I202305 NOPV

PP-C
aho Public Utilities Commission Brad Little,Governor
.Box 83720,Boise,ID 83720.0074 Eric Anderson,President
John R.Hammond,Jr.,Commissioner
Edward Lodge,Commissioner
August 8, 2023 Report# I202305
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 4th St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On August 2, 2023, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division("Staff'), conducted a Construction Inspection on Intermountain Gas Company(IGC) in
Kuna, ID pursuant to Chapter 601 of Title 49, United States Code.
Staff observed that some of the Idaho natural gas system(s) owned and operated by IGC
("Company")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. 49 CFR�192.605 Procedural manual for operations, maintenance, and emergencies.
(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.
Squeeze-Off of Plastic Pipe—OPS 309
2.2 Ground the squeeze-off tool with a static electric grounding device before placing the
squeeze-off tool on the pipe, apply a soapy water solution and wet non synthetic cloth
(such as cotton or burlap material) upstream of squeeze location, or commercially
available electrostatic discharge fluid to the pipe surface on the squeeze location to
provide for dissipation of static charge to the ground.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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Findings)
During a construction inspection on Service Line#0 1193 2-3 75 & 11014-375 at 86 & 102
N Coltsfoot Ave. Kuna, Idaho, a contractor representing IGC squeezed a service line
without using a soapy water solution and wet non synthetic cloth(such as cotton or burlap
material) upstream of squeeze location, or commercially available electrostatic discharge
fluid.
This is the second finding of the same nature in less than 3 months—also reference NOPV
#1202303.
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 a Company 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 September 22, 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 September 7, 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 September 22,2023, and must be signed by a Company
official with authority to bind the Company. The reply must include a complete statement of all
relevant facts, and all documentation, evidence, and argument the Company submits to refute any
of the above referenced probable violations.
If you do not respond to this notice by September 22, 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 dollars ($200,000). See Idaho Code §61-712A.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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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,
Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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