Exelon - PA.GovStartup time = 60 seconds or one 60111 of an hour 3,600 Mcf per hour/60 = 60 Mcf per slarl 60 Md'/starl * 3 starts per year = 180 Mcf 180 Annual Turbine Start Up Usage

-7 Exelon ®

Di icc i Dinl : 2I.S.M 1.4220 I j n a i l : ti l i d md.swer l i ii)* ('j'tixclDnuiii'ju.'uin

Exelon Business Services Company Legal Deparlment

2301 Market Slrcet/S23-1 Philadelphia, PA 19103

215 568 3389 Fax www.exeloncoi p.corn

VIA FEDERAL EXPRESS

Rosemary Chiavetla, Seerelary Pennsylvania Public Ulilily Commission Commonweallh Keyslone Building 400 Norlh Slreel Harrisburg, FA 17120

Re: Unaccounted for Gas (DHG) Reporting - 2014 Pocket No. M-2014-2399138

Dear Secretary Chiavella:

Enclosed please find PECO Energy Company's Responses to the Commission's February 11, 2015, dala requests in Ihe above-referenced proceeding. Also enclosed are PECO's Revised Annual UFG Report from 2014 and Revised December 30, 2014 Responses to Commission Dala Requests. As instructed, we have also eleclronieally mailed these Responses to Matthew Stewart, Bureau of Technical Utility Services, al [email protected].

If you have any questions aboul this filing, please do not hesitate to contact me at 215.841.4608.

Very truly yours

Michael swetn Assistant Genera

Enclosures

1 3 Z0I5

ec: D. Gill, Deputy Director, Bureau of Technical Utility Services M. Slcwarl, Engineer, Bureau of Technical Utility Services

, hereby state that the facts above set forth are true and correct

to the best of my knowledge, information and belief, and that I expect to be able to prove the same at a

hearing held in this matter. I understand that the statements herein are made subject to the penalties

of 18 Pa. C.S. § 4904 (relating to unsworn falsification to authorities).

Brian D. Crowe

February 25, 2015

Pennsylvania Public Ulility Commission FEB 1 3 2015 Invcsligalion of

PECO Energy Company P A P H ? F

L r n F

U T I L I T Y COMMISSION Unaccounted for Gas (UFG) Reporting-2014 stLRtTARY's BUREAU

Docket No. M-2014-2399138

Response of PECO Energy Company To Dala Requests ofthe Bureau of Technical Utility Services

T U S - M :

In response 2(b)(i), a Pressure Adjuslmenl of 0.483% is provided. Please provide ihe step by step derivation of this value including all pertinent dala used in its calculation. Include definitions of any variables or terminology used in this process

Response:

PECO's Pressure/Temperature adjustment has been revised lo be 763.636 Mcf.1 based on the following calculation.

6.5inwc + U J 3 p s l

Metering Pressure + Atmoshperic Pressure _ 27.8 inwc/lb _ ^

Atmospheric Pressure 14.73 PSI

Pressure Adjustment: 1.016%

Meters Not Subject to a Pressure Factor: 449.150

Total Sendout: 94,956,881 Mcf

Amount of Sendout for Meters Not Subject to a Pressure Factor: 47,727,235 Mcf

To determine the amount of LUFG for the Temperature/Pressure Adjustment, multiply the Pressure Adjusiment times the Amount of Sendout for Meters Not Subject to a Pressure Factor. Then.

! Please note, this number was revised from the previously reported figure of 456.882 Mcf in the Company's September 30, 2014 Annua] UFG filing. The Company indicalcd in its December 30T 2014 response to the Commission's dala requests that it was reviewing this adjusiment and would revise it accordingly when iis review was complete. PECO was able to further refine its estimation by collecting dala on: 1) manufacturer pressure settings for meters and regulators installed; 2) the actual number of meters that are nol calibraied to account for differences in pressure settings between meters and regulators; and 3) ihe total amouni of annual sendout going through these meters.

TUS-I-1 (Continued):

subtract oul the Amount of Sendout for Meters Not Subject lo a Pressure Factor.

(1.016 *47.727,235 Mcf) - 47.727,235 Mcf = 763,636 Mcf

The adjustment was calculated by applying the Pressure Adjusiment to the meters lhat are not calibrated to account for differences in pressure settings between meters and regulators.

Pennsylvania Public Utility Commission Investigation of

PECO Energy Company Unaccounted for Gas (UFG) Reporting - 2014

Docket No. M-2014-2399138

Response of PECO Energy Company To Data Requests ofthe Bureau of Technical Utility Services

mS-I-2:

In Response 2(a)(i), it is mentioned that the LNG Turbine start-up usage is calculated based on "engineering principles." Provide the specific principles and formulas used in these calculations, including the data used as inputs for these calculations. Provide a walk-through ofthe calculation done for PECO's 2014 UFG report as Dockcl No. M-2014-2399138, including definitions of any terms, acronyms, and variables used.

Response:

PECO uses the following calculation to determine the amouni of natural gas used to operate the LNG Turbine.

A. Start-Up Fuel

Assumptions

225 Inlet pressure of Turbine (PSIG) 0 Outlet Pressure (PSIG) 4 Pipe Diameter (Inches) 3 Number ol" Starts per year 60 Time of gas (low during start (seconds)

Equation Components

Q = Gas How in MCFH (Thousand Cubic Feet per Hour) D = Diameter of opening in inches Pi = Pressure in line in PSIA (Pounds per Square Inch Absolute)


Equation

Q = D2P<

D *((Pinlet+ 14.73) - (Poutlet + 14.73))

4 *4* ((225 + 14.73)-(0+ 14.73)) = 3,600 Mcf per hour

Startup time = 60 seconds or one 60111 of an hour

3,600 Mcf per hour/60 = 60 Mcf per slarl

60 Md'/starl * 3 starts per year = 180 Mcf

180 Annual Turbine Start Up Usage (Mcf)

Please note that this calculation includes a minor revision to the calculation provided in PECO's December 30, 2014 response to Commission data requests. PECO previously provided the following information for LNG Turbine Start Up Gas:

132 Mcf - Gas Lost per Start

The correct information is:


B. LNG Process Usage

Process usage - 2,006.74 Mcf/day - assuming the LNG turbine ran 125 days during the reporting period.

Process Usage is 250,842 Mcf.

Total LNG Turbine fuel consumption is 251,022 Mcf

The totals for the LNG turbine fuels are tracked and reported on a monthly basis by PECO's Gas System Operators (GSO).

