Company defends SSI spending and risk-ranking; PHMSA-driven MAOP and leak-prone materials shape near-term projects
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Summary
Witnesses told the commission SSI (system safety and integrity) projects account for the majority of planned GIP spending and described risk-ranking methodology, the role of subject-matter judgment, and PHMSA-driven MAOP and advisory-bulletin work (including removals of brittle plastics and legacy materials).
What parties aired: Conservation advocates, Denver and staff pressed the company on the extent to which alternatives to pipe renewal (nonpipeline alternatives) were considered and on the transparency of the company's risk-ranking process. Intervenors cited PHMSA data showing excavation damage and external forces as a major source of incidents and asked whether the company's project prioritization sufficiently accounts for those threats.
Company response: Ray Gardner, area vice president of gas engineering, said SSI projects constitute the bulk of the GIP planned-project nominal dollars and explained the company's approach: risk scoring identifies higher-risk segments and is supplemented by subject-matter-expert (SME) judgment to scope work. Gardner noted that risk models differ by asset and threat and that a single cross-category model is not feasible because different asset types (mains, services, compressor stations) and materials require distinct methods.
PHMSA and MAOP: Witnesses emphasized that new PHMSA rules and advisory bulletins (including MAOP reconfirmation requirements, brittle-plastic guidance and geohazard advisories) are driving near-term SSI work. The company said many projects respond directly to federal pipeline-safety obligations and that while routine work is ongoing at high volume (thousands of service renewals annually), larger planned SSI projects are scoped and executed with a 1'1-year runway.
Alternatives and NPAs: Witnesses agreed NPAs can be feasible for some narrow, well-scoped projects with few customers and high achievable potential; but Gardner said many SSI projects (including those addressing MAOP or system integrity) have constraints (number of customers, risk equivalence, cost-effectiveness) that limit NPA applicability. He added that appendix materials in the GIP (e.g., lists of pipe segments) reflect segments rather than fully scoped projects and therefore do not themselves establish NPA feasibility.
Next steps: Parties and the commission will consider whether the evidence in the record supports additional MAOP- or PHMSA-driven changes to the GIP and whether more formal alternatives analyses should be required for informational-period or planned SSI projects.
