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From YouTube: NTSB Public Meeting Day 2 Disc 3 of 3 March 2, 2011
Description
NTSB Public Meeting Day 2 Disc 3 of 3
March 2, 2011
Natural Gas Pipeline Explosion and Fire
San Bruno, CA September 9, 2010
A
And
we'll
begin
with
the
parties
questioning
the
fourth
panel
and
we'll
begin
with
the
city
of
san
bruno.
B
This
question
is
directed
to
fimsa,
whoever
is
best
situated
to
answer.
Yesterday,
a
member
of
the
pg
e
witness
panel
acknowledged
that
in
essence,
age
does
matter
when
it
comes
to
pipelines.
C
You
know
when
an
operator
looks
at
its
records.
It
has
the
responsibility
of
ensuring
that
those
records
are
as
good
as
they
can
be
when
it
is
conducting
its
integrity
management
plan
assessment.
It
has
the
responsibility
of
assuring
that
it
has
the
best
information
possible
and
when
it
makes
its
decisions
on
the
threats
to
assess
it
must
base
that,
on
the
best
information
available
and
put
in
safety
precautions,
the
whole
part
of
integrity
management.
C
The
whole
philosophy
is
to
identify
the
risks
and
the
threats
and
to
assess
for
them,
and
then,
once
you
know
what
you're
dealing
with
you
address,
those
you
must
have
good
information
and
your
plan
must
be
based
on
the
best
information,
the
best
integration
of
data
that
you
can.
You
can
get,
and
you
apply
good
safety
factors
into
that.
C
When
you
assess
your
pipeline
and
you
find
issues,
you
must
repair
them,
then
you
must
apply
that
to
the
rest
of
your
line.
So
and
it's
about
learning
taking
the
information
you
learn
and
putting
it
back
into
your
plan.
You
apply
mitigative
and
preventive
measures,
but
one
of
the
big
issues
that
we
are
looking
at
right
now
is
whether
operators
are
doing
a
good
job
on
risk
assessment,
whether
they
understand
what
they
have.
You
ask
specifically
about
age.
There
are
some
things
we
know
about
age.
C
C
B
C
Every
operator
is
expected
to
thoroughly
understand
their
system.
Every
pipeline
system
is
unique.
One
of
the
benefits
of
the
integrity
management
program
is
that
it
is
not
a
cookie-cutter
regulation.
It
does
not
have
a
one-size-fits-all
answer
to
integrity
issues.
It
says
you
must
know
your
pipe
and
you
must
assess
for
the
threats
to
that
pipe,
whether
they
be
very
unique
or
not,
and
then
you
must
address
them.
Thank
you.
B
D
The
we
have
a
control
room
management
regulations
coming
out
that
specifically
designed
to
look
at
control
room
issues.
The
integrity
management
program
really
looks
towards
threats
to
a
pipeline.
If
there
was,
there
was
problems
with
the
control
equipment
or
something
like
that
that
could
come
under
equipment
threat
under
the
integrity
management
plan.
If
there
was
trending
where
there
had
been
issues
for
for
that
type
of
thing,
so
that's
where
we
would
look
at
it.
E
A
A
C
G
Just
have
three
questions
in
five
minutes,
hopefully
we'll
be
short
to
miss
doherty.
I'd
like
to
ask
a
question
about
integrity
management,
as
you
and
the
cpuc
know,
and
said
it's
one
of
many
different
types
of
inspections,
but
I
would
like
to
ask
you
to
talk
a
little
bit
about
the
regulatory
approach
and
why
I
mean,
what's
the
value
of
that
particular
approach.
C
Integrity
management
is
a
performance-based
regulation.
It
is
not
prescriptive,
it
is
not
a
coca-cola
regulation.
It
requires
a
understanding
of
pipeline
facilities,
it
unders
it
requires
a
comprehensive
assessment
of
the
facility.
It
also
incorporates
the
ideas
of
risk
management,
where
you
apply
your
greatest
resources
to
your
greatest
risks.
C
It
provides
additional
protections
where
the
greatest
risks
are
to
people
and
to
the
environment
as
a
performance-based
regulation.
It
requires
us
to
well.
Let
me
back
up
performance-based
regulations
are
very
difficult.
They
are
not
easy,
but
sometimes
the
easy
solutions
are
not
the
best
solutions.
It
is
a
difficult
regulation
both
to
implement
by
operators
and
to
inspect
by
regulators,
but
we
believe
it
is
worth
the
outcome
and
we
believe
our
safety
trends
are
showing
that
it
is
effective.
G
D
Quickly,
the
integrity
management
program,
once
we
had
a
rule
out,
we
gathered
our
senior
engineering
staff
and
we
partnered
with
our
state
our
closest
business
partners.
Our
state
pipeline
safety
program
partners
and
we
developed
frequently
asked
questions
protocols
to
run
through
to
develop
out
an
implementation
plan
and
program
for
integrity
management,
integrity
management
inspections
are
certainly,
as
I
think,
our
operators
would
share
with
you
or
not
short-lived
inspections.
D
They're,
not
a
checklist,
their
investigative
approach
to
looking
at
issues
and
threats
and
assessments
of
threats
and
methodologies
that
pipeline
companies
implore
to
address
those
those
threats
they
may
there
be
inspection
team
that
consists,
maybe
four
to
five
to
eight
senior
inspectors
there
that
are
running
through
a
list
of
the
protocols
and
looking
at
records
and
and
verifying
records,
and
looking
at
methodologies
that
are
applied
to
the
threats
and
preventive
mitigative
measures
and
follow-ups.
D
So
they're
not
they're,
not
just
a
quick
checklist
approach.
They're,
not
they're,
not
just
looking
at
procedures,
they're
looking
at
procedures,
they
look
at
the
implementation
of
those
procedures
and
then
they
actually
check
the
the
activities
in
the
field.
On
occasion,
when
we
have
the
opportunity,
when
there's
a
dick
going
or
something
like
that,
that
we
can
verify
what's
done
there,
so
the
integrity
management
program
again
was
a
joint
effort
between
fimsa
and
state
pipeline
safety
partners.
We
had
several
workshops.
D
We
also
include
the
industry
and
review
of
the
faqs
and
any
of
our
guidance
material
that
we
were
pulling
together,
trying
to
address
issues
for
the
implementation
of
this
of
this
rule.
It's
a
very
extensive
integrity
rule
that
we
have,
I
think,
is
probably
one
of
the
most
significant
rule
makings
that
that
we
we
have
with
themselves.
G
Great
thanks
and
then
lastly,
a
question
for
mr
metro
in
terms
of
I
I'm
anticipating,
then
your
recommendation
coming
to
us
shortly
but
would
like
to
just
ask:
if
you
would
we
we
had
a
long
association
between
the
states
and
fems
federal
government.
