s, hence it seems
no CPUC approval was
sought at the time the
MAOP procedure,
clearly inconsistent
with the regulation, was
implemented.
87
July 22,
2015
Please describe the compensatory

measures and corrective actions
SED-004-Q87
Indirect response
with SED
with SED
Page 101
DR #
Date
Request
Submitted
PG&E Responses
to Date
PG&E intends to take to address

the potential risks associated with
the subject 240 hydraulically
independent distribution systems
as well as with the additional
grandfathered systems identified
and characterized in response to
DR #85. In the description of
compensatory measures and
corrective actions, please indicate
the basis on which you are
assigning a risk to each of the
distribution systems, including the
source of the assigned risk and the
applicability of the compensatory
measures to monitoring or
managing those risks.
Comment on
Response
was provided by
Raymond Thierry
in response to
Interrogatory under
Oath #17 My
understanding is
that, in 2008,
PG&E concluded
that the use of the
method described in
TD-4125S to
establish MAOP
does not pose a
safety risk to the
distribution
system.;
Formal response
reiterated that in
2008, PG&E
concluded that the
use of the method
described in TD4125S to establish
MAOP does not
pose a safety risk to
the distribution
system. Therefore,
PG&E has not
implemented any
additional measures
specifically
applicable to the
associated pipe.
88.
August 5
Please describe the performance

measures that PG&E uses to verify
the effectiveness of the new
processes and procedures
SED-004-Q88
The response refers to

several previously
submitted responses,
including those to Q29,
Page 102
DR #
Date
Request
Submitted
89.
August 5
90.
August 5
91.
August 5
92.
August 5
93.
August 5
implemented as backstop
measures, as described in PG&Es
response to the OII.14-11-008, and
provide the results of the
performance measures since
implementation.
Based on the results of the
performance measures, please
describe how PG&E determines
whether each backstop measure is
effective or not. Are the new
processes and procedures
implemented to improve records
and the backstop measures
described in PG&Es response to
the OII.14-11-008 effective? Is the
rate of safety events decreasing?
Provide supporting documentation.
At the time of the Carmel incident
(03/03/14), had the Pathfinder
Project completed its update of the
GD-GIS in the area where the
incident occurred?
Please summarize PG&Es
measures to ensure maps and
records updates are accurate.
Based on PG&Es root cause
analysis of incidents as required by
49 CFR 192.617 and internal
audits, are there other potentially
high risk mapping and records
issues of which PG&E is aware in
addition to unmapped plastic
inserts, unmapped stubs and
incorrectly mapped services and
mains (e.g., absence on maps of
other utilities in the vicinity of gas
pipes)?
Please describe PG&Es efforts,
and provide a copy of reference
procedure(s), to address and/or
correct the map and or
recordkeeping deficiencies and
issues resulting from PG&Es
PG&E Responses
to Date
Comment on
Response
Q48, Q56, and Q57
SED-004-Q89
Response refers to
previously submitted
responses to SED-005Q88, SED-003-Q61,
SED-005-Q100; dig-ins
per 1, through June
2015000 tickets has
decreased from 2.8 to
2.2
SED-005-Q90
No
SED-005-Q91
Refers to previous
responses, including to
SED-002-Q29
Refers to previously
submitted responses
from Raymond Thierry
including the 20
highest risks; these
risks were described at
too high a level in
explicitly include
unmapped inserts and
stubs.
SED-005-Q92
SED-005-Q93
provided material
including PG&Es
initial response to the
OII and subsequent
responses to SED-002-
Page 103
DR #
Date
Request
Submitted
94.
August 5
95.
August 5
96.
August 5
97.
August 5
98.
August 5
analysis of accidents and failures

to minimize recurrence.
Please provide documentation of
the corrective actions taken
following the incident on
7/30/2013 in Mountain View to
address the concern of unknown
and unmapped plastic inserts in
PG&Es distribution system, and
provide the time when the
corrective actions were
implemented and/or completed.
Please describe the process used to

update maps as a result of leak
repairs, such as plastic inserts, and
the quality reviews performed to
ensure that the maps are accurate
and reflect all of the recent work
on gas distribution mains and
services.
Are the risks associated with the
distribution pipelines in which the
alternative approach to
establishing MAOP per TD-4125S
was applied, different from the
risks associated with parts of the
system for which MAOP of
grandfathered segments were
established consistent with the
regulations?
On what bases are priorities
established in the Corrective
Action Program (CAP) for
determining and addressing the
root causes of incidents and close
calls experienced on the PG&E
distribution system?
How do these priorities in CAP
translate to schedules for
addressing identified root causes?
PG&E Responses
to Date
Comment on
Response
Q19 and Q20
SED-005-Q94
SED-005-Q95
submitted response to
SED-004-Q70;
enumerates specific
actions and Bates
numbers in which these
actions have previously
been described. Other
than immediate followup actions, all of the
actions described were
undertaken following
the 03/03/14 incident at
Carmel.
Describes the process
and refers to previously
submitted responses to
SED-002-Q33 and
SED-003-Q48
SED-005-Q96
No additional safety
risks have been
identified. PG&E
seems satisfied with the
results of its evaluation
in 2008.
SED-005-Q97
Describes process,
references CAP risk
assessment tool
described in previous
response to Q33 (PGEGDR-8564 thru 8580)
SED-005-Q98
SED-002-Q33, and
presents a table of CAP
Page 104
DR #
Date
Request
Submitted
99.
August 5
100.
August 5
101.
August 5
102.
August 5
103.
August 5
104.
August 5
105.
August 5
Please provide examples from the

past three years.
Please describe the role of the
Internal Audits organization in
ensuring applicable mapping and
records requirements are met.
Please summarize PG&Es
normalized measures of
performance related to excavation
damage and discuss both observed
trends and how these measures
compare with the distribution
industry as a whole.
Please provide a table showing

over the past three years, by
division, the number of map
corrections
submitted, the number of map
corrections completed, the time
required to complete, and the
number of map corrections sent
back to the originator for
additional information.
Please provide the report PG&E
commissioned Bechtel to carry out
in 1983 on pipe replacement
priorities that was delivered in
1984.
Please provide the 1985 PG&E
memo requesting the data from its
staff considered necessary to
populate the risk model being
developed, along with responses
received.
Please provide a copy of the
Bechtel report entitled Review of
the Transmission Priority Analysis
(1994) evaluating progress in
implementing its 1984 plan.
Please provide a copy of PG&Es
Standard Practice 1606, dated
PG&E Responses
to Date
Comment on
Response
notifications
SED-005-Q99
See PGE response to

SED-002-Q29
SED-005-Q100
A rolling twelve month

average shows a yearto-date reduction of 3rd
party dig-ins per 1,000
tickets as of June 2015
of 18% compared to the
same period in 2014.
CGA DiRT tool reports
were provided as PGEGDR-36786 thru 36817
Average time for
completion of map
corrections through
June 15, 2015 is 41.3
days. See also PG&E
response to PGE-GDRQ39.
SED-005-Q101
SED-005-Q102
Report provided; PGEGDR-31858 thru 31883
SED-005-Q103
Response may be in
PGE-GDR-31884 thru
31905
SED-005-Q104
Report provided; PGEGDR-31737 thru 31827
SED-005-Q105
Provided as PGE-GDR31829 thru 31837
Page 105
DR #
Date
Request
Submitted
106.
August 5
107.
August 5
108.
August 5
109.
August 5
110.
August 5
August 1965, describing its

practice for establishing MAOP.
Please provide a summary of the
staffing changes related to
mapping and records, and staffing
changes to L&M that were
proposed in the most recent gas
distribution GRC. Provide a
summary of staffing changes to
L&M for each of the past three
years.
Please provide documentation on
how the map deficiencies
summarized under the Mapping
Correction Report in the Gas
Distribution Pipeline Safety
Reports produced in response to
CPUC Decision 11-05-018,
including those related to existing
facilities not previously mapped,
for the past three years, were
identified (e.g., by Pathfinder
Project, through the corrective
action program, or by other means
- please specify which other means
or programs). Please summarize
the percentage identified by each
means.
Please provide PG&Es plan and
schedule for evaluating and
determining how to address the
risks associated with its use of an
alternative method to establish
distribution MAOP for systems
with no available pressure record
prior to July 1, 1970 as described
in TD-4125S.
Please provide a summary of
measures PG&E has implemented
to address the potential risks
referenced in DR # 108.
What is PG&Es required
timeframe, and provide copy of
reference procedure(s), for
PG&E Responses
to Date
Comment on
Response
SED-005-Q106
Refers to GRC filing

