20051101Decision memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
COMMISSION SECRETARY
COMMISSION STAFF
LEG AL
FROM:DONOVAN E. WALKER
DA TE:NOVEMBER 1, 2005
SUBJECT:PETITION OF INTERMOUNTAIN GAS FOR WAIVER
ATMOSPHERIC CORROSION INSPECTION RULE (IDAPA 31.11.01.201,
49 C.R. ~ 192.481(a)) - CASE NO. INT -05-
On September 14, 2005 , Intermountain Gas Company (Intermountain Gas
Company) filed a Petition for Waiver of a pipeline safety rule regarding atmospheric corrosion
inspection with the Idaho Public Utilities Commission (Commission). On October 4, 2005, the
Commission issued Order No. 29885, Notice of Petition and Modified Procedure, establishing a
deadline for the submission of comments and/or objections. The only comments filed were those
of Commission Staff. Staff recommends granting the Petition.
LEGAL BACKGROUND
Intermountain Gas petitioned for a waiver of the atmospheric corrosion inspection
requirements set forth by 49 C.R. 9 192.481(a). The Commission adopted this federal
regulation with Safety Rule 201 , IDAPA 31.11.01.201. The Commission s Safety Rule 3
IDAPA 31.11.01.003 , provides that any person requesting a waiver of any safety rule may
petition for a waiver pursuant the Commission s Rules of Procedure, IDAPA 31.01.01.000
seq. A waiver request must describe the specific waiver sought, refer to the particular rule or
Order that is contro Bing, and state the facts to support the waiver. ID AP A 3 1.01.01.053.
A state authority may waive compliance with federal pipeline safety standards if the
state authority operates a pipeline safety program certified pursuant to 49 U.C. 9 60105. 49
C. 9 60118(d). The Commission has a current certification for pipeline safety pursuant to 49
C. 9 60105. If the Commission grants a waiver request, it must give the Secretary of
DECISION MEMORANDUM
Transportation written notice of such waiver at least 60 days before the waiver s effective date.
49 U.C. 960118(d).
THE PETITION
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. 49 C.R. 9
192.481(a), IDAPA 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.
DECISION MEMORANDUM
STAFF COMMENTS
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 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
Staffs 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.
ST AFF 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
DECISION MEMORANDUM
perform the atmospheric corrosion inspection, at a mInImum, once every four years, with
intervals not to exceed 51 months, for its residential meters.
COMMISSION DECISION
Given the facts of this specific case, does the Commission find that a waiver from the
requirements set forth in 49 C.R. 9 192.481(a), under the terms proposed by the Company and
recommended by Staff, is appropriate and consistent with pipeline safety?
M:INT-O5-01 dw
DECISION MEMORANDUM