20051025Comments.pdf

DONOVAN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, ID 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
INTERMOUNTAIN GAS COMPANY FOR
WAIVER OF THE ATMOSPHERIC
CORROSION INSPECTION RULE (IDAP
31.11.01.201; 49 C.R. ~ 192.481(a))CO MMENTS OF THE
COMMISSION STAFF
CASE NO. INT-05-
The Staff of the Idaho Public Utilities Commission, by and through its Attorney of
record Donovan E. Walker, Deputy Attorney General, respectfully submits the following
comments in response to Order No. 29885.
INTRODUCTION
On September 14, 2005, Intermountain Gas Company (Intermountain Gas, Company)
filed a Petition for Waiver of a pipeline safety, atmospheric corrosion inspection rule with the
Idaho Public Utilities Commission (Commission). On October 4, 2005, the Commission issued
Order No. 29885, Notice of Petition and Notice of Modified Procedure, establishing a deadline for
the submission of comments and/or objections. As more fully set forth below, Staff recommends
approval of the Company s Petition.
STAFF COMMENTS OCTOBER 25 , 2005
THE PE TITI 0 N
According to its Petition, Intermountain Gas seeks a waiver of the federal pipeline
safety rule that requires each operator to inspect each pipeline or portion of pipeline that is
exposed to the atmosphere for evidence of corrosion at least once every three years. This
requirement is set forth in 49 C.R. 9 192.481(a). The Commission adopted this federal
regulation with IDAP A 31.11.01.201.
The Company states it is requesting the waiver only for residential meters. Separate
code requires yearly routine maintenance on its commercial and large volume meters, and
consequently the atmospheric corrosion inspections are done along with the required yearly
maintenance. The Application states that in July 2003, the Company installed automated meter
reading (AMR) systems for residential and commercial meters. Prior to July 2003, meter readers
on foot, would perform a visual inspection of the above ground facilities in conjunction with their
meter reads.With the Company s implementation of AMR there is no longer any regular
maintenance need or requirement to visit each residential meter on an annual basis.
Intermountain Gas states it has never experienced atmospheric corrosion or safety-
related conditions resulting from atmospheric corrosion on its residential or commercial meters in
the entire history of its operations, dating back to 1955. The Company states that the dry, arid
environment in which it operates as well as the fact that the entire steel pipeline is cathodically
protected is the reason they have not experience any corrosion in the last 50 years.
As a condition of the waiver, Intermountain Gas proposes to perform the atmospheric
corrOSIon inspection of residential meters and associated piping in conjunction with the
appropriate business district or non-business district leak survey schedule. The Company states
that non-business district leak surveys are performed every four years, and business district leak
surveys are conducted annually. The Company states that approval of the waiver to allow the
atmospheric corrosion inspections to coincide with the annual business district and four year non-
business district leak survey schedules will help the Company to maximize operating efficiencies
without jeopardizing corrosion safety requirements.
ST AFF REVIEW
Commission Staff has reviewed the Petition for Waiver filed by Intermountain Gas.
Current regulations require the Company to inspect residential meters and associated piping for
evidence of atmospheric corrosion at least once every three years, but with intervals not exceeding
STAFF COMMENTS OCTOBER 25 , 2005
39 months. As a condition of the waiver, the Company proposes to perform the atmospheric
corrosion inspection of residential meters in conjunction with the appropriate business district or
non-business district leak survey schedule. Regulations require business district leak surveys be
performed once each calendar year with intervals not exceeding 15 months, and that non-business
district leak surveys be performed at least once every five years, with intervals not exceeding 63
months. It is Intermountain Gas Company s current practice to conduct the non-business district
leak surveys every four years, which more than meets the requirement in the rule.
Commission Staff has been inspecting Intermountain Gas Company s facilities since
2001 , and has not found any incidents of atmospheric corrosion on residential meters or associated
piping. The Staff has only inspected a small portion of the Company s meters in comparison to
their total number, but has looked at meters across their entire distribution system.
Intermountain Gas Company states in its waiver request that it has never experienced
atmospheric corrosion or safety related conditions resulting from atmospheric corrosion on any of
its residential or commercial meters during the history of its operation dating back to 1955. They
credit this as a direct result of the dry and arid environment in which the Company operates, and
the fact that their entire steel pipeline system has been cathodically protected. The Staff's
inspection experience would support the Company s assessment. Staff believes that enlarging the
inspection frequency from once every three years to once every four years, as the Company has
requested, does not pose a significant threat to the safety of the pipelines.
STAFF RECOMMENDATION
Staff recommends approval of Intermountain Gas Company s request to couple
atmospheric corrosion inspections of residential meters and associated exposed piping with the
Company s annual business district and four year non-business district leak survey schedule. Staff
recommends that the Commission authorize the Company to deviate from the requirement of once
every three years, with intervals not to exceed 39 months, and order that the Company perform the
atmospheric corrosion inspection, at a minimum, once every four years, with intervals not to
exceed 51 months, for its residential meters.
STAFF COMMENTS OCTOBER 25 , 2005
Respectfully submitted this 25th day of October 2005.
Donovan E. Walker
Deputy Attorney General
Technical Staff: Bud Barthlome
i:umisc/comments/intpO5.1dwdbb
STAFF COMMENTS OCTOBER 25 , 2005
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF OCTOBER 2005
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. INT-05-, BY MAILING A COpy THEREOF POSTAGE PREPAID , TO
THE FOLLOWING:
ELDON BOOK SR
VICE PRESIDENT
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE, ID 83707
MORGAN W. RICHARDS, JR.
ATTORNEY AT LAW
804 E PENNSYLVANIA LANE
BOISE, ID 83706
CERTIFICATE OF SERVICE