provided by actual historical and forecasted demands based on actual numbers and/or other factors: Tenyear forecasted (maximum daily and annual daily average daily) volumes in the area to be served by the proposed Line; including information of the quality of gas and broken down by customer type (e.g. core, noncore commercial and industrial, and noncore electric generation; Tenyear historic monthly volumes through Line 1600; and Tenyear historic daily and annual maximum volumes through Line 1600. The Applicants state that “While SDG&E does not measure throughput by individual pipelines for the majority of pipelines on its system, as of May, 2011, it does have metered deliveries into Line 1600 at the custody transfer point with SoCalGas located at the Rainbow Metering Station.” (SDG&E/SoCalGas Opening Brief at 120 citing Exh. SDGE12 (Supplemental Testimony at 161:711).) SDG&E claims that it has provided sufficient basic information by providing Exh. SDGE12, Attachment D. They further state that the “Utilities are not aware of any Commission requirement to meter individual pipelines in their gas system at all.” (SDG&E/SoCalGas Opening Brief at 120.) ORA claims that the Applicant has misinterpreted the instructions in the Scoping Memo. The Applicants “claim to interpret the phrase ‘through Line 1600’ as meaning into and through some portion of Line 1600; and that any other interpretation would be inconsistent with how a gas system operates.” (ORA Reply Brief at 13.) ORA suggests that this information is needed to demonstrate what volumes would need to be replaced by Line 3602 if Line 1600 is derated as they propose. “Along Line 1600, SoCalGas/SDG&E measure volumes at Rainbow Metering Station, but not at points where other transmission lines
In response to the Applicants’ claims, SCGC, Sierra Club, TURN, and POC all cite the low probability of an unplanned outage on Line 3010. According to SCGC: There has only been one unplanned outage lasting one day on Line 3010 during its entire 57 year operating history, and there was no loss of service to customers. Of course, planned outages for maintenance purposes may occur, but there have only been twenty planned outages in the 57 year operating history of Line 310. The planned outages lasted between half a day and three days with seventy percent of the outages lasting one day, again with no loss of service to customers. (SCGC Opening Brief at 47.) SCGC observes, “The frequency factor for Moreno outages is even smaller than for Line 3010.” (SCGC Opening Brief at 4748.) It notes that occasionally an individual compressor engine can fail at Moreno and that the Applicants have recorded nineteen individual engine failures between 2006 and 2015. However, the duration of the outages have been short and has not impacted the overall throughput at Moreno. SCGC challenges the Applicants’ claims that Line 3010 outages impact the system at large. “The Applicants erroneously assume that the SDG&E system is completely dependent on deliveries from Rainbow.” (SCGC Opening Brief at 48.) It challenges the Applicants’ claim that “currently 3.2 million people are essentially dependent on a single pipeline” for transmission service. SCGC subscribes to a broader perspective that SDG&E is interconnected at Otay Mesa with TGN which can receive gas either as delivered from Energia Costa Azul or gas that is delivered from Ehrenberg through North Baja and Gasoducto Rosarito. “Moreover, there are options for reinforcing the SDG&E electrical systems for insuring against shedding of electric load in the event of the highly
Capacity to handle an audit of the proposed scope in the allotted time; and Independence from SDG&E and SoCalGas. Applicants shall enter into a contract with the winning bidder at their expense. Applicants shall file a Tier 1 Advice Letter with the executed contract and audit budget to the Commission’s Energy Division no later than five business days after the contract is executed. SoCalGas and SDG&E shall serve as fiscal managers of the contract with the auditor. SED staff shall have complete responsibility for overseeing the audit, and shall consult with the Commission’s Utility Audit Finance and Compliance Branch as necessary to fulfill their responsibility. SED staff shall give direction to the auditor on an as-needed basis and determine the role of participants with respect to review of the draft findings of the auditor and review of the auditor’s final report before it is filed with the Commission. Based on feedback from parties and SED, the independent auditor shall perform the following tasks including but not limited to: (ORA Opening Brief at 6-8 references some of these items.) Review and verify all relevant pipeline attribute data, bellhole examination, maps, purchase orders, construction data and etc. using 49 CFR, Part 192 regulation requirements as a validation criteria; Review and verify attribute data such as, pipe manufacturer, installation date, pipe specification, pipe class, diameter, longitudinal seam type, yield strength, wall thickness, pressure tested, pressure test medium, pressure test date, etc., for each pipeline segment identified by engineering stations; Calculate hoop stress in terms of % SMYS for each existing segment identified by engineering stations and compare it to the