San Diego Gas & Electric Company s3

SAN DIEGO GAS & ELECTRIC COMPANY

SOUTHERN CALIFORNIA GAS COMPANY

APPLICATION TO Recover Costs Recorded in their Pipeline Safety and Reliability Memorandum AccountS

(A.14-12-016)

(DATA REQUEST ORA-PSMRA-SCG-02)

Date Received: January 23, 2015

Date Responded: February 13, 2015

______________________________________________________________________

QUESTION 1:

Please provide, on a continuous and real time basis, all data requests and data responses communicated between Applicants and other parties to this proceeding. If any data requests and/or data responses have already been issued, please provide those.

RESPONSE 1:

SoCalGas/SDG&E object to the “continuous and real time” qualification of this question on the grounds that it is unreasonably burdensome. Without waiving this objection, and subject thereto, SoCalGas/SDG&E respond as follows:

Data responses related to this proceeding will be posted on SoCalGas’ and SDG&E’s respective webpages:

http://socalgas.com/regulatory/A1412016.shtml

http://www.sdge.com/regulatory-filing/13186/application-sdge-and-socalgas-recover-costs-recorded-in-PSRMAs

QUESTION 2:

Please provide, on a continuous and real time basis, all data requests communicated to

Applicants by the Commission’s Energy Division (ED), and Safety and Enforcement

Division (SED). Please also provide on a continuous and real time basis, all data

responses provided by Applicants to ED and SED.

RESPONSE 2:

Data responses related to this proceeding will be posted on SoCalGas’ and SDG&E’s respective webpages:

http://socalgas.com/regulatory/A1412016.shtml

http://www.sdge.com/regulatory-filing/13186/application-sdge-and-socalgas-recover-costs-recorded-in-PSRMAs

QUESTION 3:

For this next set of questions, please refer to Commission Decision 14-06-007, p. 33,

where the Commission found that “SDG&E and SoCalGas has over 385 miles of pipeline which do not have documentation of strength test of at least 125% of Maximum

Allowable Operating Pressure.”

a. What percentage of SDG&E’s and SoCalGas’ transmission pipeline system was

researched in order to support the Commission’s finding?

b. At the time D.14-06-007 was issued, which natural gas transmission pipelines,

including segments, in SDG&E’s and SoCalGas’s systems, had not been checked

to determine whether there was documentation of strength test records of at least

125% of Maximum Allowable Operating Pressure (MAOP). Please provide a

spreadsheet with all such pipelines and segments.

c. As part of the list provided in response to question 3b, please add a column that

identifies all such pipelines and segments which have been checked for

documentation of strength tests of at least 125% of MAOP since D.14-06-007 was

issued. Please label this column “Pipelines Checked for Documentation of

Strength Tests of at Least 125% of MAOP since Issuance of D.14-06-007”.

d. Also as part of the list provided in response to question 3b, please add a column

that identifies which of the pipelines checked for documentation of strength tests

of at least 125% of MAOP were lacking such documentation. Please label this

column “Pipelines Checked for Documentation of Strength Tests of at Least 125%

of MAOP since Issuance of D.14-06-007, but Lacking Such Documentation”.

e. Also as part of the list provided in response to question 3b, please add a column

containing information that shows the date each of the pipelines were installed.

Please label this column “Pipeline Installation Date”.

f. Also as part of the list provided in response to question 3b, please add a column

that identifies whether each of the pipelines are part of Phase 1a, Phase 1b, or

Phase 2, as defined in D.14-06-007. Please label this column “Phase number as

defined by D.14-06-007”.

g. If there are other Phases besides Phase 1a, Phase 1b, or Phase 2 into which a

pipeline falls, please identify the phase in the column requested by question 3f.

Please label this column “Additional Phases”.

h. Also as part of the list provided in response to question 3b, please provide a

column that shows which pipelines been strength tested since the issuance of

D.14-06-007 to at least at 125% of MAOP, and contain documentation of those strength

tests. Please label this column “Strength Tests Performed Since the Issuance of

D.14-06-007”.

i. Also as part of the list provided in response to question 3b, please provide a

column that shows which pipelines have been replaced. Please label this column

“Pipeline Replacement”.

j. Also as part of the list provided in response to question 3b, please add a column

that identifies the mileage of each item on the list. Please label this column

“Pipeline Miles”.

k. Please provide the total miles of pipelines identified in response to question 3j.

l. Please provide a column that identifies the date of installation of each line

provided in the list that responds to question 3b. Please label this column

“Installation Date”.

m. Please provide the document in response to question 3 in native file format. For

example, if the document is prepared using Microsoft Excel, please provide the

document in Microsoft Excel format.

n. Please ensure that the document can be sorted by each of the characteristics in the

identified columns.

