20181024Comments.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03s7
IDAHO BAR NO. 7956
nEai:l\/r-r\r\L-L,,r-I ! t-LJ
iitiil ij:T 2h fli{ ll' -:2
:.1 ':r IJi-., I I
Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83102.5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO REVISE
TARIFF SCHEDULE 170 _ NATURAL GAS
RULES AND REGULATIONS
CASE NO. AVU-G-18-07
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Brandon Karpen, Deputy Attorney General, and in response to the Notice of
Application, Notice of Modified Procedure and Notice of Comment Deadline issued in Order
No. 34167 on October 11,2018, in Case No. AVU-G-I8-07, submits the following comments.
BACKGROUND
On September 19, 2018, Avista Corporation dba Avista Utilities filed an Application
requesting that the Commission approve changes to the Company's Tariff Schedule 170 relating
to the Company's Natural Gas Rules and Regulations. The proposed changes stem from the
Company's effort to comply with Commission Order No. 33953.
Generally, the Company proposes to incorporate pertinent provisions of the
Commission's Service Rules for Gas Utilities (IDAPA 31.31.01), including rules for meter
testing and accuracy, as well as maintenance of system maps and records. The Company
proposes to move these relevant requirements into the Company's tariff.
In July 2008, Staff received an inquiry from Avista regarding an apparent conflict
between Commission Gas Service Rule 102 and Commission Safety Rule 202, relating to the
)
)
)
)
)
)
1STAFF COMMENTS ocToBER 24,2018
Commission's adoption of the National Fuel Gas Code, the Uniform Mechanical Code, and the
International Mechanical Code. After reviewing the issue, the Commission concluded that Gas
Service Rule 102 is incompatible with the Commission's Safety Rules 202.02 and203.02.
Order 30625 at 2. Consequently, the Commission suspended Gas Service Rule 102, IDAPA
31.31.01 .102. Id. at 3. The Commission further directed Staff to work with gas utilities and
other interested persons to informally review the Gas Service Rules. /d.
Avista provided Staff with proposed changes to IDAPA 31.31.01 in November 2016,
consistent with current best practices. Further discussions led to an agreement between Staff and
Avista that the integration of these revisions into the Company's tariffs would be beneficial to the
Company and the Commission. As such, in the Company's 2017 General Rate Case, the matter
of incorporating pertinent provisions from IDAPA 31.3l 0l was made part of the ultimate
settlement resolving the case.
On December 28, 2017, the Commission issued Order No. 33953, approving the
Settlement Stipulation in the rate case. Therein, the parties agreed:
The Company and interested parties will meet and confer to review the
Commission's Service Rules for Gas Utilities (IDAPA 31.31.01) to determine
which provisions should be retained and/or modified, and, if the participants agree,
incorporate those changes into the Company's tariff. Any changes requiring
Commission approval , a.8., tariff revisions, will be submitted by the Company on
or before [October 1, 2018].
Stipulation and Settlement Para. 19.
If the underlying Application is approved, the tariff regulations developed with Staff will be
incorporated into Avista's Natural Gas Tariff Schedule 170. Approval of the rules will not
change rates. The Company requested that the Commission process this Application under
Modified Procedure, with an effective date ofNovember 1,2018. Application at 8.
STAFF ANALYSIS
Staff worked with Avista to determine which provisions of the Commission's Service
Rules for Gas Utilities (Gas Service Rules) should be incorporated into its tariff. In its joint
review of the rules, some provisions were deemed to be unnecessarily prescriptive. In addition,
the rules contain obsolete references and requirements that no longer reflect current best
practices for gas utilities in general or Avista's actual practices.
Staff also notes that one existing rule (Rule 102) has caused confusion. Because Rule
102 was suspended in 2008 by the Commission but has not been formally repealed yet, the
2STAFF COMMENTS ocroBER 24,2018
similar but conflicting provisions contained in Rules 201 and202 of the Safety and Accident
Reporting Rules has created uncertainty about what code requirements the Commission has
officially adopted.
Staff appreciates the Company's willingness to collaborate with Staff, review and
evaluate the existing Gas Service Rules, and ultimately create tariff provisions that are relevant
and meet the needs of the Company and its customers. Attachment 1 compares the text of the
existing rules with the Company's proposed tariff provision that corresponds to each rule. Rule
provisions that were not incorporated into Avista's proposed tariff and substantive deviations
from the existing rules are addressed below.
Maps and Records of Facilities
Rule 1 01 .03 of the Gas Service Rules prescribes in detail the maps and records that
need to be maintained for each gas manufacturing plant, mixing plant, compressor station,
and storage facility.
The Company's proposed tariff does not include a similar provision for these types of
facilities or equipment specifically. Instead, the Company's proposal includes a more general
provision for maintaining maps and records, and Staff agrees that this is sufficient.
Meter Provers
Rule I 53.02 requires the utility to install additional meter proving stations when
and where found necessary by the Commission. Rule 153.03 requires each gas utility
using orifice meters, high pressure meters, proportional meters, or other large capacity
meters to own and maintain testing apparatus of a type approved by the Commission.
Rule 153.04 allows the Commission to oversee the accuracy of all meter provers and
methods of operation. It requires the Company to report alterations, accidents, or repairs
that might affect the accuracy of any meter prover, or the method of operating it, to the
Commission. Rule 155.01 requires all tests to determine the accuracy of registrations of
gas meters to be made with a suitable meter prover or testing equipment and prescribes
how such tests should be conducted.
Each of these rule provisions presume that the Commission will oversee and approve the
Company's meter provers and meter testing equipment and practices. However, it does not
JSTAFF'COMMENTS ocToBER 24,20t8
appear that Staff has performed these tasks in the past. The Company proposes to use the Avista
Utilities Gas Standards Manual which outlines prover calibration intervals for the different types
of provers the Company currently employs. Staff maintains that the Company and its
employees, not the Commission or its Staff, has the requisite knowledge to determine the
appropriate number of proving stations, oversee the accuracy of its provers and maintain the
appropriate meter provers to test meters. Staff agrees with Avista that these rule provisions
should not be incorporated into Avista's proposed tariff.
