I202304 NOPV

Idaho Public Utilities Commission Brad Little,Governor
` ��� P.O. Box 83720, Boise,ID 83720-0074 Eric Anderson,President
�� John R.Hammond,Jr.,Commissioner
Edward Lodge,Commissioner
May 25, 2023 Report # 1202304
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 0' St.
Bismarck, ND 58501
Dear Mr. Darras:
On May 22-24, 2023, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a Construction inspection on service lines 317-24833 & 317-50850
of Intermountain Gas Company ("IGC") pursuant to Chapter 601 of Title 49, United States Code.
Staff observed that some of the Idaho natural gas distribution system owned and operated by IGC
was out of compliance on item(s). This results in probable violations of the pipeline safety
regulations Title 49, Code of Federal Regulations,Part 192. The probable violations are as follows:
PROBABLE VIOLATION(S)
1. 192.605 Procedural manual for operations, maintenance, and emeruncies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include procedures
for handling abnormal operations. This manual must be reviewed and updated by the
operator at intervals not exceeding 15 months, but at least once each calendar year.
This manual must be prepared before operations of a pipeline system commence.
Appropriate parts of the manual must be kept at locations where operations and
maintenance activities are conducted.
OPS 500 Regulator Station Inspection and Maintenance
4.1. Regulators shall be set to lockup at the designated set pressure, unless setting during
flow conditions allows the regulator to lockup at a pressure equal to or less than the
MAOP. For example, a regulator may be set during flow conditions provided the set
pressure plus the known droop (e.g., the difference between lockup and delivery
pressure) does not exceed MAOP.

2. 49 CFR &192.739 (a) (4) Pressure limiting and regulating stations: Inspection and
testing.
Pressure limiting and regulating stations: Inspection and testing—reads: Properly
installed and protected from dirt, liquids, or other conditions that might prevent proper
operation.
Finding(s)
Regulator station 48363-RS-59887 and Regulator Station 48275-RS-59918 failed to lock
up on the primary side. Metal shavings debris was found in each of the diaphragms and
regulator bodies when disassembled. Fixed on-site with disassembly, debris removal, and
retest.
3. Appendix D to Part 192—Criteria for Cathodic Protection and Determination of
Measurements
i. Criteria for cathodic protection—A. Steel
1. A negative(cathodic) voltage of at least 0.85 volt, with reference to a saturated
copper-copper sulfate half-cell. Determination of this voltage must be made with
the protective current applied, and in accordance with sections II and IV of this
appendix.
Finding(s)
Regulator station 48267-RS-59849 did not meet the criteria of having a negative
(cathodic) voltage of at least 0.85 volts when measured with a saturated copper-copper
sulfate half cell. The CP Technician was able to fix the issue on site by removing an
insulator of one of the flange bolts to bond the inlet high pressure side with the outlet low
pressure (regulated) side of the regulator station.
REQUESTED ACTIONS
A reply to this correspondence is required no later than 45 days from the date of this letter. Please
submit a written reply providing a statement of all relevant facts including a complete description
of the corrective action(s) taken with respect to the above referenced probable violations, and all
actions to be taken to prevent future failures in these areas of concern. This written reply must be
signed by an IGC official with authority to bind the company.
Please send all documents to our office at 11331 W. Chinden Blvd, Boise, Idaho 83714-1021. Be
advised that all material you submit in response to this enforcement action may be a public record
and subject to disclosure under Idaho's Public Records Law. See Idaho Code §§74-101 et seq.
If you wish to dispute any of the above referenced potential violations, you have the right to
appear before the Pipeline Safety Division in an informal conference before July 9, 2023, at the
above address. You have the right to present relevant documents and evidence to the Pipeline
Safety Division at that conference. The Pipeline Safety Division will make available to you any

evidence which indicates that you may have violated the law, and you will have the opportunity
to rebut this evidence. See Commission Orders 35095 and 35334, which can be found at
https://puc.idaho.gov/.If you intend to request an informal conference,please contact the Pipeline
Safety Division no later than June 24,2023.
If you wish to dispute any of the allegations in this Notice,but do not want an informal conference,
you may send the Pipeline Safety Division a written reply to this Notice. This written reply must
be filed with the Commission on or before July 9, 2023, and must be signed by an IGC official
with authority to bind the company. The reply must include a complete statement of all relevant
facts, and all documentation, evidence, and argument IGC submits to refute any of the above
referenced probable violations.
If you do not respond to this notice by July 9, 2023, you may be subject to any Commission
enforcement action as allowed under Idaho law, including but not limited to, potential civil
penalties of up to two hundred thousand ($200,000). See Idaho Code §61-712A.
If you have any questions concerning this Notice,please contact me at(208) 334-0333.All written
responses should be addressed to me at the above address, or you may fax your response to (208)
334-3762.
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sincerely,
IL---
JeffBrooks
Pipeline Safety, Program Manager
Idaho Public Utility Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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