I202008 NOPV Response

EXECUTIVE OFFICES
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INTERMOUNTAIN GAS COMPANY
29
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
October 9,2020
Mr.Darrin Ulmer,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to Notice of Probable Violations dated September 14,2020(Report# 1202008)
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 Idaho Falls District conducted August 31 —September 2,2020. Specifically,we
are addressing how we plan to bring the probable violation 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 regulator stations 70065,70067,70068,70079,70094,70095,
70100, 70107 and 70110 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 Response
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.The following table
includes the mitigation plan and schedule for the nine regulator stations identified in the IPUC findings.
Regulator Station Regulator Type-Mitigation Plan Tentative
Schedule
70065 Mooney 2x1 -Plumb to existing taps between isolation valves 2022
70067 Mooney 2x1 -Plumb to existing taps between isolation valves 2022
70068 Fisher 621 -Install gauge tap between isolation valves and plumb 2022
70079 Fisher 627-Install gauge tap between isolation valves and plumb 2023
70094 Mooney 2x1 -Plumb to existing taps between isolation valves 2023
70095 Mooney 2x1 -Plumb to existing taps between isolation valves 2024
70100 Fisher 621 -Install gauge tap between isolation valves and plumb 2024
70107 Fisher 621 -Install gauge tap between isolation valves and plumb 2024
70110 Fisher 621 -Install gauge tap between isolation valves and plumb 2024

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President, Engineering& Operations Services
Intermountain Gas Company