application of san diego gas & electric company and...

OFFICE OF RATEPAYER ADVOCATESCALIFORNIA PUBLIC UTILITIES COMMISSION

Application of San Diego Gas & ElectricCompany and Southern California Gas

Company for a Certificate ofPublic Convenience and Necessity for

Application 15-09-013 – Phase 1

ORA Amended Prepared Testimonyon the Safety of Line 1600

Supporting Attachments to ORA-02

San Francisco, CaliforniaJune 6, 2017

Docket:Exhibit NumberReference NumberCommissionerALJWitness

::::::

A.15-09-013ORA-04-SA

L. RandolphC. KerstenN. SkinnerM. Botros

i

Index of Supplemental Data Request ResponsesPage Request Number Amendment Date Question #

001 ORA-06 5/23/2017 14

002 ORA-19 4/27/2017 7

003 ORA-19 5/25/2017 7

004 ORA-25 4/27/2017 1

005 ORA-87 2

007 ORA-88 1

010 ORA-88 2

011 ORA-88 3

012 ORA-88 4

013 ORA-89 1

017 SED-02 1

018 SED-03 2

019 SED-03 3

020 SED-03 7

021 SED-03 8/2/2016 2

022 SCG/SDG&E-06 N/A

ii

Index of Data Request Response 84(The full copy of ORA-84 is contained in the

Confidential Supplemental Supporting Attachments)

Page Question #

033 10

034 11

035 12

036 13

037 14

038 15

039 16

040 17

041 18

042 19

043 20

044 21

045 22

046 23

047 25

048 26

049 27

050 28

051 29

SAN DIEGO GAS & ELECTRIC COMPANY SOUTHERN CALIFORNIA GAS COMPANY

PIPELINE SAFETY & RELIABILITY PROJECT (PSRP)

(A.15-09-013)

(DATA REQUEST ORA-06)

Date Requested: April 27, 2016 Date Responded: May 12, 2016

Amended Response Submitted: May 23, 2017 ____________________________________________________________________________

3

The response to Question 14 has been amended, the change is noted in red, bold, and underline. QUESTION 14: Provide the specific values needed to determine the Maximum Allowable Operating Pressure of Line 1600 if it is derated to a distribution line, including reference to the applicable code sections of 49 Code of Federal Regulations § 192. ORA understands that if Line 1600 were to be derated, the new Maximum Allowable Operating Pressure would be established under 49 Code of Federal Regulations § 192.619, 620, or 621. RESPONSE 14:

Please refer to Response 12 to this data request, which provides the specific values needed to determine the MAOP for Line 1600 if it is derated to a distribution line at 320 psig. Per 49 CFR § 192.3 Definitions:

Distribution Line – a pipeline other than a gathering or transmission line. If Line 1600 were to be derated, the new MAOP would be established under 49 CFR §§ 192.619 and 192.621.

1



(A.15-09-013)


Date Requested: June 30, 2016 Date Responded: July 15, 2016

Amended Response Submitted: April 27, 2017 ____________________________________________________________________________

3

The response to Question 7 has been amended, changes are noted in red, bold and

underline.

QUESTION 7: Please explain the discrepancies in pipeline records between SDG&E’s 1968 report on Line 1600 (provided in response to ORA DR-14 Q2) and the L1600 pipe segment data (provided in response to ORA DR-06 Q12). RESPONSE 7:

The pipeline record provided in ORA DR-14 Q2 was developed in 1968, and the pipeline record provided in the April 27, 2017 Amended Response (and the Corrected and Updated Attachment thereto) to ORA DR-06 Q12 is the current status of Line 1600, which accounts for changes to the pipelines due to various reasons, such as replacement or relocations. The primary segment is still the 16” Diameter, 0.250” Wall Thickness and 52,000 SMYS in the current report (see DR 14). The April 27, 2017 Amended Response to ORA DR-06, Question 12 (and the Corrected and Updated Attachment thereto) reflects the pipeline segment data previously provided to ORA in: (1) Applicants’ August 12, 2016 response to ORA DR 25, Question 1; (2) , in Applicants’ August 4, 2016 email to ORA (Ogeonye Enyinwa, Nathaniel Skinner, Mina Botros, Pearlie Sabino, and Darryl Gruen) attaching an amendment to a document previously provided in response to ORA DR 19, specifically amended response to ORA DR 19 (which provided a copy of Applicants’ August 2, 2016 amended response to SED DR 3, Q2 and Attachment thereto; and (3) which was submitted on August 4, 2016, and Applicants’ July 15, 2016 response to ORA DR 19 (which provided a copy of Applicants’ original response to SED DR 3, Question 2 and Attachment thereto). In addition, the April 27, 2017 Amended Response (and the Corrected and Updated Attachment thereto) to ORA DR-06, Q12 also reflects that the Line 1600 segment for Engineering Station 17-131 was replaced as of October 26, 2016, as ORA previously was informed in Applicants’ November 30, 2016 response to ORA DR 51, Q3.

2



(A.15-09-013)


Date Requested: June 30, 2016 Date Responded: July 15, 2016

Amended Response Submitted: April 27, 2017 Second Amended Response Submitted: May 25, 2017

____________________________________________________________________________

3

This second corrected and amended response replaces the response to ORA DR-19, Question 7 submitted on July 15, 2016 and the amended response submitted on April 27, 2017 in its entirety. QUESTION 7:

Please explain the discrepancies in pipeline records between SDG&E’s 1968 report on Line 1600 (provided in response to ORA DR-14 Q2) and the L1600 pipe segment data (provided in response to ORA DR-06 Q12). RESPONSE 7:

The pipeline record provided in ORA DR-14 Q2 was developed in 1968, and the pipeline record provided in the May 22, 2017 Amended Response (and the Corrected and Updated Attachment thereto) to ORA DR-06 Q12 is the current status of Line 1600, which accounts for changes to the pipelines due to various reasons, such as replacement or relocations. The primary segment is still the 16” Diameter, 0.250” Wall Thickness and 52,000 SMYS in the current report (see DR 14). The May 22, 2017 Amended Response to ORA DR-06, Question 12 (and the Corrected and Updated Attachment thereto) also reflects corrections of inaccurate information provided in the original May 12, 2016 Attachment to ORA DR-06, Question 12. The original data was taken from a database that had not been fully updated to reflect information learned from research of historical records and to reflect recent construction activity. The corrected information was previously provided to ORA in: (1) Applicants’ August 12, 2016 response to ORA DR 25, Question 1; (2) Applicants’ August 4, 2016 email to ORA (Ogeonye Enyinwa, Nathaniel Skinner, Mina Botros, Pearlie Sabino, and Darryl Gruen) attaching an amendment to a document previously provided in response to ORA DR 19, specifically a copy of Applicants’ August 2, 2016 amended response to SED DR 3, Q2 and Attachment thereto; and (3) Applicants’ July 15, 2016 response to ORA DR 19 (which provided a copy of Applicants’ original response to SED DR 3, Q2 and Attachment thereto). Corrections are noted in red in the attachment to the May 22, 2017 Amended Response to ORA DR-06, Question 12. In addition, the May 22, 2017 Amended Response (and the Corrected and Updated Attachment thereto) to ORA DR-06, Q12 also reflects that the Line 1600 segment for Engineering Station 17-131 was replaced as of October 26, 2016, as ORA previously was informed in Applicants’ November 30, 2016 response to ORA DR 51, Q3.

3



(A.15-09-013)


Date Requested: July 29, 2016 Date Responded: August 12, 2016

Amended Response Submitted: April 27, 2017 ____________________________________________________________________________

3

The response to Question 1 has been amended, changes are noted in red, bold and

underline.

QUESTION 1:

Please provide an updated version of the table provided in response to SED DR-3, Q2 and Q3, that includes the following columns appended to the end:

a. Longitudinal Joint Factor

b. If the Joint is Known (K) or Unknown (U)

c. The year of each class location change (blank if no class location change)

d. The class location prior to each change

e. The class location after each change

Provide the response as an active Excel spreadsheet. If an entry has more than one class location change, append an additional set of items c-e to the end of the entry. Please highlight each column that contains information that SoCalGas/SDG&E claims to be confidential.

RESPONSE 1:

Some of the information provided in the attachment contains confidential information provided pursuant to G.O 66-C and Cal. Pub. Util. Code § 583 and D.16-08-024. Accordingly, a confidentiality declaration is included with the attachment.

