20180215INT to Staff 1-34.pdf

EXECUTIVE OFFICES
I rureRruouNTArru Gas CorupnNv
555 soUTH COLE ROAD . p.O. BOX 7608 . BO|SE, TDAHO 83707 . [phone] o FAX:[phone]
R[CE IVEO
?$lB f[B tS pH rr; 09
, i,' !?irii *ij#'hiS*,'*February 15,2018
Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W . Washington Street
P.O. Box 83720
Boise, ID 83720-0074
RE: First Production Request of the Commission Staff to Intermountain Gas Company
Case No. INT-G-17-07
Dear Ms. Hanian:
In regard to the above reference case, enclosed for filling with this Commission are the original
and seven (7) copies of Intermountain Gas Company's response to the First Production Request
of the Commission Staff.
Please acknowledge receipt of this filing by stamping a copy of this cover letter and retuming the
stamped copy to us.
Should you have any suggestions regarding the attached, please don't hesitate to contact me at
(208) 377-6t68.
Very truly yours,
P.
Director, Re gulatory Affairs
Intermountain Gas Company
Enclosure
Mark Chiles
Hart Gilchrist
cc
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
Post Office Box 388, Boise, ID 83701
802 W Bannock, Suite 900
Boise, ID 83702
Telephone: [phone]
Email : [e-mail]
Attorney for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILTTIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR
AUTHORITY TO IMPLEMENT AN
INFRASTRUCTURE INTEGRITY
MANAGEMENT MECHANISM
CASE NO. INT-G-I7-07
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
COMES NOW, Intermountain Gas Company, and in response to the First Production
Request of the Commission Staff dated January 25,2018, herewith submits the following
inlormation:
RBQUEST NO. l: 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.
RESPONSE TO REQUEST NO. l:
The Company is unsure of what is meant by "operating plans" in lhe above request.
Regarding capital budgets, please refer to the spreadsheet titled "2015-2022 Approved
Budget.xlsx" on the attached CD in.folder #l
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IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page I
The column labeled "Class Code View Cc Project Ranking" contains a classification of "G-
Dimp/Timp" identifying the projects that are candidates for inclusion in the IIMM, if approved.
In some coses, Inlermountain replaces all, or portions, of lateral mains os part of its aging
infrastructure initiatives. These projects are not specifically categorized in the forward-looking
budgets, but are included in the "G-System Betterments" and "G-Replacement/Maintenance"
categories in the column labeled "Class Code View Cc Project Ranking" on the attqched
spreadsheet. The Company would work with the IPUC Pipeline Safety Division to determine if the
risks of these pipes raise to the level of inclusion in the proposed IIMM.
Record Holder: Mike McGrath20S-377-6000
Location 555 S Cole Rd" Boise. ID 83707
Sponsor/Preparer Lance Elroy 208-377 -6122
REQUEST NO. 2: Please provide a similar schedule as above with actual expenditures for
the last five years.
RESPONSE TO REQUEST NO. 2:
The actual capital expendituresfor the lastfive yeors, beginningJune l, 2013, can befound
in lhe spreadsheet titled "2-5 Years - Actual Expenditures.xlsx" on the attached CD infolder #2.
Please note that Intermountain does not have recordsfor thefirst half of the year 2013 due to the
conversion to PowerPlan plant accounting software.
Record Holder:
Location:
Sponsor/Preparer
Mike McG r ath 208 -37 7-6000
555 S Cole Rd. Boise. ID 83707
Lance Eh ov 208 -37 7 -6122
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page2
REQUEST NO. 3: Please provide a system map identifying all pipe type, specifically
highlighting Aldyl-A pipe.
RESPONSE TO REQUEST NO. 3:
This map is onfile with the IPUC Safety Division.
Record Holder: Mike McGrath20S-377-6000
Location
Sponsor/Preparer Craig Chapin 208-37 7 -61 42
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.
RESPONSE TO REQUEST NO. 4:
The Aldyl A pipe was broken out into two vintage yeqrs: pre-|984 and 1984+t. Sizes and
miles for each pipe size in each vintage year are shown in the table on page 4.
Pre-1984 Aldyl A pipe is scheduled,for replacement based on the results of the DIMP Risk
Model. The original cost of pre-1984 Aldyl A pipe is $8,367,060. Only the pre-1984 pipe sizes l-
I/4", 2" and 4" are scheduledfor replacement qt this time which currently totals approximately
580 miles. The replacement costfor the pre-1984 Aldyl A pipe is estimated at $153 million based
on the remaining 580 miles at an average replacement cost of $50 per foot, os defined in the
response to Request No.5.
