1111111111 111111111 Control N mber: 48095 111111111 ill 1 1 1 Item Number: 91 Addendum StartPage: 0 SOAH DOCKET NO. 473-18-2800 ..s, PUC DOCKET NO. 48095 23!C 1 APPLICATION OF ONCOR ELECTRIC -BEFORE THE,, DELIVERY COMPANY LLC TO AMEND A CERTIFICATE OF CONVENIENCE AND NECESSITY FOR STATE OFFICE OF A 345-KV TRANSMISSION LINE IN CRANE, ECTOR, LOVING, REEVES, WARD, AND WINKLER COUNTIES ADMINISTRATIVE HEARINGS (ODESSA EHV — RIVERTON AND MOSS — RIVERTON CCN) DIRECT TESTIMONY OF ANDREW G. HEVLE ON BEHALF OF KINDER MORGAN TABLE OF CONTENTS I. POSITION AND QUALIFICATIONS 2 II. PURPOSE OF TESTIMONY .4 III. POTENTIAL IMPACT OF CROSSING OR PARALLELING ELECTRIC TRANSMISSION LINES AND NATURAL GAS, OIL, OR CO2 STEEL PIPELINES .8 IV. THE RISKS ASSOCIATED WITH ROUTING ELECTRICAL TRANSMISSION LINES NEAR STEEL PIPELINES ARE WELL-ESTABLISHED .14 V. MITIGATING RISKS TO PIPELINE INTEGRITY IS REQUIRED BY STATE AND FEDERAL LAW 18 VI. REQUESTED RELIEF 19 VII. CONCLUSION .25 LIST OF EXHIBITS EXHIBIT A L- O&M 903 EXHIBIT B INGAA "Criteria for Pipelines Co-Existing with Electric Power Lines" EXHIBIT C NACE SP0177-2014 EXHIBIT D NACE International Publication 35110 EXHIBIT E NACE International Standard SP0169-2013 EXHIBIT F Roger Floyd, "Testing and Mitigation of AC Corrosion on 8" Line: A Field Study" at 6-7 (NACE Corrosion 2004, Paper No. 04210, 2004) Page 1 000001 EXHIBIT G M. Yunovich, N.G. Thompson, "AC Corrosion: Corrosion Rate and Mitigation Requirements" at 5 (NACE Corrosion 2004, Paper No. 04206, 2004) EXHIBIT H R.A. Gummow, G.R. Wakelin and S.M. Segall, "AC Corrosion — A New Challenge to Pipeline Integrity" at 4-6 (NACE Corrosion 98, Paper NO. 566, 1998) EXHIBIT I Shane Finneran & Barry Krebs, "Advances in HVAC Transmission Industry and Its Effects on Pipeline Induced AC Corrosion" at 4-6 (NACE Corrosion 2014, Paper No. 4421, 2014) EXHIBIT J CorrPD-011 Requirements for Overhead Power Lines in the Vicinity of Kinder Morgan Pipelines, attached hereto as Exhibit J TO THE EXTENT ANY EXHIBITS INCLUDED IN THIS TESTIMONY ARE SUBJECT TO COPYRIGHT THOSE EXHIBITS SHOULD ONLY BE USED IN REVIEW OF THIS TESTIMONY AND MAY NOT BE USED FOR COMMERCIAL PURPOSES Page 2 000002 1 DIRECT TESTIMONY OF ANDREW G. HEVLE 2 I. POSITION AND QUALIFICATIONS 3 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS 4 A. Andrew G. Hevle. My business address is 1001 Louisiana St # 1000, Houston, 5 TX 77002. 6 Q. ON WHOSE BEHALF ARE YOU TESTIFYING IN THIS PROCEEDING? 7 A. I am testifying on behalf of Kinder Morgan Wink Pipeline LLC, Kinder Morgan 8 CO2 Company, L.P., Natural Gas Pipeline Company of America, LLC, and El Paso 9 Natural Gas Company, LLC (collectively "Kinder Morgan" or the "Company"). 10 Q. HAVE YOU PREVIOUSLY TESTIFIED BEFORE THE PUBLIC UTILITY 1 1 COMMISSION OF TEXAS ("COMMISSION")? 12 A. No. 13 Q. PLEASE OUTLINE YOUR EDUCATIONAL AND PROFESSIONAL 1 4 QUALIFICATIONS. 15 A. I received a Bachelor of Science in Mechanical Engineering from Louisiana Tech 16 University, and am certified by NACE International as a Corrosion Specialist, Certified 17 Coating Inspector, Cathodic Protection Specialist (CP4), Pipeline Integrity Management 18 Specialist and Senior Internal Corrosion Technologist. 19 Q. ARE YOU A MEMBER OF ANY PROFESSIONAL ORGANIZATIONS? 20 A. I am a member of NACE International, American Society of Mechanical 21 Engineers (ASME), the Society for Protective Coatings (SPCC), American Petroleum 22 Institute (API), Southern Gas Association (SGA) and Kinder Morgan's voting 23 representative on the Corrosion Committee of Pipeline Research Council International Page 3 000003 1 (PRCI). I have successfully completed the Fundamentals of Engineering (FE) 2 Examination by the National Council of Examiners for Engineering and Surveying 3 (NCEES) and am certified as an EIT. 4 Q. PLEASE DESCRIBE YOUR QUALIFICATIONS RELATED TO 5 ASSESSING THE IMPACT OF ALTERNATING-CURRENT ("AC") 6 INTERFERENCE ON NATURAL GAS, OIL, AND CO2 STEEL PIPELINES. 7 A. I am Manager of Corrosion Control for Kinder Morgan's Natural gas pipeline 8 group, responsible for the business unit's corrosion control program. I presently serve as 9 most recent past Chairman of the NACE Technical Coordination Committee (TCC), 10 which oversees all NACE International technical activities. I am a member of the task 11 group (TG 025) that developed the NACE International standard SP0177 "Alternating 12 Current (AC) Power Systems, Adjacent: Corrosion Control and Related Safety 13 Procedures," and a member of the committee that developed INGAA Foundation's report 14 "Criteria for Pipelines Co-Existing with Electric Power Lines" and a member of the 15 voting body for the task group (TG 430) draft standard "AC Corrosion on Cathodically 16 Protected Pipelines: Risk Assessment, Mitigation, and Monitorine. I have published 17 articles and made numerous presentations on the topic of corrosion control. 