The attached excel file appends the requested additional columns. Please note that the attachment also reflects the updates provided to ORA on August 4, 2016.

The updates to the table in the Corrected and Updated Attachment are noted in red and reflect the replacement of a segment in October 2016 per Resolution SED-1.

4



(A.15-09-013)

(87th DATA REQUEST FROM ORA)

Date Requested: May 23, 2017 Date Responded: June 1, 2017

____________________________________________________________________________

3

QUESTION 2: In response to ORA DR-84, Q11, SoCalGas/SDG&E stated:

“As discussed above, the High Pressure Database was updated from conservative default values for certain segments to actual values for those segments between the May 12, 2016 response to ORA DR-06, Q12 and the June 13, 2016 response to SED DR 3, Q2, a copy of which was provided to ORA in Applicants’ July 15, 2016 response to ORA DR 19…”

a. Please explain in detail what prompted SoCalGas/SDG&E to update their High Pressure Database between May 12, 2016 and June 13, 2016.

b. For how long had the High Pressure Database had incorrect information entered for the segments identified in ORA DR-84 Questions 1 to 6?

c. For Line 1600, when did SoCalGas/SDG&E complete MAOP validation? If there has been more than one period when MAOP validation has been considered complete, please provide each date, and an explanation of what occurred that prompted a new examination of MAOP validation.

d. What is the High Pressure Database used for? e. What purposes, including but not limited to integrity management, are the cumulative

stations (as described in the response to ORA DR-84 Q1) in the High Pressure Database used for?

f. What purposes, including but not limited to integrity management, are the engineering stations (as described in the response to ORA DR-84 Q1) in the High Pressure Database used for?

RESPONSE 2:

a. SDG&E and SoCalGas (Applicants) continually evaluate the High Pressure Database to identify additional updates and/or review its records. Further, the data requests received regarding Line 1600 afforded an opportunity to review the High Pressure Database and input additional updates between May and June 2016.

b. The High Pressure Database works as intended. The Applicants’ use of conservative values should not be characterized as “incorrect information” as the process for establishing conservative values was developed to align with guidance provided by ASME B31.8S Section 4, Gathering, Reviewing and Integrating Data when the data available is not completely substantiated. As stated in Applicants’ response to ORA DR-84, at the time the original response to ORA DR-06, Q12 was prepared, the High

5



(A.15-09-013)



____________________________________________________________________________

4

Pressure Database was assigned conservative values for the segments noted in ORA DR-84 Questions 1 to 6. When a wall thickness or grade value is not completely substantiated through installation records in the High Pressure Database, it is conservatively assigned a wall thickness and grade value that provides a margin of safety. The conservative value was assigned based on the diameter and year of installation, and was appropriately reflected in the High Pressure Database at the time the May 12, 2016 response to ORA DR-06, Q12 was prepared and submitted.

c. Applicants completed the MAOP validation process as outlined by the Pipeline and Hazardous Materials Safety Administration (PHMSA) in June 2013. The segments involved in the ORA DR-84 data request did not impact the validated MAOP determination of Line 1600. The segments from ORA DR-84 Questions 1-3 using conservative wall thickness and grade values validated the MAOP of 640 psig and the segments from ORA DR-84 Questions 4-6 are qualified to be grandfathered.

d. The primary purpose of the High Pressure Database is to support the Applicants’ integrity management program. It is used to represent the pipeline attributes for high pressure pipelines with geospatial references based on the source documentation within the installation package.

e. Cumulative stationing is a measurement down the centerline of the pipeline and is re-calculated each time the pipeline is modified; therefore, each reiteration of the pipe will have a new cumulative stationing value. The cumulative stationing facilitates calculating accurate lengths of the pipeline.

f. Engineering station values are memorialized on the pipeline and are intended to stay consistent over time with small modifications to account for realignments and reroutes. The benefit of “engineering stationing” is that attribute information can easily be associated to legacy drawings.

6



(A.15-09-013)


Date Requested: May 25, 2017 Date Responded: May 25, 2017

____________________________________________________________________________

3

ORA is in receipt of two updates to SoCalGas/SDG&E’s response to ORA data request 06, Question 12.

The first update was provided in April 2017, and the second in May 2017. These updates were provided

after ORA submitted its opening testimony in this proceeding. With these facts in mind:

QUESTION 1:

Please identify all portions of ORA testimony that SoCalGas/SDG&E asserts is affected by the two updated data responses. RESPONSE 1: SDG&E and SoCalGas’ (Applicants) April 27 and May 22, 2017 updates to Applicants’ original May 12, 2016 response to ORA DR-06, Q.12 corrected that response to match the updated information previously provided to ORA in (1) Applicants’ July 15, 2016 response to ORA DR 19 (which provided a copy of Applicants’ original response to SED DR 3, Q2 and Attachment thereto), (2) Applicants’ August 4, 2016 email to ORA attaching a copy of Applicants’ August 2, 2016 amended response to SED DR 3, Q2 and Attachment thereto, and (3) Applicants’ August 12, 2016 response to ORA DR 25, Question 1. The original May 12, 2016 data was taken from Applicants’ High Pressure Database, which at the time had not been fully updated to reflect information learned from research of historical records and to reflect recent construction activity, and which subsequently was updated. In addition, Applicants’ April 27 and May 22, 2017 updates included the October 26, 2016 replacement of the Line 1600 segment for Engineering Station 17-131 pursuant to Resolution SED-1, of which ORA was informed in Applicants’ November 30, 2016 response to ORA DR 51, Question 3. Applicants first learned of ORA’s reliance on the Line 1600 segment data in the original May 12, 2016 response to ORA DR-06, Q.12, rather than the updated information, upon receipt of the ORA prepared testimony marked as ORA-2 on April 17, 2017. Applicants then promptly updated the original May 12, 2016 response to ORA DR-06, Q.12 with the updated information. On May 3, 2017, Applicants emailed ORA, inquiring: “Given that Applicants’ failure to correct that response earlier may have contributed to ORA’s testimony being inaccurate, would ORA like the opportunity to amend certain affected portions of ORA-2?” Applicants’ counsel noted: “I believe the affected portions of ORA-2 are found in Section II (recommended Step 1), Section III (Step 1), Section IV.B (pp 15-16), Section IV.D, and Section V.C. We also would need ORA’s corrected testimony in time to complete our rebuttal testimony. If ORA has an interest in amending its testimony, we can discuss when we would need the amended testimony. Please let me know if ORA would like to pursue this option.” Later on May 3, ORA responded: “We appreciate your offer regarding amended testimony, and are considering our

7



(A.15-09-013)



____________________________________________________________________________

4

procedural options. We will communicate with you regarding this matter when we are ready.” Applicants’ rebuttal testimony is now due in less than three weeks. Nonetheless, Applicants remain hopeful that ORA will withdraw its testimony based on inaccurate information regarding the Line 1600 segment data, and thus avoid unnecessary factual disputes. Although Applicants do not assume responsibility for identifying each impacted area of ORA’s testimony, Applicants note the following impacted portions:

ORA-2 at 2. Summary of Recommendations. Step One — “Replace the weakest segments of Line 1600.” These segments are not “weak” as ORA relied upon the inaccurate information in reaching that conclusion. If ORA’s plan becomes a “3 step” plan, conforming changes would be needed throughout.

ORA-2 at 3, lines 20-23. The “discrepancies” identified by ORA relate to the differences between the original May 12, 2016 response to ORA DR-06, Q12 and the three later updated responses. ORA’s “discrepancies” may also refer to certain differences in segment information arising because the ORA DR-06, Q.12 response used CUM Stationing while the other responses used ENG Stationing. When common units are used, that “discrepancy” does not exist, as shown in Applicants’ response to ORA DR-84.

ORA-2 at 4, lines 7-8, 11-20, footnote 21. If ORA wishes to continue to argue for four over-pressurization devices, it may do so, but federal law only requires two devices, and ORA has performed no study of the need or cost of installing such devices, particularly if doing so on Line 1600 were deemed precedent setting.

ORA-2 at 15, line 10 through 16, line 12, and associated footnotes. This testimony relies upon inaccurate information.