The 1984+ Aldyl A pipe will be replaced as needed with no curuent plan to aggressively
replace at this time due to the change in resin in 1984 and current industry practices. The original
pipe cost for I984+ Aldyl A pipe is $ 15,588,464.
I ln its IIMM Application, the Company referenced pre-1985 vintages of Aldyl A pipe as being targetedfor replacement
by the Compony. The reference should have been to pre-1984 vintages ofAldyl A pipe.
ICC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 3
555 S Cole Rd" Boise. ID 83707
Pre-1984 Aldyl A Pipe (Mains)Pre-1984 Aldyl A Pipe (Services)
Pipe Size Miles Pipe Size Miles
l/../2 0 l/)./2 12.8
3/.)/4 0.87 1/ ))74 321
I ))0.82 1
,,0
t-r/4"8.89 t-114"8.4
2"511 2"t4.2
4"37 4"0.22
1984+ Aldyl A Pipe (Mains)1984+ Aldyl A Pipe (Services)
Pipe Size Miles Pipe Size Miles
l/))72 0 t/.)/2 49.4
1/4"1.56 3/,/4 886
I ))0 I )t 0
7-U4"12.75 r-U4"22.7
2"651 2"29.1
4"114 4"0.86
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-37 7-6000
555 S Cole Rd, Boise, ID 83707
Crais Chapin 208-37 7 -61 42
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.
RESPONSE TO REQUEST NO. 5:
The $ I 58.4 million cost was derived using the actual averoge cost of $50 per foot of pre-
1984 Aldyl A pipe replaced in 2015 and 2016 multiplied by the estimated 600 miles of remaining
pipe in the system at that time. The curuent number of miles of pre-|984 Aldyl A pipe scheduledfor
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 4
replacement is now 580 miles based on pipe replaced thru 2017. The tables below show the
derivation of the overage $50 per foot cost of replaced Aldyl A pipe in 201 5 and 20I6.
2015
District Footage Installed Actual Cost
Average Cost Per
Foot
Capital 12,542 $666,567 $53. l 5
Owyhee 3,644 $227,536 s62.44
Skyline 3,090 $266,783 $86.34
Teton 7,1 50 $ 197,604 927.64
Sawtooth 3,046 $ 140,436 s46. l l
29,472 $1,498,926 $50.86
20t6
Footage Installed Actual Cost
Average Cost Per
Foot
Capital 14,309 $747,927 ss}.27
Owyhee 5,466 $326,338 $se.70
Skyline 3,910 $308,381 $78.87
Teton 13,371 $516,425 $38.62
Sawtooth 7,034 $279,088 $39.68
44,090 $2, I 78,1 59 $49.40
Record Holder:
Location:
Sponsor/Preparer
Mike McGrath 208 -37 7-6000
555S Cole Rd. Boise. ID 83707
Craig Chapin 208-37 7 -61 42
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.
RESPONSE TO REQUEST NO. 6:
Intermountain added a new position of Public Awareness Coordinotor on April 17, 2017.
This position is dedicated to damage prevention activities and the public awareness of damage
prevention/natural gas safety. This position is in wage group 36 and was not included in the last
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 5
District
general rote case. Wage group 36 has the.following salary ronge; entry level $60,400, market level
875,500 and maximum level $90,600. The total average annual cost of this added position,
including benefits is approximately 5108,000.
In addition, Intermountain has an Engineering Associate position approvedfor 2018. This
position has been added, in part (50%o), to support the domage prevention initiatives in the field;
such os, training third-party contractors on damage prevention, attending public meetings and
conferences to promote damage prevention in the community, conduct field audits of damage
prevention best practices in the field, and provide internal guidance/leadership in damage
prevention initiatives. This position is in wage group 34-35-36 and was not included in the last
general rate case. The total average annual cost of this addedposition, includingbenefits, is
approximat ely $ 9 3, 000.
It is also worth noting that there are full-time equivalent (FTE) positions in place at
Intermountain to support pipeline integrity initiatives that were included in the last general rate
case. Intermountain has staff engineering and technical support staff adding up to L5 FTE's in the
general ffice. Additionally, there are approximately 3-5 FTE's in the field (Engineering
Associates, Service Technicians, Management, Coruosion Technicians, Leak Survey Technicians,
Sales Associates, Office Support Staff and Meter Inspectors) to support integrity initiatives,
inc luding dama ge pr ev e nt i on.