I
wonder
if
you
would
talk
just
a
little
bit
about
how
that
plays
out
during
the
course
of
the
year
next
year
you
get
to
be
the
chairman,
if
you're
not
already,
and
maybe
you
could
enlighten
us
on
that.
H
Well,
first,
let
me
address
your
first
point
in
that
the
process
for
nafsa
in
proposing
something
to
femzy
works
through
the
resolution
process
for
all
48
states,
and
we
have
we
only
meet
once
a
year
and
and
we'll
try
to
accelerate
that
process.
They
got
a
resolution
to
two
films
addressing
the
meop
for
grandfather
pipes
on
the
communication
portion
of
it.
H
As
with
all
partnerships,
there's
been
rocky
periods
in
which
there's
been
strained
relationships
over
the
last
five
years.
The
both
parties,
both
partners,
have
worked
very
hard
to
develop
a
very
good
communication
between
each
other
and
worked
very
hard
to
to
meet
quite
frequently.
For
example,
we
meet
with
femza
in
all
the
regional
meetings
which
there
are
five
we
meet
at
the
annual
meeting.
We
have
monthly
calls
with
jeff
with
the
executive
board
of
napster
and
we
meet
in
various
ways,
with
zach
and
linda
and
through
different
committees
that
we
have.
So.
F
Ever
cpuc,
thank
you,
a
quick
one
for
mr
metro
I'll.
Let
the
microphone
catch
up,
quick
one
for
mr
metro.
There
we
talked
a
couple
of
times
and
also
just
in
the
last
exchange
about
prescriptive
rules
versus
performance-based
measures
and
regulation.
There
can
you
flesh
out
what
those
two
terms
mean
and
then
I'll
have
a
follow-up.
H
We
need
to
study
whether
there's
further
enhancements
are
needed,
but
if
you
look
at
the
number
of
anomalies
that
have
been
detected
through
performance-based
measures,
if
you
look
at
the
number
of
repairs
made
the
pipeline,
there
would
be
a
very
strong
argument
that
performance
based
measures
are
working.
However,
if
you
look
at
record
keeping,
that
might
be
one
area
in
which
we
need
to
to
get
away
from
performance-based
measures
and
look
at
prescriptive
measures
that
you
must
keep
this
this
this
and
this
record.
C
B
A
C
C
C
Can
we
use
more?
We
need
to
know
more
about
the
infrastructure.
I
am
sure
that
there
will
be
people
that'll
say
we
collect
plenty
that
we
collect
too
much
and
we
aren't
using
what
we
have.
I
believe
that
that
is
probably
not
correct
that
we
do
have
data.
We
need
to
collect,
maybe
different
data.
We
need
to
have
better
understanding
of
our
infrastructure.
I
Well,
thank
you.
The
one
thing
I
was
going
to
add
was
that
the
rules,
whether
it
is
additional
prescriptive
rules
or
additional
performance
rules,
is
that
I
think
they
need
to
look
more
at
making
sure
that
there's
continuous
improvement
included
within
the
rule,
and
so
there's
not
the
opportunity
to
just
sit
with
grandfathered
pipes
and
not
make
an
effort
to
either
make
them
pickable
or
go
and
look
at
whether
they
need
to
be
replaced.
I
I
think
that
that
element
of
continuous
improvement
needs
to
be
really
strongly
included
in
any
performance-based
rule
and
if
it
needs
to
be
included
by
adding
a
few
other
prescriptive
rules,
that's
one
way
of
doing
it
or
just
make
sure
that
it's
strengthened
in
a
performance-based
rule.
J
J
You
mentioned
before
the
break
that,
if
someone
doesn't
know
what's
in
the
ground,
they
need
to
find
out
what's
in
the
ground,
and
certainly
that
sounds
reasonable
and
I
think
one
of
the
things
you
mentioned
was
they
dig
it
up
and
look
at
it
in
the
case
of
the
san
bruno
pipe
if
they
would
have
dug
it
up
and
look
looked
at
it,
they
wouldn't
have
seen
anything
abnormal
because,
as
I
understand
it,
it
was
a
we're
looking
at
a
internal
seam.
Well.
K
J
C
It's
a
good
question.
It
basically
goes
to
what.
How
do
you
know
what
you
don't
know.
I've
heard
that
stated
earlier
and
it's
a
very
good
question
with
the
san
bruno
situation.
If
they
had
known
they
and
they
excavated,
perhaps
they
would
have
seen
the
multiple
we
call
them
pups
or
the
different.
They
would
have
seen
that
the
pipe
was
constructed
somewhat
in
an
unusual
manager
manner
and
they
may
have
done
further
research
to
get
to
the
internal
seam.
It's
a
very
good
question.
C
A
L
C
C
C
C
L
C
C
M
So
we're
going
to
go
from
the
pipeline
up
to
the
country,
we'll
start
on
the
fed
side,
because
I
have
one
question:
I'd
like
to
do
from
a
federal
perspective
as
well
as
state.
One
of
the
advantages
of
performance-based
programs,
of
course,
is
that
intrinsically
you
should
be
able
to
measure
them,
and
so
mr
barrett
started
by
talking
about
sort
of
100
percent
and
california
puc
being
at
90.
D
Sure
we
we
do
a
scoring
document
each
year,
where
we
aggregate
the
the
score
based
on
the
information
that
they've
sentenced
their
jurisdictions,
their
minimum
training
and
those
sort
of
things.
With
the
program
evaluation.
We
use
that
score
to
distribute
the
grant
funding
each
year.
So,
yes,
we
do
have
have
scores
for
each
individual
state
you'll
find
that
those
scores
are
in
in
the
90s
to
the
high
90s.
M
D
Yeah
and
as
a
country,
I
say
that
we're
doing
well,
your
state
pipeline
safety
programs
are
certainly
meeting.
You
know
the
scores,
I
think,
are
primarily
probably
from
97
to
100.
Unless
there's
some
problem
with
legislation
like
the
puc
is
experiencing,
where
they
don't
have,
full
safety
authority
like
fems,
would
have
over
their
operators.
So
we
hit
them
pretty
hard
for
that,
but
the
as
the
nation
goes,
our
state
pipeline
safety
programs
are
dedicated.
D
The
folks
are
they
take
the
same
training
their
federal
inspectors
take
at
our
training
qualifications
center
in
oklahoma
city
at
tnq,
and
they
work
with
us,
you
know
and
in
glove.
You
know
we
try
to
support
them
in
any
questions
or
issues
or
investigations
that
they
have
underway.
D
We
have
we,
you
know
the
only
part.
The
only
states
that
are
not
in
the
pipeline
safety
program
are
alaska
and
hawaii.
Hawaii
was
in
the
pipeline
safety
program
back
in
the
90s
80s
in
the
early
90s
and
95.
We
decertified
that
state
for
failure
to
continue
to
do
inspections.
We
worked
with
them.
We
try
to
support
their
staff.
