I201901 NOPV Response

AINTERMOUNTAIN"' _
GAS COMPANY R�C E!V E p 555 SOUTH COLE ROAD • P.O.BOX 7608
A Subsidiary of MDU Resources Group,Inc. BOISE,IDAHO 83707•[phone]• FAX.[phone]
In the Community to Serve' £j MAY ZO AM 9: 25 www.Intgas.com
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May 16,2019 iLil 1� OMMISSION
Mr. Darrin Ulmer
Pipeline Safety,Programs Manager
Idaho Public Utilities Commission
P.O.Box 83720-0074
Boise,ID 83720-0074
Subject: Response to April 8,2019 Notice of Probable Violations—Owyhee District
Dear Mr. Ulmer,
This letter is intended to address the April 8, 2019 Notice of Probable Violations (NOPV) identified by the Idaho Public
Utilities Commission (IPUC) during the January 17, 2019 follow-up High Pressure Service Set (HPSS) inspection of
Intermountain Gas Company's(IGC)equipment in the Owyhee District.Listed below are the stated probable violations and
the respective corrective actions taken by IGC.
PROBABLE VIOLATIONS
1. 49 CFR�192.605(a)Procedural manual for operations,maintenance,and emergencies.
General.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. IGC's Standard Operating Procedure 4803 Atmospheric Corrosion Control 1.General(1.2).
If pitting and /or evidence of atmospheric corrosion is found that exceeds this oxide layer; clean and coat or
jacket the area with a material suitable for the prevention of atmospheric corrosion.
3. IGC's Standard Operating Procedure 4803 Atmospheric Corrosion Control 1.General(1.4, 1.4.2).
(1.4)All above ground natural gas piping must be re-evaluated at intervals of three (3)years not to exceed 39
months, to determine if the condition of the coating material is sufficient to provide satisfactory corrosion
protection. When the condition of the coating material is found to be unsatisfactory,the condition report(Crystal
Reports/IGC Operations/Atmospheric Corrosion)will be available for scheduling corrective actions and will be
initiated by:
(1.4.2)Operations Managers for all corrective actions required below the stop on standard meter sets.
4. IGC's Standard Operating Procedure 4803 Atmospheric Corrosion Control 5.(5.1)(5.5).
(5.1)Apply the coating to ensure a uniform protective coating sufficient to prevent atmospheric corrosion and
promote safe operation of the pipeline facility.
(5.5)Soil to air interfaces will have adequate wrap or coating applied to a height that will protect the facility.
5. IGC's Standard Operating Procedure 4803 Atmospheric Corrosion Control 8. (8.1)(8.2)(8.3) Small
Meter Sets and High Pressure Service Sets.
(8.1)Designated employee completes evaluation and necessary paperwork.
(8.2)Information is up-loaded to the Atmospheric Corrosion database for creation of a corrective action report.
(8.3)Operations/District Managers schedules corrective actions.
Page 1 of 3

INTERMOUNTAINy
GAS COMPANY 555 SOUTH COLE ROAD • P.O.BOX 7608
ASubsidiaryofMDU Resources Group,Inc. BOISE,IDAHO 83707• [phone]• FAX:[phone]
In the Community to Serve• www.intgas.com
PROBABLE VIOLATIONS(continued)
6. 49 CFR&192.605(b)(1)(2)Procedural manual for operations,maintenance,and emergencies.
(1)Operating,maintaining,and repairing the pipeline in accordance with each of the requirements of this
subpart and subpart M of this part.
(2)Controlling corrosion in accordance with the operations and maintenance requirements of subpart I of
this subpart.
7. 49 CFR 4191.479(a)(b)Atmospheric corrosion control.
Each operator must clean and coat each pipeline or portion of pipeline that is exposed to the atmosphere,except
pipelines under paragraph(c)of this section. Coating material must be suitable for the prevention of
atmospheric corrosion.
Finding:
On 01/17/19,the Idaho Public Utilities Commission personnel were conducting follow-up inspections on HPSS's
that IGC had inspected in 2018 as part of IGC's HPSS Inspection Program. The HPSS 07676-317 located at
3155 Farmway Rd. Caldwell, ID had been previously inspected by an employee of IGC on 9/04/18. Upon our
arrival the HPSS was found to have localized pitting below the stop on the outlet line of the service(Photo's 1-
3 dated 1/17/19 taken at approximately 12:15 PM by Inspector Russo). The IGC inspector noted on the HPSS
Inspection Form that the HPSS needs paint/soil-air coating wrap and all deficiencies were corrected. It appeared
at the time of our inspection no effort had been made to clean and coat the pitting or jacket the area with a material
suitable for the prevention of atmospheric corrosion. This subsequently falls under failure to follow §192.605.
Therefore, IGC was not in compliance with procedures 4803 1.2, 1.4, 1.4.29 5.1, 5.5, 8.1, 8.2, and 8.3.
Additionally,IGC did not comply with§192.605(b)(1)(2),and§192.479(a)(b).
Intermountain Gas Response
Intermountain Gas Company(IGC)acknowledges that the outlet anodeless service riser(ASR)of the HPSS
associated with service line 07676-317 had localized pitting. IGC also acknowledges the outlet riser was not
cleaned and painted during the HPSS Inspection performed on September 4,2018.In response to the findings
reported by Bruce Perkins via email on January 18,20199 IGC re-inspected the HPSS on January 21,2019 at
which time the outlet ASR was cleaned and painted.IGC also re-wrapped the inlet riser due to some nicks found
in the coating.After further investigation,IGC replaced the outlet riser on April 19,2019.(See Exhibit 1)
To improve the inspection process and documentation,IGC revised the High Pressure Service Set(HPSS)
Inspection Form.The Deficiencies Found question"Needs paint/soil-air coating wrap: ❑Yes o No"was replace
with the following questions:
• HPSS needs paint: ❑Yes o No
• Outlet anodeless service riser needs paint: ❑Yes o No o NA
• Inlet and/or outlet riser soil-to-air interface needs wrap: ❑Yes o No
The attached Compliance Alert(See Exhibit 2)was distributed to all MDU Utility Group employees. The
Compliance Alert is intended to increase awareness of the potential for pitting and/or corrosion on ASRs and to
remind personnel performing Atmospheric Corrosion(AC),Farm Tap or HPSS Inspections that ASR inspection
are always required.
On May 7,2019,the Service Technician who performed the September 4,2018 inspection and January 21,2019
follow-up inspection had the following Operator Qualifications suspended.The technician is currently receiving
training and must requalify for the following Operator Qualifications prior to completing future HPSS
Inspections.
Page 2 of 3

INTERMOUNTAIN"' 555 SOUTH COLE ROAD • P.O.BOX 7608
GAS COMPANY A Subsidiary of MDU Resources Group,Inc. BOISE,IDAHO 83707. 208 377-6000• FAX.[phone]
In the Community to Serve" www.intgas.com
• 192-0401 Corrosion Monitoring-Atmospheric,External,and Internal
• 192-0402 Coating Maintenance
Lastly,IGC is conducting an independent audit of HPSS Inspections performed by the Service Technician mentioned in this
letter. The audit will include HPSS Inspections completed since March 19, 2018, the date the technician last qualified for
the previously mentioned Operator Qualifications.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
I&/)4;L��
Pat Darras
Vice President,Engineering&Operations Services
Page 3 of 3

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