requests and identifies
a build-up in L&M
staffing from 110 in
January of 2014 to 151
at the end of 2014;
staffing at the end of
2015 is expected to be
190
Refers to process
description in SEDGDR-Q26Rev01 and
SED-GDR-Q38Rev01
for process description.
Beginning in October
2014 map corrections
have been submitted
through the CAP
process.
SED-005-Q107
SED-005-Q108
Refers to previous
response to SED-GDRQ87
SED-005-Q109
Refers to previous
response to SED-GDRQ87
SED-005-Q110
60 to 90 days, Provided
GOV-6102S as PGEGDR-31838 thru
Page 106
DR #
Date
Request
Submitted
completing its investigations of
incidents to determine contributing
factors and/or root cause?
What is PG&Es required
timeframe, and provide copy of
reference procedure(s), to
implement corrective or backstop
measures as a result of its review
and analysis of the contributing
and/or root cause(s) as described
in DR# 110?
Please list the type of maps and
records PG&E is including in its
backlog of maps to be updated and
the time required to complete
updates?
PG&E Responses
to Date
111.
August 5
112.
August 5
113.
August 5
Is PG&E including maintenance

and other leak repair work in its
reporting of time required to
complete map updates?
SED-005-Q113
114.
August 5
Please list the implementation

dates for the measures PG&E has
described in its response to the OII
to address map and recordkeeping
deficiencies contributing to
incidents and near misses.
SED-005-Q114
SED
Oral00201
July 20
OII DR SED
Oral002-Q01
SED
Oral00301
August 3
Please distribute to SED and all

other parties to OII I.14-11-008
copies of Attachment 1 (related to
the subject six incidents) with
Section 583/GO66-C
(confidential) information
redacted.
Please provide a copy of both the
job package and the M&C Gas
JSSA & Tailboard Briefing form
reviewed during the field
SED-005-Q111
SED-005-Q112
Comment on
Response
31845; Also provided
TD-4020P-02 as PGEGDR-31846 thru 31857
SED-005-Q110 and
governing procedures
previously provided in
As of July 31, 2015

PG&Es year-to-date
average mapping
duration is 29 days. For
gas distribution the
comparable duration is
14 days. Refers to
previous response to
SED-GDR-Q55.
Time to complete
updates measured only
for capital jobs, may
include certain
maintenance and leak
repair jobs
Provides table of
implementation dates
for 47 measures
described in PG&Es
response to the OII.
OII DR SED
Oral003-Q01
Page 107
DR #
Date
Request
Submitted
SED
Oral00302
August 3
SED
Oral00401
SED
Oral00402
August 5
SED
Oral00403
August 5
August 5
interviews conducted on August 3,

2015
Please identify which procedure(s)
(by procedure #s and/or Bates
stamp #s) go through the leak
survey grading, recheck, and
repair timelines.
Please provide the job description
for an Associate Distribution
Engineer
Please provide a copy of the job
package reviewed during the field
interview conducted on August 5,
2015.
Please provide a copy of the
spreadsheet with tab entitled End
User Data reviewed during the
field interviews conducted on
August 5, 2014.
PG&E Responses
to Date
Comment on
Response
OII DR SED
Oral003-Q02
OII DR SED
Oral004-Q01
OII DR SED
Oral004-Q02
OII DR SED
Oral004-Q03
Interrogatories under Oath Responses to all interrogatories were received

Interrogatories Directed to John Higgins, Vice President of T&D Operations
Interrogatory No. 1. Please list the measures used by PG&E to evaluate whether the level of staffing for locate
and mark (L&M) crews is sufficient to effectively complete assigned L&M activities.
Interrogatory No. 2. Are the current L&M crews performing locate and marks for both electric operations and
gas operations throughout PG&Es service territory?
Interrogatory No. 3. Please list the measures that PG&E uses to address missing or deficient records and maps in
carrying out its continuing surveillance responsibilities.
Interrogatory No. 4. Over the past ten years, provide the time ranges regarding the amount of time following an
incident or near miss that has been required to evaluate and identify the contributing factors to that incident or
near miss?
Interrogatory No. 5. Please list the implementation dates for the measures PG&E has described in its response to
the OII to address map and recordkeeping deficiencies contributing to incidents and near misses.
Interrogatory No. 6. When did you learn about the concerns expressed by PG&E field personnel and contractors
regarding unknown and/or unmapped inserted plastic mains and services prior to the 7/30/2013 Mountain View
incident?
Interrogatory No. 7. Do you have personal knowledge of other incident(s) or near miss(es)/near-hit(s) involving
unknown and/or unmapped plastic inserts reported by PG&E personnel or its contractors after the 7/30/2013
Mountain View incidents, and before the 3/3/2014 Carmel incident?
Interrogatories Directed to Sumeet Singh, Vice President of Asset & Risk Management
Page 108
Interrogatory No. 8. Please list the responsibilities of the Asset and Risk Management function as they relate to
managing and using maps and records.
Interrogatory No. 9. Please list the reasons for PG&Es mapping and records deficiencies that you have personal
knowledge regarding.
Interrogatory No. 10. Please list the measures taken by PG&E to ensure that the reasons for PG&Es mapping
and records deficiencies are being addressed to prevent recurrence.
Interrogatory No. 11. Please list PG&Es performance measures used to monitor the timeliness and effectiveness
of its mapping and records updating practices.
Interrogatory No. 12. When did you learn about the concerns expressed by PG&E field personnel and
contractors regarding unknown and/or unmapped inserted plastic mains and services prior to the 7/30/2013
Mountain View incident?
Interrogatory No. 13. Do you have personal knowledge of other incident(s) or near miss(es)/near-hit(s)
involving unknown and/or unmapped plastic inserts reported by PG&E personnel or its contractors after the
7/30/2013 Mountain View incidents, and before the 3/3/2014 Carmel incident?
Interrogatories Directed to Raymond Thierry, Director DIMP
Interrogatory No. 14. Please list the twenty most significant risks associated with operating the PG&E gas
distribution system.
Interrogatory No. 15. Please list the measures taken by PG&E to address the impact on risk resulting from the
acknowledged deficiencies in maps and records in complying with DIMP requirements, including those
requiring risk characterization and identification of measures to
address major contributors to risk.
Interrogatory No. 16. Provide evidence, if any, that PG&Es measures are working.
Interrogatory No. 17. What are the different risks associated with the distribution pipelines in which the
alternative approach to establishing MAOP (TD-4125S) was applied compared with parts of the system for
which the MAOP of grandfathered segments was established consistent with regulations?
Interrogatory No. 18. Please list the additional measures that PG&E has implemented to address the associated
pipe for which the MAOP has been established using the alternative method described in TD-4125S.
Interrogatories Directed to Javid Khan, Senior Director Strategy & Process Excellence
Interrogatory No. 21. Please list the corrective actions that were implemented, along with implementation dates,
to address the underlying causes of the incident at Mountain View (07/30/13).
Interrogatory No. 22. Please list the provisions in the root cause analysis process, along with their
implementation dates, to expedite action to address newly identified significant risks?
Interrogatory No. 23. Please list the metrics that Financial and Resource Management uses to monitor and
evaluate improvements to gas recordkeeping and mapping at PG&E.
Page 109
Page 110
ATTACHMENT C
Compilation Of Current Regulations Affecting Records And Maps
Provisions of California Law, the CPUC code, Commission general orders, applicable rules and
requirements in state or federal gas pipeline safety codes pertaining to pipeline safety
recordkeeping for PG&Es natural gas distribution system
The following General Orders, and gas pipeline safety code requirements are applicable to the
incidents addressed in the OII and those discovered by CPUC staff during their audits of PG&E actions
and activities as well as those identified by PG&E in their reports submitted to the CPUC.
California Law - California Public Utility Code (emphasis added by underlining)
Section 451 - Every public utility shall furnish and maintain such adequate, efficient, just, and
reasonable service, instrumentalities, equipment, and facilities, including telephone facilities, as
defined in Section 54.1 of the Civil Code, as are necessary to promote the safety, health,
comfort, and convenience of its patrons, employees, and the public.
Section 961 - (b) (1) Each gas corporation shall develop a plan for the safe and reliable
operation of its commission-regulated gas pipeline facility that implements the policy of
paragraph (3) of subdivision (b) of Section 963, subject to approval, modification, and adequate
funding by the commission.
(c) The plan developed, approved, and implemented pursuant to subdivision (b) shall be
consistent with federal pipeline safety statutes as set forth in Chapter 601 (commencing with
Section 60101) of Subtitle VIII of Title 49 of the United States Code and the regulations
adopted by the United States Department of Transportation pursuant to those statutes.
(d) The plan developed, approved, and implemented pursuant to subdivision (b) shall set forth
how the gas corporation will implement the policy established in paragraph (3) of subdivision
(b) of Section 963 and achieve each of the following:
(1) Identify and minimize hazards and systemic risks in order to minimize accidents,
explosions, fires, and dangerous conditions, and protect the public and the gas
corporation workforce.
(2) Identify the safety-related systems that will be deployed to minimize hazards,
including adequate documentation of the commission-regulated gas pipeline facility
history and capability. (emphasis added)
(9) Meet or exceed the minimum standards for safe design, construction, installation,
operation, and maintenance of gas transmission and distribution facilities prescribed by
regulations issued by the United States Department of Transportation in Part 192
(commencing with Section 192.1) of Title 49 of the Code of Federal Regulations.
(10) Ensure an adequately sized, qualified, and properly trained gas corporation
workforce to carry out the plan.
(e) The commission and gas corporation shall provide opportunities for meaningful, substantial,
and ongoing participation by the gas corporation workforce in the development and
implementation of the plan, with the objective of developing an industrywide culture of safety
Page 111
that will minimize accidents, explosions, fires, and dangerous conditions for the protection of
the public and the gas corporation workforce.
Section 963 - (b) The Legislature finds and declares all of the following:
(3) It is the policy of the state that the commission and each gas corporation place safety
of the public and gas corporation employees as the top priority. The commission shall
take all reasonable and appropriate actions necessary to carry out the safety priority
policy of this paragraph consistent with the principle of just and reasonable cost-based
rates.
California Government Code 4216 Excavation Damage Prevention (emphasis added by