ORA-2 at 21, line 23 through 23, line 9, and associated footnotes. The testimony regarding the design pressure of Line 1600 is based upon inaccurate information. Applicants note that, once the proper design pressure is recognized, there is no question that Line 1600, de-rated to 320 psig, meets 49 C.F.R. 192.621. ORA may wish to consider the remainder of its testimony from ORA-2 at 17, line 10 through 23, line 9.

ORA-2 at 25, lines 13-14, and at 29, lines 3-16, claiming “discrepancies” in data provided to ORA and SED.

The Confidential Workpapers of Mina Botros, Exhibit ORA-02-C. Applicants note that, following recognition that all of Line 1600 would be below 20% SMYS at 320 psig, ORA’s claim that Line 1600 would be a federally-defined “transmission line” rests upon ORA’s assertion that Rainbow Metering Station is not a “distribution center.” ORA’s assertion is contrary to Applicants’ longstanding definition of “distribution center,” used and recognized in SED audits of Applicants’ gas system since 2007. Applicants are Local Distribution Companies, and the gas entering SoCalGas and SDG&E’s system is primarily used to deliver gas to customers who purchase it for consumption. This is entirely consistent with the PHMSA interpretation of “distribution center.” If ORA wishes to withdraw its testimony contending that

8



(A.15-09-013)



____________________________________________________________________________

5

Line 1600 de-rated to a 320 psig MAOP would be a “transmission line” because it purportedly is not downstream of a “distribution center,” Applicants have no objection.

9



(A.15-09-013)



____________________________________________________________________________

6

QUESTION 2: With the two updated data responses, has SoCalGas/SDG&E completed its updates to data request 06,

Question 12?

RESPONSE 2: Yes, to the best of Applicants’ current knowledge

10



(A.15-09-013)



____________________________________________________________________________

3

QUESTION 3: Do the two updates mentioned update any of SoCalGas/SDG&E other data responses to ORA in this

proceeding that have not already been updated by SoCalGas/SDG&E?

RESPONSE 3: As of today, SDG&E and SoCalGas (Applicants) are not aware of any other data request responses to ORA that require updating as a result of the two updates mentioned. Since filing their Application in September 2015, Applicants have received approximately 150 data request sets, comprised of thousands of questions (including subparts), from various parties to this proceeding. Applicants have responded to all data requests with the best of their knowledge at the time of each response. When Applicants discover information, either on their own or identified by a third party, that would require amendments to previous data request responses, Applicants work to provide such updates in a timely manner. Should ORA have any questions or seek further explanation of Applicants’ prior data request responses, Applicants welcome and would appreciate the opportunity to provide such clarification.

11



(A.15-09-013)



____________________________________________________________________________

4

QUESTION 4: If the answer to question three is yes, please identify all other updated data responses.

RESPONSE 4: Please refer to the response to Question 3 above.

12



(A.15-09-013)



____________________________________________________________________________

3

In response to ORA Data Request 84, Question 11, SoCalGas/SDG&E stated:

Applicants provided the information for the relevant segments that was in Applicants’ High Pressure Database at the time of the original and updated responses. As discussed above, the High Pressure Database was updated from conservative default values for certain segments to actual values for those segments between the May 12, 2016 response to ORA DR-06, Q12 and the June 13, 2016 response to SED DR 3, Q2, a copy of which was provided to ORA in Applicants’ July 15, 2016 response to ORA DR 19 and subsequently resubmitted to ORA on August 4, 2016 following an August 2, 2016 amended response to SED DR 3 Q2.

In response to ORA Data Request 84, Question 1a, SoCalGas/SDG&E stated (confidential data redacted):

In May 2016, when the original response to ORA DR-06, Q12 was provided, Applicants’ High Pressure database had not been updated with documented wall thickness information and therefore the wall thickness defaulted to unknown for the CUM Station XXX to XXX. When a wall thickness value is unknown in the database, it is conservatively assigned a wall thickness value that provides a margin of safety. The conservative value assigned based on the diameter and year of installation, and which was reflected in the database at the time the May 12, 2016 response to ORA DR-06, Q12 was prepared, was XXX wall thickness for CUM Station XXX to XXX.

Ex. ORA-02-C Confidential Workpapers of M Botros, tab “Low Design Feet – CONF” identified a certain number of segments with weaker design features based on the May 2016 response to ORA Data Request 6, Question 12. In total 0.5 miles of weaker pipeline were identified as compared to the majority of Line 1600. With these facts in mind: QUESTION 1:

a. In May 2016, when the original response to ORA DR-06, Q12 was provided, please confirm that the data provided in the original response to ORA Data Request 6, Question 12 was the data from the High Pressure Database prior to the update SoCalGas/SDG&E

13



(A.15-09-013)



____________________________________________________________________________

4

stated in response to ORA Data Request 84 Question 1a. If not, provide the values in the High Pressure Database from that time.

b. If SoCalGas/SDG&E confirm the answer to question 1a immediately above, please also confirm that the original response to ORA DR-06, Q12 provided in May 2016 was the same information that was contained in the High Pressure Database at the time SoCalGas/SDG&E filed Application 15-09-013. If these two sets of information are not the same, please explain and provide all supporting evidence.

c. Identify all segments of Line 1600 including their length in feet, and their yield strength

using Barlow’s Formula, that had assumptions in the High Pressure Database at the time the application was filed.

d. At the time SoCalGas/SDG&E provided their original direct testimony, please confirm that

the data provided in response to ORA Data Request 6, Question 12 was the data from the High Pressure Database. If not, provide the values in the High Pressure Database from that time.

e. Identify all segments of Line 1600 including their length in feet, and their yield strength

using Barlow’s Formula, that had assumptions in the High Pressure Database at the time the original direct testimony of SoCalGas/SDG&E was filed.

f. Please confirm that the High Pressure Database as of May 2016, prior to being updated as

stated in response to ORA DR 84 Question 1a, identified engineering stations 17-131 as having a weaker MAOP of design than the majority of Line 1600.

g. Please confirm that based on the data in the High Pressure Database at the time of the

August 2016 update to SED-3 demonstrates that the MAOP of Line 1600 would be approximately 24% of SMYS if operated at 320 psig.

h. Please confirm that Applicants had not proposed replacing engineering stations 17-131 as

part of their proposal to derate Line 1600. If Applicants assert otherwise, please provide a specific reference to the testimony where SoCalGas/SDG&E stated they would replace this portion of Line 1600.

i. Provide a version of the information provided in SED-3 Question 2 at the time the

application was filed.

j. Provide a version of the information provided in SED-3 Question 2 at the time the original direct testimony was filed.

14



(A.15-09-013)



____________________________________________________________________________

5

k. Please confirm that by June 2014 SoCalGas/SDG&E had completed “active” MAOP

validation of its entire natural gas transmission system. If not, please explain.

l. Please confirm that by June 2014 SoCalGas/SDG&E had completed “active” MAOP validation of Line 1600. If not, please explain.

m. Provide an active Excel spreadsheet that includes the following:

1. Shows each of the items needed to complete Barlow’s Formula under 49 CFR Section

192.105.

2. Beginning with the date that Application 15-09-013 was filed, and ending with the date of this data request, identify each instance SoCalGas/SDG&E became aware of actual pipeline feature information on Line 1600 that was different from the information SoCalGas/SDG&E used to calculate pressure under 49 CFR Section 192.105. Be sure to identify each attribute that was different.

3. For each event identified in response to m.2, provide the supporting documentation.

4. For each even identified in response to m.2, include the date the supporting documentation was identified, the date the supporting documentation was entered into the High Pressure Database, and the date the safety attribute from the supporting documentation was used to calculate design pressure in compliance with 49 CFR Section 192.105.

5. For each event identified in response to m.2, identify when SoCalGas/SDG&E notified the Commission that updated information had become available regarding Line 1600, and what steps SoCalGas/SDG&E took to explain the updated information.

6. For each event identified in response to m.2, identify when SoCalGas/SDG&E notified Safety and Enforcement Division that updated information had become available regarding Line 1600, and what steps SoCalGas/SDG&E took to explain the updated information.

7. Has SoCalGas/SDG&E clarified to Safety and Enforcement Division that its data response to SED 3 was based upon updated information in the High Pressure Database, which had not been updated at the time Safety and Enforcement Division issued data request SED-3? If the answer is anything but an unqualified no, please provide all documentation showing that such clarification was shown to SED.