Meter Testing Standards
Rule 152.01 covers the testing of smaller capacity meters. All meters with
capacities up to and including four hundred (400) cubic feet per hour (CFH) that have
been in service ten (10) or more years as established by last set date shall be tested within
a prescribed sample size as determined in accordance with military standard 105D.
The Company proposes continuing the practice of sampling smaller capacity meters
(1,000 CFH or less) that have been in service for ten years. Additionally, the Company proposes
to use sample sizes consistent with the American National Standards Institute (ANSI)/American
Society for Quality (ASQ) Standard Zl.9 and other generally accepted inspection standards.
Military Standard 105 was cancelled by the Defense Standardization Program on February 6,
2008. See Attachment2. Staff supports using the ANSI/ASQ StandardZ9 for determining
sample sizes.
Rule 152.02 addresses testing of larger capacity meters. It requires all meters from
four hundred one (401) to three thousand (3,000) CFH that have been in service ten (10)
years as established by last set date to be replaced or field tested.
The Company proposes to use the prescribed inspection schedule for all meters over
1,000 CFH as found in the Avista Utilities Gas Standards Manual. The Company's manual
dictates testing intervals for meters based on CFH as well as by meter type. The rule assumes
that the Company is using diaphragm meters exclusively, but this is not always the case. The
Company's manual also covers testing of rotary and turbine meters as well. See Attachment 3.
Staff supports the use of the testing schedule as set forth in the Avista Utilities Gas Standards
Manual.
Rule 155.02 prescribes the rate of flow to be used in testing meters of various
capacities. The Company's proposed tariff does not include the detailed requirements
4STAFF COMMENTS ocToBER 24,2018
contained in this rule. Instead, the Company proposes to use its New Meter and Installed
Meters testing programs consistent with current Company practices.
Staff agrees that it is not necessary to prescribe the rate of flow for testing meters
in Avista's tariff. Staff maintains that Avista's meter testing program relies on acceptable
accuracy tolerances and inspection intervals as specified in the Avista Utilities Gas Meter
Measurement Performance Program (PMC Program). See Attachment 4.
Staff further recommends the Company include a provision in its tariff that states the
Company will furnish an electronic copy of the Company's current version of its Gas Standards
Manual and the Standard Operating Procedures for the Gas Meter Measurement Performance
Program (SOP) used by Avista's Gas Meter Shop to the Commission upon request or whenever
substantive changes are made to either document. The SOP is an abbreviated reference
document used by Avista employees that compiles information contained in the Company's
700+ page gas service manual into a 14 page document. Both documents would be helpful
reference tools for Staff.
Meter Tests Requested by Customers
Rule 157 allows the Commission to establish reasonable fees for testing meters. The
Company proposes providing one meter test upon request by any customer in a twelve-month
period without charge. If a customer requests more than one meter test in a twelve-month period
and the meter is found to register within 2Yo of accepted tolerance, the customer will be required
to pay the actual cost to perform the meter test. Customers will not be rebilled if a meter is
found to be registering less than2oh in error on average. The Company's proposed tariff does
not specify what amount customers will be charged for multiple meter tests. Staff intends to
continue to work with the Company to see if an appropriate charge can be determined.
SUMMARY
Staff has reviewed the Company's proposed tariff provisions and believes that it complies
with Commission Order No. 33953. Staff recommends one addition to the proposed tariff at this
time that the Company furnish an electronic copy of the Company's current version of its Gas
Standards Manual and the Standard Operating Procedures for the Gas Meter Measurement
Performance Program (SOP) used by Avista's Gas Meter Shop to the Commission upon request
or whenever substantive changes are made to either document.
5STAFF COMMENTS OCTOBER 24,20T8
STAFF RECOMMENDATION
Staff recommends the Commission:
1. Order the Company to add a provision to its tariff that states the Company will
furnish an electronic copy of the Company's current version of its Gas Standards
Manual and the Standard Operating Procedures for the Gas Meter Measurement
Performance Program used by Avista's Gas Meter Shop to the Commission upon
request or whenever substantive changes are made to either document; and
2. With the addition of this provision, approve the Company's proposed additions to
Schedule 170, Idaho Rules and Regulations, with an effective date of November 1,
2018.
Respectfully submitted this Z,(> day of October 2018.
Technical Staff: Johnathan Farley
Johan Kalala-Kasanda
Kevin Keyt
Michael Morrison
i : umisc/comments/avug I 8. Tbkkskj {kmm comments
6STAFF COMMENTS ocroBER 24,2018
(
Rule Gas Service Rule !DAPA 31.01.01 Avista Proposed Tariff
101.01 Maps, Plans, and
Records
Gas corporations must maintain maps,
plans, and records as prescribed by this
rule. A suitable map or maps shall be kept
on file in the principal office of each
division or district. The maps shall at all
times show the size, character, and
location of each street main, district
regulator, street valve and drip, and when
practicable, each service connection in the
corresponding territory served. ln lieu of
showing date of installation and service
locations on maps, a card record or other
suitable means may be used.
Maps and records shall be kept on file or
available electronically in the principal office
of each division or district. The maps shall
show the size, character, and location of
each street main, district regulator, street
valve, and when practicable, each service
connection in the corresponding territory
served. ln lieu of showing the date of
installation and service location on maps, a
separate record may be maintained. (Avista
Regulation No. 26)
101.02 Distribution
Records in District
Offices
ln each division or district office there
shall be available information about the
distribution system that will enable the
local representatives at all times to furnish
necessary information regard ing
rendering of service to existing and
prospective customers.
Each division or district office shall maintain
records of the gas distribution system that
will enable the Company to furnish
information regarding the provision of
service to Applicants and Customers. (Avista
Regulation No. 26)
101.03 Maps of
Manufactu ring, M ixi ng,
Compressor, and Storage
Facilities
Each gas manufacturing or mixing plant
and each compressor station and storage
facility shall be provided with an accurate
ground plan drawn to a suitable scale,
showing the entire layout of the plant or
station, the location, size, and character of
plant, equipment, major pipelines,
connections, valves, and other facilities
used for the production and delivery of
gas, all properly identified.
lntentionally Omitted
101.04lnspection of
Facilities
ln determining whether these rules are
being complied with, the Commission may
inspect facilities and records as necessary,
as provided in section 6L-52t,ldaho Code.