Pcnnsyivania Public Utility Commission Investigation of

PECO Energy Company Unaccounted for Gas (UFG) Reporting-2014

Docket No. M-2014-2399138

Response of PECO Energy Company To Data Requests of the Bureau of Technical Utility Services

TUS-I-3:

In Response 2(a)(ii), PECO avers that the number of "stuck" meters is based on usage data. Please explain in detail how usage data is correlated to the quantity of stuck meters. Also, provide the monthly data for account status and meter usage data, and a walk through of the calculation done for PECO's 2014 UFG report at Docket No. M-2014-2399138.

Response:

PECO determined the amouni of UFG for stuck meters by pulling the amouni of meters from Ihe billing syslem for each monlh and multiplying those amounls by the annual average monthly usage per customer. The total is then divided by the Historical Retail Sendout (Retail Sendout excludes transportation sendout for large customers) to determine the annual factor of UFG attributable to stuck meters. Then, the factor is applied to 2014 Retail Sendout. Please see Altachment TUS-I-3 for the data used to calculate this adjustment.

Il should be noted lhal PECO used 2012 assessment resulls in the Company's 2014 Annual UFG Report. The 2012 assessment incorporated data between 2009 and 2011 to smooth out the impacl that weather can have on stuck meters.

The Meter Maintenance Adjustment is composed ofthe Zero Registration Residential and Zero Registration Commercial drivers (stuck meters) contained in Attachment TUS-I-3. The number of meters associated with these drivers (each month) are multiplied by the Annual Residential & Commercial Monthly Usage amounts (see response to TUS-I-5 below) and also include the assumptions contained in Attachment TUS-I-3. The results are divided by total retail sendout.

Note, the numbers below have already had the Annual Residential & Commercial Monthly Usage amounts (from TUS-I-5 below) applied to them.

147,492 Mcf+ 428,931 Mcf = 576.423 Mcf

576.423 Mcf759.323.416 Mcf = 0.00971661


The meter maintenance factor of .9717% is applied to the 2014 Retail Send oul number of 66,168.854 Mcf.

Thus, for stuck meters the adjustment is 642,937 Mcf.

Pennsylvania Public Utility Commission Investigation of


Docket No. M-2014-2399138

Response of PECO Energy Company To Data Requests of the Bureau of Technical Utility Services

TUS-M:

In reference to Response 2(b)(i), provide a walkthrough ofthe calculation done for "% LUFG," using the values used in PECO's 2014 UFG report at Docket M-2014-2399138. Also, explain how this value is imputed to be representative of the amount of theft in PECO's distribution system.

Response:

See Attachment TUS-I-3, which contains the supporting data and principles used to calculate the components of the % LUFG. Attachment TUS-I-3 contains the following UFG drivers, which are considered lo be components of theft:

1) Consumption of Inactive Meters ("CIM") - This driver is composed of customers who are using natural gas without a contract or account.

2) Reported Theft - This driver is based on an analysis of possible meter tampering.

3) Orphan - This driver includes meters that are communicating with PECO on the network but are not associated with any account.

4) Lost Meters - This driver includes meters lhat are not in the billing system and are not being heard on the network.

5) Unmetered Service - This driver includes gas service that has been created wilhout a meter to bill the associated consumption.

6) Vacant - This driver includes properties thai are coded as being vacant in the billing system and should have no usage. However, there could be a broken meter.

7) Seasonal - This driver includes properties lhat are coded as being seasonal in the billing system and should have no usage. However, there could be a broken meter.

T U S - M (Continued):

The % LUFG is imputed to be representative ofthe amount of theft in the following manner.

Il should be noted that PECO used 2012 assessment results in tlie Company's 2014 Annual UFG Report. The 2012 assessment incorporated data from 2011.

The Theft of Service Adjustment is composed ofthe sum of the remaining drivers in Exhibit A divided by retail sendout which sums up to 0.290973%.

41.286 Mcf + 25.856 Mcf + 871 Mcf + 1 ;786 Mcf + 22.063 Mcf + 5,932 Mcf + 5,932 Met' + 43,782 Mcf + 25,106 Mcf = 172,614 Mcf

172,614 Mcf/59,323,416 Mcf = 0.00290973

This factor is applied to the 2014 Retail Send out number of 66,168,854 Mcf.

0. 00290973 x 66,168,854 = 192,533 Mcf.

Thus, for theft of service the adjustment is 192,533.

Pcnnsyivania Public Utility Commission Investigation of


Docket No. M-2014-2399138

Response of PECO Energy Company To Data Requests oflhe Bureau of Technical Utility Services

TUS-I-5:

In Response 2(b)(i), it is mentioned that the "Annual Residential Customer Monthly Usage1' is weather normalized. Describe in detail how this is done, and provide a walkthrough ofthe computation of this weather normalization performed for PECO's 2014 UFG report at Docket No. M-2014-2399138, including the raw data used to do this calculation.

Response:

Weather normalization in the Annual Residential Customer Monthly Usage calculation means that the same usage amouni (per customer) was used in each month of the year, regardless of whether it was a winter or summer month. The table below contains the raw data used to calculate the Average Residential and Commercial Customer Monthly Usage amounts (used in the % LUFG calculation in TUS-I-4 above). The results below are applied to the Meter Maintenance and Theft of Service data contained in Attachment TUS-I-3.

Residential 2011

Commercial 2011

Total Usage (Mmcf) 35,506 18,300

Total Customers 448,623 40,980 Annual UPC

(Mmcf) 0.08 0.45

Annual UPC (Ccf) 791 4,466

Monthly UPC (Ccf) 66 372

Altachment TUS-I-3 Gas Line Loss Drivers 2009-2011 Impact Assessment

Ref A B C D E F G H 1 J K L M N O 1

1 Gas Drivers Jan Feb Mar Apr May Jun Jul Aug Sop Oct Nov Dec

2 Zero Res Res 1.832 1.911 1.969 1.571 1.496 1.330 3,724 3,269 3.142 2.832 2,580 2.278 3 Zero Req Coml 1,074 1.028 1.035 1.070 1.123 1.147 1.394 1.215 1.174 1.180 1.494 1.479 4 CIM Total 1.266 1.298 1.163 503 468 6 625 525 425 325 225 120 5 CIM Res 1.139 1.168 1.047 453 421 5 563 473 383 293 203 108 6 CIM Coml 127 130 116 50 47 1 63 53 43 33 23 12 ? Reported Theft - Total (51 10 10 10 10 10 10 10 10 10 10 10 10 a Reoorted Theft - Res (5) 11 11 11 11 11 11 11 11 11 11 11 11 g Reported Theft - Coml (5) 4 4 4 4 4 4 4 4 4 4 4 4