We,
you
know
it's
kind
of
a
last
last
resort
for
us.
We'd
rather
work
with
the
state
and
help
develop
the
state
and
in
improve
the
state's
program's
performance.
D
But
in
the
case
where
you
know
they're
not
doing
inspections
and
we're
not
seeing
you
know
safety
enhancer
results,
we
need,
we
can
be
certified
state.
M
So
that's
a
great
answer
because
basically
there's
a
cut
off
where
you're
not
certified
anymore,
so
my
concerns
of
great
inflation
having
everybody
at
97
percent
is
an
accurate
portrayal.
So
you
have
cut
offs,
not
that
you
have
to
decertify,
but
if
they're
areas
that
people
aren't
performing
the
state
pucs,
that's
it's
typically.
D
Not
based
upon
the
scores
I
mean
the
scores
would
be
indicative
of
that
they
would
go
down
if
you
fail
to
start.
If
you
stop
doing
inspections
and
stop
going
to
training
and
stop
doing
the
things,
obviously
you'd
score
very
low,
so
we
don't
have
an
established
score,
that's
a
cut
off,
but
we
do
look
at
the
criteria
in
the
form
we
look
at
what
our
total
program
goals
are
and
if
you
know,
you're,
not
meeting
those,
then
then
we
would
decertify
a
state.
D
M
Them
up
on
the
other
side,
because
there's
an
interesting,
if
not
articulate,
discussion
about
performance-based
versus
prescriptive.
M
Here
of
you
know:
yeah
we
sent
out
surveys
and
had
20
people
of
15
000
respond,
that's
the
kind
of
thing
that
could
end
up
on
a
checklist
that
just
says:
oh,
we
did
surveys,
so
you
know
performance-based
means,
have
an
effective
evaluation
of
whether
or
not
your
program
works
right.
Not
just
that
you
send
things
out,
are
those
again
performance-based
quantified
and
how
you
evaluate
these
programs.
C
Definitely
we
would
agree
with
you
that
public
awareness
is
a
performance-based
regulation.
You
must
be
effective.
That's
the
simple
answer:
there
are
many
ways
that
you
can
be
effective.
You
just
have
to
figure
out
what
those
are
for
your
designated
audience.
We
heard
earlier
from
the
panel
that
they
were
using
a
survey
technique
that
it
doesn't
appear
was
effective.
We
would
have
expected
them
to
identify
that
as
ineffective
and
to
determine
what
would
be
more
effective.
C
M
That's
why
it's
asking
about
the
scorecard,
because
you
know
on
one
hand
it's
on
your
list
demonstrating
effective
awareness
program,
and
I
think
this
gets
to
some
of
the
concern
about
the
self-assessment
part,
which
is
you
know
the
way
we
heard
it
earlier.
We
were
doing
a
good
job
with
that
survey,
doing
a
bunch
of
things
when
we
look
at
it
from
another
perspective,
maybe
it
wasn't
so
I
mean
their
assessment
may
be
different
than
you're.
Taking
a
look
at
it
and
saying
that
doesn't
meet
our
criteria
of
what
effective
should
be.
C
That
is
part
of
our
job
as
regulators
to
look
at
what
the
company
is
achieving
and
to
make
a
judgment
on
whether
that
in
fact
does
meet
the
requirements
of
the
regulation
and
whether
it
is
having
an
impact.
Unfortunately,
as
regulators,
sometimes
the
performance
measures
and
the
metrics
were
used
to
measure
effectiveness
are
long
distance.
They
look
down
the
road.
So
if
you
were
to
ask
us
today
to
measure
the
effectiveness
of
a
rule
that
went
into
effect
a
short
time
before,
it
would
be
difficult
to
do
and.
M
N
Thank
you.
Yesterday
we
asked
pg
e
if
they
were
exchanging
notes
with
other
industries
regarding
safety
management
and
risk
management
processes.
I
would
have
the
same
question
for
the
regulators
and
overseers
and
I
would
start
with
the
puc
and
ask:
are
you
do
you
exchange
notes
with
either
other
regulatory
oversight
agencies
in
california
or
with
other
utilities
commissions
in
other
states,
regarding
what
what
are
effective
means
of
oversight?
N
E
Yes,
absolutely
we
were
very
active.
Okay,
now
mine's
not
working
we're
very
active
with
napster
national
pope
association
pipeline
special
safety
representatives.
We
talked
to
with
the
state
fire
marshal.
We
were
very
active.
We
talked
with
with
all
the
different
states
our
program
manager,
mr
raffi
stephanie,
spends
a
lot
of
time
talking
with
the
other
states
about
what
they're
experiencing
and
interfacing
with
films.
Also.
N
Same
question
for
films,
except
I'm
only
going
to
ask
half
the
question
because
I
know
about
the
exchanging
notes
with
other
industries,
because
I
see
jeff
wiese
at
these
multi-industry
programs
all
the
time.
So
I
know
you're
doing
that.
But
I
would
ask
the
same
question
about
are:
do
you
exchange
notes
with
other
federal
regulators
and
overseers
regarding
the
most
effective
way
and
what's
working?
What's
not
working.
C
Yes,
we
do,
as
a
matter
of
fact,
we
recently
have
met
with
some
of
our
other
counterparts.
We
met
with
epa
and
coast
guard
to
look
at
certain
provisions
of
our
regulations
to
see
if
we
could
benefit
from
each
other.
The
knowledge
we've
also
looked
at
our
enforcement
programs.
We've
looked
across
at
other
federal
agencies
to
determine
how
effective
our
programs
are
compared
to
other
agency
programs.
C
We
look
across
the
department
of
transportation
and
see
what
other
modes
have
used
and
how
we
can
learn
from
them.
I
would
also
say
that,
in
some
cases
where
we
have
cross-functional
jurisdictional
lines,
for
example,
ferc
ferc
inspects
lng
facilities,
we
do
as
well,
and
so
in
those
cases,
I
myself
have
participated
on
a
joint
inspection
with
ferc
to
learn
from
them
and
to
see
what
they
brought
to
the
table
that
we
could
benefit
and
what
we
could
share
with
them
that
they
would
benefit
by.
D
D
You
have
to
have
the
five
year
window
and
the
fourth
option
is
the
the
most
appropriate
pressure
based
on
the
performance
history
that
you
have
available.
If
you
don't
have
all
four
of
those
things
it
it.
Basically,
you
have
to
up
down
to
619
c,
which
is
the
grandfather
clause,
which
is
the
five
year
window
from
1965
to
1970..
D
That
also
invokes
the
the
class
location
factors
that
you
have
to
consider
in
that.
So
that
throws
you
back
up
to
having
to
have
design
factors
to
know
what
your
your
pipe
is
or
to
you
know,
to
address
the
other
question
you
can
assume
the
most
restrictive
design
factors
are
your
pipes.
