Supervisory Control and Data Acquisition System, Gas Control, and Geographical Information System Supervisory Control and Data Acquisition (SCADA) is the use of computers and communications networks to gather field data from numerous remote locations, perform numerical analysis, and generate trends and summary reports. SCADA is employed for many different processes, such as management of electric power lines, operation of oil refineries, and operation of automobile assembly plants. SCADA systems make it possible to control a process that is distributed over a large area with a small group of people located in a single room. PG&E’s gas SCADA system monitors and controls 6,438 miles of transmission pipeline. SCADA reports are displayed in a structured format to enhance Gas Control Operators’ ability to monitor, forecast and send commands to field equipment. Some pipelines span long distances and are usually operated from a central location using a SCADA system. About 9,000 sensors and devices are installed along the length of the pipelines to enable the display of flow rates, equipment status, valve position status, pressure set points, and pressure control among other data. The current generation of SCADA used by PG&E is based on Citect software from Schneider Electric. PG&E’s pipelines are controlled and managed from the Primary Gas Control Center (Gas Control) located in San Francisco with an alternate (duplicate) control center located in Brentwood. Several compressor stations and local control stations, such as the Milpitas Terminal are situated along the pipelines, each with a separate local control system.
recommendations in the CPSD Report (including any addendum to the CPSD Report) to improve and ensure system-wide safety and reliability. (Footnote omitted.) In addition, the scope of this investigation includes PG&E’s cooperation with discovery requests in this proceeding in the light of PG&E’s obligation under Rule 1.1 to provide complete and answers to the Commission and its staff. (Footnote omitted) Finally, the scope of the proceeding includes PG&E’s compliance with Orders and Resolutions issued by the Commission to PG&E since the date of the San Bruno incident. (Footnote omitted.) No at the [prehearing conference] raised any objection or concern with the OII’s designation of the scope of issues to be considered. This Scoping Ruling incorporates and adopts the Preliminary Scoping Memo set forth in the OII as the Scoping Memo for the proceeding. Related Actions and Proceedings On September 13, 2010, the Commission’s Executive Director ordered PG&E to reduce operating pressure in Line 132 to a 20% below the pressure at the time of the explosion. On September 23, 2010 the Commission issued Resolution L-403, ordering PG&E to “review the classification of its natural gas transmission pipelines and determine if those classifications have changed since the initial designation.” Resolution L-403 also created the IRP to gather and review facts, and make recommendations to the Commission for the improvement of the safe management of PG&E’s natural gas transmission lines. The NTSB issued Urgent Safety Recommendations P-10-2 and P-10-3 on January 3, 2011. These NTSB recommendations were to determine “the valid maximum allowable operating pressure” for its natural gas transmission lines misleading
standards called for sections not shorter than five feet in length. PG&E was in fact apparently aware of the requirement when it ordered pipe from Consolidated Western, as its purchase order included the same specification. The use of pipe sections less than five feet in length was considered an unacceptable practice according to industry safety standards in effect at the time Segment 180 was constructed. PG&E witnesses Dr. Caligiuri and Harrison assert that properly made and installed short lengths of pipe can be safe. However, PG&E has not persuaded us that these opinions should supersede or outweigh both industry safety standards that preclude the use of such short lengths and PG&E’s own 1956 purchasing specifications. By installing sections in Segment 180 that were less than five feet in length, contrary to API 5LX Section VI, PG&E created an unsafe system in violation of Section 451. This violation occurred in 1956 when Segment 180 was installed. Required Yield Strength The pipe for Segment 180 was intended to meet API 5LX Grade X42 or X52 yield strengths, which indicate minimum yield strengths of 42,000 psi and 52,000 psi. Testing revealed the ruptured pups on Segment 180 had yield strengths below 42,000 psi. Pup 1, the failed pup on which the facture initiated, was found to have a yield strength of only 36,600 psi, and Pup 2 had the lowest yield strength of 32,000 psi. Section 805.54 of ASME B31.1.8-1955 provides that “specified minimum yield strength is the minimum yield strength prescribed by the specification under which pipe is purchased from the manufacturer (psi).” CPSD contends that the Segment 180 pups were far below required yield strengths. CPSD