RESPONSE 3:

a. To address the National Transportation Safety Board’s safety recommendations and the Commission’s subsequent request as quickly as possible, SoCalGas and SDG&E implemented an expeditious process of records review and analysis. Through this process SoCalGas and SDG&E reviewed records for their entire transmission pipeline system in order to categorize pipelines for further action. As stated in the PSEP filing, transmission pipelines operated in Class 3 or 4 locations or High Consequence Areas were categorized into four categories, of which, over 385 miles were identified at that time as lacking documentation of a pressure test to at least 125% of Maximum Allowable Operating Pressure (MAOP).

b. At the time D.14-06-007 was issued, SoCalGas and SDG&E had completed their active review of transmission pipeline records to determine whether there was documentation of a strength test to at least 125% of MAOP. Accordingly, there is no list of pipelines or segments that have not been checked. That said, as part of the design and engineering phase of a PSEP pipeline project, or through routine pipeline assessment or other pipeline operations-related work, SoCalGas and SDG&E may occasionally identify pipelines or segments for further review and analysis, which may potentially result in a re-categorization of a particular pipeline or segment..

c.- g. Not applicable.

h. – n. Although a list of pipeline segments responsive to subparts b-g does not exist, SoCalGas and SDG&E provide the following list of replacements, hydrotests and abandonments, which have occurred since the inception of PSEP through 12/31/14.

QUESTION 4:

Please provide a list identifying all Phase 1 natural gas transmission lines installed in

SDG&E’s and SoCalGas’ system after Commission General Order 112 was made

effective, which lack documentation of strength tests of at least 125% of MAOP.

RESPONSE 4:

Attached please find a list of SDG&E and SoCalGas’ transmission pipelines that have portions installed after July 1, 1961 and lack documentation records demonstrating a test pressure of a least 125% of MAOP.

QUESTION 5:

Please provide the “Decision Tree” referenced in D.14-06-007, p. 16 as it existed at the

time D.14-06-007 was issued.

RESPONSE 5:

The Decision Tree referenced in D.14-06-007, p.16 as it existed at the time D.14-06-007 was issued is provided in A.14-12-016. See the Prepared Direct Testimony of Hugo Mejia (Chapter II, p.3).

QUESTION 6:

Please provide the Decision Tree referenced in D.14-06-007 as it exists today.

RESPONSE 6:

The Decision Tree referenced in D.14-06-007 as it exists today is provided in A.14-12-016. See the Prepared Direct Testimony of Hugo Mejia (Chapter II, p.3).

QUESTION 7:

Please provide each version of the Decision Tree referenced in D.14-06-007 issued

between D.14-06-007 and today.

RESPONSE 7:

There have been no revisions to the Decision Tree referenced in D.14-06-007 between the time D.14-06-007 was issued and today.

QUESTION 8:

Please briefly explain the rationale behind each of the changes to the Decision Tree since it was issued in D.14-06-007.

RESPONSE 8:

Not applicable.

QUESTION 9:

For this next set of questions, please reference D.14-06-007, p. 14. There, the Decision

discusses a “more complicated table that reconciled all the natural gas pipeline system into various classifications of risk, factors, age, documentation, etc., referred to as a

“Reconciliation”.

a. Please provide the version of this table as it existed at the time D.14-06-007 was

issued.

b. Please provide the version of this table as it exists today.

c. On today’s version of the table, please highlight the changes made when compared

to the version in existence at the time D.14-06-007 was issued.

RESPONSE 9:

a. Per conversation between Shirley Amrany and Nathaniel Skinner on January 29, 2015, attached please find two versions of the aforementioned “Reconciliation”, 1) Exhibit 34R, dated August 29, 2012, submitted into evidence on August 30, 2012 (pdf-only version), and 2) an updated version of the Reconciliation dated May 23, 2013. Please note the version of the Reconciliation included in D.14-06-007 as Attachment II was Exhibit 34 (non-revised).

b. Please see attached which reflects the version of the table as of January 2015.

c. Please see the requested highlights on the January 2015 version included in the response to 9.b. above.