So
if
you
didn't
know
what
the
grade
was
of
your
pipe
you
could
you
could
assume
24
000
for
the
lowest
grade.
That's
that
was
available
and
that's
you
know
the
lowest
of
those.
Is
your
maximum
allowable
operating
pressure.
A
A
A
Okay,
so
let's
go
back
to
this
issue
because
remember
wayner
was
probing
it
a
little
bit
and
I
just
want
to
follow
up,
because
I
think
it's
I
think
it's
important.
It
seemed
to
me
that
cpuc
and
femsa
both
had
kind
of
a
different
position
than
pg
e
had
on
that
five-year
test
with
the
hca
identification
issues,
and
I
want
to
understand
why,
when
they
did
this
to
establish
what
the
maop
mop
could
be
for
newly
identified
hcas
and
we
started
looking
at
this-
is
this
something
that
you
had
seen
before?
A
A
Okay
and
mr
metro,
maybe
if
I
can
ask
you,
because
you
have
some
awareness
of
some
potentially
some
other
operators-
is
this
something
that
other
pipeline
operators
have
done
traditionally
is?
Is
pg
e?
You
know
in
the
middle
of
the
pack.
Are
they
an
anomaly
here.
H
A
A
This
is
something
that
obviously
was
a
requirement
for
new
lines
back
in
the
early
1970s,
so
it's
been
around
for
a
long
time,
but
they're
definitely
pros
and
cons
associated
with
hydrostatic
testing,
and
we
understand
particularly
on
a
distribution
system
like
pg
e.
So
can
you
just
give
us
from
the
regulator's
perspective
some
pros
and
cons,
and
I
know
we'll
get
a
little
bit
more
tomorrow
with
the
panel
tomorrow,
please
cpuc
and
then
femsa.
E
The
downside
is
the
possibility
of-
and
I
I'm
not
a
metallurgist
by
any
stretch
of
the
imagination,
but
I
have
discussed
it
with
with
some
folks
who
are
quite
expert
in
this
regard.
There's
a
small
possibility
that
you
might
create
an
anomaly
in
the
pipe
by
raising
the
the
pressure
as
high
as
as
you
do
and
then
bringing
it
back
down.
E
Of
course,
the
other
part,
the
other
downside,
is
that
the
line
has
to
be
taken
out
of
service,
and
that
has
consequences
in
terms
of
being
able
to
deliver
gas
to
people's
homes
into
hospitals
and
that
sort
of
thing
where,
where
there's
the
others
public
the
other
aspect
of
public
safety
and
then
the
final
concern.
As
as
I
understand
it,
is
trying
to
get
the
water
out
of
the
pipe
there's
a
lot
of
time
and
effort
spent
to
keep
water
from
getting
into
pipes
because
it
creates
internal
corrosion.
A
And
if
you
have
anything
different
to
add
on
that.
C
I
would
suggest
that
we
have
found
hydrostatic
testing
to
be
of
great
value
on
the
interstate
long
lines
when
we
have
found
defects
specifically
seam
defects.
We
have
often
ordered
operators
to
conduct
hydrostatic
testing.
As
richard
mentioned,
there
are
pros
and
cons,
depending
on
the
type
of
anomaly
that
you
have
in
your
line.
You
may
be
able
to
remove
defects,
but
at
the
same
time,
if
you
are
not
using
a
specific
protocol
in
how
you
conduct
the
testing,
you
may
grow
defects
till
right
before
their
failure
stage
such
that
it
can
create
issues.
C
A
C
C
What
that
does
not
tell
you
is
what
is
left
in
the
line,
so
you
may
have
removed
all
the
harmful
anomalies
or
you
may
have
grown
some
harmful
anomalies
that
if
you
had
not
pressure
tested
them
may
have
been
stable.
So
there's
your
balance,
you
ask
for
alternatives,
internal
inspection
tools.
There
are
certain
tools
that
will
detect
cracks
and
seams,
but
they
can
only
be
used
under
certain
circumstances.
In
certain
lines,
if
you
have
lines
with
varying
diameters,
those
tools
may
not
function
effectively.
C
So
you
have
to
weigh
the
benefits
of
each
type
of
assessment
and
figure
out
what
your
overall
risk
is
and
the
overall
benefit
of
the
tool,
and-
and
I
would
not-
this
may
be-
stretching
a
little
bit.
But
I
think
people
need
to
keep
in
mind
in
addition
to
requalifying
pipe
through
these
types
of
tools
through
repair
or
rehabilitation.
I
California,
well,
I
think
what
we've
found
in
pg
e's
service
territory,
at
least,
is
that
we
haven't
seen
an
aggressive
effort
to
make
their
pipes
pigable.
If
you
will-
and
we
haven't
seen
and
a
program
to
take
the
grandfathered
pipe
and
either
make
it
either
hydrotest
it
or
replace
it.
We
haven't
seen
in
the
integrity
management
program,
thus
far
any
any
aggressive
efforts
in
those
areas.
A
I
Yes,
clearly
I
mean
the
commission
is
at
a
point
now,
where
we've
ordered
pg
e,
to
reduce
pressure
by
20
on
several
of
its
lines
and
they're
undergoing
an
an
maop
validation
effort
that
you've
recommended
that
we've
ordered
them
to
do
and
depending
on
what
the
results
of
that
are
we'll
be
looking
at
taking
additional
actions
either
requiring
pressure,
testing
or
requiring
a
replacement
program
or
perhaps
other
methods.
I
A
Okay,
thank
you
very
much.
We
actually
are
doing
really
good
we're
ahead
of
schedule.
So
I'll
turn
back
to
the
tech
panel
for
a
follow-up
round
of
questions
and
then
we'll
go
through
the
parties
in
the
board
of.
F
Inquiry
I
have
a
question
for
miss
doherty
a
few
minutes
ago.
You
mentioned
the
need
for
prescriptive
data.
C
It
works,
I
think,
we're
good.
I
would
say
that
we
need
to
look
at
both
areas.
The
we
found
through
your
investigation,
through
our
own
investigation
of
various,
invest
accidents
and
incidents
that
perhaps
operators
do
not
have
access
to
the
data
that
they
should
have.
That's
why
we
issued
the
advisory
based
on
your
recommendation.
C
F
F
C
F
C
To
that
there
is
the
one,
the
aspect
that
the
operator
collects:
data
that
we
review
during
an
inspection
for
very
specific
programs.
Perhaps
a
public
awareness
program.
The
other
aspect
is
fimsa,
and
our
state
partners
need
to
have
data
in
order
to
accurately
assess
the
risks
on
the
national
infrastructure
and
look
at
trends
can.
C
Data,
actually
there
was
one
that
was
brought
up.
I
was
asked
the
question
if
we
had
specific
data
on
the
number
of
miles
that
had
been
hydrostatically
pressure
tested-
and
I
said
I
did
not
know-
I've
later
been
told
that
we
don't
have
that
information.