Record Holder: Mike McGrath20S-377-6000
Location:
Sponsor/Preparer:
555 S Cole Rd, Boise. ID 83707
Lance Elroy 208-377 -6122
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.
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 6
RESPONSE TO REQUEST NO. 7:
The capital budget process is centrally coordinated by MDU. Each Vice President is
responsible for their oreas of responsibility to review and approve their budget request. The files
listed below desuibe the capital budget process and timelines for the curuent budget cycle (2018-
2022).
The followingfiles can be found on the attached CD infolder #7:
Request 7 - Instructions - Revised 7-19-2017.doc (Capital budget process instructions)
Request 7 - Budget Time Line.doc (Functional tasks, assigned responsible group, and torget
completion dates)
Request 7 - Budget Time Line - Internal.doc (Milestone taslrs, person(s) or group
responsible for completion, and target completion dates)
Record Holder:
Location:
Sponsor/Preparer:
Mike McGruth 208 -37 7-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden 208-377 -61 49
REQUEST NO. 8: Please provide all meeting notes, agendas, etc. related to developing
and approving the Company's previous three capital budgets.
RESPONSE TO REQUEST NO. 8:
Please see on the attached CD in folder #8 the files titled " Management Committee Meeting
Minutes - Capitol Budget.pdf" and " Boord of Directors Minutes - Capital Budget.pdf" for the
minutes from the Management Committee Meetings and Boord of Directors Meetings pertaining to
approval ofthe previous three capital budgets.
The development of the Company's capital budget is an iterative process to include
numerous communicati'ons between members of management, with changes made directly in the
PowerPlan software used by the Company. As such, there are no comprehensive documents which
clearly show the development of each specific capital budget.
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 7
Record Holder:
Location:
Sponsor/Preparer:
Record Holder:
Location:
Sponsor/Preparer:
Mike McG rath 208 -37 7-6000
555 S Cole Rd. Boise. ID 83707
Ted Dedden 208-377 -61 49
Mike McGrath 208-377-6000
555 S Cole Rd. Boise. ID 83707
Ted Dedden 208-37 7 -61 49
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.
RESPOSNE TO REQUEST NO. 9:
Please see the.file titled "IIMM Response 9.xlsx" onthe attachedCD infolder #9, which
shows lhe sources and costs of capital to fund the Company's capilal budgets for the last five yeqrs
REQUEST NO. 10: For all of the Company's High-Pressure Service Sets (HPSS) currently
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.
RESPONSE TO REQUEST NO. 10:
Please refer to the tob labeled "FIPSS List" of the spreadsheet titled "lGC-HPSS-List-
20l8.xlxs" on the attached CD in folder # I0. This is a list of HPSS in service, installation date,
location, and last inspection date (as part of the HPSS program). The tab labeled
"HPSS_Completed_Orders" is a list of the orders completed as part of the progrom and this list
has who either inspected or serviced each HPSS. Intermountain is in year 2 of a 5-year program to
inspect and service each HPSS. There have been approximately 2,000 HPSS inspected or serviced
since the program started. The initial inspection program is scheduledfor completion by the end of
2020. In addition to the llP,S,S inspection program, Intermountain conducts an Atmospheric
Corrosion (AC) inspection of HPSS on a 3-year rotation as part of ongoing federally mandated
requirement (CFR Part 192.481).
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 8
S Cole Rd R se. ID 83707
Lance Ebov 208-37 7 -6122
REQUEST NO. ll: What is the total number of HPSS that is served by the transmission
system?
RESPONSE TO REQUEST NO. il:
The total number of HPSS served by the transmission system is 1,03 l.
Record Holder:
Location:
Sponsor/Preparer
Record Holder:
Location:
Sponsor/Preparer:
system?
Record Holder:
Location:
Sponsor/Preparer:
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 377 -6000
555
Mike McGrath 208-3 77-6000
555 S Cole Rd.Boise. ID 83707
Craig Chapin 208-377 -6142
Mike McG rath 208-37 7-6000
5 5 5S
Mike McGrath2 377-6000
555 S Cole Rd. Boise. ID 83707
Crais. Chapin 208-377 -6|42
REQUEST NO. 12: What is the total number of HPSS that are served by the distribution
RESPONSE TO REQUEST NO. 12:
The lotal number of HPSS served by the distribution system is 5,275
Cole Rd ID 83707
Craig Chapin 208-377 -6142
REQUEST NO. 13: What is the total number of HPSS located within 250 yards radius of a
regulator station?