10 Orphan - Gas 245 241 227 184 184 184 184 184 184 184 99 184 i i Lost Mete re/Deleted Accounts 100 100 100 100 100 100 100 100 100 100 100 100 12 Unmetered Seivices 100 100 100 100 100 100 100 100 100 100 100 100 13 Vacant Properties 5.528 5.628 5,528 5.528 5.528 5.528 5.528 5.528 5.528 5.528 5.528 5.528 14 Seasonal Usage Properties 3.17C 3.170 3.170 3.17C 3,170 3.170 3.170 3.170 3.170 3.170 3.170 3.170 15 16

17 % of Htstoncal Retail

Sendout 18 Zero Reg Res (3X4) 9,673 10,090 10.396 8.295 7.899 7.022 19.663 17.260 16.590 14.953 13.622 1ZCI28 147.492 024862% 19 Zero Reg Coml (3X4) 31.962 30.693 30.802 31.843 33.420 34.135 41.485 36.158 34.938 35.117 44.461 44.015 428.931 0.72304% 20 CIM Res (4) 7.520 7.708 6.910 Z988 Z780 36 3.714 3.120 2.526 1.932 1.338 713 41.286 0.06959% 21 CIM Coml (4) 4.71C 4.827 4.327 1.871 1.741 22 2.326 1.954 1.582 1.210 838 446 25.856 0.04358% 22 Reported Tlieft - Res [4)16) 73 73 73 73 73 73 73 73 73 73 73 73 871 0.00147% 23 Reported Theft - Com! (4)16) 149 149 149 149 149 149 149 149 149 149 149 149 1.786 0.00301% 24 Orphan - Gas (4)(8) 2.367 2.328 2.193 1.777 1.777 1.777 1.777 1.777 1.777 1.777 956 1.777 22.063 0.03719% 25 Lost Meters/Deleted Accounts (9) 494 494 494 494 494 494 494 494 494 494 494 494 5.932 0,01000% 26 Unmetered Services (9) 494 494 494 494 494 494 494 494 494 494 494 494 5.932 0 01000% 27 Vacant Properties (4M7) 3.648 3.648 3.648 3.643 3.648 3.648 3.548 3.643 3.648 3.648 3.648 3.648 43.782 0.07380% 28 Seasonal Usage Properties (4M7) 2.092 2.092 2.092 2.092 2.092 2.092 2.092 2.092 2.092 2.092 2.092 2.092 25.106 0.04232%

29 Total Estimated Usago (Mcf)

63.182 62.498 61.579 53.725 54.568 49,943 75.917 67.221 64.365 61.940 68.167 65.930 749.037 1.26263%

UFG Calculation

32 Historical Retail Sendout (2011) 59,323.416

34

Impact assoc w/Meter Related Issues

1.26%

Current Filina UFG Adjustment

2014 Reta9 Sendout 66,168,854

Meter Maintenance Factor (1) 0.971661% 642.937

Theft Factor (2) 0.290973% 192.533

Assumptions: 1 - Meter Maintenance Factor eguals % nistoncal sendout of Zero Reg Res and Coml (P18 + P19)

Theft Factor equals % histoncal sendout of all theft (sum of P20 to P28) Zero reg gas: 20% vacant. 80% occupied - this assumption accounts for meters which appear to be stuck but could be an actual vacancy Res avg usage; 66 cd. Coml avg usage: 372 cd - monthly averages Potential ttieft based on DataRaker report - 94% res a 6% com'l Reported tneft based on a 60% rate for true reports of meft 10% of vacanfseasonal properties are not vacant onfy using residential rate - ttvs accounts for broken meters at properties that had been vacant but are no* occupied

8 - Assume orphans are 90% residential and 10% commercial - we do not know the location of an orphan meter, therefore we don't know the rate dass of the user 9-Assume that 0.01% of gas is lost to unmetered services, slow meters and lost meters each Note: Meter Maintenance is equivalent to Zero Reg meters wfiich are stuck meters Note: Theft is composed of the remaining categories: CIM. Reported Theft. Orphans, Lost/Deleted Meters, unmetered Services. Vacant Properties, and Seasonal Properties

PECO Energy Company 2014 Annual Unaccounted For Gas Report (UFG)

Distribution System Specify units for quantity of gas Mcf

A. Gas Received From Production Facilities 0

From Transmission Facilities 0

From Storage Facilities 0

From Interstate Pipelines directly into the Distribution System 94,956,881

From Other Sources (i.e., propane injections, etc.) 0

Total Gas Received by the Distribution System 94,956,881

B. Gas Delivered

To Customers (i.e., Transportation Residential, Commercial, Industrial, etc.] 91,009,560

To Storage 0

To Transmission System 0

Total Gas Delivered by the Distribution System 91,009,560

C. Adjustments Pressure/Temperature Adjustments 763,636

Distribution System Leak Rate 354,061

Company use 400,348

Theft of Service 192,533

Meter Maintenance 642,937

Purging/Other Construction activities 12,000

Unmetered Gate Station Use 2,386

Meter Read Cycle Adjustments (567,005)

Total Adjustments: 1,800,896

D. Distribution UFG sw Total 2,146,425

E. Percent UFG Percentage 2.26%

Revised on February 26, 2015

PECO's Revised Responses to Commission Data Requests - February 26, 2015

PECO ENERGY COMPANY Revised 2014 Annual Unaccounted For Gas Report fUFGV

Docket No. M-2Q14-2399138

Distribution System Adjustments

1) For each adjustment category claimed on your Unaccounted for Gas (UFG) Report filed at Docket No. M-2014-2399138, provide a definition of the adjustment as well as a detailed ratmuale or explanation explaining the need for this adjustment. For adjustments within the "Other" category, provide a definition for each individual sub-category. For example, if there are three different adjustments included under "Other,"provide separate definitions and rationales for each of these three items.

1. Pressure/Temperature Adjustments - A pressure adjuslmenl is taken lo account for pressure differences between regulator and meter capacity settings. Because ofthe difference in settings, there wilt be naturally recurring LUFG.

2. Distribution System Leak Rate - adjustment laken for the amouni of loss associated wilh naturally occurring syslem leaks. The Environmental Protection Agency's ("EPA") estimate of methane emissions calculation is used to quantify the amount of physical leakage on PECO's system. Natural gas is composed primarily of methane, which is a greenhouse gas that impacts global warming. As such, the EPA has an inleresl in quantifying and controlling "fugitive emissions" (unintentional leaks of natural gas from sealed surfaces) of nalural gas. The EPA calculates leak rates per type of pipe according to the following calculation: Miles of Main Type x Leak Rale = Amouni of Mains Loss.

3. Company Use - adjustment for operational use of natural gas at PECO facilities. This adjustment is used lo accouni for the use of LNG liquefaction turbine starting fuel, propane vaporizer fuel, and gate station pre-heater fuel. This represents gas that is nol unaccounted for. but utilized for the purpose of providing reliable supply to our ratepayers. Also included in this adjustment is the use of gas by PECO facilities for building heating purposes.