The Commission may inspect facilities and
records as necessary as provided in section
6L-527,ldaho Code. (Avista Regulation No.
26l,
Attachment I
Case No. AVU-G-18-07
Staff Comments
10/24/18 Page I of 5
102 lnspection of
Customer's Facilities
The gas corporation shall inspect the
customer's installation before the
connection of a meter to ascertain that
the installation conforms to the provisions
contained in the National Fuel Gas Code
and the Uniform Mechanical Code, as
adopted by the Commission. lf the
installation on the customer's premises
does not meet these requirements, the
Company shall refuse to connect the
meter and shall advise the customer in
writing the reasons for such refusal. See
Customer Relations Rule 3.03.a, IDAPA
31.21.01.303.a; see Safety and Accident
Reporting Rules 201 and2O2,lDAPA
31.11.01.201 and 31.11 .0L.202.
Suspended per Commission Order No. 30625
151 Standard for Service Service to the customer shall assure the
customer of adequate pressure, a definite
heat content, and accurate measurement
of gas.
The Company shall ensure that customers
receive service with adequate pressure, heat
content, and accurate measurement of gas
consumption. (Avista Regulation No. 24)
All meters with capacities up to and
including four hundred (400) cubic feet
per hour (cfh) that have been in service
ten (10) or more years as established by
last set date shall be tested within a
prescribed sample size as determined in
accordance with military standard 105D
The methodology for sample sizes and
analysis for the installed meter testing
program is derived from the American
National Standards lnstitute (ANSI) /
American Society for Quality (ASQ) Standard
21.9 (Standa rd 27.9) and other generally
accepted inspection standards.
i. For diaphragm meters 1000 CFH and
smaller, a random sample of meters shall be
selected, tested within a prescribed sample
size, and analysis conducted using Standard
21.9. The random sampling program shall
begin during the 10th year after meter
installation, as established by last set date.
(Avista Regulation No. 25.C.2.c.i)
t52.OZ Testing of Larger
Capacity Meters
All meters from four hundred one (401)to
three thousand (3,000) cfh that have been
in service ten (10) years as established by
last set date shall be replaced or field
tested.
Larger capacity meters shall be tested per
the Avista Utilities Gas Standards Manual.
(Avista Regulation No. 25.C.2.c.ii)
Attachment I
Case No. AVU-G-18-07
Staff Comments
10/24/18 Page 2 of 5
152.01Testing of
Smaller Capacity Meters
153.01 Meter Proving Each gas corporation shallown at least
one meter prover of a type approved by
the Commission and shall maintain such
equipment in proper adjustment and so
calibrated that the error of indication shall
not exceed one-half (%) percent. No meter
prover shall be so placed as to subject it to
excessive temperature variation and each
meter prover shall be equipped with
suitable thermometers and other
necessary accessories.
All tests to determine the accuracy of
registrations of gas service meters shall be
made with a suitable meter prover or testing
equipment. (Avista Regulation No. 25.C)
153.02 Additional Meter
Proving Stations
Additional meter proving stations shall be
installed when and where found
necessary by the Commission.
lntentionally Omitted
153.03 Testing
Apparatus for Large
Capacity Meters
Each gas utility using orifice meters, high
pressure meters, proportional meters, or
other large capacity meters shall own and
maintain testing apparatus of a type
approved by the Commission
lntentionally Omitted
153.04 Accuracy of
Meter Provers and
Testers
The accuracy of all provers and methods
of operation may be established from
time to time by a representative of the
Commission. Any alterations, accidents, or
repairs that might affect the accuracy of
any meter prover, or the method of
operating it, shall be promptly reported in
writing to the Commission.
lntentionally Omitted
154.01 Accuracy of
Meters
A new gas meter installed for the use of
any customer shall not be more than two
(2) percent slow and not more than one
(1) percent fast. Every meter removed
from service when opened for repairs
shall be adjusted to be not more than two
(2) percent slow and not more than one
(1) percent fast before being reset; and if
not opened for repairs may be reset
without adjustment if found to be not
more than two (2) percent in error fast or
slow, when passing as in both instances at
the test rates provided for in Rule 155
(Customer Meter Test Loads).
A new gas meter installed for the use of any
customer shall not be more than one (1)
percent slow and not more than one (1)
percent fast. Any meter removed from
service for testing or repair shall be adjusted
to the tolerance prescribed by the Avista
Utilities Gas Standards Manual prior to being
reinstalled. (Avista Regulation No. 24)
Attachment I
Case No. AVU-G-18-07
Staff Comments
10124118 Page 3 of 5
154.02 Removalof
Defective Meters from
Service
Removalof Defective Meters from
Service. No meter that is mechanically
defective shall be placed in service or
allowed to remain in service after the
defect has been discovered. When any gas
meter is not connected in service, the
inlet and outlet shall be capped to prevent
the drying out of the diaphragms.
No meter that is mechanically defective shall
be placed in service or allowed to remain in
service after a defect has been discovered.
(Avista Regulation No. 24)
155.01 Testing of Meters All tests to determine the accuracy of
registrations of gas service meters shall be
made with a suitable meter prover or
testing equipment. Unless exempted by
order of the Commission, at least two test
runs shall be made on each bellows type
displacement meter, the results of which
shall agree with each other within one-
half of one percent.
lntentionally Omitted
155.02 Gas Flows During
Testing
The rate of flow to be used in testing
meters having capacities up to and
including three thousand (3,000) cubic
feet per hour shall be twenty (20) percent
and one hundred (100) percent of the
rated capacity. The one hundred (100)
percent capacity or open run test shall not
be taken into consideration in arriving at
the accuracy of these meters. Meters
having capacities of above three thousand
(3,000) cubic feet per hour, except orifice
meters, shall be tested both at twenty
(20) percent and one hundred (100)
percent of their capacity. For the purpose
of determining the accuracy of these
meters, the average of twenty (20)
percent and one hundred (100) percent
tests shall be used.
New Meter Testing Program. a. New meters
shall be factory tested and certified to meet
accuracy criteria as specified herein. b.
