I202309 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
Oct 18, 2023 Report # I202309
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 4th St.
Bismarck, ND 58501
Dear Mr. Darras:
On October 17, 2023, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division("Staff'), conducted a construction inspection on project 667-0331 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 VIOLATIONS)
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.
IGC -Equipment Calibration, Maintenance, and Testing—OPS 501
1.1. Company personnel and contractors are responsible for the calibration,maintenance,
and testing of instruments used on company facilities, and to keep appropriate records of
the date and type of calibration, maintenance, or testing performed.
6.1. Contractors completing work for MDUG shall calibrate/maintain their equipment per
the frequencies and instructions provided in the MDUG Instrument Calibration
Requirements List.
6.2. Equipment calibration expiration dates of instruments and equipment used on
MDUG gas facilities shall be identified by a tag (e.g., sticker).
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

Findina(s)
During a construction inspection on project 667-0331 at 3151 Witnah Rd, America Falls,
Idaho contractor crew members were using a touch pyrometer whose calibration had
expired on 1/13/2023 until IPUC inspector discovered the expiration tag. Pictures
available upon request of expired calibration tag.
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 December 2,2023,
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 November 17, 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 December 2, 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 December 2,2023,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,

eff Brooks
Pipeline Safety, Program Manager
Idaho Public Utility Commission