I201904 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD•P.O.BOX 7608•BOISE,IDAHO 83707•[phone]• FAX:[phone] RECEIVED
?019 JUN 24 AM 9: 10
June 20, 2019
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Mr. Darrin Ulmer
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
P.O. Box 83720-0074
Boise, ID 83720-0074
Subject: Response to May 31, 2019 Notice of Probable Violations—Twin Falls District
Dear Mr. Ulmer,
This letter is intended to address the May 31, 2019 Notice of Probable Violations identified by
Idaho Public Utilities Commission (IPUC) during the May 14, 2019 follow-up High Pressure
Service Set inspection of Intermountain Gas Company's (IGC) equipment in Hailey, ID.
PROBABLE VIOLATIONS
1. 49 CFR 4192.605(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.
IGC's Standard Operating Procedure 3111.4 Hillh Pressure Service Sets (HPSS)
-Definitions 4. Small HPSS ... Regulating facility capable of service up to two (2) service
lines up to a maximum combined load of 700 CFH and may be located remotely or at the
building.
-Procedure 1.5. Standard HPSS facilities that serve three or more service lines shall be
reclassified and maintained as a district regulator station.
Finding:
HPSS 00967-521 is supplying 3 service lines located at 3661 A&B and 3671 A at 3671 A
Buttercup, Hailey, ID.
Intermountain Gas Response
Intermountain Gas acknowledges that some service lines, including 00967-521 have more than
two service lines connected downstream of the High Pressure Service Set(HPSS).
The HPSS Inspection Program which began in 2014 identifies HPSSs serving more than two
service lines. The specific yes/no question on the HPSS Inspection Form is "HPSS serving less

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD•P.O.BOX 7608•BOISE,IDAHO 83707•[phone]• FAX:[phone]
than three service lines".As HPSSs with more than two service lines are identified,remedial action
is taken. The preferred mitigation method is connecting the service lines to a distribution pressure
system with a MAOP of 60 psig. Often this mitigation method requires the installation of a district
regulator station and/or new distribution main the following budget year.
As mentioned in the IGC response to the IPUC's January 28, 2019 NOPV, IGC is reviewing
completed HPSS Inspection forms to confirm HPSSs identified as serving more than two service
lines are either mitigated or scheduled for mitigation. The review will include a schedule for the
outstanding mitigation or conversion of certain HPSSs to a district regulator station. IGC
anticipates completing this review by December 31, 2019.
Please contact Josh Sanders at [phone] with questions or comments.
Respectfully Submitted,
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Pat Darras
Vice President, Engineering & Operations Services
Intermountain Gas Company