Acceptance testing shall be performed by
the Company prior to installation of new
meters per the Avista Utilities Gas Standards
Manual.
lnstalled Meters Testing Program. a.
lnstalled meters shall be inspected and
tested against metering tolerance prescribed
herein and per the Avista Utilities Gas
Standards Manual. b. Meters found to be
outside the prescribed tolerances shall be
immediately adjusted or replaced. No meter
shall be reinstalled if found to be more than
two (2) percent slow or fast when tested at
the prescribed rate(s) of flow.
(Avista Regulation No. 25.C)
Affachment I
Case No. AVU-G-18-07
staff comments
10/24118 Page 4 of 5
156.01 Records of Meter
Tests
Each gas corporation shall keep records of
tests of the accuracy of each of its meters,
until superseded by a later test, but not
less than two years. These records shall
give: a. sufficient information to identify
the meter, b. the reason for the test, c.
the date of the test and reading of the
meter, d. the name of the person making
the test, and e. the accuracy as found and
as left, together with enough of the data
taken at the time of the test to permit the
convenient checking of the methods
employed and the calculations.
Meter history records shall be maintained
until superseded by a later test, but not less
than two years. These records shall give: 1.
sufficient information to identify the meter,
2. the reason for the test, 3. the date of the
test and reading of the meter, 4. the name
of the person making the test, and 5. the
accuracy as found and as left, together with
enough of the data taken at the time of the
test to permit the convenient checking of
the methods employed and the calculations.
(Avista Regulation No. 25.B)
156.02 Results of Meter
Tests
Each gas utility shall annually make
tabulations of the results of all meter
accuracy tests required by these rules.
After December 31st of each year, results of
the installed meter testing program will be
summarized, analyzed, and made available
at the request of the Commission.
(Avista Regulation No. 25.A)
157 Meter Tests
Requested by Customers
Section 6!-522, ldaho Code, states:
Consumer may have commodity or
appliance tested. Any consumer or user of
any product, commodity, or service of a
public utility may have any appliance used
in the measurement thereof tested upon
paying the fees fixed by the commission.
The commission shall establish and fix
reasonable fees to be paid for testing such
appliances on the request of the
consumer or user, the fee to be paid by
the consumer or user at the time of his
request, but to be paid by the public utility
and repaid to the consumer or user if the
appliance is found defective or incorrect
to the disadvantage of the consumer or
user under such rules and regulations as
may be prescribed by the commission.
The Company will, without charge, test the
accuracy of registration of a meter upon
request of a Customer, provided that the
Customer does not request such a test more
frequently than once in a 12-month period.
lf a Customer requests more than one meter
test within any 12-month period, the
Company shall inform the Customer, prior to
the test, that if the meter is found to register
within the 2 percent accepted tolerance
standard, under normal operating
conditions, the Customer shall be required
to pay the actual cost to perform the meter
test. No billing adjustment shall be required
if the test results show an average
registration error of less than 2 percent.
(Avista Regulation No. 25.D)
Attachment I
Case No. AVU-C-18_07
Staff Comments
10/24/18 page 5 of 5
NOTICE OF
CANCELLATION
Custodians:
Army - AR
Navy - OS
Air Force - 10
MIL-STD-I05E
NOTICE 3
06 February 2008
SL}PERSEDING
NOTICE 2
26March200l
MILITARY STANDARD
SAMPLING PROCEDURES AND TABLES
FOR INSPECTION BY ATTRIBUTES
MIL-STD-105E, dated 10 May 1989, is hereby canceled. Future acquisitions may refer to:
MIL-STD-1916, "DoD Preferred Methods for Acceptance of Product", or ANSI/ASQ 21.4,
"Sampling Procedures and Tables for Inspection by Attributes".
Users are cautioned to evaluate these documents for their particular application before citing
it as a replacement document.
(Copies of MIL-STD-1916 are available online at http://assist.daps.dla.mil or from the
Standardization Document Order Desk, 700 Robbins Avenue, Building 4D, Philadelphia, PA
19111-s094.)
(Copies of ANSI/ASQ Zl .4 are available online at www.asq.org or ASQ Distribution Center,
513l S. Third Street, Milwaukee, Wisconsin 53207-6028.)
NOT MEASUREMENT
SENSITIVE
Preparing activity:
Army - AR
(Project QCIC-2008-00 I )
Note: The activities listed above were interested in this document as of the date of this document.
Since organizations and responsibilities can change, you should verify the currency of the
information above using the ASSIST online database at http://assist.daps.dla.mil
ASMC N/A AREA QCIC
DISTRIBUTION STATEMENT A. Approved for public release; distribution is unlimited.
Source: https://assist.dla.mil -- Downloaded: 2018-10-1OT16:482
Check the source to verify that this is the current version before use
Attachment 2
Case No. AVU-G-18-07
Staff Comments
10t24118
Small-capacity meters up to 1000 CFH are grouped into "families" based on the state in
which they are installed, the manufacturing date, and the type and make of the meter.
For example, all American AC250TC meters manufactured in the year 1980 and set in
the state of ldaho constitute one family. A statistical sampling of meters to be tested in
each family is generated at the beginning of the year. The number of meters to be
tested is determined by the size of the family and the past performance of that family.
For all other meter sizes, eligible meters are selected based on their type, age, and the
last test date.
Meters that are eligible for PMC may be pulled either through a dedicated PMC service
order or when meter sites are visited for other purposes. The following table lists the
requirements by meter type and size.