18 Q. WERE YOUR TESTIMONY AND EXHIBITS PREPARED BY YOU OR 19 BY SOMEONE UNDER YOUR DIRECT SUPERVISION? 20 A. Yes. 21 Page 4 000004 1 II. PURPOSE OF TESTIMONY 2 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY? 3 A. Kinder Morgan owns an extensive network of natural gas, oil, and CO2 steel 4 pipelines in the study area that could be impacted by one or more of the routes proposed 5 by Oncor Electric Delivery Company LLC ("Oncor") in this proceeding. My testimony 6 explains that routing Oncor's proposed 345-kV electric transmission line in a manner that 7 crosses or parallels within 1,000 feet of Kinder Morgan's existing pipeline facilities could 8 cause AC interference on those facilities, which increases the risk of shock potential and 9 accelerated corrosion that can threaten pipeline integrity and create a public safety 10 hazard. I also explain The Company's obligations under state and federal law to protect 11 public safety and pipeline integrity, and I describe the measures that may need to be taken 12 to meet that obligation by mitigating any risks to the Company's steel pipelines caused by 13 Oncoes proposed facilities. I also address the potential mitigation costs associated with 14 each proposed route. Finally, I recommend that the Commission include in a Final Order 15 similar language to that which Commission has approved in prior CCN proceedings. 16 Specifically I recommend that the Commission include the following ordering 17 paragraph:1 18 Oncor must conduct surveys to identify pipelines that could be affected by 19 the proposed transmission line, and coordinate with pipeline owners in 20 modeling, and analyzing potential hazards prior to energizing the power 21 lines because of AC interference affecting pipelines being paralleled or 22 crossed. 1 Docket No. 43878, Final Order at Ordering Paragraph No. 13 ( Mar. 30, 2016); Docket No. 42583, Final Order at FoF 110 & Ordering Paragraph No. 10 (May 27, 2015); Docket No. 42087, Final Order at Ordering Paragraph No. 10 (Dec. 19, 2014). Page 5 000005 1 Kinder Morgan requests the addition of "prior to energizing the power line" as a small 2 deviation from language the Commission has previously approved in order to ensure that, 3 once energized, the electric transmission facilities do not pose the risks discussed in more 4 depth below. 1 also recommend that the Commission include the following ordering 5 paragraph: 6 Once any such hazards caused by AC interference are identified, Oncor 7 shall work with the impacted pipeline(s) to ensure that at any points at 8 which the transmission facilities parallel or cross the pipeline(s) the 9 transmission facilities will be sited and constructed so as to minimize the 10 amount of AC interference mitigation measures required to be 11 implemented by the pipeline(s) to ensure the safest conditions and to 12 minimize the cost of mitigation rneasures. 13 Because it has yet to be determined how the line will ultimately be constructed, it is not 14 certain what effects the line with have on Kinder Morgan's pipelines or the costs of 15 mitigating those effects. This language would provide Oncor and Kinder Morgan 16 flexibility in how to address the safety concerns created by AC Interference going 17 forward. This language would also provide Kinder Morgan, Oncor, affected landowners, 18 and Oncor's customers more clarity regarding how safety concerns created by AC 19 Interference will be addressed in the future. 20 Q. IS KINDER MORGAN REQUESTING THAT THE COMMISSION 21 ORDER ONCOR TO CONDUCT MITIGATION ACTIVITIES OR TO 22 REIMBURSE THE COMPANY FOR ITS MITIGATION COSTS RELATED TO 23 THE ELECTRIC TRANSMISSION LINE APPROVED IN THIS PROCEEDING? Page 6 000006 1 A. No. Kinder Morgan only requests that the Commission recognize, as it has in 2 previous cases, that there are AC interference risks associated with routing electric 3 transmission lines near existing steel pipelines resulting from Oncor's proposal to locate 4 the facilities near pipelines, and that these risks will have to be mitigated through some 5 coordination between Kinder Morgan and Oncor.2 Kinder Morgan has intervened in this 6 proceeding in order to present evidence on the potential mitigation needs that would 7 result from Oncor's proposed routes and so that it can present evidence with respect to 8 the safest manner by which Oncor's proposed routes should cross or parallel Kinder 9 Morgan's pipelines, and, finally, so that the Commission may consider these issues when 10 it determines which of the proposed routes best meets the Commission's routing criteria. 11 Q. PLEASE DESCRIBE KINDER MORGAN'S PIPELINE OPERATIONS 12 WITHIN THE STUDY AREA. 13 Kinder Morgan is one of the largest energy infrastructure companies in North America. 14 The pipelines that have intervened in this proceeding include Kinder Morgan Wink 15 Pipeline LLC, Kinder Morgan CO2 Company, L.P., El Paso Natural Gas Company, LLC 16 and Natural Gas Pipeline Company of America, LLC.