20180125Staff 1-34 to INT.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10T77
RECEIVED
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY T'OR
AUTHORITY TO IMPLEMENT AN
INFRASTRUCTURE INTEGRITY
MANAGEMENT MECHANISM
CASE NO. INT.G-I7-07
T.IRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Camille Christen, Deputy Attorney General, request that Intermountain Gas Company
(lntermountain Gas; Company) provide the following documents and information as soon as
possible, or by THURSDAY, FEBRUARY 15,2018.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3l .01 .01 .228.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS
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1 JANUARY 25,2018
Attorneys for the Commission Staff
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide the Company's operating plans and capital budgets, by
year, for 2015 through2022. Please break each out by category (services, mains, etc.) and specific
project where possible. Please indicate which projects the Company would likely include in the
Infrastructure Integrity Management Mechanism (IIMM) if it is approved.
REQUEST NO. 2: Please provide a similar schedule as above with actual expenditures for
the last five years.
REQUEST NO.3: Please provide a system map identifying all pipe type, specifically
highlighting Aldyl-A pipe.
REQUEST NO. 4: Please provide a schedule showing a breakdown of Aldyl-A pipe on the
Company's system, including miles, original cost, size, and estimated replacement cost by each
vintage year.
REQUEST NO. 5: Please provide back-up documentation for the Company's estimation
that it would cost "... approximately $158.4 million to replace all of this Aldyl-A pipe."
Application, p. 5.
REQUEST NO. 6: The Company has stated on page 5 of its Application that it has hired
additional employees to help the Company comply with laws and help the Company enforce and
inform others of Idaho's damage prevention law. Please provide a listing showing the number of
employees by classification that Company has hired, date of hire, the cost associated with those
employees, and indicate if the costs were included in the last rate case.
FIRST PRODUCTION REQUEST
TO INTERMOLTNTAIN GAS 2 JANUARY 25,2018
REQUEST NO. 7: Please provide a copy of, and explanation of, the process the Company
uses for the creation and approval of capital budgets. Please include a description of the process
and the criteria used to establish project priority.
REQUEST NO. 8: Please provide all meeting notes, agendas, etc. related to developing
and approving the Company's previous three capital budgets.
REQUEST NO. 9: Please identify the sources of capital and the cost for each used to fund
the Company's capital budgets for the last five years.
REQUEST NO. 10: For all of the Company's High Pressure Service Sets (HPSS) cunently
in service, please provide: the installation date, location, last time each HPSS was serviced, who
performed the service, and the last time each HPSS was inspected and by whom the HPSS was
inspected.
REQUEST NO. 11: What is the total number of HPSS that is served by the transmission
system?
REQUEST NO. 12: What is the total number of HPSS that are served by the distribution
system?
REQUEST NO. 13: What is the total number of HPSS located within 250 yards radius of a
regulator station?
REQUEST NO. 14: What is the total number of HPSS located within a ll4 mile radius of a
regulator station?
REQUEST NO. 15: What is the total number of HPSS located within a l12 mile radius of a
regulator station?
FIRST PRODUCTION REQUEST
TO INTERMOLTNTAIN GAS J JANUARY 25,2018
REQUEST NO. 16: What is the total number of HPSS located within a mile radius of a
regulator station?
REQUEST NO. 17: Please describe in terms of material, number of miles, size, and age
each type of pipe in the Company's system that will require replacement within the next five years
Include why it needs replacing, when it needs to be replaced, and at what cost.
REQUEST NO. 18: Please describe all other infrastructure in the system that currently or
will require replacement within the next five years. Include why it needs replacing, when it needs
to be replaced, and at what cost.
REQUEST NO. 19: Please describe any investments the Company has made over the last
five years to reduce and minimize replacement costs.
REQUEST NO.20: Please demonstrate how Operating and Maintenance (O&M) costs
will change based on each type of project listed in Exhibit No. 2, page L
REQUEST NO. 21: Please describe the per-unit financial impacts (costs and benefits) of
removing an HPSS.