8. For each event identified in response to m.2, identify when SoCalGas/SDG&E notified parties to A.15-09-013 that updated information had become available regarding Line

15



(A.15-09-013)



____________________________________________________________________________

6

1600, what specific information had been updated, and what steps SoCalGas/SDG&E took to explain the basis updated information.

RESPONSE 1: SDG&E and SoCalGas (Applicants) object that Question 1 seeks information not within the scope of this proceeding and which is unduly burdensome. ORA has records establishing the documented values for the Line 1600 segments that were amended in Applicants’ April 27 and May 22, 2017 Corrected and Updated Confidential Attachments to Applicants’ response to ORA DR-06, Q.12. Applicants’ response to ORA DR-84 explained the changes in Applicants’ High Pressure Database from the conservative default values included in Applicants’ original May 12, 2016 response to ORA DR-06, Q.12 to the documented values in Applicants’ later responses to SED and ORA. Question 1 now seeks extensive information regarding the data reflected in the High Pressure Database at various times in the past and calculations based upon that information. As ORA has documented values that establish that all segments of Line 1600 would be below 20% SMYS if de-rated to a 320 psig MAOP, such information is not relevant to any issue in this proceeding and the process of compiling such information is unduly burdensome. Without waiving and subject to their objections, Applicants respond as follows: ORA appears to seek information regarding why Applicants concluded that de-rating Line 1600 to a 320 psig MAOP would result in all segments being under 20% SMYS, thus rendering Line 1600 a distribution line under 49 CFR § 192.3, at a time when the High Pressure Database still contained conservative default values for certain segments of Line 1600. Based upon what was known about Line 1600’s construction, maintenance and operation, Applicants were confident that the weakest segments were constructed in 1949 using the original A.O. Smith pipe (wall thickness 0.250 and yield strength of 52,000) and that later installed segments were built to withstand equal or greater pressures (with equivalent or greater wall thickness and/or yield strength). Applicants intended to confirm this assumption before de-rating Line 1600, if approved by the Commission, either through records review and/or field data collection, non-destructive testing or destructive testing; if the assumption was not correct, then Applicants would have replaced the pipe segments before de-rating Line 1600. Applicants note that following the removal of the pipe segment for engineering stations 17-131, and the subsequent testing of the pipe segment, it was determined that it had the attributes of the original A.O. Smith pipe (wall thickness 0.250 and yield strength of 52,000), as anticipated, also confirming the conservatism of the interim values.

16


A.15-09-013 CERTIFICATE OF PUBLIC CONVENIENCE & NECESSITY FOR THE

PIPELINE SAFETY & RELIABILITY PROJECT

DATA REQUEST SED-02 Date Requested: May 24, 2016 Date Responded: May 31, 2016

______________________________________________________________________

1

QUESTION 1: Per phone conversation between Matt Epuna (SED) and Doug Schneider (SoCalGas/SDG&E), as a follow up to SED DR 1 regarding pressure test location data on Line 1600, please provide the section(s) that were pressure tested, the reason that the section was pressure tested, and whether replacement was due to condition, relocation, response to excavation damage, etc. RESPONSE 1: The majority of the pressure tests that have occurred on Line 1600 have been for relocations due to development and freeway work and compose the majority of the pressure tests depicted on the diagram provided in Question 4 of Data Request SED-01 submitted on February 11, 2016. In researching the data to answer this follow-up question, we found that there were some additional projects that were hydrotested and are in process of being entered into the database. These projects are expected to be 2,000 feet or less and were performed for valve replacements to allow for inline inspection or cylindrical repairs post inline inspection as denoted in SED-01 Question 12. Once these projects are added to the database, we will update our response to Question 4.

17



(A.15-09-013)

(SED DATA REQUEST- 3)


____________________________________________________________________________

2

QUESTION 2: A segment by segment engineering analysis for the entire Line 1600 with any unknown pipeline characteristics identified and any assumed values detailed. RESPONSE 2: Some of the information provided in the attachment contains confidential information provided pursuant to G.O. 66-C and Cal. Pub. Util. Code § 583. As part of the Maximum Allowable Operating Pressure (MAOP) validation process each segment was analyzed to determine the appropriate MAOP based on year of installation, pipe properties, class location, test records and historical operating pressures. The segment in the attached document (SED DR 3 Q2 and Q3 L1600 SEGMENTS.pdf) highlighted in gray has an unknown wall thickness and grade and the corresponding engineered value is prefixed with a “DT” (Decision Tree) designation. In addition as described in Question 1 above, an assessment and remediation of Line 1600 has been completed using In-Line-Inspection (MFL, TFI, Caliper) and External Corrosion Direct Assessment and deemed fit for service.

18



(A.15-09-013)



____________________________________________________________________________

3

QUESTION 3: Provide a detailed analysis of all segments that have been pressure tested, with traceable, verifiable, and complete test records. RESPONSE 3: SDG&E and SoCalGas interpret “traceable, verifiable and complete” to mean “reliable and accurate” and respond as follows: See response to Question 2, above. Some of the information provided in the attachment contains confidential information provided pursuant to G.O. 66-C and Cal. Pub. Util. Code § 583. As mentioned in SED DR 2, there are still some projects being entered into the database and once added this response will be updated.

19



(A.15-09-013)



____________________________________________________________________________

7

QUESTION 7: Please submit a detailed operational plan for Line 1600 if it operates as a distribution line. RESPONSE 7: As discussed in the Prepared Direct Testimony of Neil Navin served in A.15-09-013, Line 1600 is proposed to be repurposed to operate as a distribution line with a MAOP of 320 psig which corresponds to a hoop stress of less than 20% of Specified Minimum Yield Strength (SMYS). The line will generally remain in the same basic physical configuration as currently exists with some modifications to further integrate it into the distribution system including pressure regulation/limiting features and distribution interconnections. Additional interconnection points with the new Pipeline Safety & Reliability Project natural gas transmission line (Line 3602) will also be constructed. The repurposed Line 1600 will be integrated into SDG&E’s distribution operations and be operated and maintained consistent with current established codes, standards and operating practices for SDG&E’s distribution pipelines. These include all operations and maintenance (O&M) activities required in General Order 112 and associated codes for distribution lines. O&M activities include maintaining cathodic protection, periodic patrolling including leak patrols, valve inspection and maintenance, pressure regulator inspection and maintenance and other operational activities such as locate and mark in response to 811 “call before you dig” requests. Historical asset and O&M records would continue to be maintained as required and O&M data going forward would be included with that associated with the distribution system. Please refer to the Prepared Direct Testimony of Neil Navin in the link below: https://www.sdge.com/sites/default/files/regulatory/A.15-09-013%20Prepared%20Direct%20Testimony%20of%20N.%20Navin%203-21-16_0.pdf

20



(A.15-09-013)

(SED DATA REQUEST- 3 Amended)


Amended Response: August 2, 2016 ____________________________________________________________________________

1

QUESTION 2: A segment by segment engineering analysis for the entire Line 1600 with any unknown pipeline characteristics identified and any assumed values detailed. RESPONSE 2: Some of the information provided in the attachment contains confidential information provided pursuant to G.O. 66-C and Cal. Pub. Util. Code § 583. As part of the Maximum Allowable Operating Pressure (MAOP) validation process each segment was analyzed to determine the appropriate MAOP based on year of installation, pipe properties, class location, test records and historical operating pressures. The segment in the attached document (Confidential SED DR 3 Q2 L1600 SEGMENTS_revised.pdf) highlighted in gray has an unknown wall thickness and grade and the corresponding engineered value is prefixed with a “DT” (Decision Tree) designation. In addition as described in Question 1 above, an assessment and remediation of Line 1600 has been completed using In-Line-Inspection (MFL, TFI, Caliper) and External Corrosion Direct Assessment and deemed fit for service.