Prover
Calibration lnterval
Meter Type and Size Test Frequency
Diaphragm, 250-1 000 CFH Statistical sampling
Diaphragm, between 1000 and 3000 CFH Every 10 years
Diaphraom, 3000 and qreater CFH Every 5 vears
Rotary, allsizes Differential test every 5 years
Turbine, all sizes Spin test annually and proof tested
every 10 years
Meter Provers Calibration Interval
SNAP Prover or Bell Prover Every Second Calendar Year
Transfer Prover Every Second Calendar Year
METERING & REGULATION
METER DESIGN
REV. NO. 18
DATE 01101t18frvtsraSTANDARDS18 0F 20
SPEC.2.22Wilitias
NATURAL GAS
Attachment 3
Case No. AVU-G-18-07
Staff Comments
t0/24118
AVISTA IJTILITIES
GAS METER
MEASIJREMENT
PERFORMANCE PROGRAM
(PMC PROGRAM)
GAS METER SHOP - STANDARD OPERATING PROCEDURE &vrrs
Title: Gas Meter Measurement Performance Program Date:'J./1.112
Jurisdiction: Washington, ldaho, Oregon Manager: David Howell Page 1 of 14
Attachment 4
Case No. AVU-G-18-07
Staff Comments
10124118 Page I of 14
CONTENTS
1. CONTENTS2. SCOPE3. GENERAL4. GAS METER MEASUREMENT PROGRAM REQUIREMENTS5. APPENDIX - COMPLIANCE STANDARDS
a. IDAPA 31.31.01.000, "Service Rules for Gas Utilities", Rules l5l-200 (Standards for
service)b. Avista OR Gas Tariff Rule No. 18, effective dates April 1, 2008 tlrru January 1,2012c. OAR 860-023 (Public Utility Cornrnission)d. Avista gas tariff Rule No. 170, Section 20, effective Novernber 30,2011
e. WAC 480-90 "Gas companies - operations", Section 333, 338, 343, 8L 348
GAS METER SHOP - STANDARD OPERAT!NG PROCEDURE AEvrcra
Title: Gas Meter Measurement Performance Program Date:1./1./L2
Jurisdiction: Washington, ldaho, Oregon Manager: David Howell Page 2 of t4
Attachment 4
Case No. AVU-G-18-07
StaffComments
l)l24ll8 Page2 of 14
SCOPE
This procedure covers the methodology, testing requirements, and annual reporting guidelines for
Avista's gas meter measurement performance testing program (PMC Program) for new and in-service
meters.
Deviations or changes to this SOP (Standard Operating Procedure) shall be approved by the Gas
Measurement Manager. Material changes require collcurrence with thc govcming commission. Non-
material changes shall be submitted to the commissions in conjunction with annual meter performance
statistics.
GAS METER SHOP - STANDARD OPERATING PROCEDURE &vtsr,a
Title: Gas Meter Measurement Performance Program Date:1./1./L2
iurisdiction: Washington, ldaho, Oregon Manager: David Howell Page 3 of 1,4
Attachment 4
Case No. AVU-G-18-07
Staff Comments
l1l24ll8 Page 3 of l4
GENERAL
COMPLIANCE
Oregon: Gas meter testing requirements for Avista are promulgated by Oregon Administrative Rules,
Chapter 860, Division 023 "Service Standards", Section 0015 (Testing Gas and Electric Meters). It is the
intent that this prograrn is in accordance with the aforementioned Oregon Adrninistrative Rules.
Idaho: Gas meter testing requirements for Avista are promulgated by Title 3 1, Chapter l, "service Rules
for Gas Utilities", IDAPA 31 .31.01 .000, Rules I 51-200 (Standards for scrvice). Avista gas mctcr tcsting
program is cornpleted in accordancc with IDAPA 31.31.01.0000* and Avista Gas Meter Testing Program
dated llll20l2.
*(Rule 152 - Avista's randotn sampling prograln is completed for meters 0-1000 CFH and in accordance
with ANSI/ASQ 21.9, Inspection by Variables. The IDAPA rule refers to the obsolete military standard
105D, Inspcction by Attributes.)
llasltington' Gas meter testing requirements for Avista are promulgated by Washington Adrninistrative
Code, Chapter 480-90 "Gas companies - operations", Section 333 (lnitial accuracy of meters), Section
338 (Metcring tolerance), Section 343 (Staternent of meter test procedures), and Section 348 (Frequency
of periodic meter tests. Avista gas tariff Rule No. 170, Section 20, effective November 30, 201 l, has
been approved and is in compliance with the requirernents of WAC 480-90 and prescribes the minimum
inspection and testing requirements. It is the intent that this program is in accordance with WAC 480-90
HISTORY
Avista's current random meter measurement performance program is in accordance with ANSI Zl.9
(lnspection by Variables). Random sampling and testing is completed for all domestic meters 1000 CFH
and smaller. The program was revised and upgraded in 2009. The prior program was in accordance with
inspection standard ANSI Zl.4 (lnspection by Attributes). The change in inspection standard and
programmatic changes were completed in order to enhance the quality and accuracy of the measurement
performance program.
In 2011 the gas meter testing program was enhanced as follows:o Random sampling program - Redefined a meter population. Previously a meter population was
defined as meters of the same model, installed in the sarne State jurisdiction, and purchased in the
sarne year. The revised definition for a meter population now includes meters of the same model,
size, and manufactured in the salne year. The new dcfinition rcmoves the criteria to test meters by
state. A statistical analysis of meter testing results for all three (3) states revealed that the mean
accuracy and standard deviation of accuracy about the meall are similar for all three states and
that any difference is not statistically significant, indicating that state test results can be
combined. Random sampling gas mcter testing requirements for 2012 were developed using the
revised meter population definition.
GAS METER SHOP - STANDARD OPERATING PROCEDURE &vtsru
Title: Gas Meter Measurement Performance Program Date:1./t/L2
Jurisdiction: Washington, ldaho, Oregon Manager: David Howell Page 4 of t4
Aftachment 4
Case No. AVU-G-18-07
Staff Comments
10124/18 Page 4 of 14
a
a
Installed turbinc Meters: Changes were madc to cxpand turbinc testing requiremcnts to include
both single rotor and dual rotor auto adjust meters.
lnstalled rotaty tneters; Changes were made to provide clarilication regarding necessary test
requirements for rotary meters.
