20050929_1342.pdf

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DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:DONOVAN E. WALKER
DATE:SEPTEMBER 27, 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-G 95..3 INT -P'-O:;~Ol
On September 14, 2005, Intermountain Gas Company (Intermountain Gas
Company) filed a Petition for Waiver of Rule with the Commission. The Company requests that
its Application be processed by Modified Procedure.
THE APPLICATION
According to its Application, the Company 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. 9 192.48 1 (a). The Commission adopted this federal
regulation with IDAP A 31.11.01.201.
The Company states that 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.
DECISION MEMORANDUM
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Intermountain Gas states that 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, Jntermountain 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.
STAFF RECOMMENDATION
Commission Staff recommends that the Company s Application be processed by
Modified Procedure, with a 21-day comment period.
COMMISSION DECISION
Does the Commission preliminarily find that the public interest may not require a
hearing to consider the issues presented by the Company s Application, and that this proceeding
may be processed under Modified Procedure with a 21 ~day comment period?
Donovan E. Walker
M:INTGO503 dw
DECISION MEMORANDUM