I202201 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
April 29,2022
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to Notice of Probable Violation dated March 17,2022(Report#1202201)
Dear Mr.Brooks,
This letter is intended to address one probable violation stemming from a field inspection conducted by the Idaho
Public Utilities Commission(IPUC)on March 14-16,2022,in Intermountain Gas Company's(IGC)Nampa
District.
PROBABLE VIOLATION
1. 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. Which is also covered in IGC OPS 500 Sec.4.1.
Finding(s)
During the inspection it was noted that:
• Regulator stations 48325-RS-60738,48321-RS-59930, 48321-RS-59936,48318-
RS-59839,48267-RS-59881,48363-RS-59887 had one or both regulators fail to
lock up at the pre-established set point preventing proper operation.
Intermountain Gas Response
Intermountain Gas Company (IGC) acknowledges the findings brought forth by the Idaho Public Utilities
Commission on five of the six regulator stations. The regulator station listed as 48318-RS-59839 appears to be
in error. IGC information has the regulator station inspected during the March 14-16, 2022, inspection as
regulator station 48267-RS-59849. As stated in previous responses,IGC created a Failed to Lockup Mitigation
Plan that includes the following:
• Identification of regulator station regulators that failed a lockup test two or more times during calendar
years 2016-2018.
• Review of the identified stations for an appropriate mitigation option: monitor, rebuild, pilot sulfur
heat,pilot heat, stainless steel stems for pilots,line heater, or strainers.
• Creation of a ten-year schedule based on a consequence of failure rating.
IGC used the criteria of two or more failed lock up tests in a three-year period(2020-2022)to evaluate the need
to add the regulator stations referenced in the inspection to the Failed Lock up Mitigation Plan. The following
table was extracted from the annual inspection questions,Regulator I Operated Properly and Regulator 2 Operated
Properly.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
Maximo ID Station Number 2020 Reg 1 2020 Reg 2 2021 Reg 1 2021 Reg 2 2022 Reg 1 2022 Reg 2 Add to Plan
48325-RS-60738 30077 YES YES NO YES NO YES Currently on mitigaion plan
48321-RS-59930 30112 YES YES YES YES NO YES NO
48321-RS-59936 30113 YES YES NO YES NO YES YES
48363-RS-59887 30125 YES YES YES YES NO YES Currently on mitigaion plan
48267-RS-59849 30163 \O YES YES YES NO YES YES
48267-RS-59881 30167 YES YES NO YES NO YES YES
Based on the results,three of the stations identified with lockup failures in 2022,48321-RS-59936,48267-RS-
59849 and 48267-RS-59881 will be added to the Failed Lock up Mitigation Plan. Regulator stations 48325-
RS-60738 and 48363-RS-59887 are currently included in the Failed Lock up Mitigation plan. The information
from the latest inspections will also be used to determine if the remediations for the regulator stations currently
on the plan are appropriate,or if a change to the remediation plan is needed. Station 48321-RS-59930 will not
be added to the Failed Lock up Mitigation Plan based on its 2020-2022 annual inspection results because the
regulator was repaired after the failed lock up that occurred during the March 14-16, 2022, inspection and has
not met the criteria of failing lock two times in a three year period.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
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Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company