underlining)
4216(a) As used in this article the following definitions apply:

"Approximate location of subsurface installations" means a strip of land not more than
24 inches on either side of the exterior surface of the subsurface installation.
"Approximate location" does not mean depth.
4216.2. (a) (1) Except in an emergency, any person planning to conduct any excavation shall
contact the appropriate regional notification center, at least two working days, but not more
than 14 calendar days, prior to commencing that excavation, if the excavation will be
conducted in an area that is known, or reasonably should be known, to contain subsurface
installations other than the underground facilities owned or operated by the excavator and, if
practical, the excavator shall delineate with white paint or other suitable markings the area to be
excavated.
4216.3. (a) (1) Any operator of a subsurface installation who receives timely notification of any
proposed excavation work in accordance with Section 4216.2 shall, within two working days of
that notification, excluding weekends and holidays, or before the start of the excavation work,
whichever is later, or at a later time mutually agreeable to the operator and the excavator, locate
and field mark the approximate location and, if known, the number of subsurface installations
that may be affected by the excavation to the extent and degree of accuracy that the information
is available either in the records of the operator or as determined through the use of standard
locating techniques other than excavating, otherwise advise the person who contacted the
center of the location of the operator's subsurface installations that may be affected by the
excavation, or advise the person that the operator does not operate any subsurface installations
that would be affected by the proposed excavation. (emphasis added)
4216.4. (a) When the excavation is within the approximate location of subsurface installation,
the excavator shall determine the exact location of subsurface installations in conflict with the
excavation by excavating with hand tools within the area of the approximate location of
subsurface installations as provided by the operators in accordance with Section 4216.3 before
using any power-operated or power-driven excavating or boring equipment within the
approximate location of the subsurface installation, except that power-operated or power-driven
Page 112
excavating or boring equipment may be used for the removal of any existing pavement if there
are no subsurface installations contained in the pavement
4216.6. (a) (1) Any operator or excavator who negligently violates this article is subject to a
civil penalty in an amount not to exceed ten thousand dollars ($10,000).
4216.6. (a) (2) Any operator or excavator who knowingly and willfully violates any of the
provisions of this article is subject to a civil penalty in an amount not to exceed fifty thousand
dollars ($50,000).
(c) If an operator of a subsurface installation has failed to comply with the provisions of
Section 4216.3, has failed to comply with paragraph (2) of subdivision (a) of Section
4216.2, or has failed to comply with subdivision (b) of Section 4216.4, the operator
shall be liable to the excavator who has complied with Sections 4216.2 and 4216.4 for
damages, costs, and expenses resulting from the operator's failure to comply with these
specified requirements to the extent the damages, costs, and expenses were proximately
caused by the operator's failure to comply.
CPUC General Order requirements

General Order 58A - Standards for Gas Service (37 C.R.C. 589) (Original Order Approved August 1,
1919 Effective September 1, 1919) (Revised Order Approved March 1, 1923 Effective April 1, 1923)
(Revised Order Approved May 31, 1932 Effective July 1, 1932) (Decision No. 24827, Case No. 3181)
[Revised April 12, 1989 Effective April 12, 1989] [Resolution G-2870] Revised December 16, 1992,
Effective December 16, 1992
Section 3. System Maps and Records

b. A suitable map or maps shall be kept on file in the principal office of each division or
district. Maps shall at all times show the size, character and location of each street main, district
regulator, operating valve and drip, and when practicable, each service connection in the
corresponding territory served. In lieu of showing service locations on maps, a card record, a
computerized system, or other suitable means may be used.
Section 9. Pressure Testing Equipment and Tests

a. Each gas utility shall own and maintain at least one recording pressure device on each
principal distribution main leaving each major control facility such as a compressor station,
holder station or transmission terminal. No utility shall maintain less than two such devices
unless specifically relieved in writing by the Commission. Official pressure data taken from
such devices shall be preserved as a continuous record for a period of at least one (1) year.
b. Each gas utility shall own and maintain at least one low pressure, portable pressure recording
device for each one hundred (100) miles or fraction thereof of low pressure main in any
separate distribution system.
c. On low pressure distribution systems each gas utility shall during the six months of the peak
season of the year make at least one 24-hour record of pressure each week at the outlet of
customer's meters for each one hundred (100) miles or less of distribution main in each district
or separate distribution system. Such record shall bear the address of the customer where the
Page 113
pressure is taken and the dates, together with such other information as the Commission may
from time to time direct and shall be filed and retained for a period of at least two calendar
years in the principal office of each district or division. In lieu of fifty percent (50%) of the
above required number of records from portable pressure recording devices at customer's
premises there may be substituted an equal number of twenty-four (24) hour records from
recording pressure devices permanently located at critical points on the distribution system.
d. On high pressure distribution systems, gas utilities shall maintain permanently located
pressure recording devices at critical points and shall preserve in the district or division offices
the data from these devices for a period of at least one (1) year.
Section 22. Maintenance and Operation of Facilities

