I202005 NOPV

Idaho Public Utilities Commission Bmd Uttle,Govemor
PO Box 83720,Boise,ID 83720-0074 Paul Kjellander,Commissioner
Kristine Raper,Commissioner
Eric Anderson,Commissioner
July 14, 2020 Report# 1202005
Pat Darras
Intermountain Gas Company
400 N 0 St.
Bismarck, ND 58501
Dear Mr. Darras:
On July 6-7, 2020 the Idaho Public Utilities Commission, Pipeline Safety Division, pursuant to Chapter
601 of Title 49, United States Code, conducted the field inspection of Intermountain Gas Company's
(IGC) equipment in the Twin Falls District.
During the inspection it was observed that some of the Idaho natural gas distribution system owned and
operated by 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 violations are
listed below:
PROBABLE VIOLATIONS
1. 49 CFR§192.739(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 1 regulator station on the list was 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.
2. 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.
472 West Washington Street,Boise ID 83702
Telephone:[phone] Facsimile:[phone]

Finding:
During the inspection it was noted that regulator station 50087 (primary) had one of its
regulators fail to lock up at the pre-established set point preventing proper operation.
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 2.3
Pipelines installed through or in contact with structural supports(i.e. concrete abutments,piers,
walls, etc. shall be insulated from and supported by the structure
Finding:
Patrol ACP-575-001 gas line/wrap was touching the wing wall, concern of rubbing coating away.
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 August
31, 2020, 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 August 17,
2020.
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 August 31, 2020 and must be signed by a NWGP 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 August 31, 2020,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
IGC TWIN FALLS FIELD PROBABLE VIOLATIONS LETTER—PAGE 2

($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-
4045.
We appreciate your attention to this matter and your effort to promote pipeline safety.
S"n .
Dr
Pipeline Safety, Program Manager
Idaho Public Utility Commission
IGC TWIN FALLS FIELD PROBABLE VIOLATIONS LETTER—PAGE 3