I202004 NOPV Response

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EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY %�' a JUL 3 ! AIM 9: 41
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]•FAX:[phone]
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 Violations dated June 19,2020(Report# 1202004)
Dear Mr.Ulmer,
This letter is intended to address three probable violations stemming from a field inspection of Intermountain Gas
Company's(IGC)equipment in the Boise District conducted June 15-18,2020. Specifically,we are addressing how
we plan to bring the probable violations into full compliance.
PROBABLE VIOLATIONS
1. 49 CFR 4192.739(a)(1)Pressure limiting and regulating stations: Inspection and testing.
Each pressure limiting station, relief device(except rupture discs), and pressure regulating
station and its equipment must be subjected at intervals not exceeding 15 months, but at least
once each calendar year, to inspections and tests to determine that it is--(1)In good
mechanical condition.
Finding:
During the inspection it was noted that 3 regulator stations on the list were not plumbed for lock-up.
Meter inspector was unable to demonstrate that the regulators were functioning properly and were able
to lock-up when the necessity arrives.
Intermountain Gas Resnonse
IGC acknowledges the findings brought forth by the IPUC stated above. As stated in previous responses,IGC
created a Not Plumbed for Lockup Mitigation Plan.The plan identified regulator stations that are not equipped
with pressure ports to perform flow and lockup and includes a ten-year mitigation schedule. Regulator station
40165 was retired on July 13, 2020. Regulator stations 40167 and 40170 are scheduled to be retrofitted in
2021.
2. 49 CFR 4192.739(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 station 40169(primary)had one of its regulators fail
to lock up at the pre-established set point preventing proper operation.
Intermountain Gas Resnonse
IGC acknowledges the findings brought forth by the IPUC stated above. Because the regulators at regulator
station 40169 did not fail a lockup test two or more times during calendar years 2016-2018,regulator station
40169 was not included in the IGC Failed to Lockup Mitigation Plan.The following table was extracted from
the annual inspection questions,Regulator I Operated Properly and Regulator 2 Operated Properly.Based on

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
556 SOUTH COLE ROAD-P.O.BOX 7608•BOISE,IDAHO 83707• [phone]•FAX:[phone]
the 2017-2020 annual inspection results and because the regulator was repaired after the failed lockup that
occurred during the June 15-18, 2020 field inspection, regulator station 40169 was not added to the Failed
Lockup Mitigation Plan.
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
40169 Yes Yes Yes Yes Yes Yes Yes Yes No
3. 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...
IGC Procedure 3120.2 2.4
Pipelines installed through pipe hangers shall be centered in the hanger and the pipe must not
come in contact with the bracket.
Finding:
During the inspection it was noted that patrol PP42501 I was off center and making contact with
the bracket.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC stated above. The pipeline hanger at PP-425-011
located at South Eckert Road and the Boise River was adjusted on June 22,2020. (See Figure 1.)
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President, Engineering&Operations Services
Intermountain Gas Company

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD•P.O.BOX 7608• BOISE,IDAHO 83707• [phone]•FAX:[phone]
Figure 1
PP425011 located at South Eckert
Road and the Boise River
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