4. Theft of Service - potential loss associated with unbilled gas usage due to consumption on inactive meters, lost meters, properties that were reported as vacanl or seasonal, but actually were not. gas meter/module tampering, etc. Although PECO uses analytics lo idcnlify and address theft, il is nol practically achievable to identify and eliminate all potential theft of services due lo customer behavior.

5. Meter Maintenance - adjustment for loss associated with defective meters (e.g. zero registration - stuck meters) not accurately measuring gas usage, which can be highly variable and dependent on weather. Cold weather can increase the amount of broken meters as well as the average usage for each meter.

6. Purging - When new gas services are constructed/installed or when existing pipes are replaced, repaired or otherwise returned to service after interruption, it is necessary to purge the lines of air. This is done with vented gas, which displaces air in the pipes to ensure safe operation after inslallalion. repair or replacement. The gas loss associated with purging is unmetered and accounted for through a calculation, which includes the estimated instances of purging per year.

- I - Docket No. M-2014-2399138


pipe diameter, gas pressure utilized lo vent the air, and amount of time required to complete purging. A Purging adjustment is taken to account for the loss associated with these activities.

7. Unmetered Gas Station Use - adjustment for unmetered use by pneumatic equipmeni al PECO gate stations. This represents gas lhat is not unaccounted for, but utilized for the purpose of providing reliable supply to our ratepayers. Calculations are based on manufacturer speci fications.

8. Meter Read Cycle Adjustments - A Meter Read Cycle adjustment is required to convert usage based on a billing cycle lo usage based on a calendar cycle. The Gas Received included in the line loss calculation is based on a calendar cycle. Thus, for comparability, the Gas Delivered included in the line loss calculation should include: 1) gas billed by the Company on a calendar cycle. 2) an estimate of gas used by customers on a calendar cycle (for which the Company has not yet billed); and 3) gas used by customers in a previous calendar cycle (for which the Company has billed in the current calendar cycle).

Pressure/Temperature Adjustments

2) For each adjustment in your UFG Report fded at Docket No. M-2014-2399138, provide the following information (including for any individual sub-category within the "Other" category).

a. Describe in detail the methodology used to obtain the raw data or measurements used to determine this value, including but not limited to:

i . A listing ofthe equipmeni used to take/make the measurements (meters, sensors, visual checks, eic.)

N/A. Pressure/Temperature adjustments are based on calculations, not measuremenls.

ii . The frequency of the measurements

N/A. Pressure/Temperature adjustments are based on calculations and not based on measuremenls.

iii. The accuracy and lolerances ofthe measurements

N/A. Pressure/Temperature adjustments are based on calculations and not based on measurements.

iv. Provide a written verification lhat all equipment listed in response to i , above, has been properly maintained and calibrated according lo industry standards and/or manufacturers, specifications

N/A. Pressure/Temperature adjustmenls are based on calculations and nol based on measurements.

-2 - Docket No. M-2014-2399138


b. Describe in detail the methodology and calculations used to arrive at the final value for the adjustment, including but not limited to:

i . The formula(s) used in the calculation, including definitions and explanations for all values and variables used in the calculation.

The Pressure/Temperature adjustment was revised to be 763,636 Mcf.1

6.5inwc u j i p r . Metering Pressure + Atmoshperic Pressure 27.8 inwc/lb _

Atmospheric Pressure 14.73 PSI

Pressure Adjusiment: 1.016%

Meiers Not Subject to a Pressure Factor: 449,150

Total Sendout: 94,956,881 Mcf

Amount of Sendout for Meiers Not Subject lo a Pressure Factor: 47,727,235 Mcf

To determine the amount of LUFG for the Temperature/Pressure Adjustment, multiply the Pressure Adjustment times the Amount of Sendout for Meters Not Subject to a Pressure Factor. Then, subtract out the Amount of Sendout for Meters Not Subject to a Pressure Factor.

(1.016 * 47,727,235 Mcf) - 47,727.235 Mcf = 763.636 Mcf

ii . The empirical or legal justification for the use of this formula. For example, is (his a formula derived in-house by the company, and if so how was this done? If the formula is provided by another source (i.e., an industry standards group, federal or state agency, academic study, etc.). provide a reference to the source of this formula.

The adjustment was calculated by applying the Pressure Adjustment to the meters that are not calibrated to account for differences in pressure settings between meters and regulators.

1 Please note, this number was revised from the previously reported figure of 456,882 Mcf. The Company indicated in its December 30, 2014 response to the Commission's data requests that it was reviewing this adjustment and would revise it accordingly when its review was complete. PECO was able to further refine its estimation by collecting data on: 1) manufacturer pressure settings for meters and regulators installed: 2) the actual number of meters (hat are not calibraied to account for differences in pressure sellings between meters and regulators; and 3) (he tolal amount of annual sendout going through these meters.

- 3 - Docket No. M-2014-2399138


Distribution System Leak Rate


a. Describe in detail the methodology used lo obtain the raw data or measurements used lo determine this value, including but not limited lo:

i . A listing of the equipment used lo take/make Ihe measuremenls (meters, sensors, visual checks, etc.)

N/A. Leak rates are based on EPA calculations and distribution system mileage.



iii. The accuracy and tolerances of the measurements


iv. Provide a written verification that all equipment listed in response to i , above, has been properly maintained and calibrated according to industry standards and/or manufacturers' specifications

N/A. Leak rales are based on EPA calculations and distribution system mileage.

b. Describe in detail the methodology and calculations used to arrive al the final value for the adjustment, including but not limited to:

i . The formula(s) used in the calculalion, including definitions and explanations for all values and variables used in the calculation.

The total loss based on leaks is 354,061 Mcf /year. Please note, this number was revised on December 30, 20142 from the previously reported figure of 437,017 Mcf. The previously reported number was based on a 2008 composite leak percentage. It took a snapshot of the type and amount of pipes comprising PECO's system al that lime. The charts below contain an updated picture of PECO's system makeup as of 2013. The revised

2 On December 30, 2014. PECO submitted a Revised Annual LUFG Plan concurrently with its responses lo Commission data requests.

- 4 - Docket No. M-2014-2399138


number of 354,061 Mcf reduces the amount of lost gas attributable to this adjustment.

The leak calculation was based on multiplying the number of miles of each asset by the value provided in the EPA Greenhouse Gas filings. The miles of mains and number of services are consistent with what was submilted in the 2013 DOT Report.