RESPONSE TO REQUEST NO. 13:
The total number o/'HPSS located within a 2S}-yard radius of a regulator station is 1,805.
REQUEST NO. 14: What is the total number of HPSS located within a ll4 mile radius of a
regulator station?
RESPONSE TO REQUEST NO. 14:
The total number of HPSS located within a I /4 mile radius of a regulator station is 3, I 63.
ICC RESPONSE TO FrRST REQUEST FOR PRODUCTION Page 9
REQUEST NO. 15: What is the total number of HPSS located within a ll2 mile radius of a
regulator station?
RESPONSE TO REQUEST NO. 15:
The total number of HPSS located within a l/2 mile radius of a regulator station is 4,673.
Record Holder:
Location:
Sponsor/Preparer:
Record Holder:
Location:
Sponsor/Preparer:
Record Holder:
Location:
Sponsor/Preparer:
Mike McG rath 208 -37 7 -6000
555 S Cole Rd. Boise. ID 83707
Crais Chaoin 208-377 -6142
Mike McGrath 208-377 -6000
555 S Cole Rd. Boise,ID 83707
Craig Chapin 208-377 -61 42
REQUEST NO. 16: What is the total number of HPSS located within a mile radius of a
regulator station?
RESPONSE TO REQUEST NO. 16:
The total number of HPSS located within a one-mile radius of a regulator station is 5,537.
Mike McGr ath 208 -37 7-6000
555 S Cole Rd, Boise, ID 83707
@:6142
REQUEST NO. l7: 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.
RESPONSE TO REQUEST NO. 17:
Pre-1984 Aldyl A pipe is the only pipe required to be replaced in the nextfive yeors due to a
potential susceptibility to brittle-like cracking. Additional information on the pre-1984 vintage
Aldyl A pipe recommendedfor replacement can be found in the 728-page white paper by the
American Gas Association titled " lnformation About Aldyl A Piping, " as described in the response
to Request No. 26. Aldyl A pipe is a medium density polyethylene material ranging in pipe size
.from %" to 4". Approximately 580 miles of pre-L984 Aldyl A pipe remain in the distribution system
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 10
and it is fiscally and operationally impractical to replace all 580 miles infive years, The age of
Aldyl A pipe ranges from approximately 24-50 years. Installations began in 1968 and started to
phase out in I994. The approximate replacement cost per /bot is estimated at $50, as described in
the response to Request No. 5. Intermountain is proposing a 10-15 year timeframefor replocement
of pre-1984 Aldyl A pipe, as explained in the response to Request No. 24 below.
Record Holder: Mike McGrath20S-377-6000
Location:
Sponsor/Preparer
Location:
Sponsor/Preparer:
555 S Cole Rd. Boise. ID 83707
Crais Chapin 208-377 -6142
555 S Cole Rd.Boise, ID 83707
Craie Chapin 208-37 7 -6142
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.
RESPONSE TO REQUEST NO. 18:
Other than Aldyl A pipe replacements and IIPSS removals, Intermountain does not have
plans to replace other infrastructure as part of apipeline integrity initiative over the next 5 years.
However, this is subject to change as new idormation is identified and incorporated into the TIMP
and DIMP risk models which Intermountain uses on an on-going basis. Additionally, the Company
will work with the IPUC Pipeline Safety Division to continuously evaluate risks and the potential
/b r .futur e i nfr as tr uc tur e r epl ac e me nt.
Record Holder: Mike McGrath20S-377-6000
REQUEST NO. 19: Please describe any investments the Company has made over the last
five years to reduce and minimize replacement costs.
RESPONSE TO REQUEST NO. 19:
Intermountain utilizes industry best practices to guide efforts to minimize infrastructure
replacement costs. The Company piloted a progrom to use a pipe splitting machine to reduce the
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page I I
costs of replacing Aldyl A plastic pipe. This allows the Company to pull the new plastic pipe
through the existing Aldyl A pipe, thus reducing the cost of excavating the trench, replacing asphalt
and other surface restoration. The pilot was successful and Intermountain plans to incorporate the
pipe splitter method of replacing Aldyl A pipe where practical goingforward.