So
that
is
a
piece
of
information
that
might
be
useful.
It
might
help
us
better
assess
the
nation's
infrastructure.
F
K
You
I
have
a
question
both
for
cpuc
and
mr
daugherty
from
femsa,
and
this
refers
to
mr
sal's
statement
yesterday
regarding
rcvs
and
asv,
and
one
comment
was
regarding
the
technical
hurdles
using
these
valves.
K
C
I
would
like
to
comment
on
that.
I
would
mention
that
we
have
recently
issued
an
anprm
on
our
liquid
side
and
will
likely
be
issuing
an
amprm
on
the
gas
side
that
asks
that
very
question
should
asv's
or
rcvs
have
broader
use,
and
should
the
government
require
the
installation
of
those
and
where
should
those
be
installed?
Our
integrity
management
rules
led
the
way
when,
with
rulemaking
that
said,
operators
should
consider
those
valves
the
placement
of
those
to
protect
hcas.
C
E
And
at
the
puc,
this
is
very
much
as,
as
I
indicated
in
my
answer
to
to
the
city.
This
is
very
much
a
high
priority
item
for
us
in
our
rule,
making
to
consider
whether
or
not
we
should
require
the
installations
of
automatic,
shutoff
valves
or
remotely
controlled
valves.
As
a
matter
of
fact,
one
of
the
first
issues
that
we
addressed
in
this
regard
was
to
order
pg
e
to
undertake
a
study
of
where
they
might
place
automatic
or
remote
remotely
controlled
valves,
and
we
did
that
very
early
on
soon
after
the
pipeline.
E
E
J
H
I
don't
have
a
data
on
that.
I
can't
tell
you
off
the
top
of
my
head.
I
know
just
looking
at
the
issue
from
the
30
000
foot
level.
Is
that
the
valves
while
while
they
are
a
very
good
idea
and
are
needed,
there's
appropriate
places
to
to
install
these
valves
in
appropriate
conditions,
and
we
need
a
feasibility
study
done
to
determine
those
thresholds
where
the
proper
places
are
and
and
what
the
appropriate
appropriate
places
are
for
these
valves
to
be
installed.
J
C
C
C
C
C
I
believe
so
the
I
have
seen
estimates
that
replacing
50
of
valves
would
be
very
much
in
the
millions
like
600
million.
It
would
be
very,
very
costly.
A
Thank
you,
mr
chatra.
Do
we
have
parties
who
have
questions
city
of
san
bruno.
E
Thank
you
certainly
we're
looking
at
that.
Absolutely
I
mean
that's
that's
part
of
bringing
the
rate
making
into
more
closely
aligning
the
rate
making
with
the
with
the
safety
work.
That's
going
on
the
maintenance,
and
that
sort
of
thing
is
to
to
take
a
look
at
pipeline
replacement
in
in
particular
situations
and
encourage
it
when
we
feel
that
it's
necessary.
C
On
the
federal
side,
the
regulations
do
not
require
full-scale
replacement
of
pipelines.
However,
I
will
say
that
we
are
considering
how
some
of
these
infrastructure
issues
can
be
addressed
in
the
long
term.
I
would
also
mention
that
we
have
suggested
to
certain
pipeline
operators
that
segments
of
line
that
have
shown
to
have
been
problematical
be
replaced
and
some
of
those
lines
are
being
replaced,
so
it
may
not
always
require
a
rule
making
solution
to
obtain
good
results
for
the
public.
F
G
Sorry
about
that,
I
you
know
if
you
allow
me.
G
Always
have
questions
I'd
like
to
follow
the
line
of
questioning
that
the
city
began
there
because
I
think
we're
very
much
interested
clearly
as
safety
regulators,
the
cpuc
and
femsa
would
like
nothing
more
and
the
rest
of
our
state
pairs.
State
partners
then
have
brand
new
pipeline
systems
out
there.
So
just
interested
more
in
exploring
some
of
the
impediments-
and
I
know
the
states
have
been
thinking
about
this
a
lot,
but
they
have
different
impediments
at
a
federal
level.
You
know
it's.
It
goes
to.
How
does
a
company
recover
those
costs?
G
H
Many
states
have
pipeline
replacement
programs
now,
when
you
talk
about
putting
in
valves
there's
a
limited
source
of
dollars
that
the
states
have
so
it's
if
they
have
a
lot
of
cast
iron
and
unprotected
bare
steel
to
remove
it's
going
to
be
one
or
the
other.
It's
going
to
be
very
difficult
to
balance
the
two
and
and
from
a
risk
assessment
strategy.
I
would
look
at
replacing
the
bare
steel
and
the
cast
iron
first.
G
Great
thank
you
and
then
lastly,
for
miss
dougherty.
I
first
of
all
I
appreciate
vice
chairman
hart's
comments
that
he
and
member
sumwald-
and
I
have
been
in
a
number
of
interagency
committees
together,
which
I
always
find
very
fascinating
and
ntsb
has
led
the
way
on
a
lot
of
the
safety
culture
initiatives.
So
I
appreciate
that,
but
are
there
any
other
forms?
Miss
daugherty
might
want
to
comment
on.
C
Yes,
thank
you
for
the
opportunity
to
correct
my
oversight.
One
of
the
areas
that
we
are
doing
we're
reaching
out
to
is
international.
There
are
a
lot
of
countries
that
have
pipeline
infrastructure,
some
of
it's
older
than
ours,
and
so
we
are
reaching
out
to
them.
We
also
hope
to
have
an
international
forum
this
summer
to
pull
some
of
our
counterparts
from
around
the
world
to
sit
down
and
talk
about
how
we
address
some
of
these
infrastructure
issues.
C
A
C
A
No
additional
questions
from
the
parties
member
weiner.
L
L
L
In
other
words,
do
you
just
flow
down
a
copy
of
them?
Do
you
write
your
own
regulations?
What's
the
relationship.
E
E
They
review
they
review
our
programs
and
I've
forgotten
whether
we
actually
have
a
certification
in
this
program
or
not.
We
do
right
right,
I'm
sorry.
I
have
so
many
programs,
it's
sometimes
hard
to
recall.
L
We
do
have
a
certification.
Yes,
is
this
an
annual
certification?
Yes,
now
then
cpu
uc
has
an
inspector
cadre.
I
presume.
E
E
E
That's
that's
the
current
situation.
Yes,
we
used
to
have
our
entire
utility
safety
and
reliability,
ability,
branch
to
electric
safety,
communication,
safety
and
gas
safety,
but
about
a
year
prior
to
I
think,
san
bruno,
we
decided
that
we
needed
to
have
people
specialize
in
pipeline
safety
and
the
other
side
does:
electric
safety
and
communication
safety.
L
Accidents
and
investigations,
the
the
audits
and
inspections
are:
are
they
a
paperwork
exercise
or
are
they
really
go
out
and
kick
the
tires.