GAS METER SHOP - STANDARD OPERATING PROCEDURE lHivtsra
Title: Gas Meter Measurement Performance Program Date:1.h/L2
iurisdiction: Washington, ldaho, Oregon Manager: David Howell Page 5 of 14
Attachment 4
Case No. AVU-G-18-07
Staff Comments
l}l24l18 Page 5 of 14
GAS METER MEASUREMENT PROGRAM REQUIREMENTS
I. Tests of Customer Meters
a. Avista shall maintain a quality control program to verify performance accuracy of new
meters and installed ureters.
b. Testing of Small Capaci{z Meters. All meters with capacitics up to and including one
thousand ( 1,000) cubic feet per hour (cft) at %" differential prcssure that havc bcen in
servicc ten ( l0) or rlore years as established by either the last install date or manufacture
date shall be tested through annual random sampling using sample size methods in
accordance with ANSI/ASQ-Z1.9 or other generally accepted statistical method that
confbrms to the requirements of the applicable sections of ANSI B.109.1 and 8109.2
measuring in-seruice performance of diaphragm type gas metel's.
Testing of Larger Capacity Meters. All meters with capacities greater than one thousand
(1,000) cflr that have been in service ten (10) years as established by either last install or
manufaclure date shall be replaced or ficld tcsted based on a periodic schedule.
Diaphragm type meters shall be tested in accordance with applicable sections of ANSI
B109.1 and 8109.2. Rotary type nleters shall be tested in accordance with applicable
sections of ANSI 8 109.3.
II. Customer Meter Accuracy
a. Accuracy of Metersi. Pressure Differential (Diaphragm) Meters:l. A new gas meter installed for the use of any customer shall not be more
than one (1) percent slow or fast.
2. Every meter removed from seryice and opened for repair shall have the
meter tolerance adjusted to 100% plus or minus 0.57o, with no greater
spread than 0.lYo between the check and open prior to being reinstalled.3. Meters not opened for repairs may be reinstalled without adjustment if
found to be not more than two (2) perccnt in error fast or slow, when
passing as in both instances at the test rates provided for in Section E
(Customer Meter Test Loads).
ii. Rotary Meters
1. A new gas meter installed for the use of any customer shall not be more
than one (1) percent slow or fast.
2. Meters inspected by differential testing shall confirm that the meter is
performing within 150% of the manufacturer's specification for
differential pressure at the operating pressure.
3. Every meter tested by proving shall be adjusted to be not more than two
(2) percent slow or fast before being reinstalled.
iii. Turbine Meters
l. A new gas meter installed for the use of any customer shall not be more
than one (1 ) percent slow or fast.
C
GAS METER SHOP - STANDARD OPERATING PROCEDURE &vtsrrn
Title: Gas Meter Measurement Performance Program Date:1.1L/t2
Jurlsdiction: Washington, ldaho, Oregon Manager: David Howell Page 6 of L4
Attachment 4
Case No. AVU-G-18-07
Staff Comments
l}l24l18 Page 6 of l4
2. Meters inspected by spin testing shall confinn that the meter is
perfonning within the manufactures lirnits.3. Every meter tested by proving shall be adjusted to be not more than two
(2) percent slow or fast before being reinstalled.
b. Removal of Defective Meters liom Service. No meter that is rnechanically defective shall
be placed in service or allowed to remain in seryice after the def'ect has been discovered.
When any gas meter is not connected and in service, the inlet and outlet shall be capped
to prevent the drying out of diaphragms. The exception shall be when stored indoors
during the testing and/or repair process.
m. Customer Meter Test Loads
a. Testing of Meters, Test Equipment. All tests to determine the accuracy of registrations of
gas service meters shall be made with a suitable meter prover or testing equipment as
detailed in this standard.
b. Gas Flows During Testing. The rate of flow to be used in tcsting meters, except orifice
type meters and high volume meters with capaciry in excess of test equiprnent capability,
shall be tested both at twenty (20) percent (Check) and one hundred (100) percent (Open)
of their capacity. For the purpose of determining the accuracy of these meters, the
average of the two flow volume tests shall be used.
High Volume Meters. Turbine and rotary meters that have rated capacities in excess of
the mechanical limits of the proving equiprnent shall be tested at a minimum of two
points of flow with each at or above a minimum of l5Yo of the rated capacity of the
meter. For purposes of the test the two tests shall be averaged and shall conform to the
standards set forth in Section II (customer meter accuracy).
IV. Meter Test Procedures and Test Records
a. Reportingi. After December 31 of each year, meter test results will be summarized, analyzed
and forwarded to the Commission. Retention and filing of records will be in
accordance with the appropriate Commission rcquirements.
b. Test Recordsi. After December 3I of each year, meter test results will be summarized and
analyzed. Each gas utility shall annually make tabulations of the results of all
meter accuracy tests required by these rules. Retention of records will be in
accordance with the appropriate Commission as follows:l. ldaho: IDAPA 31.31.01.1562. Oregon: OAR 860-023-0015(4)
3. Washington: WAC 480-90-353
c
GAS METER SHOP - STANDARD OPERATING PROCEDURE &vrcrs
Title: Gas Meter Measurement Performance Program Date:1./1/1.2
Jurisdiction: Washington, ldaho, Oregon Manager: David Howell PageT oft4
Attachment 4
Case No. AVU-G-18-07
Staff Comments
l)l24ll8 Page 7 ol 14
Each gas corporation shalI keep records oftests ofthe accuracy ofeach ofits
meters, which may be superseded by a later test, but shall be maintained for not
less than two years. These records shall give:
l. sufficient information to identify the meter,2. the reason fbr the test,
3. tlie date of the test and reading of the rneter,4. an identification of the person making the test, and5. accuracy, as found and as left, together with enough ofthe data taken at
the time of the test to pennit the convenient checking of the methods
employed and the calculations.
Technical Standard. Technical perfbrmancc requircments for diaphragm natural gas
meters shall be per the current versions of ANSI B 109. I and ANSI 8109.2. Technical
performance requirements for rotary type natural gas meters shall be per the current
versions of ANSI 8 109.3.
d. Uniquely Defective Test. An individual meter test result within a random sample of
more than 10% error shall be declared a uniquely defective test and disregarded. A
substitute test will be made with meter selected froni within the same test farnily. Subject
meter shall be adjusted or replaced.
V. New Meters
a. New meters shall be factory tested and certified to meet acclrracy criteria specified by
Section D.
Manufacturers shall provide results of ncw meter tcsting that conforms to
generally accepted practice for meter accuracy and perfonnance. Diaphragm
meters shall meet the standards set forth in ANSI B109.1 and ANSI 8.109.2.
