I201801 NOPV

March 12, 2018 CERTIFIED MAIL
Q
Hart Gilchrist !
Intermountain Gas Company
555 South Cole Rd
Boise, ID 83707
Dear Mr. Gilchrist:
On February 7, 2018 the Idaho Public Utilities Commission, Pipeline Safety Division,
was notified in memo by Greg Watkins that Intermountain Gas Company(IGC) had just
discovered two casings that were not in compliance with the leak survey intervals.
In the memo it was brought to our attention that the Idaho natural gas distribution system
owned and operated by IGC was out of compliance on two shorted casing leak surveys.
This results in probable violations of the pipeline safety regulations Title 49, Code of
Federal Regulations, Part 192 and IGC's Standard Operating Procedures (Procedure
4801, 5.4 Casings, pg. 5 of 7). Those probable violations are listed below:
PROBABLE VIOLATIONS
1. 49 CFR 092.605 (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 48015.4 Casings 5.4.4. (2.)
If option (1) is impractical....the casing may be monitored with leak detection
equipment at intervals not to exceed those prescribed by O.P.S. in sections
192.705 and 192.721.
2. 49 CFR �192.721 (b)(2) Distribution Systems: PatrollinR.
Outside business districts, at intervals not exceeding 7 % months, but at least
twice each calendar year.
Findin s
It was revealed in the memo that the leak surveys on shorted casings (72501110
and 82700901) were not monitored with leak detection equipment at the intervals

required by standard operating procedure 4801- Cathodic Protection. The
previous leak survey for this portion of the distribution system was completed in
April of 2017. To be in compliance, the leak survey must have been completed
by the third week of November 2017. The surveys were completed in April and
ultimately"closed" inadvertently by the Corrosion Technician in IGC's
compliance software(the software automatically schedules a new 6 month survey
to be accomplished). This subsequently did not generate the next 6 month survey
and therefore IGC was not in compliance. After discovering the error, IGC
conducted a survey of both casings (Feb 2, 2018).
The standards and compliance manager informed us that IGC is implementing
changes to the process that will eliminate the possibility of such an event
happening in the future.
Under Title 6, Idaho Statutes,You are subject to civil penalty under 61-712A. Civil
penalty for violation. Any person who violates or fails to comply with, or who procures,
aids or abets any violation of Title 61 of 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 ($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.
A reply to this letter is required no later than 45 days from the date of this letter. Please
send all documents to our office at P.O. Box 83720-0074, Boise, Idaho 83720-0074. Be
advised that all material you submit in response to this enforcement action is subject to
being made publicly available.
You have a right to appear before the Pipeline Safety Division in an informal conference
before April 16, 2018 at the Commission's offices at 472 W. Washington St, Boise. You
have the right to present relevant documents to the Commission at the conference. At the
informal conference, the Commission 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. If you intend to request an informal conference,please contact the Pipeline
Safety Division no later than April 2, 2018.
If you wish to dispute the allegations in this notice,but do not want the informal
conference, you may send to the Pipeline Safety Division at the above address a written
reply to this notice. This written reply must be filed with the Commission on or before
April 16, 2018, and must be signed by a Company Official. The reply must include a
complete statement of all relevant facts including a complete description of the corrective
action you took to correct the non-compliance and actions to be taken to prevent future
repeat failures in these areas of concern.

If you do not respond to this notice, as specified above, by April 16, 2018, you will be
deemed to have admitted the allegations and will be subject to statutory civil penalties.
If you have any questions concerning this notice, please contact me at [phone].
Also all written responses should be addressed to me at the above address or you may fax
your response to [phone].
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sincerely,
V. Joe Leckie
Executive Director/Program Manager
Idaho Public Utility Commission