E
They're
both
they're
primarily
paperwork
exercises,
however,
but,
but
we,
a
number
of
years
ago
across
all
of
our
safety
programs,
said
that
we
need
to.
We
need
to
test
what
we
find.
We
need
to
look
go
out
and
look
over
the
shoulder
of
of
the
person
who's,
doing
the
inspection
for
the
utility
or
the
maintenance
work
for
the
utility
and,
if
they're
an
inspector,
we
need
to
one
make
sure
that
they're
finding
what
they're
supposed
to
find.
E
E
We
have
we
have
the
ability
to
open
an
order,
instituting
investigation.
Well
it
we
have
a.
I
should
back
up
a
little
bit.
We
have
a
progressive
enforcement
scheme
that
we
use
or
our
staged
enforcement
scheme
that
we
use,
which
begins
with
telling
the
the
operator-
and
this
applies
to
the
electric
side
as
well
as
the
the
gas
side.
E
E
If
we
see
that
either
that
they're
not
responding
in
a
timely
manner
and
taking
care
of
their
responsibilities
or
we're
seeing
a
pattern
of
egregious
behavior,
then
we
have
the
ability
to
take
an
enforcement
action
against
them
through
an
order
instituting
investigation
at
the
commission
we're
exploring
now
the
pennsylvania
model
and
the
and
the
oregon
model,
where
they
have
statutory
authority
to
impose
just
upon
natural
gas
pipeline
operators,
specific
penalties.
It's
an
issue
for
us
of
delegation
from
the
commission
to
be
able
to
issue
a
citation.
M
So
I
thank
fems
for
taking
us
through
your
auditing
evaluation
and
it's
nice
to
hear
the
state
of
the
industries
at
97
percent,
so
just
to
keep
this
balanced.
California
puc,
you
do
these
audits.
Is
there
a
scorecard
report
card?
How
do
they
get
sort
of
collated
up
into
some
overall
look
at
how
an
organization
is
doing
and
then
can
you
benchmark
that
against
others
in
california.
E
E
That's
an
area
of
improvement
for
us
that
that
femsa
has
requested
that
we
undertake
in
our
there
was
a
an
opportunity
for
improvement
that
they
pointed
out
to
us
in
their
last
audit
and
and
they've
agreed
to
work
with
us
in
terms
of
defining
what
those
criterion
are
by
which
we
can
judge
the
performance.
M
So
you'll
be
able
to
take
those
audits
and
put
them
up
into
a
report
again
benchmark
within
the
state,
pretty
small,
but
being
able
even
to
look
at
trends
in
a
company
over
time
or
to
set
thresholds
of
where
some
kind
of
intervention
or
enforcement
is
required.
It
helps
you
to
quantify
those
and
then
gives
you
a
sense
across
the
country,
but
right
now
that's
not
really
the
approach,
it's
more
qualitative.
E
That's
with
that's
with
respect
to
the
integrity
management
program.
Now,
as
I
talked
about
with
with
the
other
member,
we
have
general
order
112,
where
we
do
inspections
of
many
many
aspects
of
of
the
utilities
operation
and
we
capture
that
data
in
our
databases,
and
we
do
use
that
to
help
target
our
inspective
activities,
because
before
we
go
out
and
do
a
geo,
112
audit,
we
look
at
what
the
problems
were
that
we
had
in
the
past.
M
So
you
may
have
example,
approaches
and
models
that
you're
using
in
other
areas
that
you
can
transfer
over
here
and
and
quantify
that
a
little
bit
more.
Yes,
absolutely
the
last
question
and
curious
about
this
and
the
chairman
helped
sort
of
clarify
it
for
me.
Actually,
I
was
wondering
what
happens
when
there's
sort
of
a
difference
between
a
federal
and
state
perspective
on
an
issue
and
what
the
chairman
have
clarified
was
you
know,
pg
e
came
with
something
that
nobody
really.
What
we're
hearing
is
nobody
done
before.
C
I
would
agree
when
the
state
always
has
the
prerogative
of
implementing
regulations
that
are
more
stringent
than
the
federal
regulations.
In
fact,
that's
a
great
thing.
They
know
the
circumstances,
so
many
states
adopt
the
federal
regulations
directly.
Some
have
more
robust
and
more
stringent
regulations
which
they
are
entitled
to
do.
C
A
Okay,
so
they
must
at
least
meet
or
incorporate
those
regulations.
That
is
correct.
Okay,
mr
metro,
how
many?
How
many
states
actually
go
beyond
the
federal
regulations
in
in
certain
areas.
D
We
actually
don't
do
not
collect
that
information.
How
many
states
have
more
stringent,
but
there
has
been
some
surveys
that
we
conducted
with
the
national
association
of
pipeline
safety
representatives,
where
I
think
quite
a
few
or
a
majority
of
states
have
some
regulations,
usually
in
the
reporting
area.
That's
more
restricted,
it's
more
restrictive
than
what
fems
is.
A
D
D
We
evaluate
the
program,
we
support
them
in
their
inspections,
but
you
know
I
think
films
could
on
on
the
for
a
given
incident
for
a
given
isolated
thing
that
we
could
take
additional
action
if,
if
deemed
necessary
at
the
current
stage,
we're
working
with
california
puc
we're
working
well
together
we're
going
to
do
some
joint
work
in
looking
at
the
risk
assessment
documents
with
pg
e
we're
we're
going
in
together,
we're
not
leading
that
we're
going
in
as
partners
in
that.
D
So
there
is
it's
a
partnership.
That
is
what
I
would
leave
you
with.
A
Okay,
but
you
all
have
limited
resources.
Mr
clark,
you
had
a
conversation
with
technical
panel
and
we
have
ftes
full-time
equivalents.
You
have
pys,
you
know
persian
years,
and
so
you
have
a
you,
have
less
than
20
pys
that
work
on
pipeline
safety?
A
C
We're
currently
authorized
a
little
over
200.
I
think
the
number
is
like
206
with
you
know,
turnover
we're
probably
just
at
200
as
far
as
the
entire
organization,
roughly
half
of
that,
a
little
over
half
of
that
like
126,
are
inspectors
now
that
is
spread
throughout
our
five
region
offices
and
the
inspectors.
That
is
five
region
offices
and
district
offices.
C
I
would
point
out
that,
according
to
our
statistics,
the
state
programs
regulate
roughly
eighty
percent
of
the
pipeline
mileage
simply
because
of
the
interest
state
facilities
and
they
roughly
augment
the
federal
workforce
of
200
people
by
an
additional
300.
A
D
For
the
kellogg
year,
2009
activities,
approximately
63
percent
of
the
total
program
cost
for
the
program
that
year
was
federal
dollars.
We
project
we're
in
the
middle
of
looking
at
the
india.
It's
a
reimbursable
grant.
The
state's
calendar
year,
2010
activities
have
currently
taken
place,
they're
now
putting
they're
sending
to
us
their
end
of
year.