Rotary meters shall meet the standards set fbrth in ANSI B109.3.
b. Inspection and acceptance testing by the Utility prior to installation of new meters
i. Each meter shipment will be inspected for physical damage. Meters found to be
darnaged or in damaged packaging will be tested, repaired and/or calibrated or
returned to the manufacturer as described herein. All costs for tests, return
shipping and/or calibration to meters described in this section sliall be borne by
the manufacturer.
ii. Normal acceptance testing described herein, not associated with physical damage
found on arival of the shipment, will be perfonned by the Utility at the Utility's
expense for all meters not f'actory tested prior to shipment. Expanded testing
beyond nomal test quantities for shipments found to be non-confonning througlt
acccptance testing will be paid for by the manufacturer or the shipment retumed
to the manufacturer per ncgotiations between the Utility and thc rnanufacturer.
GAS METER SHOP - STANDARD OPERATING PROCEDURE frvrcru
Title: Gas Meter Measurement Performance Program Date:1./1.11.2
Jurisdiction: Washington, ldaho, Oregon Manager: David Howell Page 8 of 14
Attachment 4
Case No. AVU-G-18-07
Staff Comments
l)l24ll8 Page 8 of 14
c. New diaphragx type meters, less than or equal to 1000 CFH:
i. The rnethodology for the random sarnplir-rg of new meters is derived from
ANSVASQ Zl.9 or other gcnerally accepted statistical rncthod that confonns to
the requirements of the applicable sections of ANSI B.l09.l and B109.2.
l. The lot size to determine random sample quantity shall be the size of the
shipment
2. Acceptable Quality Limit (AQL) for analysis of new meters will equal
1.5.
ii. Sarnple size:
l. Normal inspection is the default inspection level.2. Sample size for meter types with five (5) test histories are eligible for
application of switching rules in general accordance with the guidelines
contained within the Standard as modified below.3. Switching Rules:
a. Normal to tightened: Switching rules for transition from normal
to tightened inspection shall be applied if 2 out of 5 lots have
been rejected on original inspection. Testing beyond the sarnple
size for normal inspection lcvcl will be paid for by the
manulbcturer.b. Tightened to Normal: Switching rules tbr transition fi'om
tightened to normal inspection may be applied when testing has
been at the tightened level and 5 consecutive batches have been
acceptable on original inspectionc. Normal to Reduced: Switching rules for transition frorn normal
to reduced inspection (inspection level II to inspection level III)
may be applied if:
Preceding 5 lots have been on normal inspection and
none have been rejected, AND
Meter model has been in steady production without
major design modifications (as detennined by the
Company).
d. Rcduced to Normal: Switching rules for transition from reduced
to normal (inspection level III to inspection level II) shall be
applied if:
i. A batch is rejected under reduced inspection, ORii. Meter model has not been in steady production or a
major design modification has occurred (as determined
by the Company).
4. Random sampling per the Standard shall be discontinued if 5 consecutive
lots under tightened inspection are not accepted. Acceptance procedures
1l
GAS METER SHOP - STANDARD OPERATING PROCEDURE ^&vrcrxTitle: Gas Meter Measurement Performance Program Date: L/t/L2
Jurisdiction: Washington, ldaho, Oregon Manager: David Howell Page 9 of 14
Attachment 4
Case No. AVU-G-18-07
Staff Comments
l}l24ll8 Page 9 of 14
as detailed herein shall not be rcsumed until corrective action has been
taken. At that time, tightened inspection procedures shall be used.
i. New large capacity diaphragm meters shall be tested against metering tolerance
of Section D.ii. Meters found to be outside of tolerance shall be adjusted per section D. If the
meter cannot be adjusted within these standards, it shall be returned to the
manufacturcr.
e. Ncw rotary meters.
i. Rotary meters shall meet the accuracy requirements as specilied in Section D and
appropriate requirements of ANSI 8 1 09.3.
f. New turbine meters.
New turbine meters shall meet the accuracy requirements as specified in Section
D and shall be spin tested at installation to verify they will operate within the
accuracy limits as specified by the manufacture.
VI. Installed meter testing program
a. General: Meters shall be inspected and tested against metering tolerance prescribed in
Section D. Meters found to be outside the tolerances shall be imrnediately adjusted or
replaced.
b. Domestic meters. diaphragm type 1000 CFH and smaller. randomly sampled: A random
sample of domestic meters shall be selected, tested against tolerances prescribed by
Section D.1, and analysis conducted using the Standard. The annual random sampling
program shall begin during the lOth year after meter manul'acture date. The methodology
fbr sample sizes and analysis for the meter testing program is derived from ANSI/ASQ
Zl .9 (hereafter may be refemed to as the Standard) or other generally accepted statistical
method that conforms to the requirernents of the applicable sections of ANSI 8.109.1 and
8109.2 measuring in-service perforrnance of gas rncters.
i. The lot size to determine random sample quantity shall be the size of the meter
population. A meter population should include randomly sampled meters in
approximate proporlion to the number of meters installed in each operating area.
ii. A meter population is defined as meters of the same rnodel, size, and
manufactured year.
l. Meter population is synonymous with thc term lot as used in the
Standard.
2. Major design changes to a meter model within a single year shall be a
new population for sampling
GAS METER SHOP - STANDARD OPERATING PROCEDURE .&vtsru
Title: Gas Meter Measurement Performance Program Date:1./'J./1.2
Jurisdiction: Washington, ldaho, Oregon Manager: David Howell Page 10 of L4
Attachment 4
Case No. AVU-G-18-07
Staff Comments
10124118 Page 10 of l4
d. Ncw diaphragrn meters, greater than 1000 CFH.
lil Random sample of meters to be tested within a population will be identified at
the beginning of a calendar year. The year's random sample may be modified as
described below. Meters shall be chosen at randorn and in sufficient quantities to
rneet the guidelines for sarnpling as detailed in the standard.
1. Every meter in a population will be considered eligible tbr testing. If
seruice work brings a service person to a meter that was not chosen via
the beginning of year randorn sample, and the required test quota of
meters has not yet been completed, the meter located at the service work
site will be eligiblc for substitution into the test samplc of the meter
population for that year.
