I202104 NOPV

Idaho Public Utilities Commission Brad Little,Govemor
PO Box 83720,Boise,ID 83720-0074 Paul Kjellander,Commissioner
Kristine Raper,Commissioner
Eric Anderson,Commissioner
April 12, 2021 Report# 1202104
Pat Darras
Intermountain Gas Company
400 N 0 St.
Bismarck, ND 58501
Dear Mr. Darras:
On March 23-24, 2021 the Idaho Public Utilities Commission, Pipeline Safety Division, pursuant to
Chapter 601 of Title 49, United States Code, conducted a Records Audit of Intermountain Gas Company
(IGC).
During the audit inspection it was observed that IGC was out of compliance on some items. This results
in probable violations of the pipeline safety regulations Title 49, Code of Federal Regulations, Part 192.
Those probable violation(s) are listed below:
PROBABLE VIOLATION(S)
1. 49 CFR§192.605(a) Procedural manual for operations, maintenance,and emergencies
Each operator shall prepare and follow for each pipeline, a manual of written procedures for
conducting operations and maintenance activities and for emergency response...
2. 49 CFR§192.751 (c) Prevention of accidental ignition
(c)Post warning signs, where appropriate.
IGC Procedure 3323.1
Section 1.5 Prevention states that... Post public warning signs in order to give notice to the
public that no smoking or open flames are allowed in construction or other affected areas.
Findin s
During field inspections within the companies districts the PUC has found that not all
occurrences of venting or leaking have had signage present as stated in IGC Procedure 3323.1.
During the records audit there were no signs or barricades utilized per the Job Safety Analysis
provided for Form 457 Report#600-008865.Therefore, records are unable to demonstrate that
the Procedure was followed.
11331 W.Chinden Blvd.,Building 8,Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

REQUESTED ACTIONS
A reply to this correspondence, as outlined below, is required no later than 45 days from the date of this
letter. 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,
subject to disclosure under Idaho's Public Records Law. See Idaho Code §§74-101 et seq.
You have a right to appear before the Pipeline Safety Division in an informal conference before May 27,
2021, at the Commission's offices at 11331 W. Chinden Blvd, Bldg 8,Ste 201-A, Boise. You have the right
to present relevant documents 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 IDAPA 31.01.01.21-26. If you intend to
request an informal conference, please contact the Pipeline Safety Division no later than May 13, 2021.
If you wish to dispute 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 May 27, 2021 and must be signed by a IGC official with authority to bind the
company. The reply must include a complete statement of all relevant facts including a complete
description of the corrective action(s)taken and any and all actions to be taken to prevent future
failures in these areas of concern.
If you do not respond to this notice by May 27, 2021,you may be subject to statutory civil penalties and
further enforcement, as allowed under Idaho law. Idaho Code §61-712A states that "[a]ny person who
violates or fails to comply with, or who procures, aids or abets any violation of title 61, Idaho Code,
governing safety of pipeline facilities and the transportation of gas, or of any order, decision, rule or
regulation duly issued by the Idaho public utilities commission governing the safety of pipeline facilities
and the transportation of gas, shall be subject to a civil penalty of not to exceed two thousand dollars
($2,000)for each violation for each day that the violation persists. However,the maximum civil penalty
shall not exceed two hundred thousand dollars ($200,000)for any related series of violation."
If you have any questions concerning this notice, please contact me at(208) 334-0321. Also,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.
Since el ,
r
Darrin M. Ulmer
Pipeline Safety, Program Manager
Idaho Public Utility Commission
IGC RECORDS PROBABLE VIOLATIONS LETTER—PAGE 2