I202003 NOPV Response

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EXECUTIVE OFFICES d-�, I^� 'f)
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555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]•FAX:[phone]
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July 29,2020
Mr.Darrin Ulmer,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to Notice of Probable Violation dated June 19,2020(Report# 1202003)
Dear Mr. Ulmer,
This letter is intended to address one probable violation stemming from a field inspection of Intermountain Gas
Company's(IGC)equipment in the Nampa District conducted June 8-10,2020.
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 Procedure 4306 Sec. 4.1.1.
Finding:
During the inspection it was noted that regulator stations 30017,30018,30019,30022,30084,30090,
30095, 30100, 30110 and 30195 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 IPUC stated above. 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
heater, pilot heater, stainless steel stems for pilots, line heater, or strainers.
• Creation of a ten-year schedule based on a consequence of failure rating.
Regulator station 30018 is scheduled to be replaced in 2020. Regulator station 30019 is scheduled to be
retrofitted with strainers in 2022. The remaining eight regulator stations were not identified during the 2019
review.The following table was extracted from the annual inspection questions Regulator I Operated Properly
and Regulator 2 Operated Properly. Based on the results,regulator stations 30017 and 30110 have been added
to the Failed to Lockup Mitigation Plan; each being scheduled to have pilot sulfur filters installed in 2026.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
Station 2017 2017 2018 2018 2019 2019 2020 2020 Add to
Number Reg 1 Reg 2 Reg 1 Reg 2 Reg 1 Reg 2 Reg 1 Reg 2 Plan
30017 Yes Yes No Yes No Yes Yes Yes Yes
30022 Yes Yes Yes Yes Yes Yes Yes Yes No
30084 Yes Yes Yes Yes Yes Yes Yes Yes No
30090 Yes Yes Yes Yes Yes Yes No Yes No
30095 Yes Yes Yes No Yes Yes Yes Yes No
30100 Yes Yes Yes Yes Yes Yes Yes Yes No
30110 Yes Yes Yes Yes No Yes No Yes Yes
30195 NA NA NA NA Yes Yes Yes Yes No
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