The bulk of the pipe replacement is done by Intermountain contractors, who have incentives
built into their contracts to fficiently replace pipe. They are incentivized through pricing
mechanisms, quality assurance checks and Company oversight of projects. Intermountain also
engages in the review of replacement projects to ensure that costs are reasonable.
Intermountain works with local and state jurisdictions to coordinate pipe replacement
associated with road replacement, downlown revitalization and other similar projects to lower the
costs of installation. This joint effort reduces the cost of installation because of lower excavation
costs, such as, concrete/asphalt replacement, trenching, and labor.
Intermountoin uses its DIMP model for //P^SS replacement to assist with strategically
deciding not only the highest risk HPSS to replace, but also the projects that have the potential to
replace more HPSS at a lower cost.
Record Holder:
Location:
Sponsor/Preparer
Mike McGrath 208-37 7 -6000
555 S Cole Rd. Boise. lD 83707
Lance Ek ov 208 -37 7 -6122
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 1 .
RESPONSE TO REQUEST NO. 20:
Exhibit No. 2, page I shows examples of potential capital projects that could be included in
the IIMM and these same types of projects may, or may not, impact O&M costs. IIMM projects
may reflect capital costs, O&M costs, or both. For example, HP.SS may need to be replaced
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 12
(capital) or they may need to be subjected to increased inspections @AW b mitigate risks to the
Company's system. Adding personnel to comply with laws promulgated under PHMSA is on
example of O&M costs incurred to ensure safe and reliable service.
Record Holder:
Location:
Sponsor/Preparer:
Record Holder:
Location:
Sponsor/Preparer:
Mi ke McGrath 208 -37 7 -6000
555 S Cole Rd. Boise. ID 83707
Hart Gilchrist 208-3 77-6086
Mike McGrath 208-377-6000
555 S Cole Rd ise. ID 83707
Lance Elroy 208-377 -6122
REQUEST NO. 21: Please describe the per-unit financial impacts (costs and benefits) of
removing an HPSS.
RESPONSE TO REQUEST NO. 21:
The Company has evaluated HPSS removal projects during 2015-2017 and the average cost
per unit for those projects was around $4,000 to $6,000 per unit. The range in the per-unit costs to
remove an HPSS is due to the factors explained below.
To remove an HPSS, a distribution pressure main needs to be near the service line serving
the customer. This requires the Company to run o new distribution pressure main neor, or parallel
with, the high-pressure system. Once this is done, the HPSS canbe removedandthe customer's
service line can be tied inlo the new distribution pressure main.
The benefit of removing IIP,SS is avoiding a potential incident resultingfrom on HPSS being
hit by a vehicle or other outside force which could lead to injury, loss of life, property damage, gas
loss, and service interruption.
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page l3
REQUEST NO. 22: Application at 4 - The Company states that it is faced with additional
f-ederal, 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.
RESPONSE TO REQUEST NO. 22:
The spreadsheet titled "Summary of Regs and Requirements.xlsx" on the attached CD in
.folder #22 includes o summary of some recent requirements/regulations that have had an impact on
Intermountain; as u,ell as anticipated upcoming requirements/regulations. The spreadsheet has a
summary of the requirements along with timelines and estimated costs
Record Holder:Mike McGrath 208 -37 7-6000
Location:
Sponsor/Preparer Lance Elroy 208-377 -6122
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.
(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,
RESPONSE TO REQUEST NO.23:
(a) The acceleration of infrastructure replacement benefits customers and the
Company in the following ways
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 14
555 S Cole Rd. Boise. ID 83707
1. It accelerates the reduction of the risks associatedwith potential
hazardous leaks - improving the safety of customers, Company
employees, and the public.
2. It lowers the potential of major incidents resulting in bodily
injury, loss of life, and property damage.
3. It improves long-term reliability of service by reducing service
outages.
(b) Replacement schedules are determinedfrom the DIMP Risk Model, which
prioritizes replacement of the high-riskprojectsfirst. Current pre-1984 Aldyl
A pipe replacement would toke close to 100 years based on the current pipe
replacement schedule of 5-7 miles per year. Optimization could occur by
accelerating the replacement of pre-1984 Aldyl A pipe to a l0-15 year
timeframe.