Program
cost
we're
reviewing
those
costs
and
then
we'll
be
funding
them.
I
estimate
the
california
pucs
estimated
program.
Cost
reimbursement
for
calendar
2010
would
be
about
63.
A
Okay,
so
there's
kind
of
a
symbiotic
relationship
here
between
the
states
and
the
feds
we
provide.
The
federal
government
provides
resources
for
the
states
to
conduct
their
programs.
A
The
states
are
providing
data
to
the
federal
government
for
their
data
collection,
record,
keeping
risk
assessment
type
programs,
but
when
we
look
at
what
kind
of
the
scope
of
the
regulatory
activity
is
over
the
years,
when
you
all
went
to
performance
based
regulations,
you
didn't
take
away
any
of
the
prescriptive
regulations
you
built
on
what
was
there
before
what
you
had
been
doing
in
the
past.
This
was
another
layer
on
that
correct.
A
C
C
C
C
We
have
right
now
both
prescriptive
inspections
and
the
performance-based
integrity
management
inspections
and
as
our
regulations
develop,
we
will
continue
to
maintain
that
simply
because,
as
you
pointed
out,
we
have
a
baseline
of
prescriptive
regulations
and
then
we
added
on
the
performance
on
top
of
that,
so
we
will
always
need
people
that
can
focus
on
prescriptive
compliance
and
also
performance
base.
I
hope
I
answered
your
question.
A
Well,
maybe
what
I
can
do
is
share
with
you
a
couple
of
accidents
that
we've
investigated
and
errors
in
performance-based
oversight,
where
we've
seen
that
there
are
problems.
Maybe
you
can
help
me
understand
how
you
how
you
address
these
we've
looked
at
accidents,
in
which
there's
a
segment
of
pipeline
that
should
have
been
identified
as
an
hca,
but
it
wasn't
by
the
operator,
and
so
this
is
kind
of
to
me
so
a
little
bit
similar
than
with
the
situation
that
we
have
with
the
records
here.
A
You're
relying
on
the
operator
to
provide
you
information
and
you
at
some
point
have
to
accept
that
information
is
valid.
This
goes
back
to
mr
clark
with
the
trust,
but
verify
you
know,
take
the
information
that
they
give
you
but
go
out
and
make
sure
that
what
they're
telling
you
is
the
right
thing.
A
If
we
get
into
even
more
detail,
we
look
at
the
kingman
accident
and
in
that
accident
you
all
identified
in
their
integrity
management
program,
some
things
that
were
not
included
that
were
that
should
have
been
you
inspected,
their
their
program
for
their
anhydrous,
ammonia
pipe
and
the
inspection
revealed
that
that
they
didn't
have
a
number
of
things
with
respect
to
their
baseline
assessments
and
the
risk
factors
required
by
regulations
that
were
not
addressed
by
enterprise.
Who
is
the
operator
noted
the
following
risk?
A
Factors
were
not
addressed:
seam
type,
results
of
previous
assessments,
defect,
type
and
size
that
the
assessment
method
can
detect
and
and
defect
growth
rate.
Those
were
not
present,
so
you,
you
identified,
you
gave
us
this
plan
and
all
of
these
required
pieces
of
it
were
missing.
Okay,
so
that
was
that
was
great.
Somebody
actually
looked
at
it.
They
gave
him
feedback,
but
they
missed
one
thing:
they
missed.
A
They
missed
leak,
history
and
that
wasn't
part
of
of
their
plan,
and
so
then,
when
we
come
back
and
we
have
2020
hindsight
we're
coming
in
after
the
fact
something's
already
happened.
We
have
plenty
of
time
to
take
a
look
at
it,
but
we
identified
that
here
we
missed
another
one
and
so
with
performance
based.
A
A
That's
not
very
many,
that's
10,
you
know
10
people
per
state.
C
You
raise
very
good
points
and
we
are
definitely
well
aware
that
it
is
a
challenge
to
get
out
to
those
facilities
and
find
problems.
I
would
go
back
and
mention
that
it
is.
It
is
not
the
regulator's
responsibility
to
assure
that
operators
comply.
It
is
the
operator's
responsibility
to
assure
that
they
comply.
C
C
We
will
not
know
them
as
detailed
and
in-depth
as
a
company
personnel,
but
we
do
bring
a
couple
of
things.
We
learn
from
national
review
or
in
the
case
of
the
states,
the
state's
review
of
plans
we
learn
for
triggers
and
flags
and
we're
trained
to
find
those
areas.
We
don't
catch
them
all.
I
wish
we
would.
We
do
miss
some,
but
I
think
the
important
point
is
that
we
have
to
train
our
personnel
to
look
for
those
flags.
C
We
have
to
work
side
by
side
with
our
states
and
share
that
information
of
how
to
look
for
now.
You
mentioned
performance
regulations
and
I
would
point
to
a
recent
study
done
on
deepwater
horizon
and
that
study
looked
at
what
could
have
been
done
a
little
bit
better
and
I
believe
that
the
results
of
that
study
said
look
performance-based.
Regulations
are
a
way
we
may
want
to
go.
C
They
validated
the
approach
that
we
are
taking.
I
sound
repetitive
and
I
apologize,
but
it's
not
easy
it's
hard,
but
it's
worth
the
effort.
If
we
can
get
the
job
done
right,
then
we'll
be
focusing
our
resources
on
the
risks
we'll
be
addressing
threats
to
the
infrastructure
and
therefore
making
the
public
safer.
A
What
tools
do
you
have
to
get
to
a
point
where
you
incentivize
the
operator
to
not
have
those
defects
so
that
you
don't
have
to
take
the
comb
through
and
find
them?
Is
it
the
cost
of
doing
business
or
they
you
know,
is
there?
Is
there
a
real
disincentive
for
them
to
have
an
error
in
in
their
plan
I'll.
C
I'll
speak
to
that
first,
and
simply
because
my
mic
is
on
on
the
federal
side,
we
have
a
variety
of
enforcement
mechanisms.
When
we
find
that
an
operator
has
not
complied
with
our
rule,
we
can
issue
a
warning
to
them,
depending
on
the
degree
we
can
issue
a
notice
of
amendment
or
we
can
issue
a
civil
penalty.
Those
civil
penalties
can
be
quite
large
and,
depending
on
the
severity
of
the
violation,
we
will
use
those,
and
we
have
shown
that
we
will
do
those
we've
we're
in
the
multi-millions
of
civil
penalties.
C
That
is
not
the
preferable
way.
The
preferable
way
is
for
a
industry
to
stay
in
compliance,
but
we
will
take
action
if
we
find
an
operator
is
endangering
the
public
by
not
complying
with
the
rules.
Now,
I
would
suggest
also
that,
in
the
administration's
proposal
we
have
looked
at
raising
our
civil
penalty
limits
such
that
we
can
have
an
even
stronger
bite.