Mains

No. Miles Asset Type

Leak Rate Mcf/mile/yr Annual Loss

1 791 Cast Iron 239 189,049

2 428 Bare Steel 110 47,080

3 2777 Coated Steel 3 8,331

4 2765 Plastic 12 33,180 5 0 Copper N/A 0

Total 6761 277,640 Mcf

Services

No. Miles Asset Type

Leak Rate Mcf/service/yr Annual Loss

1 0 Cast Iron N/A 0 2 41,214 Bare Steel 1.7 70,064

3 8,646 Coated Steel 0.2 1,729 4 389,315 Plastic 0.01 3,893

5 2,450 Copper . 0.3 735 Total 441,625 76,421 Mcf

Company Use

ii . The empirical or legal justification for the use of this formula. For example, is this a formula derived in-house by the company, and if so how was this done? If the formula is provided by another source (i.e., an industry standards group, federal or state agency, academic study, etc.). provide a reference to the source of this formula.

As previously stated, the formula is derived from the EPA.

It should be noted that volumes associated with turbine and vaporizer fuel are subject to rounding.

-5 - Docket No. M-2014-2399138


Additionally, PECO sets its Company Use equipment according to manufacturer specifications. PECO also employs manufacturer estimations for the quantity of gas required to operate the equipment. The loss associated wilh using this equipment is not tracked. Instead. PECO uses the manufacturer specifications and estimations to develop calculations, which determine the amount of loss.

Finally, the PECO Gas Planl conducts winter readiness tests on its vaporizers to ensure proper operations, and secondary tuning/emission tests for environmental purposes. The loss associated with these tests is not tracked.

LNG Turbine:

PECO uses the following calculations to determi nc the amount of nalural gas used to operate the LNG Turbine.

A. Start-Up Fuel

Assumptions

225 Inlet pressure of Turbine (PSIG) 0 Outlet Pressure (PSIG) 4 Pipe Diameter (Inches) 3 Number of Starts per year 60 Time of gas How during start (seconds)

Equation Components

Q = Gas How in MCFH (Thousand Cubic Feet per Hour) D = Diameter of opening in inches Pi ^ Pressure in line in PSIA (Pounds per Square Inch Absolute)

Equation

Q = D2P,

D* D *((Pinlel+ 14.73) - (Poutlet + 14.73))

4 H * ((225 + 14.73) - (0 + 14.73)) = 3,600 Mcf per hour

Startup time = 60 seconds or one 60 l h of an hour

3,600 Mcf per hour/60 = 60 Mcf per start

60 Mcf/start * 3 starts per year = 180 Mcf

180 Annual Turbine Start Up Usage (Mcf)

- 6 - Docket No. M-2014-2399i38

P E C O ' s Revised Responses to Commission Data Requests - February 26, 2015

Please note, the LNG Turbine Start-Up Fuel is more detailed than what was provided in its December 30, 2014 response to Commission data requests. Additionally, the calculalion includes a minor revision to the one provided in PECO's December 30, 2014 response to Commission data requests. PECO previously provided the following information for LNG Turbine Start Up Gas:


The correct information is:


B. LNG Process Usage

Process usage - 2,006.74 Mcf/day - assuming the LNG turbine ran 125 days during the reporting period.

Process Usage is 250,842 Mcf.

Total LNG Turbine fuel consumption is 251,022 Mcf

The totals for the LNG turbine fuels are tracked and reported on a monthly basis by PECO's Gas Syslem Operators (GSO).

2) For each adjustment in your UFG Report filed at Docket No. M-2014-2399138, provide the following information (including for any individual sub-category within the "Other" category).

a. Describe in detail the methodology used lo obtain the raw data or measurements used lo determine this value, including but not limited to:

i. A listing ofthe equipment used to take/make the measurements (meters, sensors, visual checks, etc.)

The LNG Turbine start-up usage is a calculation based upon engineering principles. The LNG Turbine calculations are tracked and measured through an orifice plate and through pressure differential and temperature transmitters. The data obtained from the orifice and the transmitters are input into the Gas SCADA system.


The LNG Turbine fuel process is recorded daily.


Accuracy of 0.25%

- 7 - Docket No. M-2014-2399138


iv. Provide a written verification that all equipment listed in response to i . above, has been properly maintained and calibrated according to industry standards and/or manufacturers1 specifications

PECO has wrilten verification ofthe of the annual calibration records to measure the LNG turbine process. The records are kept at PECO's West Conshohocken Gas Plant.

b. Describe in detail the methodology and calculations used to arrive at the final value for the adjustment, including but not limited lo:

i . The formula(s) used in the calculalion, including definitions and explanations for all values and variables used in the calculation.

The LNG Turbine calculations are derived from internal engineering processes described in response lo 2(a)(i) above. The calculations determine the amount of gas required to start-up and run the LNG turbine (for the liquefaction process). This fuel is tracked daily by the GSO.

ii. The empirical or legal justification for the use of this formula. For example, is this a formula derived in-house by the company, and if so how was this done? If the formula is provided by another source (i.e., an industry standards group, federal or state agency, academic study, etc.), provide a reference to the source of this formula.

The LNG Turbine process equipment is monitored in PECO's Control Room in Gas SCADA and calculated utilizing an American Gas Association approved process, with calibration ofthe equipment being performed annually to assure accuracy.

Vaporizer Fuel

LNG Vaporizer fuel is calculated by a rotary meter and associated pressure and temperature transmitters. The following are the calculations for vaporizer fuel usage:

Vaporizer fuel usage is calculated according to the following monthly meter readings (in Mcfs):

- 8 - Docket No. M-2014-2399138


Vaporizer

sep

oct 12

nov 92

dec 448

jan 4,148

feb 1,707

mar 3,639

apr 1

may

jun

Jul aug

Totals 10,047



i . A listing of the equipment used to take/make the measurements (meters, sensors, visual checks, etc.)

The LNG Vaporizer usage is tracked through rotary meter and associated pressure and temperature transmitters and monitored daily by the GSO.


The measurement is recorded daily into Gas SCADA.


Meter accuracy: + / - 0.5%

Transmitter accuracy + / - 0.25%

iv. Provide a wrilten verification (hal all equipment listed in response to i , above, has been properly maintained and calibrated according to industry standards and/or manufacturers' specifications

PECO has written verification of the of the annual calibration records of the transmitters utilized to measure the LNG vaporizer process. The records are kept at West Conshohocken Gas Plant.


-9- Dockct No. M-2014-2399138

PECO's Revised Responses to Cominission Data Requests - February 26, 2015

i . The Ibnnula(s) used in ihe calculation, including definitions and explanalions for all values and variables used in the calculation.

