I201804 LOC

Maho P
ublic Utilities Commission Gov.C.L."Butch"Otter,Governor.
�- P.O.Box 720 Boise,ID 83720-0074 Paul KJellander,Commissioner
Kristine Raper,Commissioner
Eric Anderson,Commissioner
LETTER OF CONCERN
November 16, 2018 CERTIFIED MAIL
Pat Darras
Intermountain Gas Company �o jp�®�
400 N 4th St. 7711
Bismarck, ND 58501
Dear Mr. Darras:
On August 22-23,2018, representatives of the Idaho Public Utilities Commission, Pipeline Safety,
pursuant to Chapter 601 of Title 49, United States Code,conducted an onsite specialized inspection of
your Nampa inspection unit.
As a result of the inspection,it appears there are areas of concern that do not fully meet the intent of
the pipeline safety regulations Title 49,Code of Federal Regulations, Part 192 for calendar year 2018.
The items listed below are of concern:
1. § 192.197(c)(2)Control of the pressure of gas delivered from high-pressure distribution systems
-reads: ...A service regulator and a monitoring regulator set to limit, to a maximum safe value,
the pressure of the gas delivered to the customer.
2. § 192.739(a) (4) 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.
3. IGC Procedure 3112.5 Sec 5.5—reads:A strainer or filter may be installed upstream of the
regulator(s)in areas where slag or debris is a concern.
During the inspection it was noted that eight stations had either the primary or secondary regulators fail
to properly lock-up when tested. The primary cause of these failures was metal shavings,weld slag or
sulfur.
The above mentioned items were brought to the attention of your representatives during the onsite
inspections.We would request that you review these matters and respond in writing within 30 days
regarding the above issue including any planned corrective actions.

If you have any questions concerning this notice, please contact me at(208) 334-0331.Also all written
responses should be addressed to me at: P.O. Box 83720-0074, Boise, Idaho 83720-0074 or you may fax
your response to(208)334-3762.
Because of the good faith that you have exhibited up to this time,we expect that you will take action to
bring your program into compliance with pipeline safety regulations.
We appreciate your att tion to this matter and your effort to promote pipeline safety.
Sincerely,
r
V. a Leckie
Executive Director
Idaho Public Utility Commission