a. Each gas utility, unless specifically relieved in any case by the Commission from such
obligation, shall operate and maintain in safe, efficient and proper condition all of the facilities
and instrumentalities used in connection with the furnishing, regulation, measurement and
delivery of gas to any customer up to and including the point of delivery, which point, for the
purpose of these rules, shall be deemed to be the outlet fitting of the meter installed by the
utility, or the point where the pipe owned and installed by the utility connects to the customer
owned piping, whichever is further downstream.
General Order 112 effective Jan 17, 1961, Appendix A Rules Governing Design, Construction,
Testing, Maintenance and Operation of Utility Gas Transmission and Distribution Piping Systems
Sec. 102 Purpose: 102.1 The purpose of these rules is to establish minimum requirements for
the design, construction, quality of materials, location, testing, operation and maintenance of
facilities used in the transmission and distribution of gas, to safeguard life or limb, health,
property and public welfare and to provide that adequate service will be maintained by gas
utilities operating under the jurisdiction of the commission.
Sec. 104 Intent; 104.3 It is not intended that these rules be applied retroactively to existing
installations in so far as design, fabrication, installation, established operating pressure and
testing are concerned. It is intended, however, that the provisions of these rules shall be
applicable to the operation, maintenance, and up-rating of existing installations.
Sec. 107 Compliance with ASA Code; 107.1 Gas transmission and distribution facilities shall
be constructed and operated in compliance with the provisions of Section 8 of the American
Standard Code for pressure piping, known as the American Standard Code for Gas
Transmission and Distribution Piping Systems, ASA B 31.8-1958, and in compliance with the
further requirements of the additional rules herein prescribed.
Several Sections: Section 845.43, Section 847.13 and Section 852.3 of ASA B 31.8-1958 are
herewith amended in their entirety to conform with General Order 58-A of the Commission.
Section 212 for Maximum Allowable Operating Pressures for Low Pressure Distribution
systems, stated that section 845.43 of ASA B 31.8-1958 is amended entirely to conform to
General Order 58A.
Page 114
Sec. 301 General: 301.1 The responsibility for the maintenance of necessary records to
establish that compliance with these rules has been accomplished rests with the utility. Such
records shall be available for inspection at all times by the commission or the commission staff.
Sec. 302 Specifications: 302.1 Specifications for material and equipment, installation, testing
and fabrication shall be maintained by the utility.
Sec. 303 Operating and Maintenance Procedures: 303.1 Plans covering operating and
maintenance procedures, including maximum actual operating procedures to which the line is
intended to be subjected, shall be maintained by the utility.
303.2 No pipeline shall be operated in excess of the maximum operating pressure recorded by
the company in accordance with this section.
ASA B 31.8-1958 Edition 01/17/6196

850. O&M; 850.3 Basic Requirements - Each operating company having gas transmission or
distribution facilities within the scope of this code shall (a) Have a plan covering operating and
maintenance procedures in accordance with the purpose of this code. (c) Keep records
necessary to administer the plan properly.
Section 841 With the exception of tie-in pieces, all pipelines, mains and services were to be
pressure tested following construction. Leak tests were required for lines to be operated at less
than 100 psig.
Federal Gas Pipeline Safety Code Requirements USDOT
Beginning in the early 1970s,97 the USDOT successor to the Federal Power Commission issued
requirements for natural gas pipelines. These were contained in 49 Code of Federal Regulations Part
192 (49 CFR 192)Transportation of Natural and other Gas by pipeline: Minimum Federal Safety
Standards. Pertinent requirements are provided below.
Subsections
192.13(c) - Each operator shall maintain, modify as appropriate, and follow the plans, procedures,
and programs that it is required to establish under this part.
192.605(a) Each operator shall prepare and follow for each pipeline, a manual of written procedures
for conducting operations and maintenance activities and for emergency response.
192.605(b)(3) - Making construction records, maps, and operating history available to appropriate
operating personnel.
96
These requirements were imposed initially in California by CPUC General Order 112 imposed by Decision
S1269, effective January 17, 1961.
97
49 CFR Part 192 minimum requirements for the transportation of natural gas by pipeline were published in
the Federal Register (35 FR 13257) August 19, 1970; effective date November 12, 1970.
Page 115
192.605(b)(8) Periodically reviewing the work done by operator personnel to determine the
effectiveness, and adequacy of the procedures used in normal operation and maintenance and
modifying the procedures when deficiencies are found.
192.613(a) Each operator shall have a procedure for continuing surveillance of its facilities to
determine and take appropriate action concerning changes in class location, failures, leakage history,
corrosion, substantial changes in cathodic protection requirements, and other unusual operating and
maintenance conditions.
192.613(b) If a segment of pipeline is determined to be in unsatisfactory condition but no immediate
hazard exists, the operator shall initiate a program to recondition or phase out the segment involved, or,
if the segment cannot be reconditioned or phased out, reduce the maximum allowable operating
pressure in accordance with 192.619 (a) and (b).
192.614(c)(4) - If the operator has buried pipelines in the area of excavation activity, provide for
actual notification of persons who give notice of their intent to excavate of the type of temporary
marking to be provided and how to identify the markings.
192.614 Damage prevention program
(c) The damage prevention program required by paragraph (a) of this section must, at a minimum:
(5) Provide for temporary marking of buried pipelines in the area of excavation activity before, as far
as practical, the activity begins.
(6) Provide as follows for inspection of pipelines that an operator has reason to believe could be
damaged by excavation activities:
(i) The inspection must be done as frequently as necessary during and after the activities to verify the
integrity of the pipeline; and
(ii) In the case of blasting, any inspection must include leakage surveys.
192.615 (a)(3) Prompt and effective response to a notice of each type of emergency, including the
following:
(i) Gas detected inside or near a building.
(7) Making safe any actual or potential hazard to life or property.
192.617 - Each operator shall establish procedures for analyzing accidents and failures, including the
selection of samples of the failed facility or equipment for laboratory examination, where appropriate,
for the purpose of determining the causes of the failure and minimizing the possibility of a recurrence.
192.619 - (a) No person may operate a segment of steel or plastic pipeline at a pressure that exceeds a
maximum allowable operating pressure determined under paragraph (c) or (d) of this section, or the
lowest of the following:
(1) The design pressure of the weakest element in the segment, determined in accordance with
subparts C and D of this part. However, for steel pipe in pipelines being converted under
Page 116
192.14 or uprated under subpart K of this part, if any variable necessary to determine the
design pressure under the design formula (192.105) is unknown, one of the following
pressures is to be used as design pressure:
(i) Eighty percent of the first test pressure that produces yield under section N5 of
Appendix N of ASME B31.8 (incorporated by reference, see 192.7), reduced by the
appropriate factor in paragraph (a)(2)(ii) of this section; or
(ii) If the pipe is 1234 inches (324 mm) or less in outside diameter and is not tested to
yield under this paragraph, 200 psia. (1379 kPa)
(2) The pressure obtained by dividing the pressure to which the segment was tested after
construction as follows:
(i) For plastic pipe in all locations, the test pressure is divided by a factor of 1.5.
(ii) For steel pipe operated at 100 psia. (689 kPa) gage or more, the test pressure is
divided by a factor determined in accordance with the following table:
Class
location
Factors, segment
Installed before (Nov. 12,
1970)
Installed after (Nov. 11,

1970)
Converted under
192.14
1.1
1.1
1.25
1.25
1.25
1.25
1.4
1.5
1.5
1.4
1.5
1.5
(3) The highest actual operating pressure to which the segment was subjected during the 5
years preceding the applicable date in the second column. This pressure restriction applies
unless the segment was tested according to the requirements in paragraph (a)(2) of this section
after the applicable date in the third column or the segment was uprated according to the
requirements in subpart K of this part:
192.619 - (c) The requirements on pressure restrictions in this section do not apply in the following
instance. An operator may operate a segment of pipeline found to be in satisfactory condition,
considering its operating and maintenance history, at the highest actual operating pressure to which the
segment was subjected during the 5 years preceding the applicable date in the second column of the
table in paragraph (a)(3) of this section. An operator must still comply with 192.611
192.621 - (a) No person may operate a segment of a high pressure distribution system at a pressure
that exceeds the lowest of the following pressures, as applicable:
(1) The design pressure of the weakest element in the segment, determined in accordance with
subparts C and D of this part.
(3) 25 psia. (172 kPa) gage in segments of cast iron pipe in which there are unreinforced bell
and spigot joints.
Page 117
(4) The pressure limits to which a joint could be subjected without the possibility of its parting.
(5) The pressure determined by the operator to be the maximum safe pressure after considering
the history of the segment, particularly known corrosion and the actual operating pressures.
192.1007 What are the required elements of an integrity management plan? (DIMP)
A written integrity management plan must contain procedures for developing and implementing the
following elements:
(a) Knowledge. An operator must demonstrate an understanding of its gas distribution system
developed from reasonably available information.
(1) Identify the characteristics of the pipeline's design and operations and the
environmental factors that are necessary to assess the applicable threats and risks to its
gas distribution pipeline.
(2) Consider the information gained from past design, operations, and maintenance.
(3) Identify additional information needed and provide a plan for gaining that
information over time through normal activities conducted on the pipeline (for example,
design, construction, operations or maintenance activities).
(4) Develop and implement a process by which the IM program will be reviewed
periodically and refined and improved as needed.
(b) Identify threats. The operator must consider the following categories of threats to each gas
distribution pipeline: corrosion, natural forces, excavation damage, other outside force damage,
material or welds, equipment failure, incorrect operations, and other concerns that could
threaten the integrity of its pipeline. An operator must consider reasonably available
information to identify existing and potential threats. Sources of data may include, but are not
limited to, incident and leak history, corrosion control records, continuing surveillance records,
patrolling records, maintenance history, and excavation damage experience.
Page 118
ATTACHMENT D
Standard of Care for Pipeline Maps and Records
In its December 22, 2014 response to OII I.14-11-008, PG&E states:

Good recordkeeping, however, is just one of a number of complementary safeguards built into
PG&Es system, which is why PG&E has also implemented, and continues to implement,
robust measures to backstop reliance on sometimes imperfect records and thus maximize the
safety of its employees, contractors, and the public.
PG&E further states:
While PG&E constantly strives to improve its gas distribution recordkeeping, the sheer scope
of its distribution systemcomprising more than 77,000 miles of pipe, three times the
circumference of the globe, with literally miles of related recordsmakes this an enormous
undertaking, and attainment of perfectly accurate recordkeeping impossible.
We understand that attainment of perfectly accurate recordkeeping is a significant challenge; however,

accurate maps and records represent the foundation on which safe management of a gas distribution
system rests. The importance of this foundation is recognized and emphasized by the Gas Distribution
Pipeline Integrity Management program (DIMP) regulation (Subpart P of 49 CFR Part 192, issued
December 4, 2009) in which the following requirements appear:
192.1007 What are the required elements of an integrity management plan?
A written integrity management plan must contain procedures for developing and implementing
the following elements:
(a) Knowledge. An operator must demonstrate an understanding of its gas distribution system
developed from reasonably available information.
(1) Identify the characteristics of the pipeline's design and operations and the environmental
factors that are necessary to assess the applicable threats and risks to its gas distribution
pipeline.
(2) Consider the information gained from past design, operations, and maintenance.
(3) Identify additional information needed and provide a plan for gaining that information over
time through normal activities conducted on the pipeline (for example, design, construction,
operations or maintenance activities).
(4) Develop and implement a process by which the IM program will be reviewed periodically
and refined and improved as needed.
(5) Provide for the capture and retention of data on any new pipeline installed. The data must
include, at a minimum, the location where the new pipeline is installed and the material of
which it is constructed.
Page 119
The emphasis in 192.1007 is on the fundamental importance of system knowledge in managing

pipeline integrity, and on the recognition that sufficient information may need to be assembled over
time.
The reality is that current maps and records are inadequate to support effective integrity management.
In any event, the utility has a responsibility to operate its facilities safely. While violations are
typically framed in terms of failure to comply with federal or state regulations, the actions underlying
this failure may also constitute violations of PG&Es obligation to furnish such services necessary to
promote the safety, health, comfort, and convenience of its patrons, employees, and the public.98
Therefore in evaluating whether and why evidence of imperfect maps and records represents violations
of regulatory requirements, we address the standard of care that an operator could be measured in its
efforts to responsibly manage its requirements and obligations, including those in 49 CFR
192.1007(a) of the distribution pipeline integrity management regulation.
GO 112 represents the minimum requirements for design, construction, testing, operation and
maintenance of gas systems in California. Regarding maps and records, there are also two elements to
consider, both driven by regulations: (a) what information should be retained in an accessible form to
support safe operations and maintenance, and (b) what process should be employed to compensate for
acknowledged imperfections in maps and records.
Information an Operator should Retain
In our view, a reasonable person would opt to retain and maintain information that engineers and
supervisors, considering that the utility is dealing with distribution of a potentially explosive substance
that needs to be properly controlled to ensure public safety, would feel necessary to:
Demonstrate compliance with generally accepted consensus standards such as ASA B31.1.8,
ASME B31.8, and eventually Part 192 requirements as well as guidance provided by the AGA
for transmission and distribution of gas by pipeline.
Understand the basis for design and selection of materials, fittings (valves, drips, couplings and
joining techniques), repair methods, methods to connect service lines, pressure control district
regulators, construction techniques, corrosion controls, functional and strength testing, and
leakage history.
Readily locate buried gas lines during normal operations, maintenance and emergencies,
including information needed to locate lines that may exist in non-paved areas; and the location
of equipment for shutting down and isolating sections of a main.
Documentation would have to include designs, constraints on operating conditions such as pressures,
documentation of testing of new or modified lines, charts to ensure operating pressures were not higher
98
Page 120
than MAOPs, material specifications, construction standards, joining techniques, operating history
data, (locations and numbers and the nature of repairs, leaks, corrosion records), inspections, operating
practices and procedures and emergency response plans.
Process to Compensate for the Acknowledged Imperfections in Maps and Records
Regulations, predating DIMP, that relate to the appropriate standard of care include:
49 CFR 192.603 General provisions.

(a) No person may operate a segment of pipeline unless it is operated in accordance with this
subpart.
(b) Each operator shall keep records necessary to administer the procedures established under
192.605.
49 CFR 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of written
procedures for conducting operations and maintenance activities and for emergency response. For
transmission lines, the manual must also include procedures for handling abnormal operations. This
manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at
least once each calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where operations and
maintenance activities are conducted.
(b) Maintenance and normal operations. The manual required by paragraph (a) of this section must
include procedures for the following, if applicable, to provide safety during maintenance and
operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements
of this subpart and subpart M of this part.
(2) Controlling corrosion in accordance with the operations and maintenance requirements of
subpart I of this part.
(3) Making construction records, maps, and operating history available to appropriate operating
personnel.
49 CFR 192.605(b)(8) Periodically reviewing the work done by operator personnel to determine
the effectiveness, and adequacy of the procedures used in normal operation and maintenance and
modifying the procedures when deficiencies are found.
49 CFR 192.617 Each operator shall establish procedures for analyzing accidents and failures,
including, for the purpose of determining the causes of the failure and minimizing the possibility
of a recurrence.
49 CFR 195.60 If the Secretary or the NTSB investigate an accident involving a pipeline facility,
the operator of the facility shall make available to the Secretary or the Board all records and
information that in any way pertain to the accident, and shall afford all reasonable assistance in the
investigation of the accident.
49 CFR 195.401(b) Whenever an operator discovers any condition that could adversely affect the
safe operation of its pipeline system, it shall correct it within a reasonable time.
Page 121
As implied by these pipeline safety regulations, a prudent operator would focus on:
a. Developing a base of information (maps and records) that incorporates the best and most
complete information available to the operator, and that is accessible to those whose work
responsibilities require that information be they employees, contractors, or others working in
and around the pipelines;
b. Identifying on an ongoing basis the imperfections (gaps, errors and inconsistencies) in available
information, and assuring that these imperfections, as well as their implications to safe
operation and maintenance practice, are recognized, and their significance understood by those
relying on the maps and records to safely conduct their work responsibilities; correct
imperfections as necessary;
c. Taking advantage of every possible opportunity to confirm the accuracy of and as necessary to
correct the information base;
d. Scrutinizing all available sources of information (e.g., reportable incidents, internally identified
close calls, internal and external audit findings) for evidence of errors and gaps in the
information base, and acting to correct the information and, as appropriate, to institute backstop
measures (to ensure the safety of those relying on the maps and records to safely conduct their
work responsibilities) when correction of the information base may be too long considering the
risk of the data errors or gaps;
e. Assuring that backstop measures are implemented on a time frame consistent with the risk
associated with or safety significance of the information imperfections being addressed;
f. Verifying implementation and effectiveness of backstop measures employed as stopgaps while
an accurate and complete information base is being developed;
g. Verifying both the timeliness and the accuracy of changes to the maps and records resulting
from new construction, maintenance and information from point (c) above.
Figure D-1 illustrated these process principles as they apply to distribution system maps and records.
Observables
The attainment of perfect maps and records is a worthy goal. An operator is required to ensure the
safety, health, comfort, and convenience of its patrons, employees, and the public.99 This is
demonstrated by three observables:
1. The absence of impactful events evidenced by its operation;
2. Rigorous application of root cause analysis to understand and support correction of contributors to
impactful events; and
3. Ongoing operation in which zero defects are evidenced in its maintenance of maps and records.
99
Cal. Pub. Util. Code 451
Page 122
Figure D-1
D Pruden
nt Management of Pip
peline Map
ps and Reccords
Identify Reecord Keeping

g
Requiremen
nts and
Industry Prractices &
Standards; Develop
Consistent Implementing
(O&M) Proocedures; Traain
& Qualify Personnel
P
Construct orr Modify