The LNG Vaporizer usage is derived from rotary meter reads and associated pressure and temperature transmitters. Both devices lake readings/measurements that are transmitted and monitored in the Control Room Gas SCADA and recorded daily.

ii . The empirical or legal justification for the use of this formula. For example, is this a formula derived in-house by the company, and if so how was this done? If the formula is provided by another source (i.e., an industry standards group, federal or state agency, academic study, etc.). provide a reference to the source of this formula.

N/A - PECO utilizes actual readings.

Gate Station Pre-heater fuel


a. Describe in detail the methodology used lo obtain the raw data or measurements used to determine this value, including but not limited to:

i. A listing ofthe equipment used to take/make the measurements (meters, sensors, visual checks, clc.)

Gate Station Pre-heater fuel allows the Company lo maintain gas temperatures above freezing to prevent damage to the pipes and Ihe ground or roadway surrounding the pipes. Accordingly, PECO must take temperature and pressure variations into consideration at each gate station. Preheaters keep the temperature of gas above freezing at all (imes. While gas is used to fuel the preheaters, PECO does not track its preheater fuel usage with meters. Instead, Pre-heater fuel usage is determined by utilizing a factor of 0.12% ofthe station throughput. This is an in-house calculation (hal was reviewed and verified by a third party engineering firm. There are some upstream pressure changes lhat occur at individual stations lhat impact the factor but not enough to change the factor per station. The factor variance is 0.02%.

Gate Station pre-heater fuel consumption for the reporting period was 103,579 Mcf. This is inclusive of all the gate station preheaters on the PECO system.

ii . The frequency ofthe measurements

Gale Station pre-heater fuel usage is recorded daily in the Gas SCADA System.

iii . The accuracy and tolerances of the measurements

- 10 - Docket No. M-2014-2399138


Pre-heater fuel usage is calculated at a factor of 0.12% of station throughput with a variance of 0.02%.

iv. Provide a written verification that all equipment listed in response to i, above, has been properly maintained and calibrated according to industry standards and/or manufacturers' specifications

The gale station pre-heaters are checked and calibraied annually and records are available in the West Conshohocken Gas Plant.


i. The formula(s) used in the calculation, including definitions and explanalions for all values and variables used in the calculation.

The pre-heater fuel usage calculation multiplies the 0.12% factor by Tolal Sendoul (minus Company Use gas). The 0.0012 factor is multiplied by (he Sendout for each gate station that utilizes preheaters. Please note that not all of PECO's gale stations utilize preheaiers.

i i . The empirical or legal justification for the use of this formula. For example, is Ihis a formula derived in-house by the company, and if so how was this done? If the formula is provided by another source (i.e., an industry standards group, federal or stale agency, academic study, etc.), provide a reference to the source of this formula.

The calculation was verified by an independent consultant.

The following list is for the TETCO Gale Stations on the PECO system:

West Conshohocken

Tilghman Street

East Greenville

Planehrook

Hatfield

Upper Providence

Buckingham

Center Poinl

Brookhaven

Hershey's Mills

Eagle

East Pikeland

- I I - Docket No. M-2014-2399138


Skippack

Flower

The following list is for the TRANSCO Gate Stations on the PECO system:

West Conshohocken

Tilghman Street

Coatesville

Parksburg

Kennett Square

Pottstown

Ivyland

Ore land

Morrisville

Dolington

Concord

The following list is for the Eastern Shores Gate Station on the PECO system:

Jennersville

The following list is for the Direct Pipeline Customers on the PECO system:

Eddystone

Kimberton

An additional 35,969 Mcf of PECO's Company Use represents natural gas used by PECO owned facilities (for heating purposes). This usage is obtained from PECO's Customer Information Management System (CIMS), which is the Company's billing system, and is based on monthly meter reads.

Theft of Services and Meter Maintenance

2) For each adjustment in your UFG Report fded at Docket No. M-2014-2399J38, provide the following information (including for any individual sub-category within the "Other" category).



- 12 - Docket No. M-2014-2399138

PECO's Revised Responses to Commission Data Requests - February 26,2015

CIMS and Gas Meters.


The number of stuck meters is based on meter usage data, and the number of consumption on inactive meters is based on meter usage data and accouni status. Both are tracked monthly.

iii . The accuracy and lolerances oflhe measurements

Subjecl to the accuracy ofthe meter at each properly, both sources accurately reflect the volume of stuck meters and consumption on inactive accounts.


AN PECO gas meters are calibrated within PUC required standards, and validated through random and periodic sampling programs following PUC regulations. Testing results are filed wilh PUC on annual basis.



PECO used the following formula for both theft of service and meter maintenance3:

% LUFG = (((estimated number of residential meters each month) x (average residential monthly usage)) + ((estimated number of commercial meters each month) x (average commercial monthly usage)))/sendout Estimated number of residential/commercial meters each month:

Theft of Service - the amount of theft (such as consumption on inactive meters) is identified in CIMS via meter usage data on meters without a cusiomer of record. Additional types of theft are estimated based on historical experience on gas theft cases, ll is practically impossible lo have a precise account for all potential theft of service.

Meter Maintenance - broken meters are identified via CIMS and meter dala analytics to delerminc the volume of broken meters.

Annual residential customer monthly usage = Annual residential customer usage divided by total number of residential customers; the number is then weather normalized4

and annualized.

PECO is providing a more detailed and revised calculation than what was previously provided in its December 30, 2014 responses to Commission data requests.

- 13 - Docket No. M-2014-2399138


Annual commercial customer monthly usage = Annual commercial customer usage divided by total number of commercial customers; the number is then weather normalized* and annualized.

Total Sendout = measurement of all volumes in Mcl" that were received into the Company's distribution syslem.

Please see Exhibit A, which contains the monthly dala used to calculate the % LUFG formula and iis components. Additionally, it should be noted thai PECO used 2012 assessment results in the Company's 2014 Annual UFG Report. The 2012 assessment incorporated dala between 2009 and 2011 to smooth out the impact that weather can have on stuck meters.

The Meter Maintenance Adjustment is composed of the Zero Registration Residential and Zero Registration Commercial drivers (stuck meters) contained in Exhibit A. The number of meters associated with these drivers (each month) arc multiplied by the Annual Residential & Commercial Monthly Usage amounts and also include the assumptions contained in Exhibit A:

Residential 2011

Commercial 2011

Total Usage (Mmcf) 35,506 18,300

Total Customers 448,623 40,980 Annual UPC

(Mmcf) 0.08 0.45

Annual UPC (Ccf) 791 4,466

Monthly UPC (Ccf) 66 372

The results are divic ed by total retail sendoul.

Note, the numbers below have already had the Annual Residential & Commercial Monthly Usage amounts (from the above table) applied lo them.