If
somebody
does
something
wrong
now,
I
will
also
mention
something
else.
E
E
Being
a
regulator,
it's
it's
difficult
to
stand
on
the
outside
and
look
inside
what's
going
on
in
an
operation.
So
our
first,
my
my
first
direction
to
my
people
is
that
I
don't
want
them
to
be
on
the
outside.
Looking
in,
I
want
them
to
be
on
the
inside
looking
around,
but
even
being
on
the
inside.
Looking
around,
you
can't
know
everything
that
the
operator
knows
and
and
if
there
is
an
expectation
that
we
achieve
that,
then
that's
an
unrealistic
expectation.
E
As
far
as
performance-based
regulation,
it's
not
only
difficult
to
judge
whether
performance
has
been
achieved
in
the
manner
that
you
want
it
to
be
achieved,
but
it's
also
very
difficult
to
enforce
performance
based
on
regulations,
because
the
case
that
you
have
to
bring
to
to
bear
becomes
quite
complex.
It's
nuanced
in
terms
of
whether
or
not
there
has
been
a
violation
of
one
order
or
another,
and
whether
that
order
of
magnitude
of
that
violation
requires
a
penalty
to
be
assessed.
It
does
not
mean
that
it
cannot
be
done
by
any
stretch
of
the
imagination.
E
So
what
we
do
in
terms
of
attempting
to
address
these
sorts
of
issues
is
that
we
take
a
systems
approach
to
safety,
just
as
femza
does,
and
we
we
look
at
so
here's
the
the
vision
for
my
organization
and
our
organization,
I
should
say
not
my
organization
and
the
culture
that
we
try
to
to
to
develop
within
our
organization,
and
that
is
first
of
all,
we
have
to
be
experts
in
our
field.
We
have
to
know
the
rules.
E
We
have
to
know
the
laws
we
have
to
know
as
much
as
we
can
about
those
that
we
are
regulating
and
what
their,
what
their
incentives
are,
where
it
is
they're
trying
to
go
all
the
different
elements
of
a
system
that
that
that
you
have
to
understand
in
order
to
know
where
an
organization
is
headed
and
how
they're
trying
to
get
there.
The
second
thing
is,
we
have
to
be
objective.
E
We
can't
bring
emotion
and
personal
perspective
we
have
to.
We
have
to
be
critical
in
our
thinking
when
we
see
something
we
have
to
go
beyond.
Is
it
if
it's
written
down
on
the
piece
of
paper
whether
or
not
we
then
look
and
verify
trust
but
verify?
F
E
It's
important
to
have
a
a
just
safety
culture,
also,
which
is
important
in
terms
of
being
a
regulator,
a
just
regulator.
One
of
the
problems
with
prescriptive.
The
enforcement
of
prescriptive
regulations
is
that
many
times
it
becomes
a
gotcha
game.
We
don't
want
to
have
a
gotcha
conversation
when
it
comes
to
the
safety
of
the
natural
gas
system
in
the
state
of
california.
E
C
E
E
The
commission,
I
believe,
is
moving
in
the
direction
of
taking
a
broader
and
deeper
look
at
that
regulatory
scheme
and
the
balance
between
prescriptive
regulation
and
performance-based
regulation
and
and
rate
making,
which
gives
us
just
another
insight
into
actually
a
deep
insight
into
what's
going
on
on
the
inside.
When
because
when
you
start
looking
at
the
money
and
where
it's
going
and
what
the
priorities
are
then
you're,
there.
H
Congress
has
authorized
the
states
to
receive
up
to
80
funding,
but
they've
never
appropriated
that
amount
we've
been
looking
at
around
60
percent
appropriation
could
be
less
could
be
more.
We
don't
know
this
coming
year.
The
other
point
that
you
brought
up
is
training
training.
We
only
have
one
training
facility
in
the
united
states,
it's
in
oklahoma,
city,
oklahoma
and
that's
for
all
500
engineers
inspectors.
We
need
more
training
facilities
across
the
nation
and
more
trainers.
A
Thank
you
all
very
much.
This
is
has
been
a
great
panel.
We've
got
a
lot
of
good
information
to
think
about
as
we
go
forward
with
our
analysis
and
our
report
preparation.
We
very
much
appreciate
your
service
and
your
your
frank
and
kander
can
candid
answers
to
our
questions.
I
underst
I
understand
we
do
have
one
witness
that
the
tech
panel
would
like
to
recall
from
yesterday.
Miss
ward,
we'll
excuse
this
fourth
panel
and
recall
a
witness.
A
Ms
ward,
he
was
already
sworn
yesterday,
so
you
don't
need
to
do
it
again,
correct
okay,
mr
barinsky,
did
you
have
some
questions
for
mr
fassett.
O
O
I
wanted
to
revisit
our
integrity
management
discussion
from
yesterday's
session
too,
just
looking
for
a
little
more
clarity
and
also,
I
think
it
might
set
the
stage
for
session
five
tomorrow
and
I'd
like
to
know
a
little
bit
more
about.
If
you
could
indicate
the
specific
threats
identified
for
line
132
section
180.,
as
you
knew
them
before
the
accident.
P
I
don't
recall
specifically,
I
believe,
though
ms
peralta
mentioned
that
in
the
morning-
and
I
referenced
it
in
mr
in
a
response
to
mr
whis
yesterday
afternoon,
but
there
was
an
inter
interacting
threats
between
corrosion
and
outside
force,
associated
with
the
fact
that
it's
crossing
that
it's
in
a
seismic
area
and
it's
an
older
line.
O
So
those
so
mainly
that's
that's
two
threats
really
that
you're
you're
inspecting
for
that's
correct,
that's
correct,
and
how
did
you
arrive
at
this
list?
You
know
what
was
the
criteria
that
you
used
to
do
to
establish
those
threats.
P
It's
through
well,
it's
through
our
risk
assessment
procedures
established
in
rmp6
that
we
discussed
yesterday.
P
P
Threats,
external
corrosion
direct
assessment
was
used
to
evaluate
the
corrosion
aspect
of
it
and
we
monitored
to
determine
if
there
was
any
outside
force,
any
land
movement.
I
believe
we
have
records,
I
don't
recall
if
they
were
provided
as
an
exhibit
through
a
dr
or
not,
but
we
have
records
to
show
that
that
there
was
no
outside
force
on
that
point.
A
Just
to
make
sure
everyone
else
has
an
opportunity
to
anybody
else
want
to
follow
up,
seeing
no
requests
any
of
the
members
of
the
board
of
inquiry.
No.
Thank
you.
Thank
you
very
much,
mr
fassett,
for
being
available
to
come
back,
and
this
concludes
our
our
deliberations
for
the
day,
and
we
will
reconvene
tomorrow
morning
at
nine
o'clock
to
consider
the
testimony
from
the
final
panel
we're
adjourned.