I202301 LOC

Idaho Public Utilities Commission Brad Little,Governor
P.O. Box 83720, Boise, ID 83720.0074 Eric Anderson,President
John R.Hammond,Jr.,Commissioner
Edward Lodge,Commissioner
Letter of Concern
April 10, 2023 Report# I202301
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 4th St.
Bismarck, ND 58501
Dear Mr. Darras:
On March 27-30, 2023, the Idaho Public Utilities Commission, Pipeline Safety Division,
pursuant to Chapter 601 of Title 49, United States Code, conducted a Records inspection of
Intermountain Gas Company (IGC).
As a result of the inspection, it appears there are area(s) 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 2022.
The item(s) listed below are of concern:
1. 49 CFR�192.605 Procedural manual for operations, maintenance, and emergencies.
(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.
Finding(s)-
Per IGC OPS 706 Leak Survey (1.1) Leak survey shall be documented in the Inspection
and Survey application (e.g., IQGeo), except for unodorized lines and shorted casings
which will be documented in PCAD. Prior to the implementation of OPS 402-Corrosion
Control, shorted casings will be documented in legacy software applications. At a
minimum, leak survey records shall contain the following information: (1.1.3) Survey
Method. After viewing 2022 Leak Survey records, the Survey Method was not identified.
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

The above-mentioned item(s) were brought to the attention of IGC compliance representatives
during the inspection. We would request that you review these matter(s) and respond in writing
within 30 days regarding the above issue(s) including any planned corrective actions.
If you have any questions concerning this notice, please contact me at [phone]. All
written responses should be addressed to me at: 11331 W Chinden Blvd, Ste 201-A, Boise, Idaho
83714 or you can fax your response to [phone].
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 attention to this matter and your effort to promote pipeline safety.
Sincerely,
Jeff Broo s
Pipeline Safety, Program Manager
Idaho Public Utility Commission