exorbitant costs. Id. Instead, Edison argued, failure to comply with the GOs in the first instance should be considered only a “nonconformance” or “variance” with the GOs. The Commission rejected that argument, finding that utilities are required to comply with relevant safety statutes, Commission GOs, and decisions. Id. at 62, Conclusion of Law 3. The Commission stated: “If a utility fails to comply with a GO, it is violating that GO.” Id. at 63, Conclusion of Law 4. The Commission also held that the fact that a utility has limited resources “does not eliminate the existence of a violation but may be a factor in assessing penalties.” Id., Conclusion of Law 6. Because the data gathering and integration mandate cannot be fulfilled with inaccurate data, the presence of inaccurate data in the GIS system can result in a violation of 49 CFR 192.917(b). CPSD witness Stepanian described examples from the NTSB Report as examples of erroneous GIS data: (1) indicating 40 foot depth of cover, (2) showing pipe as seamless, and (3) not reflecting the six Segment 180 pups. Exhibit CPSD-1 at 32. With respect to the first, PG&E believes that the reference to six segments with a 40 feet depth of cover in the NTSB Report is a “simple data entry error” since 4.0 feet is a common depth of cover. PG&E Opening Brief at 68, footnote 352. Those depth-of-cover errors may be simple but we are not prepared to dismiss them as unimportant. On the other hand, CPSD has not persuaded us that the fact that PG&E’s GIS did not reflect the presence of the defective Segment 180 pups is a data gathering and integration error. With respect to the admittedly erroneous GIS data showing several Line 132 segments, including Segment 180, as 30-inch diameter seamless pipe, PG&E witness Keas suggests that such errors are (1) excusable due to the age of
General Emergency Response Issues Federal Emergency Response Regulations Title 49 of the CFR includes the following provisions for which CPSD alleges emergency response violations by PG&E: 49 CFR 192.605 – Procedural Manual: As noted in Section 5.3.1, 49 CFR 192.605(a) requires operators to prepare and follow a manual of written procedures for conducting operations and maintenance activities and for emergency response. Paragraph (c) states that for transmission lines, the required manual shall include enumerated procedures to provide safety when operating limits have been exceeded. 49 CFR 192. 615 – Emergency Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency, including at a minimum 11 enumerated conditions or activities (Paragraph (a)); furnish supervisors a copy of the procedures, train personnel, and review employee activities for effectiveness (Paragraph (b)); and establish and maintain liaison with fire, police, and other public officials (Paragraph (c)). 49 CFR 192.616 – Public Awareness: Paragraph (a) provides that operators must develop and implement a written continuing public education program that follows the guidance provided in the American Petroleum Institute’s (API) Recommended Practice (RP) 1162. Paragraph (d) provides that the program must include provisions to educate the public, government organizations, and persons engaged in excavation regarding enumerated conditions and activities. 49 CFR 199.105 – Drug Tests Required: Paragraph (b) requires operators to conduct post-accident drug tests. 49 CFR 199.225 – Alcohol Required: Paragraph (a) requires operators to conduct post-accident alcohol tests.
16 26 49 CFR 192.917(c) - Use of improper risk ranking algorithm - - 0 2,093 2,093 17 28 Section 451 - Creation of unsafe condition by avoiding hydrostatic testing or ILI - - 0 2,093 2,093 18 29 49 CFR 192.13(c) - Failure to follow internal work procedures 9/9/2010 - - 0 1 1 19 30 Section 451 - Failure to follow internal work procedures 9/9/2010 - - 0 1 1 20 31 49 CFR 192.605(c) - Failing to have adequate written procedures 9/9/2010 - - 0 1 1 21 32 Section 451 - Unsafe conditions at Milpitas Terminal - - 0 194 194 22 38 49 CFR 192.615(a)(3) - Failure to respond promptly and effectively 9/9/2010 - - 0 1 1 23 39 49 CFR 192.615(a)(1) - Failure to receive, identify, and classify notices 9/9/2010 - - 0 1 1 24 40 49 CFR 192.615(a)(4) - Failure to provide resources at scene 9/9/2010 - - 0 1 1 25 41 49 CFR 192.615(a)(6) - Failure to adequately perform emergency shutdown 9/9/2010 - - 0 1 1 26 42 49 CFR 192.615(a)(7) - Failure to make hazards safe 9/9/2010 - - 0 1 1 27 43 49 CFR 192.615(a)(8) - Failure to notify responders 9/9/2010 - - 0 1 1 28 44 49 CFR 192.605(c)(1) and (3) - Failure to have adequate emergency manual 9/9/2010 - - 0 1 1 29 45 49 CFR 192.615(a)(2) - Failure to follow adequate procedures for communication with first responders 9/9/2010 - - 0 1 1 30 53 49 CFR199.225(a) - Failure to perform alcohol tests 9/9/2010 - - 0 1 1 31 34 Section 451 - Unsafe condition caused by emergency response deficiencies 9/9/2010 - - 0 1 1 32 55 Section 451 - Unsafe condition due to budget cutting - - 0 983 983 Total Offenses 27,036 32,219 59,255 (End of Appendix B)