21

BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA

In the Matter of the Application of San Diego Gas

& Electric Company (U 902 G) and Southern California

Gas Company (U 904 G) for a Certificate of Public

Convenience and Necessity for the Pipeline Safety &

Reliability Project

Application 15-09-013

SIXTH SET OF DATA REQUESTS PROPOUNDED BY SAN DIEGO GAS &

ELECTRIC COMPANY (U 902 E) AND SOUTHERN CALIFORNIA GAS COMPANY

(U904G) UPON THE OFFICE OF RATEPAYER ADVOCATES

ALLEN K. TRIAL

San Diego Gas & Electric Company

8330 Century Park Court, CP32A

San Diego, CA 92123

Tel: (858) 654-1804

Fax: (619) 699-5027

E-mail: [email protected]

RICHARD W. RAUSHENBUSH

Work/Environment Law Group

351 California St., Suite 700

San Francisco, CA 94104

Telephone: (415) 518-7887

Facsimile: (415) 434-0513

[email protected]

Attorneys for Applicants:

SAN DIEGO GAS & ELECTRIC COMPANY

SOUTHERN CALIFORNIA GAS COMPANY

April 28, 2017

22

TO: OFFICE OF RATEPAYER ADVOCATES

PLEASE TAKE NOTICE San Diego Gas & Electric Company (“SDG&E”) and

Southern California Gas Company (“SoCalGas”) (jointly, “Applicants”) hereby request that the

Office of Ratepayer Advocates (“ORA”) provide a written response to this Data Request in

accordance with the Rules of Practice and Procedure of the California Public Utilities

Commission (“Commission”).

In accordance with Article 10 of the Commission’s Rules of Practice and Procedure,

please produce the following INFORMATION and described categories of DOCUMENTS.

Please provide your response no later than the due date requested below. If you are unable to

provide the information by this date, please provide a written explanation as to why the response

date cannot be met and your best estimate of when the information can be provided. Please e-

mail all responses that can be transmitted electronically. If attachments cannot be electronically

transmitted, please notify the undersigned via e-mail or phone and arrangements will be made for

the alternate submission of said attachments.

GENERAL INSTRUCTIONS

1. Answer in the greatest detail you are able for each of the Data Requests.

2. Include a copy of each data request that the response addresses before each

response.

3. Sign your name to your answers to the Data Request.

4. Return the completed and signed copy of your answers to

[email protected] and [email protected] as an

attachment to electronic mail by close of business on May 12, 2017.

5. Any of the Data Requests and your answers thereto may be offered as evidence in

any hearing in the above-styled and numbered cause.

6. In answering the Data Requests, you are required to set forth each responsive fact,

circumstance, act, omission, or course of conduct, whether or not admissible in

23

2

evidence at trial about which you have or had information or which is or will be

the basis for any contention made by you with respect to the Application.

7. The Data Request shall be interpreted to make requests for information inclusive

rather than exclusive.

8. You are required to supplement your answers to include information acquired

after filing your responses to the Data Requests if you obtain information upon

the basis of which you know that the response was incorrect or incomplete when

made, or you know that the response that was originally correct and complete

when made is no longer true and complete and the circumstances are such that

failure to amend the answer is in substance misleading.

9. If you are not capable of answering any of the Data Requests completely, please

state the portion of the Data Request that you are unable to answer, and to the

extent possible set forth the reasons for you inability to answer more fully, and

state whatever knowledge or information you have concerning the unanswered

portion.

10. If requested information is not available in exactly the form requested, furnish

carefully prepared estimates, designated as such, and explain the basis of the

estimate, or indicate that you are unable to obtain the information and explain the

reason that you cannot obtain the information. Where information is supplied

pursuant to this instruction, explain why the information is being supplied in a

form different from that requested.

11. If you withhold under a claim of privilege any document(s) responsive to the Data

Requests, furnish a list specifying each document so identified, then set forth

separately with respect to each document:

a. the alleged privilege or claim of confidentiality under which the document

is being withheld;

b. the title of the document;

c. the author of the document;

d. the date of the document;

e. a brief statement of the subject matter dealt within the document;

f. the full names of all persons to whom the document is addressed and to

whom copies of the document have been furnished;

g. the name and location of the present depository and custodian of the

document; and

h. the Data Request(s) to which the identification of the document is

responsive.

12. Applicants hereby requests that such privilege log be served with your service

upon Applicants of your responses to the Data Requests.

24

3

13. When an identified document has been destroyed, is alleged to have been

destroyed, or exists but is no longer in your possession, custody or control, state

the following:

a. the date of the document;

b. the names and titles of the author(s), sender(s), and recipients(s) of the

document;

c. the reason for the document’s destruction, disposition, or non-availability;

d. person(s) having knowledge of its destruction, disposition, or non-

availability; and

e. the person(s) responsible for its destruction, disposition, or non-

availability.

14. As to any document made available in response to the Data Request, state the

Data Request to which the document is made available as a response.

15. Where the context herein makes it appropriate, each singular word shall include

its plural and each plural word shall include its singular. All words and phrases

shall be construed as masculine, feminine or neuter gender according to the

context.

16. Documents to be produced include all documents in your possession, custody or

control, which includes not only actual physical possession, but constructive

possession, and the right to obtain possession from a third party, such as an agent

or representative.

DEFINITIONS

These definitions apply to the following Data Request:

1. “And” and “or” means and/or.

2. “Communication” shall mean any inquiry, discussion, conversation, negotiation,

agreement, understanding, meeting, telephone conversation, letter,

correspondence, note, telegraph, advertisement, or any other form of transaction

whether oral or written.

3. “Concerning” shall mean in whole or in part, directly or indirectly, referring to,

relating to, connected with, commenting on, responding to, showing, describing,

analyzing, reflecting and constituting.

4. “Document(s)” refers to all tangible things, writings and means of communication

or storage of any kind, including the original and all non-identical copies, whether

different from the original by reason of any notation made on such copies or

otherwise and produced by any process or written or produced by hand and

whether or not claimed to be privileged or exempt from production for any

reason. The term “document” shall include without limitation letters,

25

4

correspondence, memoranda, reports, notes, diaries, statistics, telegrams, minutes,

contracts, reports, studies, texts, statements, receipts, returns, summaries,

pamphlets, brochures, advertisements, circulars, trade letters, press releases, news

clippings, books, booklets, periodicals, prospectuses, interoffice and intra-office

communications, e-mails, internet postings, offers, notations of any sort of any

conversations, notations of telephone calls, data generated and recorded by

computer systems and computer system peripherals, notations of meetings or

other communications, bulletins, printed matter, computer printouts, teletypes,

telefax, invoices, worksheets, counterpads, appointment books, charts, graphs,

forecasts, plans, drawings, blueprints, indices, data sheets, data processing cards,

data processing tapes or disks, ledgers, journals, books of entry, financial

statements, statistical statements, understandings, agreements, drawings, sketches,

working papers, checks, any financial instruments, bills, notes, certificates, deeds,

deeds of trust, bills of sale or other instruments of conveyance, instruments

reflecting ownership, deposition transcripts, laboratory and engineering reports

and notebooks, status and progress reports, minutes and records of conferences,

agenda for conferences, reports and summaries of interviews, reports and

summaries of investigations, reports and summaries of negotiations, opinions,

notes and reports of consultants, opinions and notes and reports of experts, patent

appraisals, and any and all drafts, alterations, modifications, changes, notes,

translations and amendments of any of the foregoing categories of documents. In

addition, the term “document” shall mean graphic or aural records and aural

representations of any kind, including without limitation, photographs, charts,

graphs, microfiche, microfilm, video tape recordings, and transcripts of such

recordings, motion pictures, computer tapes, disks or computer cards, and any

electronic, mechanical or electric recording or storage media, and transcripts of

such recording or representations of any kind, including, without limitation tapes,

cassettes, films, discs, recordings, and transcriptions of any audio or video

recordings. Also, any copy of any such document which contains any notations,

initials, date stamps or any other markings or information not a part of the original

is to be considered a separate “document”.

5. “Identify” or “identification” means, when used in reference to:

A natural person:

a. Full name;

b. Present or last known residence and business address (including

street name and number, city or town, and state or country);

c. Present position, business affiliation, and job description (if the

present business or residence address or present position, business

affiliation, or job description are unknown, such a statement and

the corresponding last known such information); and

d. Position, business affiliation, and job description at the time in

question, with respect to the Data Request or other request

involved.

26

5

A document:

a. Its description (e.g., letter, memorandum, report, etc.);

b. Its title, date, and number of pages thereof;

c. Its subject matter;

d. Its author’s identity;

e. Its addressee’s identity;

f. The identity of each person who signed it;

g. The identity of each person who received it; and

h. Its present location and its custodian’s identity (if such document

was, but is no longer, in the possession of or subject to the control

of the Complainant, such statement and the manner and date of the

disposition made thereof).

