HomeMy WebLinkAbout20130628IGC to Staff 1-6.pdfREQUEST NO. 1: The Company’s Application for authority to sell liquid natural gas (“LNG”) says: “[t}he
peak day plan from the IRP and other on‐going forecasts are used to determine the amount of Nampa
LNG needed for core market peak day withdrawals for each heating season. Under this request, the
remaining tank capacity after core market needs, less a 50% reserve margin, would be made available
for non‐utility sales.” See Case No. INT‐G‐13‐02, Application p.4. Given the core market peak day
withdrawals forecasted in this Integrated Resource Plan (“IRP”), please provide the LNG capacity
available to meet core market needs and non‐utility sales. As part of your response, please explain
whether Large Volume Service (“LV‐1”) customers are included as core market customers when
determining the LNG capacity available for non‐utility sales.
RESPONSE to REQUEST NO. 1: Nampa LNG withdrawals are considered to be at the top of the supply
stack and therefore the inventory at Nampa is held in reserve until all other resources are exhausted.
The Base Case model run indicates that Nampa withdrawals are not forecast to be required through
2017 as existing Plymouth LNG inventory is available. From a minimum operating standpoint,
Intermountain intends to have at least 1.3 million therms in the Nampa facility on October 1st of each
year which, when considering boil‐off and the minimum inventory level, would have the potential to
provide at least 500,000 therms for withdrawal in any given year. However, the Company is now
preparing to serve non‐utility LNG customers and intends to liquefy all such volumes in advance and so
will, in all likelihood, have significantly more than 1.3 million therms in the tank on October 1 of each
year. Since Intermountain committed in its LNG filing (Case No. INT‐G‐13‐02) to make any LNG in the
Nampa facility, even if intended for non‐utility markets, available for utility peak day withdrawal; it is
very likely that much more than 500,000 therms would be available for utility withdrawals in any given
year. The specific amount however is impossible to quantify at this point.
For modeling purposes, LV‐1 tariff customer sales are considered as “core market” purchases.
Name, job title and telephone number of person who prepared the response: R. David Swenson,
Manager – Industrial Services ph. 377‐6118
Name, job title and telephone number of record holder: Michael P. McGrath, Director of Regulatory
Affairs ph. 377‐6168
REQUEST NO. 2: Please provide a back cast analysis comparing the actual number of LV‐l customers and
their usages to what has been forecasted in the last two IRPs. Similar to the LV‐l comparison, please
provide a similar comparison by schedule for all other industrial customers.
RESPONSE to REQUEST NO. 2: Attached hereto is a copy of the requested comparison and the Company
has included with that comparison all industrial customer counts and volumes in addition to LV‐1. The
worksheet only depicts a comparison to the 2010 IRP and the follow‐on IRP information is forthcoming.
Name, job title and telephone number of person who prepared the response: R. David Swenson,
Manager – Industrial Services ph. 377‐6118
Name, job title and telephone number of record holder: Michael P. McGrath, Director of Regulatory
Affairs ph. 377‐6168
REQUEST NO. 3: Page 72 defines lost and unaccounted for (“LAUF”) gas as “the difference between
volumes of natural gas delivered to Intermountain’s distribution system and volumes of natural gas
billed to Intermountain’s customers.” Please explain how the Company adjusts its LAUF gas calculations
for known leaks and line breaks that may occur between the city gate and customers meters.
RESPONSE to REQUEST NO. 3: Intermountain completes a Gas Loss Report for each line break which
includes an estimate of total natural gas “lost” during the break. If a beginning point can be determined
for a line leak, a Gas Loss Report would also be prepared. These reports are totaled at the end of the
year and the grand total for the year is then subtracted from the annual LAUF.
Name, job title and telephone number of person who prepared the response: Tyler Muzzana, Engineer
ph. 377‐6044
Name, job title and telephone number of record holder: Michael P. McGrath, Director of Regulatory
Affairs ph. 377‐6168
REQUEST NO. 4: Several local distribution companies have recently established protocols to
systematically remove and replace select portions of DuPont Aldyl A medium density polyethylene pipe.
Does the Company have this type of pipe on its distribution system? If so, does the Company have a
replacement plan? If so, please provide the replacement plan.
RESPONSE to REQUEST NO. 4: Per the Distribution Integrity Management Program (DIMP), regulatory
requirements which became effective in 2011 (192 Subpart P), IGC is required to analyze risk of failure
on our system and perform actions to help mitigate or reduce those risks. IGC has developed a GIS
based risk model which utilizes input from Subject Matter Experts, leak history and maintenance history
to help identify and prioritize risks on our system. It is known in the industry that Aldyl‐A pipe
manufactured prior to 1984 is susceptible to cracking under certain circumstances with pre 1973 Aldyl‐A
being the most susceptible. This industry knowledge, coupled with the results of the risk model and
regulatory requirements, has caused IGC to be more proactive at replacing certain Aldyl‐A pipe within
our system. In order to be efficient in what we are replacing, we utilize the DIMP risk model and district
knowledge to prioritize replacement during each year.
Name, job title and telephone number of person who prepared the response: Tyler Muzzana, Engineer
ph. 377‐6044
Name, job title and telephone number of record holder: Michael P. McGrath, Director of Regulatory
Affairs ph. 377‐6168
REQUEST NO.5: In Order No. 32139, the Commission stated the Company “should provide appropriate
notice to city and county leaders as part of the IRP process.” Please provide a list of city and county
leaders the Company notified of the IRP process. As part of your response, please provide the number of
attendees at each IRP workshop, and any notable feedback the Company may have received from city
and county leaders regarding the IRP process.
RESPONSE to REQUEST NO. 5: Attached hereto is a list of invitees to both the Boise and Idaho Falls IRP
Public Meetings. You will note those invitees include Mayors, Councilman and various city leaders. Also
attached is a copy of the “sign‐in sheet” for each of those meetings which would indicate 20 people
were in attendance at the Boise Public Meeting along with 26 people at the Idaho Falls Meeting.
During the IRP public vetting process, a representative from the City of Rexburg became concerned that
Intermountain Gas’ IRP planning process did not adequately account for the long‐term growth
anticipated in the Rexburg area. It was explained that the IRP’s five‐year planning horizon, to include
updated growth projections, was revised every other year and that currently there is more than
adequate natural gas delivery capacity for the Rexburg area.
Name, job title and telephone number of person who prepared the response: Lori Blattner, Regulatory
Analyst e‐mail Lori.Blattner@intgas.com
Name, job title and telephone number of record holder: Michael P. McGrath, Director of Regulatory
Affairs ph. 377‐6168
REQUEST NO.6: In Order No. 32139, the Commission stated “Intermountain should carefully consider all
DSM programs that are available to encourage customers to use natural gas efficiently, and Company
review of programs must be included in its IRPs. Its IRPs in the future must reflect that it has evaluated
DSM programs for all customer groups.” Please provide all cost‐effectiveness tests the Company used in
order to evaluate its current and potential demand‐side management (“DSM”) programs.
RESPONSE to REQUEST NO. 6: Intermountain used the Total Resource Cost test along with the Utility
Cost Test when evaluating DSM options. Attached to this Response is the Excel file “IGC 2012 IRP DSM
Scenarios” which outlines those programs evaluated under these tests.
Name, job title and telephone number of person who prepared the response: Lori Blattner, Regulatory
Analyst e‐mail Lori.Blattner@intgas.com
Name, job title and telephone number of record holder: Michael P. McGrath, Director of Regulatory
Affairs ph. 377‐6168