I201806 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 411 St.
Bismarck, ND 58501
Dear Mr. Darras:
On September 10-12,2018 the Idaho Public Utilities Commission, Pipeline Safety Division, pursuant to
Chapter 601 of Title 49, United States Code,conducted the Idaho Falls#2 field inspection of
Intermountain Gas Company's(IGC)equipment in the Teton 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 some 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§192.707(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....
Finding:
During the inspection it was noted that along crossroads adjacent to regulator stations 70127,
70130,70134 and 70136 there were no visual line markers.
2. 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 tests to determine that it is--(1)In good mechanical
condition.

Findin :
During the inspection it was noted that 9 regulator stations on the list were not plumbed for
lock-up. Meter inspector was unable to demonstrate that the regulators were functioning
properly and were able to lock-up when the necessity arrives.
3. 49 CFR§192.479(a)(b)Atmospheric corrosion control:General
a) Each operator must clean and coat each pipeline or portion of pipeline that is exposed to the
atmosphere, ...
b) Coating material must be suitable for the prevention of atmospheric corrosion.
Findin :
During the inspection it was noted that regulator stations 70070 and 70129 had some coating
issues and were in need of paint to cover bare steel that was showing.
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.
Si ,
ckie
ExeEu ve Director
Idaho Public Utility Commission