147,492 Mcf+ 428,931 Mcf = 576,423 Mcf

576,423 Mcf/59,323.416 Mcf = 0.00971661

The meter maintenance factor of .9717% is applied to the 2014 Retail Send out number of 66,168,854 Mcf.

Thus, for stuck meters the adjustment is 642,937 Mcf.

4 Weather normalization in the Annual Residential Cusiomer Monthly Usage calculation means thai ihe same usage amount (per customer) was used in each month ofthe year, regardless of whether it was a winter or summer month.

5 Weather normalization in the Annual Commercial Cu-stoiner Monthly Usage calculalion also means lhal the same usage amount (per customer) was used in each monlh of the year, regardless of whether it was a winter or summer month.

- 14- Dockct No. M-2014-2399138


The Theft of Service Adjustment is composed ofthe sum ofthe remaining drivers in Exhibit A divided by retail sendoul which sums up to 0.290973%.

41.286 Mcf + 25.856 Mcf + 871 Mcf + 1,786 Mcf + 22,063 Mcf + 5,932 Mcf + 5,932 Mcf+ 43,782 Mcf + 25,106 Mcf = 172,614 Mcf

172,614 Mcf/59.323.416 Mcf = 0.00290973

This factor is applied to the 2014 Retail Send out number of 66,168.854 Mcf.

0.00290973 x 66,168,854 = 192,533 Mcf.

Thus, for theft of service the adjustment is 192,533.

i i . The empirical or legal justification for the use of this formula. For example, is this a formula derived in-house by the company, and if so how was this done? If the formula is provided by another source (i.e., an industry standards group, federal or state agency, academic study, etc.),

. provide a reference to the source of this formula.

The formula is an in-house methodology used to estimate revenue loss. Using account and usage information to monitor the possibility of broken meters and consumption on inactive meters is commonly used in the utility industry. While all reported theft cases are addressed immediately, theft cannot be fully prevented or predicted and therefore unreported theft remains a driver for which the impact to LUFG cannot be fully determined or reduced.

Purging


a. Describe in delail the methodology used to obtain the raw data or measuremenls used lo determine this value, including but not limited to:

i . A listing ofthe equipment used to take/make the measuremenls (meters, sensors, visual checks, clc.)

N/A. Purging adjustments are based on assumptions and estimates and not based on measurements. The number of purges is based on the average number of main installation projects, the average number of purges per project and an average purge time considering different types of projects.

ii . The frequency ofthe measurements

N/A. Purging adjustments are based on assumptions and estimates and not based on measurements.

- 15 - Docket No. M-2014-2399138


iii. The accuracy and tolerances ofthe measurements


iv. Provide a wrilten verification lhat all equipment listed in response to i , above, has been properly maintained and calibrated according lo industry standards and/or manufacturers' specifications


b. Describe in detail the methodology and calculations used to anive at the final value for the adjustment, including but not limited to:


The Purging adjustment was calculated assuming 600 instances of purging due lo new construction. Each instance assumes 2" vent pipe, 5 minutes of purging, and 10 psig inlet pressure going to atmosphere. The algebraic formula is as follows:

Q = D2* i\ Q = Gas flow in Mcf/h (Thousand Cubic Feet per Hour) D = Diameter of opening in inches !\ = Pressure in line in PSIA (Pounds per Square Inch Absolute) Absolute inlet pressure = 74.73 Absolute Outlet Pressure = 14.73 Q = Gas f low per hour (mcf/h) = 240 Mcf/h

Multiplying Q by Number of events and Average Purge Time the total calculation is:

Q total = 2 4 0 ^ x 600 events/Year x 300 seconds 13600 seconds per hour

Q total = 12.000 Mcf/Year

Gas loss per v a n t (Mcf) = 20 purse v

Please note that this calculation corrected a prior mistake in PECO's Annual LUFG Report submitted in September 2014. PECO previously attributed 6,000 Mcf to purging activities. Upon review of this figure, PECO determined that it inadvertently swilched the Number of Purges and the Time of Gas Flow During Venting figures in that calculation. PECO has corrected this discrepancy, which changes the previously reported amouni of loss associated with purging to 12,000 Mcf/'

i i . The empirical or legal justification for the use of this formula. For example, is this a formula derived in-house by the company, and if so how was this done? If the formula is provided by another source (i.e., an

A PECO corrected this figure in its Revised Annual LUFG Plan and responses lo Commission data requests submitted on December 30, 2014.

- 16 - Docket No. M-2014-2399138


industry standards group, federal or state agency, academic study, etc.), provide a reference to the source of this formula.

The formula used is the basic How calculation through an orifice.

Unmetered Gate Station Use




PECO utilizes pneumatic equipment in the gate stations such as Bristol Remote Set Regulators (manufactured by Emerson), & T.S. I/P Positioners (manufactured by Moore). PECO Plant Operations maintains data sheets on all equipment and verifies the manufacturer recommendations on equipment annually. Pneumatic equipment is set to manufacturer recommendations.


Currently, Plant Operations does not have periodic measurement criteria in place. Gate station pneumatic equipment is checked on an emergent basis and calibrated annually.


Gate station pneumatic equipment is checked annually to ensure the equipment meets the manufacturer recommendations.


Gate station pneumatic equipment is checked annually to ensure the equipment meets the manufacturer recommendations.

b. Describe in detail the methodology and calculations used to anive at the final value for the adjustment, including but nol limited to:


N/A. Gate station pneumatic equipment is checked annually lo ensure the equipmeni meets the manufacturer recommendations.

- 17- Docket No. M-2014-2399138


i i . The empirical or legal justification for the use of this formula. For example, is this a formula derived in-house by the company, and if so how was this done? If the formula is provided by another source (i.e., an industry standards group, federal or state agency, academic study, etc.), provide a reference lo the source of this formula.

Gate slation equipmeni is set to manufacturer recommendations and checked annually.

Meter Read Cycle Adjustments


a. Describe in delail the methodology used to obtain the raw data or measurements used to determine this value, including but not limited to:

i . A listing ofthe equipmeni used to take/make the measurements (meters, sensors, visual checks, etc.)

N/A. The Meter Read Cycle Adjustment is an Accounting Adjusiment.

ii . The frequency of ihe measurements

N/A. The Meter Read Cycle Adjustment is an Accounting Adjustment.



iv. Provide a wrillen verification that all equipment listed in response to i , above, has been properly maintained and calibrated according to industry standards and/or manufacturers' specifrations


b. Describe in detail the methodology and calculations used to an ive at the final value for the adjustment, including bul not limited lo:


The Meter Read Cycle Adjustment is calculated by taking the estimated usage from August 2014 that will be billed in September 2014 and subtracting from it the estimated usage from August 2013 that was billed in September 2013. As the usage included in the unadjusted Gas Delivered number represents usage

- 18 - Docket No. M-2014-2399138


billed from September 2013 to August 2014, the Meter Read Cycle Adjustment converts the annual billed usage to annual calendar usage.

