20130822Staff 6-12 to INTG.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR
AUTHORITY TO CHANGE ITS PRICES
(2013 PURCHASED GAS COST ADJUSTMENT)
i
CASE NO.INT.G-13-05
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
:! r..'i'j
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl T. Klein, Deputy Attorney General, requests that Intermountain Gas Company (Company)
provide the following documents and information as soon as possible, but no later than
MONDAY, SEPTEMBER 9, 2013.1
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
' Staffis asking for an expedited response, and understands that the Company can produce the requested information
by September 9,2013. If the expedited deadline is problematic, please call Staff s attorney at [phone].
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 1 AUGUST 22,2013
the person preparing the documents. Please identiff the name, job title, location and telephone
number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 6: Please provide the percentage of estimated annual load comprised of
index purchases, fixed-price hedges for a term ofone year or less, and fixed-price hedges from
previous multi-year contracts. In your response, please include the estimated or actual weighted
average prices for each type of procurement contract.
REQUEST NO. 7: Please provide the Gas Loss Reports from each line break that
occurred during this PGA year. As part of your response, please explain how the reports are
used to estimate the quantity of lost gas from each line break.
REQUEST NO. 8: Workpaper No. 8 shows annual statistics on lost and unaccounted
for gas. Using the same format, please provide the following information:
a) the number of meter audits associated with drive rate errors and pressure errors;
b) gas loss due to customers having the incorrect meter size installed;
c) gas loss from measurement errors related to translating metered consumption to billed
consumption; and
d) gas loss from measurement differences between Intermountain's distribution system
meters and Northwest Pipeline's meters.
REQUEST NO. 9: 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. Please provide the quantity of lost gas likely due to defects in the pre 1984
Aldyl-A pipe.
REQUEST NO. 10: On page 3 of Confidential Workpaper No. 10, please explain why
the cost of gas managed by the first referenced gas marketer is consistently more per dekatherm
than the gas managed by the second referenced gas marketer. If the difference is because the two
SECOND PRODUCTION REQUEST
TO INTERMOI.INTAIN GAS AUGUST 22,2013
companies manage different types of contracts, please explain why customers benefit from
having one company manage the fixed or locked-in prices (physical and option pricing
mechanisms), and another manage the first-of-the-month index prices.
REQUEST NO. 11: Please explain how the Company estimated the costs of its index
purchases.
REQUEST NO. 12: For this PGA year, please provide a schedule of the Company's
expenses at its Nampa LNG facility. As part of the response, please explain how the funds
collected from the sale of LNG were used in accordance with Order No. 32793 (i.e. - Operations
and Maintenance of the LNG facility, or LNG facility capital improvements).
DATED at Boise, Idaho, tnis Z\/aay of August 2013.
fu-ut -Karl T. Klein
Deputy Attorney General
Technical Staff: Matt Elam/ 6-12
i :umisc:prodreq/intg I 3.5kkme prod req2
SECOND PRODUCTION REQUEST
TO INTERMOLINTAIN GAS AUGUST 22,2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22*, DAY OF AUGUST 2013,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFT' TO INTERMOUNTAIN GAS COMPANY, IN CASE NO.
INT-G-I3-05, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MICHAEL P McGRATH
DIR _ REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE TD 83707
EMAIL: [e-mail]
MORGAN W RICHARDS JR
zuCHARDS LAW OFFICE
PO BOX 2076
BOISE ID 83701
E-MAIL : [e-mail]
SECRETARY
CERTIFICATE OF SERVICE