PG&E Corporate Responsibility and Sustainability Report 2018

PG&E Chapter 11 Update

Compliance

Our environmental policy (PDF) requires strict adherence to all applicable environmental laws and regulations, reflecting the foundation of PG&E’s environmental commitment. We also aim to go beyond compliance by setting objectives and standards that exceed legal and regulatory baselines.

Our Approach

Environmental Management System

PG&E’s operations are subject to extensive federal, state and local environmental laws and regulations. These requirements relate to a broad range of activities, including preventing the discharge of pollutants; safely transporting, handling and storing hazardous materials; properly managing hazardous wastes; protecting threatened and endangered species; and reporting and reducing emissions of air pollutants and greenhouse gases (GHGs) such as carbon dioxide, methane and sulfur hexafluoride.

To meet these requirements, PG&E employs an Environmental Management System (EMS) modeled after the ISO 14001 environmental management standard and consistent with the ISO standard’s “Plan, Do, Check, Act” model for continuous improvement. The EMS uses a series of compliance work processes that help enable PG&E to manage regulatory compliance and our environmental impacts by each line of business.

The Vice President, Land and Environmental Management of Pacific Gas and Electric Company oversees our commitment to meeting environmental requirements. Compliance performance updates are reviewed monthly by PG&E’s officers, and an annual environmental compliance summary is presented to the Compliance and Public Policy Committee of the PG&E Corporation Board of Directors.

Compliance Program Milestones

Planning

In 2018, PG&E closed the gaps identified in a third-party analysis of our EMS, including re-establishing and communicating the roles and responsibilities within the EMS, performing an aspects and impacts analysis, and conducting an internal desktop and site audit using a third-party contractor. In 2018, PG&E prepared its EMS for third party-certification to the ISO 14001:2015 standard. We will pursue third-party certification in future years.

Implementation and Operation

PG&E employs a variety of operational controls to help ensure that the actions we take in meeting our environmental compliance obligations are correct and repeatable. We also learn from our experiences and integrate any lessons into our work processes and staff development.

In 2018, we continued to find new opportunities for applying technologies and processes to further our compliance efforts and minimize impacts on the environment. Key EMS initiatives included:

  • Deploying a cloud-based solution to track and trend data from environmental incidents and compliance activities.
  • Using the same cloud-based tool to start tracking our project environmental release to construction process.
  • Enhancing and expanding the use of an automated tool to assess construction, operations and maintenance activities for potential environmental impacts using geographic information system spatial data.

PG&E conducts training to ensure employees have the skills and knowledge to correctly perform environmental activities associated with their work. Each year, PG&E trains thousands of employees on various environmental compliance responsibilities. Additionally, we require employees to take a training course on our environmental policy to reinforce every employee’s role in supporting PG&E’s goal of environmental leadership.

Reviews and Corrective Actions

An environmental auditing program is critical to ensure compliance with the many environmental laws and regulations relating to our business.

We review and audit environmental performance in three ways: self-assessments, internal audits, and compliance testing and risk reviews.

  • Self-Assessments: Environmental personnel perform self-assessments of facilities or projects they oversee. Each assessment evaluates a facility or project for compliance with environmental regulations.
  • Internal Audits: The Internal Auditing department—which reports directly to PG&E Corporation and Pacific Gas and Electric Company Vice President, Internal Audit and Chief Risk Officer—conducts systemic and programmatic controls-based audits to independently analyze the effectiveness of our environmental compliance management systems.
  • Compliance Testing and Risk Reviews: These reviews, designed to assess the adequacy of controls and risk mitigation, as well as compliance work processes, are conducted by the Pacific Gas and Electric Company Risk and Compliance Department.

During 2018, we performed 3,101 self-assessments and eight internal audits for environmental matters. We reviewed and assessed the controls of compliance work processes in 2018; testing began in 2019.

In addition, we review environmental-related risks periodically (annually for low risks and semi-annually for medium or high risks). We review mitigation processes for all risks on a monthly basis.

In pursuit of continuous improvement, we also employ a corrective action process, which includes performing root cause analyses of noncompliance issues identified through environmental agency inspections and tracking detailed corrective action plans to resolution.

Measuring Progress

Operational Performance

PG&E tracks and reports a wide range of annual environmental compliance performance indicators. This section covers our performance results for 2018.

Reported Unintentional Releases and Permit Exceedances

We report unintentional releases that exceed regulatory thresholds, as well as many smaller releases, in an effort to ensure operational transparency to local agencies. We reported a total of 166 releases, defined as an unintentional discharge of a regulated substance that required notification to the State of California or exceeded thresholds allowed in applicable permits.

Agency Inspections

In 2018, a total of 552 agency inspections were conducted at our facilities. The majority of these inspections were performed by Certified Unified Program Agencies, such as city and county environmental health departments and fire departments.

Environmental Sanctions and Penalties

To measure compliance results, we categorize all written enforcement actions issued by a regulatory agency as either Level 1 (findings that resulted in an actual or potential environmental impact) or Level 2 (findings that did not result in an actual or potential environmental impact). We also track the percentage of agency inspections that do not result in written enforcement actions.

We received six Level 1 enforcement actions in 2018. Our rate of inspections without a written enforcement action was 93 percent, about three points above our target of 90 percent.

In 2018, PG&E paid a total of $93,000 in environmental penalties.

Compliance Data
2016 2017 2018
Level 1 Enforcement Actions 3 3 6
Percentage of Inspections Without a Written Enforcement Action 95% 93% 93%
Releases/Exceedances 225 164 166
Penalties Paid $135,650 $28,350 $93,000
Agency Inspections 790 539 552
Audits Performed Footnote 1 62 53 8
Self-Assessments Performed 4,752 2,609 3,101
  • 1. Includes system audits, internal audits, and compliance and risk management reviews performed by PG&E. Beginning in 2018, PG&E no longer tracked comprehensive reviews, which led to the one-time decrease in audits performed. Comprehensive reviews are performed by personnel from the Land and Environmental Management department who are not responsible for compliance at the facility or the project being inspected.1