reputable industry studies, new pipelines also pose risks. The hook cracks are resident anomalies of the manufacturing process of electric flash welded longitudinal seams utilized by a single pipe manufacturer A.O. Smith. These stable manufacturing defects do not present an immediate threat unless they interact with other known risks such as corrosion or other integrity threats. Therefore, it is impractical to predict the remaining life of an old buried pipeline or rely on arbitrary time horizons (e.g., 50 years or 20 years) without knowing the actual threats from an integrity assessment and calculate the life based on the extent of threats and other factors. Even with additional information, engineering estimates should not be exclusively relied on to make professional judgments. For example, thirdparty excavations and earth movements are serious time independent threats that are very difficult to predict. In the original application, Applicants stated that hydrotesting was not practical or feasible. Later in the proceeding, they state that it is possible but costly at approximately $million, with a portion of testing to occur in high consequences areas. The results of pressure testing is one major factor to consider when ascertaining how long Line 1600 should remain in service. Therefore, as discussed in the following Section, Applicants must submit a hydrostatic pressure test or replacement plan consistent with Pub. Util. Code § 958. However, as stated earlier, it is impractical to predict the duration of fitness for safe operation solely from pressure test data and pressure testing will never remove or cure the known stable hook crack defects on Line 1600.
reputable industry studies, new pipelines also pose risks. The hook cracks are resident anomalies of the manufacturing process of electric flash welded longitudinal seams utilized by a single pipe manufacturer A.O. Smith. These stable manufacturing defects do not present an immediate threat unless they interact with other known risks such as corrosion or other integrity threats. Therefore, it is impractical to predict the remaining life of an old buried pipeline or rely on arbitrary time horizons (e.g., 50 years or 20 years) without knowing the actual threats from an integrity assessment and calculate the life based on the extent of threats and other factors. Even with additional information, engineering estimates should not be exclusively relied on to make professional judgments. For example, thirdparty excavations and earth movements are serious time independent threats that are very difficult to predict. In the original application, Applicants stated that hydrotesting was not practical or feasible. Later in the proceeding, they state that it is possible but costly at approximately $million, with a portion of testing to occur in high consequences areas. The results of pressure testing is one major factor to consider when ascertaining how long Line 1600 should remain in service. Therefore, as discussed in the following Section, Applicants must submit a hydrostatic pressure test or replacement plan consistent with Pub. Util. Code § 958. However, as stated earlier, it is impractical to predict the duration of fitness for safe operation solely from pressure test data and pressure testing will never remove or cure the known stable hook crack defects on Line 1600.
216389464.docx