REQUEST NO. 22: Application at 4 - The Company states that it is faced with additional
federal, state, and local requirements. Please describe the additional requirements imposed and
when they became effective. Additionally, describe all potential regulatory requirements the
Company is expecting over the next five years and the projected cost to satisfy each requirement.
REQUEST NO. 23: Application at 4 - The Company states that it would like to accelerate
replacement projects ahead of the timelines calculated by its Transmission and Distribution
Integrity Management Program models and that budgetary constraints often only allow the
Company to maintain a more modest replacement schedule.
(a) Please explain how accelerating pipeline and infrastructure replacements benefits
customers and the Company.
4 JANUARY 25,2018
FIRST PRODUCTION REQUEST
TO TNTERMOTINTAIN GAS
(b) Explain how replacement schedules are currently developed and how the
Company would like to optimize them.
(c) Please describe all alternatives to resolve budgetary constraints the Company has
considered.
REQUEST NO. 24: Application at 5 - The Company states that it would like to accelerate
the replacement of Aldyl-A pipe.
(a) Please describe the Company's desired "accelerated" schedule for replacement of
Aldyl-A pipe including timing, costs, and benefits.
(b) Please provide the Company's procedures/rules/regulations for handling of
Aldyl-A pipe.
REQUEST NO.25: Application at 5 - The Company states that Pipeline andHazardous
Materials Safety Administration (PHMSA) has proposed a rule for automatic and remote controlled
shut off valves. Please describe the scope of this proposed requirement on the Company's system
including the number and type of valves required for compliance including the cost of valves and
installation.
REQUEST NO. 26: Application at 5 - The Company states that it must make certain
capital investments to satisfy federal, state, and local regulations. Please identify all federal, state,
and local regulations the Company is referring to. Please provide copies of all documentation
supporting the legal requirements and need to accelerate replacements including regulations, letters,
memorandums, etc.
REQUEST NO.27: Application at 5 - The Company states that IPUC Pipeline Safety has
encouraged inspection and replacement of HPSS on their system. Please describe the current
inspection and replacement plan and the referenced "more aggressive" plan in terms of time and
dollars.
REQUEST NO. 28: Application at7 - The Company proposes that the IPUC Pipeline
Safety Division and the Company conduct Infrastructure Project Review Meetings at regular
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 5 JANUARY 25,2018
intervals. Please define what the Company anticipates these project reviews would encompass.
Please define the term "regular intervals."
REQUEST NO. 29: Application at 4 - The Company states that 42 states have
implemented a form of integrity management and infrastructure replacement programs. Please cite
the programs by state that the Company believes most closely align with its perceived needs.
REQUEST NO.30: Please quantify how many HPSS are located in High Consequence
Areas, as defined by 49 C.F.R. $ 192.903.
REQUEST NO.31: Please describe all bare steel and cast iron pipe in the Company's
system including size, total length, and age.
REQUEST NO. 32: Please describe the Company's risk management program record
keeping and data management policies and procedures.
REQUEST NO. 33: For each HPSS replacement project completed during 2015,2016 and
2017, please provide the cost estimate included in the capital budget, and the actual costs.
REQUEST NO.34: For each Aldyl-A pipe replacement project completed during 2015,
2016 and 2017, please provide the cost estimate included in the capital budget, and the actual costs.
DATED at Boise, Idaho, this LEnburof January 2018
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Camille Christen
Deputy Attorney General
Technical Staff: Joe Terry
Joe Leckie
Kevin Keyt
Mike Louis
i:umisc:prodreq/intg I T.Tccjtjlkskml prod req I
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 6 JANUARY 25,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF JANUARY 2018,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, N CASE
NO. INT-G-17-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MICHAEL P McGRATH
DIR - REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
IOI5 W HAYS ST
BOISE TD 83702
E-MAIL: [e-mail]
L,4,a*,,
SECRETAY-
CERTIFICATE OF SERVICE