(c) Budgets are determined based on Company needs in a particular year to allow
for customer growth and continuous system improvements, including:
1. Required mains and services to serve new customers,
2. Required system enhancements to add copacity and/or reinforce
those areas needing additional capacity based on growth,
3. Road improvements determined/required by city, county, state
andfederal agencies,
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 15
4. Continuous system improvements required by federal
c o de s /mandat e s /r ul e s t o maint ain c o mpl ianc e,
J. Continued technologt upgrades ond enhancements to maintain
compliance and increase efficiencies and
6. Continued upgrade and/or replacement of buildings, structures
and vehicles due to age.
Intermountain's effort to overcome the budget constraints highlighted above
focuses on cost controls and improved efficiency of operations. For example,
Intermountain has been using an industry leading joint trench programfor
over 20 years that reduces the cost to install new pipe by as much as 50-60%.
The industry leading component to the program is that Intermountoin has been
partnering with ldaho Power and other utilities to utilize o common
subcontractor to jointly install utilities. This is unique in the industry because
most joint trench progroms are common trench, but utilize separate
subcontractors to install each utility. By utilizing one subcontractor, the
process is more fficient and cost ffictive.
Another example is the Automated Meter Reading Program. Intermountain
has reduced operating costs through reading meters electronically. This
progrom is curuently being expanded to include afixed network reading
system, further enhancing fficiencies.
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 16
Record Holder:
Location:
Sponsor/Preparer
Intermountqin continuously evaluates opportunities to leverage technology to
improve efficiency. This includes optimizing the compliance tracking process
through an electronic system and utilizing industry leading leak survey
equipment to allow for more fficient leak surveys. The equipment allows for
technicians to use a laser type technologt to survey pipes and equipment from
up to 100 feet away. These are just afew examples of Intermountain's
commitment to improving fficiency and reducing costs to overcome budget
constraints.
Mike McGrath 208-37 7-6000
555 S Cole Rd" Boi se, ID 83707
Crais Chaprn and Lance Ehqt 208-377 -6142 & 208-377 -6122
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.
RESPONSE TO REQUEST NO. 24:
(a) Based on the Company's TIMP and DIMP risk models, the Company's Aldyl A
replacement program is currently projected to span 100 years, with 5-7 miles of
pipe replaced per year.
The desired replacement schedule of the Aldyl A pipe is 10-15 years at o cost of
$ 10-$ I 5 million per year, bosed on the currently estimated $50 per foot, as
described in the response to Request No. 5.
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 17
Benefits include:
l. Reduced risk associated with potenttal hazardous leaks,
2. Reduced risk of potential major incidents resulting in bodily injury, loss
of lfe, and property damage, and
3. Improved long-term reliability of service.
(b) Intermountain's DIMP program is the primary federal regulation that drives the
way the Company handles Aldyl A. Additionally, there are other advisories,
industry studies and recommended practices outlined in the AGA report titled
" lnformation About Aldyl A Piping, " which is provided in the response to
Request No. 26.
Regarding the physical handling of Aldyl A, Intermountain handles it the same as
other plastic pipe in the system. There are a few special considerations when
field employees encounter Aldyl A. Early vintage Aldyl A service punch tees
(SPf) are susceptible to leaking. When service tee connections are exposed
during maintenance activity, the section of main where the SPT is located is
replaced or in some coses, an over-cap repair kit is installed on the SPT. The
following procedure is required on all plastic pipe, however; the requirement
was implemented to avoid uacking of Aldyl A pipe. "Any pinch off location on
plastic pipe shall be marked with either a black permanent marker or black
electrical tope ot the squeezed portion o/ the pipe to prevent additional pinch offs
in that localion. "
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 18
Record Holder:
Location:
Sponsor/Preparer
Mike McG rath 208-37 7-6000
555 S Cole Rd. Boise. ID 83707
Craig Chapin & Lance Eho\r 208-377 -6142 & 208-377 -6122
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.
RESPONSE TO REQUEST NO. 25:
The scope of the proposed requiremenl for outomatic and remote controlled shut off valves
can befound in thefiles titled "Scopefor ASV and RCV.pdf" and "PHMSA-2}11-0023-01IS.pdf'
on the attached CD in.folder #25.
Depending on the requirements and stipulations of the final rule for outomatic shutoff and
remote-controlled valves (ASV and RCV), it is estimated that the Company may be required to
install 25-30 actuators on existing aboveground valves. The cost of each actuator is estimated at
$ l0K-$20K depending on size. Installation cost is estimated at $50K-$ I 50K per ASV depending on
location, access, distonce from power and SCADA requirements.