An oral communication:

a. Its date and the place where it occurred;

b. Its substance; and

c. The identity of each person to whom such communication was

made, and each person who was present when such communication

was made.

Any other context:

a. A description with sufficient particularity that the thing may

thereafter be specified and recognized, including relevant dates and

places, and the identification of relevant people, entities and

documents; and

b. When used as a part of a request for facts to support a particular

allegation or contention, it includes identification of documents

produced by others as a part of the discovery process, experts’

reports, and applicable portions of deposition transcripts,

identification of oral communications, and any and all other forms

of recorded facts, whether or not you have finally decided on its

use at trial.

6. “Application” means that certain application, and amendment to application,

known as A.15-09-013 before the Public Utilities Commission of the State of

California.

7. “Relate to” is used in its broadest possible sense and includes but is not limited to

its various forms such as “relating to” as well as anything that, directly or

indirectly, generally or specifically, regards, relates to, refers to, analyzes,

comments on, comprises, concerns, constitutes, contains, contradicts, deals with,

demonstrates, describes, embodies, evidences, identifies, mentions, pertains to,

reflects, responds to, states, or is in any way whatsoever, directly or indirectly,

connected factually, logically or otherwise to the matter discussed.

27

6

8. “Proposed Project” means that certain gas pipeline project proposed by Applicants

in the Application.

9. “SMYS” means specified minimum yield strength.

10. “MAOP” means maximum allowable operating pressure.

11. “CFR” refers to the Code of Federal Regulations.

12. “psig” means pounds per square inch gauge

13. “You” and “your” refer to ORA.

DATA REQUESTS

DATA REQUEST NO. 1

ORA-02 at page 15, line 14 states: “Specifically, the design pressure of Line 1600’s weakest

pipeline segments would operate at 24% SMYS, [footnote omitted] and the next weakest

segments would operate at approximately 22% SMYS [footnote omitted].” Utilizing the data

provided in Applicants’ April 27, 2017 Corrected and Updated Response to ORA DR-6, Q12,

please state the design pressure and % of SMYS of the weakest pipeline segment in Line 1600

determined in accordance with 49 CFR Part 192, Subparts C and D.

DATA REQUEST NO. 2

ORA-02 at page 16, lines 6 and 7 states that “By ORA’s calculations, the approximate distance

of the segments exceeding 20% SMYS with an MAOP of 320 psig is approximately 0.5 miles.”

Utilizing the data provided in Applicants’ April 27, 2017 Corrected and Updated Response to

ORA DR-6, Q12, please state the number of miles of Line 1600 that exceed 20% of SMYS.

Please provide ORA’s workpapers that support this response and identify the person responsible

for preparing the workpapers and this response.

DATA REQUEST NO. 3

Please admit that the design pressure for Line 1600 under 49 CFR Part 192 is defined by an

equation in 49 CFR § 192.105. If ORA does not so admit, please explain the factual basis for

ORA’s response, produce any documents supporting ORA’s response, and identify the person(s)

responsible for drafting the response.

28

7

DATA REQUEST NO. 4

Please admit that utilizing the data provided in Applicants’ April 27, 2017 Corrected and

Updated Response to ORA DR-6, Q12 and the formula required in 49 CFR § 192.105, the

calculated design pressure for Line 1600 steel pipe is 812.5 psig for Class 3 locations, which is

the governing Class location. If ORA does not so admit, please explain the factual basis for

ORA’s response, produce any workpapers and documents supporting ORA’s response, and

identify the person(s) responsible for drafting the response.

DATA REQUEST NO. 5

Please admit that Applicants’ Proposed Project, with respect to de-rating the northern 45 miles of

Line 1600, as described in SDGE-8-R Updated Prepared Testimony of Norm G. Kohls,

Attachment A, San Diego Gas & Electric and Southern California Gas Co. Pipeline Safety &

Reliability Project (PSRP) Report, Attachment XI L-1600 De-rating Impacting Analysis, SDGE-

12 Supplemental Testimony of SDG&E and SoCalGas at 100-101, and in Applicants’ Response

to ORA DR-83, will equip the lines connecting to the de-rated Line 1600 that are designed to

operate at a lower pressure than Line 1600 with service regulators or other pressure limiting

devices in series that meet the requirements of 49 CFR §§ 192.195 and 192.197(c). If ORA does

not so admit, please explain the factual basis for ORA’s response, produce any workpapers or

documents supporting ORA’s response, and identify the person(s) responsible for drafting the

response.

DATA REQUEST NO. 6

Please admit that Applicants have described steel materials as the only material that the pressure

carrying components of the Line 1600 pipeline are constructed from. If the answer is anything

other than an unqualified affirmation, please describe the other materials and provide

documentation substantiating your response.

DATA REQUEST NO. 7

Please admit that Line 1600 does not contain any segments of cast iron pipe. If ORA does not so

admit, please explain the factual basis for ORA’s response, produce any documents supporting

ORA’s response, and identify the person(s) responsible for drafting the response.

29

8

DATA REQUEST NO. 8

After over 68 years of operating as a transmission line at pressures exceeding 500 psig, and

based on all the information known to ORA, does ORA agree that joints on the northern 45 miles

of Line 1600 (proposed to be de-rated under the Proposed Project) could be subjected to a

pressure of 320 psig without the possibility of any of them parting? If the answer is other than

an unqualified affirmative, please provide the factual basis for ORA’s response, produce ORA’s

workpapers and supporting documents for ORA’s response, and identify the person(s)

responsible for preparing the workpapers and this response.

DATA REQUEST NO. 9

In response to ORA DR 19 Question 6, Applicants provided ORA a copy of SED DR 3, which

included a “Line 1600 Fit for Service Report” in response to Question 1. Given the information

provided, please admit that 320 psig is a pressure 50% lower than the 640 psig value that

Applicants, as the operators of Line 1600, have determined is a safe pressure at which to operate

Line 1600. If ORA does not so admit, please explain the factual basis for ORA’s response,

produce any documents supporting ORA’s response, and identify the person(s) responsible for

drafting the response.

DATA REQUEST NO. 10

Please admit that Applicants’ Proposed Project, with respect to de-rating the northern 45 miles of

Line 1600, as described in SDGE-8-R Updated Prepared Testimony of Norm G. Kohls,

Attachment A, San Diego Gas & Electric and Southern California Gas Co. Pipeline Safety &

Reliability Project (PSRP) Report, Attachment XI L-1600 De-rating Impacting Analysis, SDGE-

12 Supplemental Testimony of SDG&E and SoCalGas at 100-101, and in Applicants’ Response

to ORA DR-83, will install overpressure protective devices as required in a manner that will

prevent the maximum allowable operating pressure from being exceeded, in accordance with 49

CFR § 192.195. If ORA does not so admit, please explain the factual basis for ORA’s response,

produce any documents supporting ORA’s response, and identify the person(s) responsible for

drafting the response.

DATA REQUEST NO. 11

Considering the information provided in Applicants response to ORA DR 14 Question 2 and any

other information available to ORA, please admit that the highest actual operating pressure to

which Line 1600 was subjected during the 5 years preceding July 1, 1970 exceeded 320 psig. If

ORA does not so admit, please explain the factual basis for ORA’s response, produce any

documents supporting ORA’s response, and identify the person(s) responsible for drafting the

response.

30

9

DATA REQUEST NO. 12

Please admit that the highest actual operating pressure to which Line 1600 was subjected during

the 5 years preceding July 1, 1970 exceeded 325 psig. If ORA does not so admit, please explain

the factual basis for ORA’s response, produce any documents supporting ORA’s response, and


DATA REQUEST NO. 13





DATA REQUEST NO. 14





DATA REQUEST NO. 15

In SDGE-8-R Updated Prepared Testimony of Norm G. Kohls, Attachment B, Line 1600

Hydrotest Study and Cost Estimate, it is described that Line 1600 supplies gas to approximately

152,000 customers through approximately 50 connections. It goes on to describe the

complexities, system modifications and actions necessary to keep these customers in service

while the hydrotest is performed.

a. Does ORA contend that these complexities, system modifications and actions and the

costs associated with them can be avoided if a gas test is performed at 487.5 psig as

proposed by ORA? Please state all facts that support your response, produce all

workpapers and documents that support your response, and identify the person(s) that

prepared this response.

b. Other than the changes associated with substituting natural gas for water, please describe

the system modifications and actions to keep the customers in service that will not be

required if a gas test is performed as recommended by ORA compared to a hydrotest.

