I201805 NOPV

�+ Idaho Public Utilities Commission Gov.C.L."Butch"Otter,Governor
`! P.O.Box 83720 Boise,ID 83720-0074 Paul Kjellander,Commissioner
Kristine Raper,Commissioner
Eric Anderson,Commissioner
November 16, 2018 CERTIFIED MAIL
Pat Darras
Intermountain Gas Company
400 N 41'St.
Bismarck, ND 58501
Dear Mr. Darras:
On August 21-23,2018 the Idaho Public Utilities Commission, Pipeline Safety Division, pursuant to
Chapter 601 of Title 49, United States Code,conducted the Nampa#2 field inspection of Intermountain
Gas Company's(IGC) equipment in the Owyhee District.
During the inspection it was observed that some of the Idaho natural gas distribution system owned and
operated by IGC was out of compliance on three items. This results in probable violations of the
pipeline safety regulations Title 49,Code of Federal Regulations, Part 192. Those probable violations are
listed below:
PROBABLE VIOLATIONS
1. 49 CFR§192.323(d)Casing.
Each casing used on a transmission line or main under a railroad or highway must comply with
the following:if vents are installed on a casing, the vents must be protected from the weather to
prevent water from entering the casing.
Finding:
During the inspection it was noted that one vent(#267-01-315)was completely buried and
three others were within a few inches of being in the same condition. The concern is during
inclement weather either snow would cover vent or water intrusion.
2. 49 CFR§192.707(a)(1)Line markers for mains and transmission lines.
... a line marker must be placed and maintained as close as practical over each buried main and
transmission line:At each crossing of a public road and railroad;and....

Findina:
During the inspection it was noted that along Columbia driving to reg station 40107 there were
no visual line markers. On one end a carsonite was found flat on the ground, but on the other
end there were no markers.
3. 49 CFR§Appendix D of Part 192—Criteria for Cathodic Protection and determination of
measurements.
I. Criteria for cathodic protection—A.Steel... (1)A negative(cathodic) voltage of at least 0.85
volt, with reference to a saturated copper-copper sulfate half-cell. Determination of this voltage
must be made with the protective current applied, and IA IN sections/I and IV of this appendix.
Findin :
During the inspection it was noted that at the following locations CP readings were unable to be
ascertained:Casing 267-01-305 and Odorizer 30070. CP technician believes possible cause due
to broken lead.
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 January
11,2019 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 December 28, 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 January 4,2019,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 January 4,2019,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(208) 334-0331.Also all written
responses should be addressed to me at the above address or you may fax your response to(208) 334-
3762.
We appreciate your attention to this matter and your effort to promote pipeline safety.
K
;kie
Executive Director
Idaho Public Utility Commission