I201907 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD•P.O.BOX 7608• BOISE,IDAHO 83707•[phone]•FAX:[phone] RECEIVED
August 9,2019 919 AUG 12 AM 9: 45
Mr.Darrin Ulmer
Pipeline Safety,Program Manager
Idaho Public Utilities Commission
P.O.Box 83720-0074
Boise,ID 83720-0074
Subject:Response to July 2,2019 Notice of Probable Violations—Nampa District
Dear Mr. Ulmer,
This letter is intended to address the July 2, 2019 Notice of Probable Violations identified by Idaho Public Utilities
Commission (IPUC) as a result of the June 17-21, 2019 field inspection of Intermountain Gas Company's (IGC)
equipment in the Nampa District.
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 teste to determine that it is--(1)In good mechanical condition.
Finding:
During the inspection it was noted that seven regulator stations on the list were not plumbed for lock-up.
Meter inspector was unable to demonstrate that the regulator was functioning properly and was able to lock-
up when the necessity arises.
Intermountain Gas Response
As mentioned in IGC's December 21,2018 response to the November 16,2018 Notice of Probable Violations—Idaho
Falls District(previously Teton District) and IGC's June 5, 2019 response to the April 30, 2019 Notice of Probable
Violations—Boise District, IGC has completed a data review of all regulator stations inspections from the previous
year. From this review it has been determined that 89 regulator stations are not plumbed for a gauge or other
appurtenance to test for lock-up. Subsequently, IGC is conducting an engineering review of each of the 89 regulator
stations to determine the best solution to resolve the issues pertaining to lock-up testing. The engineering review will
include a schedule and plan for the retrofit,replacement,or abandonment of the 89 regulator stations. IGC anticipates
completing this engineering review by December 31,2019.
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 stations 30025,30027,30035,30052,30053,30078,30084
and 30095 had one or both regulators fail to lock up at the pre-established set point preventing proper
operation.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD• P.O.BOX 7608•BOISE,IDAHO 83707•[phone]• FAX:[phone]
Intermountain Gas Response
As mentioned in IGC's December 13,2018 response to the November 16,2018 Letter of Concern and IGC's June 5,
2019 response to the April 30,2019 Notice of Probable Violations, IGC is currently investigating the application of
filtration devises at each IGC regulator station that failed lock-up two or more times during the three-year period from
2016-2018. The initial data review was completed in June 2019. The remediation plan will include an installation
schedule for the locations where debris filtration is identified as a potential solution. The eight regulator stations
(30025,30027,30035, 30052, 30053,30078,30084 and 30095)that had one or both regulators fail to lock-up at the
pre-established set point were not identified during the initial review.A review of each station's maintenance history
from January 2014 to July 2019 identified minimal instances when the primary or secondary regulator failed to lock-
up. See Figure 1. If the primary or secondary regulator at these eight regulator stations fail to lock-up during the
2020 annual inspection,they will be investigated for the application of filtrations devises.
3. 49 CFR 4192.199(h)Requirements for design of pressure relief and limiting devices.
...Except for a valve that will isolate the system under protection from its source of pressure, be designed to
prevent unauthorized operation of any stop valve that will make the pressure relief valve or pressure limit
device inoperative....
Finding:
During the inspection it was noted that on regulator station 30044 the relief valve was not secure upon arrival
the lock was laying on the ground below the valve.
Intermountain Gas Response
IGC acknowledge the relief at regulator station 30044 was not properly locked. Before the conclusion of the station
inspection,the IGC meter inspector properly installed the lock upstream of the relief valve.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company

Figure 1: Lock-up Summary
Nampa Regulator Station Leek-up Summary
Regulator 1 Regulator 2
Year Asset la Operated Property Operated Property
2019 30025 Yes Yes
2018 30025 Yes Yes
2017 30025 NO Yes
2016 30025 Yes Yes
2015 30025 Yes Yes
2014 30025 Yes NO
2019 30027 Yes Yes
2018 30027 Yes Yes
2017 30027 Yes Yes
2016 30027 Yes Yes
2015 30027 Yes Yes
2014 30027 Yes Yes
2019 30035 Yes Yes
2018 30035 Yes Yes
2017 30035 Yes Yes
2016 30035 Yes Yes
2015 30035 Yes Yes
2014 30035 Yes Yes
2019 30052 Yes Yes
2018 30052 Yes Yes
2017 30052 Yes Yes
2016 30052 No Yes
2015 30052 Yes Yes
2C14 30052 Yes yes
2019 30053 - Yes
2018 30053 Yes Yes
2017 30053 Yes Yes
2016 30053 Yes Yes
2015 30053 No Yes
2014 30053 yes yes
2019 ?3 NO Yes
2018 Yes Yes
2017 Ma Yes
2016 __; _ Yes Yes
2015 Yes Yes
2014 Yes Yes
Yes. Yes
2018 30M Yes Yes
2017 30094 Yes Yes
2016 30CREs no Yes
2015 30C;S,= Yes Yes
2014 30M Yes Yes
2019 30095 Yes Yes
2018 3OC95 Yes No
2017 30095 Yes Yes
2016 3009.5 Yes Yes
2015 30095 Yes Yes
2014 30095 Yes Yes