31

10

DATA REQUEST NO. 16

Given the 68 year operating history of Line 1600 as a transmission line at pressures consistently

exceeding 500 psig, and given that Resolution No. SED-1 currently allows the pipeline to be

operated at pressures up to 512 psig, and considering the information provided in Applicants

response to ORA DR 14 Question 2 regarding historical operating pressures for Line 1600,

please respond to the following. For each subsection below, please state all facts that support

your response, produce all workpapers and documents that support your response, and identify

the person(s) that prepared the response.

a. Please describe and explain the reasons for testing line 1600 with gas at a pressure of

487.5 psig.

b. Describe what will be accomplished by said test, including but not limited to, what new

information will be learned by completing this test.

c. Describe how this test will provide useful and meaningful information regarding the

safety of Line 1600. Describe the useful and meaningful information that will be

provided.

d. State whether a test at this pressure will expose potentially critical defects in the pipeline.

Describe those defects and explain why those defects haven’t already been exposed at

current transmission level operating pressures.

e. Describe why performing a gas test of Line 1600 at 487.5 psig is a good value for

SDG&E’s customers.

Dated in San Diego, California, this 28th day of April, 2017.

Respectfully submitted,

By: /s/ Allen K. Trial

Allen K. Trial

ALLEN K. TRIAL

8330 Century Park Court, CP32A

San Diego, California 92101

Telephone: (858) 654-1804

Facsimile: (619) 699-5027

[email protected]

Attorney for Applicants:

SAN DIEGO GAS & ELECTRIC COMPANY

SOUTHERN CALIFORNIA GAS COMPANY

32



(A.15-09-013)



____________________________________________________________________________

20

QUESTION 10: Explain why the response to ORA DR-06, Q12 contains different engineering stations than the response to ORA DR-25, Q1. If the responses come from different databases or other systems, please explain the underlying documentation and what part of the SCG/SDG&E organization(s) bears responsibility for their maintenance and accuracy. RESPONSE 10:

As set forth in response to Question 1, Cumulative Stationing vs. Engineering Stationing, the attachment to Applicants’ response to ORA DR-06, Q12, including Applicants’ April 27, 2017 Corrected and Updated Confidential Attachment to Applicants' Response to ORA DR 6, Question 12 1600 Pipe Segment Data (now further updated in Applicants’ May 22, 2017 Corrected and Updated Confidential Attachment to Applicants' Response to ORA DR 6, Question 12 L1600 Pipe Segment Data), refers to “cumulative stations,” not “engineering stations.” By contrast, the attachment to Applicants’ response to ORA DR-25, Q1, including Applicants’ April 27, 2017 Corrected and Updated Confidential Attachment to Applicants’ Response to ORA DR-25, Q1, refers to “engineering stations,” not “cumulative stations.”

33



(A.15-09-013)



____________________________________________________________________________

21

QUESTION 11: Do SCG/SDG&E’s updates to its responses to ORA DR-06 Q12 identified in this data request mean that SCG/SDG&E claims it provided inaccurate information to ORA in the instances where that information have been updated? If not, please explain. RESPONSE 11:

To the extent that ORA is referring to differences in stationing, as set forth in response to Question 1, Cumulative Stationing vs. Engineering Stationing, the attachment to Applicants’ response to ORA DR-06, Q12, including Applicants’ April 27, 2017 Corrected and Updated Confidential Attachment to Applicants' Response to ORA DR 6, Question 12 1600 Pipe Segment Data (now further updated in Applicants’ May 22, 2017 Corrected and Updated Confidential Attachment to Applicants' Response to ORA DR 6, Question 12 L1600 Pipe Segment Data), refers to “cumulative stations,” not “engineering stations.” By contrast, the attachment to Applicants’ response to ORA DR-25, Q1, including Applicants’ April 27, 2017 Corrected and Updated Confidential Attachment to Applicants’ Response to ORA DR-25, Q1, refers to “engineering stations,” not “cumulative stations.” With respect to the values attributed to the specific pipeline segments corrected in Applicants’ April 27, 2017 Corrected and Updated Confidential Attachment to Applicants' Response to ORA DR 6, Question 12 1600 Pipe Segment Data (and now further updated in Applicants’ May 22, 2017 Corrected and Updated Confidential Attachment to Applicants' Response to ORA DR 6, Question 12 1600 Pipe Segment Data), Applicants provided the information for the relevant segments that was in Applicants’ High Pressure Database at the time of the original and updated responses. As discussed above, the High Pressure Database was updated from conservative default values for certain segments to actual values for those segments between the May 12, 2016 response to ORA DR-06, Q12 and the June 13, 2016 response to SED DR 3, Q2, a copy of which was provided to ORA in Applicants’ July 15, 2016 response to ORA DR 19 and subsequently resubmitted to ORA on August 4, 2016 following an August 2, 2016 amended response to SED DR 3 Q2.

34



(A.15-09-013)



____________________________________________________________________________

22

QUESTION 12: Please explain why allegedly inaccurate information was originally provided in response to ORA DR-06, Q12. SoCalGas/SDG&E stated in the Amended Response to ORA DR-19, Q7: “The April 27, 2017 Amended Response to ORA DR-06, Question 12 (and the Corrected and Updated Attachment thereto) reflects the pipeline segment data previously provided to ORA in: [ORA DR-25, Q1; amending ORA DR- 19, which amended SED DR-03, Q2].” RESPONSE 12:

Please see the response to Question 11.

35



(A.15-09-013)



____________________________________________________________________________

23

QUESTION 13: Please provide the change log or other similar information that tracks changes to the database or information used to provide the response to ORA DR-06, Q12. If no such log is available, explain: a. How SCG/SDG&E tracks and maintains attribute information of its natural gas pipelines to ensure compliance with state and federal natural gas pipeline safety requirements. b. How SCG/SDG&E tracks changes and updates to attribute information of its natural gas pipelines to ensure compliance with state and federal natural gas pipeline safety requirements. RESPONSE 13: The Attachments identified in response to Questions 1-6 include documentation of the changes to the High Pressure Database. See documents entitled FORM 2112 PIPELINE DATABASE UPDATE.

36



(A.15-09-013)



____________________________________________________________________________

24

QUESTION 14: How many different sources of information did SCG/SDG&E use to determine the pipeline attributes of Line 1600 it provided ORA in the response to ORA DR-06, Q12? Please list all such sources. RESPONSE 14:

Applicants have consistently responded to all data requests from the same data source, the High-Pressure Data Base, and documents referenced therein.

37



(A.15-09-013)



____________________________________________________________________________

25

QUESTION 15: How many different sources of information did SCG/SDG&E use to determine the pipeline attributes of Line 1600 it provided ORA in the April 2017 updated response to ORA DR-06, Q12? Please list all such sources. RESPONSE 15:

Applicants have consistently responded to all data request from the same data source, the High-Pressure Data Base, and the documents referenced therein. As discussed in response to Question 11, the High Pressure database was updated from conservative default values for certain segments to actual documented values for those segments between the May 12, 2016 response to ORA DR-06, Q12 and the June 13, 2016 response to SED DR 3, Q2, a copy of which was provided to ORA in Applicants’ July 15, 2016 response to ORA DR 19, and has been further updated and resubmitted to ORA thereafter.

38



(A.15-09-013)



____________________________________________________________________________

26

QUESTION 16: How many different sources of information did SCG/SDG&E use to determine the pipeline attributes of Line 1600 it provided ORA in the response to ORA DR-25, Q1. Please list all such sources. RESPONSE 16:

Applicants have consistently responded to all data request from the same data source, the High-Pressure Data Base, and the documents referenced therein. As discussed in response to Question 11, the High Pressure Database was updated from conservative default values for certain segments to actual documented values for those segments between the May 12, 2016 response to ORA DR-06, Q12 and the June 13, 2016 response to SED DR 3, Q2, a copy of which was provided to ORA in Applicants’ July 15, 2016 response to ORA DR 19, and has been further updated and resubmitted to ORA thereafter.