2. A meter in the beginning of year random sarnple list for the year will
then be removed tiom the scheduled test list.3. Meter populations 50 or fewer units are subject to modified sample size.
Sample quantity shall be set to avoid repeat testing of a meter more than
once every ten years.
iv. Inspection Levels, Sample Size and Test result analysis:
1. General: Analysis of population sample results shall conform to the
guidelines contained in the Standard. Acceptable Quality Limit (AQL)
for analysis will equal 10.0.2. Normal inspection is the default level of inspection.3. Inspection levels fbr meter types with 5 year test histories are eligible fbr
application of switching rules.4. Switching rules:
a. Normal to tightened: Switching rules for transition from normal
to tightened inspection shall be applied if 2 out of 5 lots have
been rejected.b. Tightened to Normal: Switching rules for transition from
tightened to nonnal inspection may be applied when testing has
been at the tightened level and 5 consecutive batches have been
acceptable.
c. Normal to Reduced: Switching rules for transition from normal
to reduced inspection may be applied if:
i. Preceding 5 lots havc been on normal inspection and
none have been rejected.
d. Reduced to Normal: Switching rules for transition from reduced
to normal shall be applied if:
i. A batch is rejected.
5 Discontiuuc randonr samnl in failure of mcter pooulation. A meter
population shall be declared dcfcctive and removed from service when:
GAS METER SHOP - STANDARD OPERATING PROCEDURE &vtsra
Title: Gas Meter Measurement Performance Program Date:1./1.11.2
Jurisdiction: Washington, ldaho, Oregon Manager: David Howell Page 11 of 14
Attachment 4
Case No. AVU-G-18-07
Staff Comments
10124/18 Page ll of 14
a. 3 consecutive yearly inspections for a population under tightened
inspection are not accepted based on AQL of 10.0 for overall
performance (double specification limit).
6. Removal of failed meter population: Removal of a meter population of
less than 2500 units during the year following having failed2
consecutive years of testing under tightened test criteria. Removal of
meter population of more than 2500 units may take place over 2 years.
Removal of meter population of more than 5000 units may take place
over 3 years. Removal of meter population of more than 7500 units may
take place over 4 years.
Installed diaphragm meters, greater than 1000 CFH, periodic test.
i. 1001 CFH through 3000 CFH: Inspected and proved evety ten (10) years or
sooner.ii. Larger than 3000 CFH: Inspected and proved every five (5) years or sooner.iii. All rneters shall be tested against metering tolerarrce of Section D.
iv. Meters found to be outside of tolerance shall be adjusted to within the tolerances
as specified in Section D.
d. Installed rotary meters, periodic test
i. Testing of installed rotary meters will be done using either a portable transfer
prover or differential testing device. A differential test shall confirm a minimum
of 2 points. Results of a differential test or prover test shall show that the meter
is perfonning within the accuracy as detail in Section D.
ii. Meters shall be inspected and tested every five (5) years or sooner.
c Installcd turbine metcrs, periodic test
i. Installed single rotor turbine meters shall be inspected and spin tested annually
and determined to be within the manufactures acceptability limits. Turbine
meters failing the spin test shall be removed frorn the field and repaired prior to
any subsequent installation.ii. Installed auto adjust meters shall be inspected annually and determined to be
operating within the manufactures acceptability limits. Meter Delta A (AA), the
difference between the main and scnsing rotor pulses, that cxceed the
manufactures recolnmended operating parameters shall be repaired or replaced.
iii. All turbine meters will be transfer proveu at a maximum intewal of every ten
years. Meters that are tested using a prover shall meet or exceed the meter
accuracy requirements of Section D.
GAS METER SHOP _ STANDARD OPERATING PROCEDURE &utsrl
Title: Gas Meter Measurement Performance Program Date:1./111.2
Jurisdiction: Washington, ldaho, Oregon Manager: David Howell Page 12 of L4
Attachment 4
Case No. AVU-G-18-07
Staff Comments
10124118 Page 12 of 14
VII. Meter Test Equipment and Application
a. Meter test equipment
i. Transfer Prover. The accuracy of the testing equipment is ascertained through:
l. Monthly, in-house self testing procedures
2. Sending of Standard Meter Module to the manufacturer for periodic
calibration. The period between factory calibrations shall not exceed
frve (5) years.
b. Sonic Nozzle Prover and Bell Prover
i. The accuracy of the testing equipment is ascertained through an automatic test
diagnostic. The diagnostic is completed each time the prover is powered on.
ii. The test equipment shall be factory calibrated every two (2) years.
c. Meters shall be tested on either: Sonic Nozzle, Bell Prover, or Transfer Prover.
GAS METER SHOP - STANDARD OPERATING PROCEDURE &vrcrr
Title: Gas Meter Measurement Performance Program Date:1./L/L2
Jurisdiction: Washington, ldaho, Oregon Manager: David Howell Page 13 of 14
Attachment 4
Case No. AVU-G-18-07
staff comments
l)l24l18 Page l3 of 14
APPENDIX _ COMPLIANCE STANDARDS
IDAPA 31.31.01.000, "Service Rules for Gas Utilities", Rules l5l-200 (Standards for service)
Avista OR Gas Tariff Rule No. 18, eflbctive dates April l, 2008 thru January 1,2012
OAR 860-023 (Public Utility Commission)
Avista gas tarilTRule No. 170, Section 20, effective November 30, 20l l
WAC 480-90 "Gas companies - opcrations", Section 333, 338, 343, & 348
GAS METER SHOP - STANDARD OPERATING PROCEDURE &vrcra
Title: Gas Meter Measurement Performance Program Date:1./111.2
Jurisdiction: Washington, ldaho, Oregon Manager: David Howell Page L4 of 14
Attachment 4
Case No. AVU-G-18-07
Staff Comments
10/24/18 page t4 of t4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF OCTOBER 2018,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. AVU-G-18.07, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-MAIL: linda. [e-mail]
avistadockets@ avi stacom. com
DAVID J MEYER
VP & CHIEF COI.]NSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: [e-mail]
-b
CERTIFICATE OF SERVICE
SECRETAryV