20050914Petition for waiver.pdf

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Morgan W. Richards
ISB # 1913
804 East Pennsylvania Lane
Boise, Idaho 83706
Telephone [phone]
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Attorney for Intennountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
INTERMOUNTAIN GAS COMPANY
FOR WAIVER TO MODIFY ATMOSPHERIC
CORROSION CONTROL PATROL FREQUENCY
Case No. INT -05-
PETITION FOR WAIVER
Intennountain Gas Company ("Intennountain ), an Idaho corporation with general
offices located at 555 South Cole Road, Boise, Idaho, hereby requests a waiver from IDAP
31.11.01 - Safety and Accident Reporting Rules for Utilities, Rule 201 (SARR 201), compliance
with the Code of Federal Regulations, Title 49, Section 192.481(a), as it pertains to exposed
facilities associated with residential meters.
Communications in reference to this Petition should be addressed to:
Eldon Book
Sr. Vice President, General Manager of Utility Operations
Intennountain Gas Company
Post Office Box 7608, Boise, ID 83707
and
Morgan W. Richards
Attorney
804 East Pennsylvania Lane, Boise, ID 83706
In support of this Petition, Intennountain does allege and state as follows:
Intennountain is a gas utility, subject to the jurisdiction of the Idaho Public Utilities
Commission, engaged in the sale of and distribution of natural gas within the State of Idaho
under authority of Commission Certificate No. 219 issued December 2 , 1955 , as amended and
supplemented by Order No. 6564, dated October 3 , 1962.
Intennountain provides natural gas service to the following Idaho communities and
counties and adjoining areas:
Ada County - Boise, Eagle, Garden City, Kuna, Meridian, and Star;
Bannock County - Chubbuck, Inkom, Lava Hot Springs, McCammon, and Pocatello;
Bear Lake County - Georgetown, and Montpelier;
Bingham County - Aberdeen, Basalt, Blackfoot, Firth, Fort Hall, Moreland/Riverside, and
Shelly;
Blaine County - Bellevue, Hailey, Ketchum, and Sun Valley;
Bonneville County - Ammon, Idaho falls, Iona, and U con;
Canyon County - Caldwell, Greenleaf, Middleton, Nampa, PaTIna, and Wilder;
Caribou County - Bancroft, Conda, Grace, and Soda Springs;
Cassia County - Burley, Dec1o, Malta, and Raft River;
Elmore County - Glenns Ferry, Hammett, and Mountain Home;
Fremont County - Parker, and St. Anthony;
Gem County - Emmett;
Gooding County - Gooding, and Wendell;
Jefferson County - Lewisville, Menan, Rigby, and Ririe;
Jerome County - Jerome;
Lincoln County - Shoshone;
Madison County - Rexburg, and Sugar City;
Minidoka County - Heyburn, Paul, and Rupert;
Owyhee County - Bruneau, and Homedale;
Payette County - Fruitland, New Plymouth, and Payette;
Power County - American Falls;
Twin Falls County - Buhl, Filer, Hansen, Kimberly, Murtaugh, and Twin Falls;
Washington County - Weiser.
Intennountain s properties in these locations consist of transmission pipelines, a
compressor station, a liquefied natural gas storage facility, distribution mains, services, meter
and regulators, and general plant and equipment.
II.
Intennountain seeks with this Petition for Waiver to obtain a waiver from compliance
with the Code of Federal Regulations, Title 49, Section 192.481(a). This section of the code
requires operators of natural gas pipelines to "inspect each pipeline or portion of a pipeline that is
exposed to the atmosphere for evidence of atmospheric corrosion.. .at least once every 3 years
but with intervals not exceeding 39 months.
Currently, Intennountain inspects regulator stations, commercial and large volume meters
for atmospheric corrosion on an annual basis which allows us to incorporate the atmospheric
corrosion inspections with other routine maintenance that is required, by code, on an annual
basis. By this waiver, Intennountain is requesting a change to the atmospheric corrosion
inspection interval for residential meters from three (3) years to four (4) years.
III.
In July of2003 , Intennountain implemented an automated meter reading (AMR) system
for residential and commercial meters to improve customer service through more accurate meter
reads and to continue improvement in operating efficiencies. Prior to July of2003
Intennountain perfonned the atmospheric corrosion control monitoring on residential and
commercial meters and associated exposed piping in conjunction with the monthly meter reading
function. Meter readers, on foot, would perfonn a visual inspection of the above ground
facilities associated with a residential or commercial customer meter as they perfonned their
monthly meter reads. Intennountain does not have a regular maintenance need or requirement to
visit each residential meter on an annual basis.
Intennountain has never experienced atmospheric corrosion or safety-related conditions
resulting from atmospheric corrosion on our residential or commercial meters in the entire
history of our operations, dating back to 1955. This is a direct result of the dry, arid
environment Intennountain operates in and the fact that the entire steel pipeline system is
cathodically protected.
With the implementation of AMR, Meter Readers are no longer physically observing
each residential and commercial meter during the course of routine meter reading to visually
examine for atmospheric corrosion on residential and customer meters and associated exposed
piping. The results from the years of monthly atmospheric corrosion inspections that were
perfonned in conjunction with the monthly meter reading activity affinned that atmospheric
corrosion does not exist on Intennountain s residential and commercial meters.
IV.
In April of 1999, The Office of Pipeline Safety contemplated changing the onshore
atmospheric corrosion inspection interval from three (3) to five (5) years due to "the generally
low incidence of serious problems on protected pipelines , as stated in the Federal Register dated
April 7, 1999, Volume 64, Number 66.
Intennountain requests consideration for a waiver from Code of Federal Regulations
Title 49, Section 192.481(a):
Each operator must inspect each pipeline or portion of pipeline that is exposed to the
atmosphere for evidence of atmospheric corrosion as follows:
If the pipeline is located onshore, then the frequency of the inspection is at least once
every 3 calendar years, but with intervals not to exceed 39 months.
As a condition of the waiver, Intennountain proposes to perfonn the atmospheric corrosion
inspection of residential meters and associated exposed piping in conjunction with the
appropriate business district or non-business district leak survey schedule. Intennountain has
already exceeded federal leak survey requirements by increasing the frequency of our non-
business district leak survey from five (5) years to four (4) years. Additionally, our business
district leak survey is perfonned annually.
Approval of this waiver will facilitate Intennountain s continued efforts to maximize
operating efficiencies without jeopardizing atmospheric corrosion safety requirements by
coupling atmospheric corrosion inspections with Intennountain s annual business district and
four (4) year non-business district leak survey schedules.
VI.
This Petition is filed pursuant to the applicable statutes and the Rules and Regulations of
the Commission.
VII.
Intennountain requests that this matter be handled under modified procedure pursuant to
Rules 201-204 of the Commission s Rules of Procedure. Intennountain stands ready for
immediate consideration of this matter.
WHEREFORE, Intennountain respectfully petitions the Idaho Public Utilities
Commission as follows:
a. That the proposed waiver herewith submitted be approved without suspension and
made effective upon approval.
b. That this Petition be heard and acted upon without hearing under modified
procedure, and
c. For such other relief as this Commission may detennine proper herein.
DATED at Boise, Idaho, this 16th day of September, 2005.
INTERMOUNTAIN GAS COMPANY
Eldon Book
Senior Vice President
General Manager Utility Operations
By
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Morgan W. Ric ards, Jr.
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Attorney for Intennountain Gas Company