Pipeline Sysstem; Developp
and Retain Required
R
Records in Required
R
Form & in Secure
S
Accessible Location
L
Correct Deficiencies in
Records & Procedures by
b
Addressing
g the
Underlying
g Causes of
Identified Deficiencies
D
for all Reco
ords, Maps &
Procedures Affected by
these Deficciencies
If Records Deficiencies
D
are too Exten
nsive for
Quick Correection:
o - Develo
op &
Implemeent Correctivee
Action Program
P
(Prioritizzed),
o - Identify
fy
Compen
nsatory
Measurees
(Backsto
ops),
o - Train Personnel
P
andd
Implemeent
m Recordkeeeping
Investigatiion of PG&E Distributtion System
Evaluate Opeerational
Experience ((e.g., leak
causes, inciddent causes,
inspection reesults,
necessary coorrosion
control practtices, pipe
exposure repports, audit
reports) for E
Evidence of
Inadequate R
Records &
Recordkeeping
Procedures
Monitor Corrrective
Action Progrram
Implementattion
Monitor Effeectiveness of
Compensatorry Measures
(Backstops); Modify as
Needed
Make effectiive use of
Performancee Measures in
Monitoring
Paage 123
ATTACHMENT E
Examples of Factors Contributing to Records and Mapping Issues
The six incidents cited in the OII are not the only sources that have revealed records or mapping issues
but rather are a representative set of examples. Table E-1 in this Attachment contains additional
examples of records or mapping issues, including: unmapped plastic inserts, unmapped stubs,
unmapped test stations, valve positions mapped incorrectly, maps that have removed abandoned mains.
The SED investigated each of the six incidents in the OII, but in many of these additional examples
there was no investigation because the incident did not meet the incident reporting criteria.100 We have
gathered the limited information on the additional example incidents from PG&Es CAP program.
These additional examples show that the incidents cited in the OII are not just isolated occurrences.
Plastic Inserts - PG&E has been routinely inserting plastic into steel and cast iron mains and service
lines for several decades. It appears that the records for these insertions have neither been consistently
created nor maps consistently updated and maintained. This appears to be the case not only for the
early insertions but also for ones that occurred at later dates.101 Thus the number and the extent of
inaccurate maps and records related to plastic inserts cannot be determined. PG&E uses its CAP
program to communicate and correct errors associated with plastic inserts as they are discovered.
Stubs - A second major issue identified in the six OII examples involves service line stubs created
from services that have been taken out service or never placed in service. Although there is a program
to reevaluate the necessity of keeping the record of the stub active, it appears that the program has not
been consistently followed and there are many stubs102 throughout the distribution system whose
records need to be evaluated for accuracy to prevent further incidents. The additional examples in
Table E-1 show that there are issues not only with inaccurate records of where the stub was cut-off, but
that some stubs shown on the maps are not in the location where they are shown, or they have
potentially been cut-off at the main and thus no longer exist. Inaccurately mapped stubs are an issue
when other infrastructure work requiring excavation is performed since service line stubs may cross
the street from the gas main to the property line for those properties that previously had gas service.
Valve Location - A third issue addressed by the six OII examples is valve locations and position. In the
OII example in Milpitas, a valve listed as normally open was actually closed and when the feed from
the opposite direction was closed to perform a tie in, approximately 1000 customers lost gas service.
Similarly, in the additional examples provided, while PG&E was working on a regulator station on
October 10, 2014 a valve listed as part of the Napa area Transmission system was closed but it actually
was a distribution valve and approximately 250 customers lost gas service.
100
The SED staff investigates incidents where there is a loss of life, an injury, a financial loss of more than
$50,000, or that media is on the scene. Other incidents that are considered important even if they do not meet
any of these criteria can also be investigated.
101
See Section 6.1 in the main report for additional examples.
102
See PG&E response to SED 003-052 where PG&E has identified the number of stubs to be over 71,000 in
GD GIS based on records from 18 divisions. This record may not be accurate as PG&E field crews are finding
that some of the stubs may not exist.
Page 124
Test Station Location - Test stations where tracer wires can be accessed are an important tool to
accurately locate and mark underground gas facilities. Accordingly, it is important to have the location
of all ETS stations accurately reflected on maps and records. When L&M crews are forced to rely on
signals from stations located a long distance from the area being marked, the strength of the signal
from gas lines is drastically reduced. This loss of signal strength may also result from the signal
jumping onto other facilities. Thus it is important to utilize the closest ETS to the line being located.
Additionally, when ETS stations are a long distances from excavation locations, and the risk of
obtaining inaccurate signals is great, L&M crews are still not taking advantage of existing gas line
locations shown on readily accessible maps. Using such map information can at a minimum, be a red
flag to the L&M crew that signals obtained from remote ETS stations may not be accurate,
necessitating further coordination with the excavator to avoid excavation damage to gas lines.
Abandoned Mains - Another area of concern is that abandoned mains are removed from system maps
and in some situations they are located close to live mains. This situation has resulted from a PG&E
policy103 to delete these mains, with some discretion at the Division level as to whether or not to follow
through. Thus, when third party excavators, and sometime PG&E crews, uncover an unmarked
abandoned line, they may mistakenly believe that it is the live line, and may not exercise the needed
care in continuing excavation.
In summary, there are numerous records and mapping issues with the PG&E distribution system. Until
they have been corrected, damage from excavation will continue to occur.
Table E-1 Additional Incidents Derived from PG&E Responses to Data Requests
Date (Issue)
Reference
Description
Location
04/18/13
4 plastic main hit by PG&E crew, apparently miss

marked, confusion over size, material
Stub off of 4 main, not on map nor marked
San Jose
01/20/15
(stub issue)
06/19/06
(valve issue)
SED 2013041802
SED 2015012001
SED 2006061901
Pittsburg
10/17/14
SED 003-Q38
(stub issue)
SED 003-Q52
(stub issue)
SED 001-Q12
Supp01, Bates
7710
4 main hit by water contractor but PG&E not sure of

one way or two way feed to area, 900 customers lost
gas due to one way feed
Prior to Procedure TD4460P-11 mapping corrections
were informal so PG&E cannot provide data on the
number of errors
Number of stubs over 71,000 in GD GIS 18 divisions
but crews are finding that some of the stubs may not
exist
Damage Prevention, mark-out mentions stubs
103
San Jose
System wide
System wide
System wide
PG&E Standard Practice 410.21-1, Mapping Standards, effective 04/01/77, Section II.3.
Page 125
Date (Issue)
Reference
Description
Location
05/01/80
(stub issue)
(plastic
inserts)
(abandoned
main)
2014
(stub issue)
Filed with
CPUC staff
Mapping standard SP 410.21-1 effective 05/01/80 on

page 15 describes how to map plastic inserts in mains,
on page 9 describes how to take abandoned mains off
of the map, on page 18 describes how to handle stubs,
on page 19 discusses inserted services
System wide
SED 002-Q19
Attach, CAP
7003107 Bates
18316
SED 001-Q12
Sup03, Bates
30353
SED 001-Q12
Sup03, Bates
30358
SED 001-Q12
Sup03, Bates
30404
SED 001-Q12
Sup03, Bates
30410
SED 001-Q12
Sup03, Bates
30453
SED 001-Q12
Sup03, Bates
30466
1 abandoned service not located, cut at property line

and not main, later cut at main
Santa Rosa
CAP on 2009 job not updated until 2014
Antioch
CAP on missed service replacements due to incorrect

data for 2011 installations found only because of a
leak on one of the services
CAP 7008952 - 2 stubs hit by O/S contractor
Danville
CAP for services installed in 2003 to 2005 in

