On March 12, 2012, the CPUC's Consumer Protection and Safety Division (CPSD) issued its analysis of Pacific Gas and Electric Company’s (PG&E) records management prior to the natural gas transmission pipeline rupture in San Bruno, Calif., in 2010.
The reports conclude that PG&E’s 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. On the basis of PG&E’s own records catalog, CPSD estimates that prior to the rupture of Line 132 PG&E stored its pipeline records for any given job in up to 10 different locations, without the necessary document control processes in place to track their location, existence, or contents.
The reports conclude that the recordkeeping issues identified could have been addressed had PG&E put the right people, processes and systems in place over time, and provided clear records management guidance. The creation of a formal records management program with supporting records management policies, procedures, systems, and training would have ensured that appropriate attention and protection was given to PG&E documents, so that the evidence and information they contain could have been retrieved more efficiently and effectively.
The reports conclude that PG&E failed to keep and maintain information needed to promote gas safety. Alleged PG&E recordkeeping failures include the location of re-used pipe in service, numbers and conditions of leaks, pressure information, and other information critical to pipeline safety.
The reports were prepared as part of the CPUC’s Penalty Consideration Case (I.11-02-016) into whether PG&E’s gas transmission pipeline recordkeeping was unsafe, whether it violated the law, and if so whether deficient PG&E recordkeeping caused or contributed to the pipeline rupture in San Bruno.
Parties in this case may serve written testimony in response to CPSD’s reports and Evidentiary Hearings are scheduled to begin in September.
Report and Testimony of Margaret Felts: Ms. Felts report identifies how recordkeeping affects the practical aspects of installation and maintenance of gas transmission pipeline infrastructure.
CPSD Recordkeeping Report: This report discusses energy recordkeeping specifically with respect to natural gas transmission issues relevant to the failure of Line 132.