39



(A.15-09-013)



____________________________________________________________________________

27

QUESTION 17: How many different sources of information did SCG/SDG&E use to determine the pipeline attributes of Line 1600 it provided ORA in the April 2017 updated response to ORA DR-25, Q1. Please list all such sources. RESPONSE 17:

Applicants have consistently responded to all data request from the same data source, the High-Pressure Data Base, and the documents referenced therein. As discussed in response to Question 11, the High Pressure Database was updated from conservative default values for certain segments to actual documented values for those segments between the May 12, 2016 response to ORA DR-06, Q.12 and the June 13, 2016 response to SED DR 3, Q2, a copy of which was provided to ORA in Applicants’ July 15, 2016 response to ORA DR 19, and has been further updated and resubmitted to ORA thereafter.

40



(A.15-09-013)



____________________________________________________________________________

28

QUESTION 18: When answering questions 14, 15, 16, and 17, if SCG/SDG&E used a data source in one response it did not use in another response, please explain why. RESPONSE 18:

NA. All data sources were the same.

41



(A.15-09-013)



____________________________________________________________________________

29

QUESTION 19: When answering questions 14, 15, 16, and 17 if SCG/SDG&E did not use a data source in one response that it used in another response, please explain why. RESPONSE 19:

NA. All data sources were the same.

42



(A.15-09-013)



____________________________________________________________________________

30

QUESTION 20: Provide the name(s), title(s), and part of the SoCalGas/SDG&E organization for who: a. Prepared the original response to ORA DR-06, Q12. b. Prepared the April 2017 updated response to ORA DR-06, Q12. c. Prepared the original response to SED DR-03, Q2 (and thus ORA DR-25, Q1). d. Prepared the April 2017 updated response to SED DR-03, Q2 (and thus ORA DR-25, Q1). e. Prepared the original response to ORA DR-19, Q7. f. Prepared the April 2017 updated response to ORA DR-19, Q7. RESPONSE 20: SDG&E and SoCalGas (Applicants) object to the term “prepared” as vague and ambiguous, and thus potentially overbroad and unduly burdensome if deemed to include every employee who contributed data to the High Pressure Database. Subject to and without waiving their objections, Applicants respond as follows: These responses were prepared by various personnel in the pipeline integrity department under the direction of Maria Martinez (Director - Pipeline Integrity).

43



(A.15-09-013)



____________________________________________________________________________

31

Update to ORA DR-19, Q7

QUESTION 21: Please confirm that at no point in the response to ORA DR-25 Q1 has SCG/SDG&E stated that the information contained therein was an update or revision to the response contained in ORA DR-06, Q12. RESPONSE 21:

ORA DR-25 Q1 specifically requested “Please provide an updated version of the table provided in response to SED DR-3, Q2 and Q3, that includes the following columns appended to the end”. Applicants provided the updated information requested by ORA DR-25 Q1. ORA clearly was aware of the later data provided to SED, and received the updated data it requested through ORA DR-25 Q1. Although SCG/SDG&E did not state in the response to ORA DR-25, Q1 that it superseded the earlier response to ORA DR-06, Q12, SCG/SDG&E assumed that ORA was aware that it was receiving “updated” data as ORA DR-25, Q1 specifically requested it. ORA also received updated data through its receipt of SCG/SDG&E’s responses to SED DR-3, Q2 and Q3. At no time before receiving ORA’s testimony on April 17, 2017 was SCG/SDG&E aware that ORA was relying on the un-updated data provided in response to ORA DR-06, Q12, rather than the updated data provided to ORA in response to ORA DR-19 and ORA DR-25, Q1. Despite serving thousands of data request questions on SCG/SDG&E, ORA never asked about the differences in Line 1600 segment data between the early response to ORA DR-06, Q12 and the later responses to ORA DR-19 and ORA DR-25, Q1, despite being aware of the discrepancies as set forth in ORA’s April 17, 2017 testimony. SCG/SDG&E regrets that ORA relied upon the earlier response rather than the later responses with the updated data.

44



(A.15-09-013)



____________________________________________________________________________

32

QUESTION 22: Please confirm that at no point in the response to ORA DR-19 Q7, prior to the April 2017 update, has SCG/SDG&E stated that the information contained therein was an update or revision to the response contained in ORA DR-06, Q12. RESPONSE 22:

Please see the response to Question 21 above.

45



(A.15-09-013)



____________________________________________________________________________

33

QUESTION 23: Please confirm that ORA DR-19, Q7 specifically asked for the differences between the response to ORA DR-06, Q12 and the 1968 SDG&E report provided in response to ORA DR-14, Q2, which asked:

a. Please provide a copy of the pressure log used to establish the Maximum Allowable Operating Pressure of Line 1600. b. What was the maximum in service pressure experienced by Line 1600 between 1965 and 1970?

RESPONSE 23:

ORA DR-19, Q7 states: “Please explain the discrepancies in pipeline records between SDG&E’s 1968 report on Line 1600 (provided in response to ORA DR-14 Q2) and the L1600 pipe segment data (provided in response to ORA DR-06 Q12).” ORA DR-14, Q2 states, in part: “a. Please provide a copy of the pressure log used to establish the Maximum Allowable Operating Pressure of Line 1600. b. What was the maximum in service pressure experienced by Line 1600 between 1965 and 1970?”

a. Please see response to ORA DR14 Q2. In addition, 49 CFR § 192.619(c) does not specify actual copies of written pressure records to be preserved.

b. Please see response to ORA DR14 Q2.

46



(A.15-09-013)



____________________________________________________________________________

35

QUESTION 25: Please confirm that the response to SED DR-3, Q2 was based on “the Maximum Allowable Operating Pressure (MAOP) validation process”. RESPONSE 25:

As stated in SoCalGas/SDG&E response to SED DR-3 Q2: “As part of the Maximum Allowable Operating Pressure (MAOP) validation process each segment was analyzed to determine the appropriate MAOP based on year of installation, pipe properties, class location, test records and historical operating pressures.”

47



(A.15-09-013)



____________________________________________________________________________

36

QUESTION 26: Regarding Line 1600, has SCG/SDG&E ever found errors in the data during the MAOP validation process? Please explain and indicate if the information was more conservative (i.e. the data SCG/SDG&E had been using resulted in lower MAOPs than the data discovered during the MAOP validation process) or was less conservative (i.e. the data SCG/SDG&E had been using resulted in higher operating pressure than the data discovered during the MAOP validation process). RESPONSE 26:

Applicants object that “ever found errors in the data during the MAOP validation process” is vague and ambiguous, and thus could be overbroad, unduly burdensome and beyond the scope of this proceeding. Assuming that ORA is asking about whether errors were introduced into Applicants’ High Pressure Database, Applicants respond as follows: No, until a reliable source document is found conservative numbers are used, which provide a margin of safety. Basing the analysis on conservative values sets the maximum allowable operating pressure (MAOP) as determined by Section 192.619(a)(1) at lower setting.

48



(A.15-09-013)



____________________________________________________________________________

37

QUESTION 27: If any of the data discovered in the MAOP validation process resulted in lowering the MAOP of Line 1600, please identify all such data, including the initial data that was used, and the updated data. Please be sure to include in spreadsheet format all necessary factors to identify this change, including: a. Engineering stations; b. Date of the discovery of the new data; c. All attributes needed to calculate design based MAOP under 49 CFR Section 192.105 that

changed due to discovery of the new data. Please be sure to itemize each attribute provided in response to question 27c.

RESPONSE 27: No data resulted in the change of the MAOP of Line 1600.

49



(A.15-09-013)



____________________________________________________________________________

38

QUESTION 28: Please confirm that the 1968 report to the Commission, provided in response to ORA DR-14, Q2, erroneously states that the 14” segments of Line 1600 under Lake Hodges had not been tested. RESPONSE 28: The 1968 report to the Commission provided reflected information available at the time. As part of the MAOP validation process, Applicants located the testing documents for the 14” section of pipeline.

50



(A.15-09-013)



____________________________________________________________________________

39

QUESTION 29: Are there any other errors of which SoCalGas/SDG&E is now aware of in the 1968 report to the Commission, provided in response to ORA DR-14, Q2? RESPONSE 29:

Applicants object that this Question is vague and ambiguous, and thus may be overbroad, unduly burdensome and beyond the scope of this proceeding. To the extent that the Question is limited to errors regarding Line 1600 wall thickness and yield strength, and without waiving their objections, Applicants respond as follows: No.

51