Yosemite Division not being mapped, found by leak
survey in 2014
CAP for unmapped stub found in Central Coast
Division in 2014
Churchills-Green
Hills?
Emails on CAP in Bates 30464 from QC report on

regulator station and valves mentions valve position
not noted
SED 001-Q12
Sup03, Bates
30495
SED 001-Q12
Sup03, Bates
30499
CAP on 2 so called abandoned main that actual was

tied in and pressurized
San Jose Division

regulator station,
DR E-15 V-83J8K
Central Coast
Division, no town
given
Selma
2014
2014
2015
(stub issue)
2014
2014
(stub issue)
(valve issue)
2014
10/08/14
(plastic
inserts)
10/10/14
(valve issue)
SED 001-Q12
Sup03, Bates
30503
CAP on unmapped plastic inserted service (1/2

plastic in 1 steel in 4 casing) over drainage ditch
in Fresno Division on
maps start
on Bates 30501. This inserted service was identified
after corrective measures were instituted following the
Carmel incident.
Cap on Valve 91 in Napa mapped as transmission
system valve but was on distribution line and when
closed for work on regulator station, 243 customers
lost service
No location given
Hollister
Napa
Page 126
Date (Issue)
Reference
Description
Location
11/14
SED 001-Q12
Sup03, Bates
30522 et.al
Menlo Park
(stub issue)
SED 001-Q12
Sup03, Bates
30530
SED 001-Q12
Sup03, Bates
30566
CAP on map that has missing services, numerous

other CAPs for similar situations see Bates 30525,
30526 thru 30529, 30530 thru 30532 (see below),
30616, 30715, 30720, 30746, 30756,
CAP shows stub which proved to be services, at
&
in Chico
CAP with many mapping issues found when QC
doing follow up on leak repairs, one of the issues
appears to be an unmapped plastic insert or joiner.
These corrective measures were instituted following
the Carmel incident.
CAP has mapping errors that show service stubs that
are really active services; appears to be a large
problem; this one is in Central Coast is similar to issue
in East Bay Division
CAP shows 2 services to one building but only one is
active so other may be a stub, found when setting a
new meter at the building in San Francisco; similar
situation at lot in North Bay Division - Bates 30675
CAP on abandoned mains after confusion and active
mains being hit, system wide issue because these
mains are removed from the system maps
CAP for missing ETS box in Sacramento Division in
Stockton
Mission Division,
no town given
2014 (plastic
inserts)
2014
(stub issue)
SED 001-Q12
Sup03, Bates
30600 to 30607
2015
SED 001-Q12
Sup03, Bates
30672
2015 (ETS
Box)
2015
05/28/15 (stub
issue)
SED 001-Q12
Sup03, Bates
30703 to 30714
SED 001-Q12
Sup03, Bates
30782
SED 001-Q12
Sup03, Bates
30833
SED 001-Q12
Sup03, Bates
30891
CAP on empty lot that still shows an active gas

service at
CAP for stub hit by contractor, not on maps at
Chico
Multiple
Divisions
San Francisco
System wide
Sacramento
Division no town
given
San Jose
Santa Rosa
Page 127
ATTACHMENT F
Observations on Root Cause Analysis
Observations on the Exponent Root Cause Analysis
In our experience a root cause analysis can be performed for many reasons, including:
e. Identifying a cause or contributing factor that, if corrected, will prevent future similar
accidents;
f. Identifying lessons that may promote the achievement of better consequences;
g. Identifying a set of contributing factors that inform both corrective actions and identification of
similar vulnerabilities (physical, operational, and cultural characteristics) for elimination or
change;
h. Evaluation of whether negligence contributed to the occurrence of or to adverse consequences such as economic loss, death or injury - from an event.
The approach taken by Exponent in its analysis of the root cause of the incident at Camel104 (03/03/14 see discussion below) determined root cause by:
Root cause analysis: The root cause analysis was performed based on eliminating a
contributing cause and re-assessing the event timeline. If the removal of a contributing cause
prevented the occurrence of the problem, this cause was considered a root cause.
While this is certainly a valid approach for defining root cause, and in the analysis of the Carmel
incident helped define measures of great value in preventing future similar events, it inherently limits
the ability of the organization for which the analysis is performed to achieve the objectives noted in
point (c) above. For example, tracing the root cause back to a point in time, or to a particular
maintenance crew, or to a group of mappers that might have been dealing with an unmanageable
backlog at the time of the error, would add information of use in an organizations efforts to focus on
identifying other possible insertion mapping errors.
Our concern here is that a root cause analysis whose scope includes addressing the first three reasons
cited above might also contribute information of use in addressing the fourth reason (negligence
related to liability). Thus, liability concerns have the potential to seriously limit the value of a root
cause investigation. Avoiding this limitation seems critical to learning as much as possible from
consequential events.
104
Carmel Gas Incident, Exponent, Failure Analysis Associates, April 2014, Doc. no. 1401752.000 6877.
Page 128
Exponent Root Cause Analysis

At the request of PG&E, Exponent Failure Analysis Associates (Exponent) conducted an investigation
of the gas leak and subsequent explosion on March 3, 2014 in Carmel-by-the-Sea (Carmel), California.
In a Statement of the Limitations of this study, Exponent stated:
Exponent investigated specific issues relevant to this incident, as requested by the client. The
scope of services performed during this investigation may not adequately address the needs of
other users of this report, and any re-use of this report or its findings, conclusions, or
recommendations presented herein is at the sole risk of the user.
The Exponent report stated:
Flow into the house: Because the house was reportedly unoccupied for an extended period
prior to the incident, it is likely that some of the plumbing traps had dried out, rendering the
water seal in the trap ineffective. This allowed for a direct pathway into the living space from
the sewer system. The results of the helium gas migration test and a fire photograph provided
by PG&E provide support to the toilet being the most likely entry path for large volumes of
natural gas entering the house on the day of the incident.
No observation was made on whether the gas pressure was sufficient to have blown out the plumbing
traps had they not been dry.
The Exponent report further stated:
The data collection effort was focused on retrieving the job folder for the installation of the
plastic insert of the 2-inch line on 3rd Avenue. In spite of the extensive data collection and
review effort, the installation job folder has yet to be located.
A Timeline and Causal Analysis Diagram were developed as part of the root cause analysis.
The resulting root cause was determined to be:
Inadequate verification of system status and configuration when performing work on a live
line.
The Exponent report further stated:
Performance of Root Cause Analysis
The root cause analysis is performed in a structured sequence of steps that lead to identification of the
root cause and any contributing causes. When a significant event occurs, the root cause analysis
examines the apparent cause (such as material failure or human error), as well as programmatic and
Page 129
management causes that failed to prevent the incident. The root cause analysis was performed in the
following steps:
o Identification of initiating events from the timeline, as described above.
o Causal analysis: This step included the causal analysis for each of the identified initiating
events. The causal analysis results in identifying the cause of each initiating event. These are
identified as
o Root cause analysis: The root cause analysis was performed based on eliminating a
contributing cause and re-assessing the event timeline. If the removal of a contributing cause
prevented the occurrence of the problem, this cause was considered a root cause.
o Validation of the root cause: After completion of the root cause analysis, validation was
provided by review with key participants.
The outcome of this effort was the identification of a single root cause. This information formed the
basis for developing recommended corrective actions.
The problem statement developed for performing this root cause analysis is:
On March 3, 2014, while tapping into an existing 2" steel line, gas was released, entered a
residence and ignited causing an explosion.
A Causal Analysis Diagram, located in Appendix F, considers the two aforementioned initiating
events in the problem statement with the resulting root cause being:
Inadequate verification of system status and configuration when performing work on a live line.
Page 130
ATTACHMENT G
Response to March 6, 2014 Gas Incident Violation Letter

