I202405 NOPV

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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
April 16, 2024 Report#I202405
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck,ND 58501
Dear Mr. Darras:
On April 8-9, 2024, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a Field inspection in the Nampa district of Intermountain Gas
Company ("IGC")pursuant to Chapter 601 of Title 49, United States Code.
Staff observed that some of the Idaho natural gas distribution system owned and operated by IGC
was out of compliance on item(s). This results in probable violations of the pipeline safety
regulations Title 49, Code of Federal Regulations,Part 192.The probable violations are as follows:
PROBABLE VIOLATION(S)
1. 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.
OPS 500 Regulator Station Inspection and Maintenance
4.1. Regulators shall be set to lockup at the designated set pressure, unless setting during
flow conditions allows the regulator to lockup at a pressure equal to or less than the
MAOP. For example, a regulator may be set during flow conditions provided the set
pressure plus the known droop (e.g., the difference between lockup and delivery
pressure) does not exceed MAOP.
IGC NAMPA FIELD INSPECTION PROBABLE VIOLATIONS LETTER—PAGE 1

2. 49 CFR 4192.739 (a) (4) Pressure limiting and regulating stations: Inspection and
testing.
Pressure limiting and regulating stations: Inspection and testing—reads: Properly
installed and protected from dirt, liquids, or other conditions that might prevent proper
operation.
Finding(s)•
Regulator station 48371-RS-1289867 (Dithiazine), 48371-RS-59980 (oil), 48371-RS-
59992, 48371-RS-59976 (metal shavings) failed to lock up on the primary side and
48371-RS-59977 (weld slag) on the secondary side. Metal shavings, compressor oil or
Dithiazine debris were found in the diaphragms and regulator bodies when disassembled.
All issues were fixed on-site upon disassembly, debris removal, and were then retested
with adequate lock up.
REOUESTED ACTIONS
A reply to this correspondence is required no later than 45 days from the date of this letter. Please
submit a written reply providing a statement of all relevant facts including a complete description
of the corrective action(s) taken with respect to the above referenced probable violations, and all
actions to be taken to prevent future failures in these areas of concern. This written reply must be
signed by an IGC official with authority to bind the company.
Please send all documents to our office at 11331 W. Chinden Blvd, Boise, Idaho 83714-1021. Be
advised that all material you submit in response to this enforcement action may be a public record
and subject to disclosure under Idaho's Public Records Law. See Idaho Code §§74-101 et seq.
If you wish to dispute any of the above referenced potential violations, you have the right to
appear before the Pipeline Safety Division in an informal conference before May 31, 2024, at
the above address. You have the right to present relevant documents and evidence to the Pipeline
Safety Division at that conference. The Pipeline Safety Division 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. See Commission Orders 35095 and 35334, which can be found at
https://puc.idaho.gov/. If you intend to request an informal conference,please contact the Pipeline
Safety Division no later than May 16, 2024.
If you wish to dispute any of the allegations in this Notice,but do not want an informal conference,
you may send the Pipeline Safety Division a written reply to this Notice. This written reply must
be filed with the Commission on or before May 31, 2024, and must be signed by an IGC official
with authority to bind the company. The reply must include a complete statement of all relevant
facts, and all documentation, evidence, and argument IGC submits to refute any of the above
referenced probable violations.
IGC NAMPA FIELD INSPECTION PROBABLE VIOLATIONS LETTER—PAGE 2

If you do not respond to this notice by May 31, 2024, you may be subject to any Commission
enforcement action as allowed under Idaho law, including but not limited to, potential civil
penalties of up to two hundred thousand($200,000). See Idaho Code §61-712A.
If you have any questions concerning this Notice,please contact me at(208)334-0333. 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.
Sincerely,
/-A-Y��
Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utility Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
IGC NAMPA FIELD INSPECTION PROBABLE VIOLATIONS LETTER—PAGE 3