I201701 NOPV

Idaho Public Utilities Commission C.L.Butch otter,Governor
P.O.Box 83720,Boise,ID 83720-0074 Paul Kiellander,Commissioner
Kristine Raper,Commissioner
Eric Anderson,Commissioner
NOTICE OF PROBABLE VIOLATION
CERTIFIED MAIL-RETURN RECEIPT REQUESTED
May 16, 2017
Hart Gilchirst "N
VP, Operations
Intermountain Gas Company
555 S. Cole Road
Boise, Idaho 83709
Dear Mr. Gilchrist
On January 18, 2017, representatives of the IPUC inspected Intermountain Gas Company's (IGC)
pipeline safety records and procedures required under 49 C.F.R. §191 & 192 the Idaho Pipeline
system owned and operated by Intermountain Gas Company.
Intermountain Gas Company Regulator Station #30069 experienced pilot regulator filter failure
due to contaminants in filter subsequently causing over pressure and a unintentional release of
gas on two separate occasions. Initial release was at 6:00pm on 12-14-2016 for approximately
98 minutes and then an un-reported second release occurring at 4:41pm on 12-16-2016 for 63
minutes. Asa part of this inspection, based on these findings, the IPUC found the following.
It appears that Intermountain Gas Company has committed probable violations of the pipeline
safety regulations, Title 49, CFR Parts 191 and 192. The probable violations are in reference to
a reportable incident that occurred on December 14, 2016, and reported on PHMSA Form F
7100.1, Report# 201601264658, filing on December 28, 2016:
Probable Violation 1: Intermountain Gas Company failed to timely notify the National
Response Center per their response on PHMSA Form F 7100.0, Part A- Key Report
Information line item #6- National Response Center Report Number and item#7-time
reported to NRC.

This is a violation of IGC Procedure 3010.5 and violation of 49 CFR Part 191, subpart
§191.5(b).
IGC had an obligation to comply with the following;
a. IGC Procedure 3010.5- Natural Gas Emergency Response Plan, Appendix C, Initial
Telephone Report to Federal Agency states: If the incident is reportable by
telephone to the OPS, the following information is reported to the 24-hour number
at the earliest practical moment following notification of the incident:
1. Name of Company (Intermountain Gas Company)
2. Name and telephone number of person calling.
3. Define incident that has occurred.
4. Time incident occurred, day and hours (24-hour time).
S. location of incident.
6. Fatalities or personal injuries, if any.
7. Cause of incident and extent of damage.
b. §191.5 Immediate Notice of Certain Incidents.
(a) At the earliest practicable moment following discovery, each operator shall give
notice in accordance with paragraph (b) of this section of each incident as defined
in §191.3.
(b) Each notice required by paragraph (a) of this section must be made to the
National Response Center either by telephone to 800-267-2675 or electronically at
http://www.nrc.uscg.mil and must include the following information:
(1) Names of operator and person making report and their telephone numbers.
(2) The location of the incident.
(3) The time of the incident.
(4) The number of fatalities and personal injuries, if any.
(5) All other significant facts that are known by the operator that are relevant
to the cause of the incident or extent of the damages.
Probable Violation 2: Intermountain Gas Company failed to produce requested Forms
431 and 433.
This is a violation of IGC Procedure 3370.2 and violation of 49 CFR Part 192, subpart
§192.605(a).
IGC had an obligation to comply with the following;

a. IGC Procedure 3370.2- Material and/or Component Failures states: Forms 431 and
433 are to be completed per procedure.
IGC Definitions; Component... any part or system of parts within a unit including
valves, REGULATORS, strainers or other manufactured devices whose integrity or
reliability is necessary to maintain safety.
Failure... any time a COMPONENT or material is not performing as intended,
expected, warranted or represented.
b. §192.605 Procedural manual for operations, maintenance, and emergencies.
Each operator shall include the following in its operating and maintenance plan:
(a) 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. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least once
each calendar year. This manual must be prepared before operations of a pipeline
system commence. Appropriate parts of the manual must be kept at locations
where operations and maintenance activities are conducted.
Intermountain Gas Company did not review documentation that these procedures were
followed.
Probable Violation 3: Intermountain Gas Company failed to report a release at the Nampa
Gate Regulator Station # 30069 occurring on December 16, 2016 at 4:41 pm. Nampa Gate
pressure log data and IGC Gas Loss Report-Form 308 obtained from prior reportable
incident on December 14, 2016, PHMSA Form F 7100.1, Report # 20160128, filing date
December 28, 2016, indicates that there was a release for approximately 64 minutes
according to the time log and pressures. The volume of gas released would have exceeded
the reportable incident criteria of three million cubic feet or more. The IPUC believes that
this event should have been a recordable incident reportable to PHMSA, NRC and IPUC.
This is a violation of IGC Procedure 3010.5 as well as violations of 49 CFR Part 191,
subparts §191.5(b), §191.9(a), and 49 CFR Part 192, subpart §192.605(a).
IGC had an obligation to comply with the following;

a. IGC Procedure 3010.5- Natural Gas Emergency Response Plan, Appendix C, Initial
Telephone Report to Federal Agency states: If the incident is reportable by
telephone to the OPS, the following information is reported to the 24-hour number
at the earliest practical moment following notification of the incident:
1. Name of Company(Intermountain Gas Company)
2. Name and telephone number of person calling.
3. Define incident that has occurred.
4. Time incident occurred, day and hours (24-hour time).
5. Location of incident.
6. Fatalities or personal injuries, if any.
7. Cause of incident and extent of damage.
b. §191.5 Immediate Notice of Certain Incidents.
(a) At the earliest practicable moment following discovery, each operator shall give
notice in accordance with paragraph (b) of this section of each incident as defined
in §191.3.
(b) Each notice required by paragraph (a) of this section must be made to the
National Response Center either by telephone to 800-267-2675 or electronically at
http://www.nrc.uscg.mil and must include the following information:
(1) Names of operator and person making report and their telephone numbers.
(2) The location of the incident.
(3) The time of the incident.
(4) The number of fatalities and personal injuries, if any.
(5) All other significant facts that are known by the operator that are relevant
to the cause of the incident or extent of the damages.
C. §191.9 Distribution System: Incident Report
(a) Except as provided in paragraph (c) of this section, each operator of a distribution
pipeline system shall submit Department of Transportation Form RSPA F
7100.1 as soon as practicable but not more than 30 days after detection of an incident
required to be reported under§191.5.
d. §192.605 Procedural manual for operations, maintenance, and emergencies.
Each operator shall include the following in its operating and maintenance plan:
(a) 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. For transmission lines,the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and

updated by the operator at intervals not exceeding 15 months, but at least once
each calendar year. This manual must be prepared before operations of a pipeline
system commence. Appropriate parts of the manual must be kept at locations
where operations and maintenance activities are conducted.
Intermountain Gas Company did not review documentation that these procedures
were followed.
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, 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
July 7, 2017 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 June
20, 2017.
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 July 7, 2017, 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 July 7, 2017, 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].
Very truly yours,
V. Joe Leckie
Executive Administrator
Idaho Public Utilities Commission
Attached Forms/Documents:
PHMSA F 7100.1
NAMPA GATE IGC PSI.PV
IGC PROCEDURE 3370.2
IGC PROCEDURE 3010.5/APPENDIX C
IGC GAS LOSS REPORT-FORM 308
PHMSA FACT SHEET
NAMPA GATE PHOTOS
IPUC FORM 1