I201803 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
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555 SOUTH COLE ROAD•P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone] P'A t;
December 20,2018
Mr.Joe Leckie
Executive Director
Idaho Public Utilities Commission
P.O. Box 83720-0074
Boise,ID 83720-0074
Subject: Response to November 16,2018 Notice of Probable Violations—Sawtooth District
Dear Mr. Leckie,
This letter is intended to address the November 16,2018 Notice of Probable Violations identified by Idaho Public Utilities
Commission(IPUC)during the May 15,2018 HPSS specialized inspection of the Sawtooth District.
PROBABLE VIOLATIONS
1. 49 CFR 4192.479(a)(b)Atmospheric corrosion control.
Each operator must clean and coat each pipeline or portion of pipeline that is exposed to the atmosphere...
Coating material must be suitable for the prevention of atmospheric corrosion.
2. IGC's Standard Operating Procedure 4803 Atmospheric Corrosion Control 4.Color(4.1).
Small Meter Sets and High Pressure Service Sets(HPSS)will be gray unless otherwise specified.
3. IGC's Standard Operating Procedure 4803 Atmospheric Corrosion Control 4.Color(5.1).
Apply the coating to ensure a uniform protective coating sufficient to prevent atmospheric corrosion and
promote safe operation of the pipeline facility.
4. 49 CFR 4192.605(b)(1)(2)Procedural manual for operations,maintenance,and emereencies.
Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart
and subpart M of this part. Controlling corrosion in accordance with the operations and maintenance
requirements of subpart 1 of this subpart.
Findines•
During your inspection it was noted that the High Pressure Service Set (HPSS) for service line 00395-625
located at 114 S 600 West in Paul, Idaho had corrosion issues beyond what is considered light surface oxide,
as a result it had numerous leaks. A contributing cause of the leaks is the lack of a uniform protective coating
sufficient to prevent atmospheric corrosion.
Intermountain Gas Response
Intermountain Gas Company (IGC) acknowledges that the HPSS on service line 00395-625 had the presence of light
surface oxide and leaks at some threaded connections. Within two weeks of receiving the May 14-16, 2018 Idaho PUC
Pipeline Safety Inspection Summary findings, the Corrosion Technician investigated the HPSSs with reported shorts.
Using trouble shooting methods, the Technician found the HPSS was not shorted to the corrugated metal pipe. On
December 12,2018,the Technician returned to take ultrasonic thickness(UT)readings of the pipe nipples included in the
HPSS. All UT readings were within API 5L tolerances, thus indicating no wall loss due to corrosion. IGC affirms that
since the pipe was being appropriately cathodically protected, we are promoting safe operation of the pipeline.

Additionally,no corrosion leaks were found. The leaks on the HPSS discovered during the IPUC inspection were repaired
by greasing the inlet stop and tightening loose fittings. (See Figure 1.) Lastly, IGC accelerated the HPPS Inspection
schedule of this HPSS from 2019 to May 29, 2018. The inspection included painting the HPSS assembly, replacing the
regulator and testing for lock-up.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
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Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company
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Figure is HASS-116 S.500 W,Paul. ID
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