Those valves curuently installed below ground would require relocation above ground and
would require a new vqlve and qctuator. The number of new valves is estimated at l0-15 valves
and would be a.full port ball valve, trunnion mounted with double block and bleed capabilities. The
cost of each valve/actuator is estimated at $20K-$50K depending on size. Installation costs are
estimated at $75K-$200Kwhich does not include the cost of property.
Record Holder: Mike McGrath20S-377-6000
Location: 555 S Cole Rd. Boise. ID 83707
Sponsor/Preparer: Craig Chapin and Lance Ekoy 208-377 -6142 & 208-377 -6122
ICC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 19
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.
RESPONSE TO REQUEST NO. 26:
The.following regulations require Intermountain to make capital investments
- P6rt 192
H - Customer Melers, service REgulators and
Li nes Valving and EFV installation on service lines, labor and infrastructure to control gas pre5sore
Corrosion prolEction equipmenl, rectifiers, anodes, telernetry, casing replacement" shorl stee!
pipe replacement, bridge crossing replacement, pipe replacement, integrity mangemenl
asgessr.lenls, labor
Odorization o{gas - equiprnent, SCAoA equipment and softtvare forcontrol room managernent.
looling and equipment for emergency rrangempnt, labcr
Equipme^t and tools !o assisl with rnainlenance, software fortracking rnaintenance. equipment,
pipe and valve replacement due to rnaintence, labor
Softrvare for tracking and conducting qualification
Subpart I - Corrosioo Conlrol
SubDart L - Operations
The documentation supporting the needfor accelerated replacement of Aldyl A pipe is
summarized in a comprehensive 728-page white paper created by the American Gas Association
and is shown in the file titled "AGA Report Aldyl A Piping.pdf" on the attached CD infolder #26.
Intermountain utilizes the information summarized in the AGA report, along with DIMP risk
modeling, to determine the need for accelerated pipe replacement.
Subpart M - Maintenance
subpart N - Qualification of Pipeline Personnel
Subpart O - Gas Transm,ssion Pipeline lntegrity
,Managemenl (TIMP)
,Subgart P - Gas Oistribution Pipeline lntegrity
lMangernent {DIMP}
l
I Local, State, Municipal Franchise Requirements
Software. labor, pipe assessment and replacements
Software, labor, pipe assessment and replacernents
lntermountain musl relocale, lower gas facilities. committing capital inveslment to support
Municipal,/County/slate and Federal projects, such as, road relocation and wideningjobs.
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Lance Elr oy and Cr arg Chaprn 208 -37 7 -6 1 42 & 208 -37 7 -6 122
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 20
*erulltion Capital lnvestffients
Record Holder:
Location:
Sponsor/Preparer:
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.
RESPONSE TO REQUEST NO. 27:
The curuent inspection plan of HPSS is /o complete all initial inspections by 2020 and a
more aggressive inspection plan is not needed at this time.
The curuent removal plan of HPSS is based on available budgetary dollars and is prioritized
on rislcs such as:
1. Remote IIPSS location on or neqr a transmission line,
2. Location and proximity to vehicle trffic/roadways,
-i. Pressure in upstream pipeline and
4. Proximity to other potential danger/damagefromfarm equipment, driveways, RV
par king, I ive s toc k, e tc.
While it is impractical to remove all HPSS, those with higher risk and located remotely
would be the initial focus versus those HPSS located at the meter near the building/structure/house.
The total number of remote IIPSS is approximately 3,760. A more aggressive plan could result in
removing 300-500 HPSS per year over a S-year period. This would reduce the amount of remote
HPSS by 40.0% - 66.5%. The historical cost of removal is typically $4,000 - $6,000 per HPSS
based on overages from 20I 5-2017. Assuming increasing removal costs over time could result in
removal costs of $8,000 per remote IIPSS. This results in an estimated cost of $2.a-$a.0 million per
year to accommodote a more aggressive removal plan over a S-year period.
Record Holder:
Location:
Sponsor/Preparer:
Mike McG rath 208 -37 7-6000
55s S Col eRd Boise. ID 83707
Craie Chapin 208-377 -6142
ICC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 21
REQUEST NO. 28: Application at7 - The Company proposes that the IPUC Pipeline
Safety Division and the Company conduct Infrastructure Project Review Meetings at regular
intervals. Please define what the Company anticipates these project reviews would encompass.
Please define the term "regular intervals."