Mountain View, California,
Sumeet Singh (PG&E) to Michael Robertson,
April 4, 2014
Page 131
Sumeet Singh
Vice President
Asset and Risk Management
Gas Operations
6111 Bollinger Canyon Road

San Ramon, CA 94583
Phone: 925.244.3189
E-mail: Sumeet.Singh@pge.com
April 4, 2014
Mr. Michael Robertson

Gas Safety and Reliability Branch
Safety and Enforcement Division
California Public Utilities Commission
320 West 4th Street, Suite 500
Los Angeles, CA 90013
Re: Response to March 6, 2014 Gas Incident Violation Letter

Mountain View, California
Dear Mr. Robertson:
This letter summarizes PG&Es response to the Safety and Enforcement Divisions (SED) letter dated March 6,
2014, regarding the gas incident that occurred on July 30, 2013 in Mountain View, California, affecting a one-inch
plastic service line insert.
In its letter, the SED found PG&E in violation of Title 49 of the Code of Federal Regulations Part 192.605(b).
PG&E agrees with this violation. We have taken corrective actions and are developing preventative actions to
address and minimize recurrence of the issue.
Actions taken immediately following the incident:
Replaced the damaged pipe, conducted a leak survey of the area (no additional leaks were detected), and
restored gas service.
Updated the distribution plat map to reflect the completed replacement work.
Conducted an extensive search into existing records and construction drawings in an effort to determine
why the inserted plastic gas service was not shown on the distribution plat map or the job installation
drawing. PG&E was not able to locate the records for the plastic insert job, which PG&E believes
occurred prior to 1980.
Ongoing preventive actions include:
Reduced the average amount of time that it takes to update our mapping systems with the details of post
construction as-built jobs from 75 days to 34 days in 2013.
Implemented a Corrective Action Program across Gas Operations so that every employee has the ability
and is continuously encouraged to submit any issues from a personal safety related observation to any
differences they identify between the information on our maps and records to what is in the ground. Each
item is assigned an owner, prioritized, and tracked through completion.
As you are aware, on March 3, 2014 we had an explosion related to distribution work in Carmel. While the
specific circumstances of the Mountain View and Carmel incidents do not precisely match, we believe the
following additional steps instituted following the Carmel incident will also address the Mountain View
incident:
Distribution and training of a 5 Minute Meeting on March 24, 2014 to field personnel throughout
PG&Es system that enhances tapping procedures incorporating process safety principles. This introduces
new measures to be taken to identify whether or not steel pipe has been inserted. This guidance, which
Mr. Michael Robertson

April 4, 2014
Page 2
includes a checklist to be followed for each job, walks employees through three successive steps, each
adding another level of confidence regarding possible insertions before work begins. These steps are: 1)
review associated documentation, looking specifically for indications that documents match; 2) look at the
job site to read the street, checking that facilities match documentation; and 3) perform a physical
verification for plastic or to utilize existing fittings to determine if a previous insertion exists.
Developing and implementing a field QA/QC plan to verify that the steps outlined in the March 24 5
Minute Meeting are being uniformly applied by field personnel. These quality verification activities are
also expected to identify further safety enhancements.
Approval of the use of a bolt-on steel tap fitting. Work Procedure TD-4150P-110 -Continental Steel to PE
Mechanical Bolt-On Saddle Punch Tee, published on March 24, 2014, provides field personnel detailed
procedures about how to use a bolt-on saddle punch tee as a further validation step that steel pipe has not
been previously inserted, as required. This is a technique that can be used to fulfill the physical verification
noted in the 5 Minute Meeting if other fittings are not available.
Continuing implementation of the Pathfinder Project to convert critical distribution asset data from an
existing Computer Aided Design (CAD)-based system and paper to an integrated SAP and Global
Information System (GIS). Deployment of the Pathfinder Project is continuing throughout PG&Es
operating divisions, with complete system-wide deployment planned in 2015.
Upcoming preventive actions include:
Instituting an R&D project with other industry operators to develop non-destructive testing methods that
can be used to confirm inserted pipe prior to commencing work.
We would welcome the opportunity to meet with you and your team to further discuss our preventive action
plans. In the interim, should you have any questions please do not hesitate to contact ChristiAne Mason at
(925) 328-5795or C6MW@pge.com.
Sincerely,
/S/
Sumeet Singh
Vice President, Asset and Risk Management
cc:
Aimee Cauguiran, CPUC

Dennis Lee, CPUC
Liza Malashenko, CPUC
Nathan Sarina, CPUC
Larry Berg, PG&E

Larry Deniston, PG&E
Bill Gibson, PG&E
ChristiAne Mason, PG&E

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Investigation of PG&E Distribution System Recordkeeping

September 30, 2015

Investigation of PG&E Distribution System Recordkeeping

Investigation of PG&E Distribution System Recordkeeping

7. CHANGES IMPACTING PG&ES CONTROLS ON NATURAL GAS

Investigation of PG&E Distribution System Recordkeeping

Identify recordkeeping violations that have occurred.

Facts Related to PG&E Recordkeeping

See SP 410.21-1 pages 31-32.

PG&E Initial Report in Response to the OII, December 22, 2014.

Investigation of PG&E Distribution System Recordkeeping

PG&E is completing implementation of the Pathfinder Project to bring together available

The US Department of Transportation Distribution Integrity Management Program (DIMP)6

Refer to 49 CFR 192.1007 and 192.605(b)(4).

Investigation of PG&E Distribution System Recordkeeping

Regulations such as 49 CFR 192.605(b)(4), 192.605(b)(8), 192.617, 192.1007, and 192.613,

Investigation of PG&E Distribution System Recordkeeping

Failure to meet operating pressure restrictions contained in 49 CFR 192.619(a), or establish

Investigation of PG&E Distribution System Recordkeeping

Purpose and Scope

In response to several incidents, by this order, the California Public

Determine what recordkeeping violations, including those potentially associated

Provide a report and testimony in support of the Gas Distribution Recordkeeping

PG&E Initial Report in Response to the OII, December 22, 2014.

Investigation of PG&E Distribution System Recordkeeping

Participated in two presentations (one by phone, one in person) by knowledgeable

Interviewed six working level PG&E employees, in a monitored environment, to

Reviewed the PG&E executive responses to twenty-five (25) interrogatories

Investigation of PG&E Distribution System Recordkeeping

1.3.2 PG&E Response to the OII

It contends that a company as large as PG&E cannot be expected to have

See PG&E Response to OII dated 12/22/14, page 5.

See PG&E Response to OII dated 12/22/14..

PG&E Response to OII dated 12/22/14, page 2.

Investigation of PG&E Distribution System Recordkeeping

o Efforts to improve accuracy,

o Efforts to improve map and record accessibility,

o Efforts to improve controls,

o Actions to improve operational safety.

Impact of Records Gaps on Distribution System MAOP

Investigation of PG&E Distribution System Recordkeeping

Previous PG&E and CPUC Investigation of Records

Previous Consideration of Recordkeeping Issue

Findings of Duller and Norths Related to Recordkeeping at PG&E

Duller and Norths report found:

This report contains a review and assessment of PG&Es policies, procedures,

Testimony of Duller and North, at p. 6-25, lines 30-32.

Testimony of Duller and North, at p. 1-10, lines 15-24.

GasTransmissionSystemRecordsOII_DR_025-Q02(i) Supplement - Summary of Information Management

Investigation of PG&E Distribution System Recordkeeping

series of site visits to PG&Es facilities. While this review focuses on

PG&E failed to maintain the records management practices necessary to promote

In 2011 PG&E commissioned Pricewaterhouse Coopers (PwC) to undertake an

www.arma.org/garp; Principles include: accountability, compliance, transparency, availability, integrity,

Investigation of PG&E Distribution System Recordkeeping

CPSD understands PG&E plans to make necessary changes to its records

Previous Studies of Records Adequacy at PG&E

The 1984 report contained the following observation:

Investigation of PG&E Distribution System Recordkeeping

PWA APPROACH TO THE INVESTIGATION

See OII I.14-011-08 pages 2 to 7.

Investigation of PG&E Distribution System Recordkeeping

Under the provisions of 49 CFR 192.619.