The adjustment amouni is based on unbilled usage, which is calculated monthly and recorded in the books and records of the Company. The process to calculate unbilled usage each month is as follows:

1) Sendout (in Mcl") is obtained from metering performed at PECO's gale stations.

2) Adjusted Calendar Sales are calculated starting with the entire month's Sendout (in Mcf). which is adjusted for a historical rolling 24-month line loss factor (Sales as a percentage of Sendoul).

3) Billed Sales are obtained from CIMS

4) Unbilled Sales = Adjusted Calendar Sales - Billed Sales + Prior Month

ii . The empirical or legal justification for the use of this formula. For example, is this a formula derived in-house by the company, and if so how was this done? If the formula is provided by another source (i.e.. an industry standards group, federal or state agency, academic study, etc.), provide a reference to (he source of this formula.

The Company must include usage (and revenue) for the calendar cycle on its books in accordance with Generally Accepted Accounting Principles.

- 19 - Docket No. M-2014-2399138

Eshibil A Gas Line LOSS Dnvers 2009-2011 Impact Assessment

Rel A a C D E F G H 1 J K L M K 1 O 1

1 Gas Drivers Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

2 Zero Req Res 1,832 1.911 1.969 1.571 1.496 1.330 3.724 . 3.269 3.142 2.832 2.580 2.278 3 Zero Reg Coml 1.074 1.028 1.035 1.070 1,123 1.147 1.394 1.215 1.174 1.180 1.494 1.479 4 CIM Tota! 1,266 1.298 1.163 503 468 6 625 525 425 325 225 120 5 CIM Res 1.139 1.168 1.047 453 421 5 563 473 383 293 203 108 6 CIM Coml 127 130 116 50 47 1 63 53 43 33 23 12 7 Reported Theft - Total (5) 10 10 10 10 10 10 10 10 10 10 10 10 8 Reoorted Theft - Res (5) 11 11 11 11 11 11 11 11 11 11 11 11 9 Reported Theft - Com! (5) 4 4 4 4 4 4 4 4 4 4 4 4

10 Orphan - Gas 245 241 227 184 184 184 184 184 184 184 99 184 11 Lost Meters/Deleted Accounts 100 100 100 100 100 100 100 100 100 100 100 100 12 Unmetered Services 100 100 100 100 100 100 100 100 100 100 100 100 13 Vacant Properties 5.528 5.528 5,528 5.528 5.528 5.528 5.528 5.526 5.528 5,528 5.528 5.528 14 Seasonal Usacje Properties 3.170 3,170 3.170 3.170 3.170 3.170 3.170 3.170 3.170 3.170 3.170 3.170 15 16

17 % of Historical Retail

Sendout IS Zero Reg Res (3H4I 9.673 10,090 10.396 8.295 7.899 7.022 19.663 17.260 16.590 14.953 13.622 12.028 147.492 0.24862% 19 Zero Req Coml (3H4) 31.962 30.593 30.802 31.843 33.420 34.135 41.485 36.158 34.938 35.117 44.461 44.015 428.931 0.72304% 20 CIM Res (41 7.520 7.708 6.910 2.988 2.780 36 3.714 3.120 2,526 1.932 1.338 713 41.286 0.06959% 21 CIM Com! (4) 4.710 4.327 4.327 1.871 1.741 22 2.326 1.954 1.582 1.210 838 446 25.856 0.04358% 22 Reported Theft - Res (4K6) 73 73 73 73 73 73 73 73 73 73 73 73 871 0.00147% 23 Reported Theft - Coml (41(6) 149 149 149 149 149 149 149 149 149 149 149 149 1.786 0,00301% 24 Orphan - Gas (41(81 2,367 2.328 2.193 1.777 1.777 1.777 1.777 1.777 1.777 1.777 956 1.777 22.063 0,03719% 25 Lost Meters/Deleted Accounts (9) 494 494 494 494 494 494 494 494 494 494 494 4S4 5.932 0.01000% 26 Unmetered Services (9) 494 494 494 494 494 494 494 494 494 494 494 494 5.932 0.01000% 27 Vacant Properties (4)(7> 3.648 3.648 3.648 3.648 3.648 3.648 3.648 3.648 3.648 3.648 3,648 3.648 43.782 0.07380% 28 Seasonal Usage Properties (4V71 2.092 2.092 2.092 2.092 2.092 2.092 2.092 2.092 2.092 2.092 2092 2.092 25.106 0.04232%

29 Total Estimated Usage (Mcf)

63.182 62.498 61.579 53.725 54.568 49.943 75.917 67.221 64.365 61.940 68,167 65.930 749.037 1.26263% 30

UFG Calculation 31 Current Ftlina UFG Ad i ust ment

32 Historical Retail Sendout (2011) 59.323.416 2014 Retail Sendout 66,168,854

33 Meter Maintenance Factor (1) 0.971661% 642,937

34

Impact assoc w/Meter Related Issues

1.26% Theft Factor (2) 0.290973% 192.533

Assumptions: 1 - Meter Maintenance Factor equals % historical sendout of Zero Reg Res and Coml (P18 + P19)

Theft Factor equals % historical sendout of all ttieft (sum of P20 to P28) Zero reg gas: 20% vacant. 80% occupied - this assumption accounts for meters which appear to be stuck but could be an actual vacancy Res avg usage: 66 ccf. Coml avg usage: 372 ccf - monthly averages Potential theft based on DataRaker report - 94% res a 6% com'l Reported theft based on a 60% rate for true reports of theft 10% ot vacanJ/seasooal properties are notvacarft onlv usitvj cesidaniial rate. - Ihis. aGeowts. (ot brafcap. meterc at fr.nnfit'fues, ft^at. t\ari. lacwA W . w « wan wrajpial Assume orphans are 90% residential and 10% commercial - we do not Know the location of an orphan meter, therefore we don't know the rate dass of ttie user Assume that 0,01% of gas is lost to unmetered services, slow meters and lost meters each

Note: Meter Maintenance is equivalent to Zero Reg meters which are stuck meters Note: Theft is comprised of the remaining categones: CIM, Reported Theft. Orphans. Lost/Deleted Meters, Unmetered Services, Vacant Properties, and Seasonal Properties

'age 1 of

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Documents

Exelon - PA.GovStartup time = 60 seconds or one 60111 of an hour 3,600 Mcf per hour/60 = 60 Mcf per slarl 60 Md'/starl * 3 starts per year = 180 Mcf 180 Annual Turbine Start Up Usage