RESPONSE TO REQUEST NO. 28:
Intermountain anticipates the need to meet with the IPUC Pipeline Sofrty Division on a
quorterly basis to review infrastructure projects. The meetingfrequency can be determined
mutually and may increase or decrease in.frequency depending on the need to review pro.jects.
Record Holder:
Location:
Sponsor/Preparer
Mike McGrath 208 -37 7-6000
555 S Cole Rd. Boise. ID 83707
Lance Elroy 208-377 -6122
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.
RESPONSE TO REQUEST NO. 29:
As stated in the Application on page 4, "the commonfocus of these approved programs is
system safety and reliability of service. " Intermountain shares this same commitment and has
crafted the proposed IIMM to achieve both of these goals. The below states have programs which
closely align with the goals of Intermountain's proposed IIMM.
o Colorado: Pipeline System Integrity Adjustment (Public Service Company of Colorado)
o Florida: Gas Reliability Infrastructure Program (Florida Public Utilities Company)
o Indiana: Complionce and System Improvement Adjustment and Pipeline Safety Adjustment
(Southern Indiana Gas and Electric Company)
o Louisiana: Rate Stabilization Program (CenterPoint Energt)
o Minnesota: Gas Utility Infrastructure Cost Rider (Xcel Energy)
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 22
o Mississippi: Rate Stabilization Program (CenterPoint Energy)
. Nebraska; Syslem SaJbty and Integrity Rider (Black Hills Energy)
o Oklahoma: Rate Stqbilization Program (CenterPoint Energy)
Record Holder Mike McGrath 208-37 7-6000
Location 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer:Mike McGrath 208-37 7-6000
REQUEST NO. 30: Please quantify how many HPSS are located in High Consequence
Areas. as defined by 49 C.F.R. $ 192.903.
RESPONSE TO REQUEST NO. 30:
65 HPSS are located in High Consequence Areas.
Ilecord Holder: Mike McGrath20S-377-6000
Location:555 S Cole Rd. Boise. ID 81707
Sponsor/Preparer:Crais Chapin 208-377-6142
REQUEST NO. 31: Please describe all bare steel and cast iron pipe in the Company's
system including size, total length, and age.
RESPONSE TO REQUEST NO.31:
There are no bare steel or cast iron pipes in the Company's distribution system.
Record Holder: Mike McGrath20S-377-6000
Location:
Sponsor/Preparer:Craig Chapin 208-377 -6142
REQUEST NO. 32: Please describe the Company's risk management program record
keeping and data management policies and procedures.
RESPONSE TO REQUEST NO.32:
The Company's risk mqnogement program record keeping is the responsibility of
the Company's Engineering Department which gathers the data required to complete the risk
ranking analysis. After each risk model run, the Engineering Department will export the necessary
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page23
555 S Cole Rd. Boise. ID 83707
risk datafrom the GIS system and utilize Access and Excel to sum the risk data and update the risk
ranking. All Access and Excel files related to risk model analysis will be archived on the
Company's internal Integrity Management Share Point Page.
Section 10.0 Recordkeeping of the DIMP Plan states that records are maintained.for l0
years andfurther states specifically which records are to be retained.
TIMP records (forms) are located on the Company's internal Engineering SharePoint Page.
All data management policies and procedures are referenced within the TIMP ond DIMP
programs.
Record Holder:
Location:
Sponsor/Preparer
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-37 7 -6000
555 S Cole Rd. Boise" ID 83707
Craig Chapin 208-377 -6142
Mike McGrath 208-37 7-6000
555 S Cole Rd. Boise. ID 8370f
Crais Chaoin 208-377-6142
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.
RESPONSE TO REQUEST NO. 33:
The table below is a summary of all budget and aclual costs of all I/PSS replacement
pro.jects for 20 I 5-20 I 7.
Budget Actual
2015 $1 10,125 $ 140,556
2016 $251,688 $ 135,749
2017 $284,082 $6 I 5,45 8
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 24
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
RESPONSE TO REQUEST NO. 34:
The table below is a summary of all budget and actual costs of all Aldyl A replacement
projects .for 20 I 5 -20 I 7.
Budget Actual
2015 $ 1,289,168 $ 1,530,843
2016 $ 1,100,038 s770,414
2017 $ 1,408,650 $ 1,095,652
Record I{older:
Location:
Sponsor/Preparer:
Mike McG rath 208 -37 7-6000
555 S Cole Rd, Boise, ID 83707
Craie Chapin 208-377 -6142
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 25