I202402 NOPV

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
March 6, 2024 Report# I202402 Rev.1
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On February 28, 2024, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a field inspection of (36) Intermountain Gas Company HPSS's
(High-Pressure Service Set) in the towns of Homedale, Wilder, and Greenleaf within the Nampa
District.
Staff found that some of the Idaho natural gas system(s)owned and operated by IGC("Company")
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. 49 CFP 4192.317 Protection from hazards.
(b)Each aboveground transmission line or main,not located offshore or in inland navigable
water areas,must be protected from accidental damage by vehicular traffic or other similar
causes, either by being placed at a safe distance from the traffic or by installing barricades.
OPS 1000 Distribution Integrity Management Plan
3.2.4. Other Outside Force Damage
Other outside force damages are a result from fire or explosion, deliberate or willful acts,
such as vandalism and vehicular damage. Only aboveground facilities are considered when
determining if this threat is present. The primary concern is areas where gas piping is close
enough to vehicular traffic such as automobiles, trucks, forklifts, snowplows, construction
equipment, etc., where it may be reasonably expected that damage from vehicle movement
could occur. Facilities in locations known to be subject to vandalism, destruction,
wreckage,sabotage,or other harm(e.g.,unauthorized adjustment or valve movement)may
carry the other outside force damage threat.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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OPS 403 Section 2 INSPECTION CRITERIA
2.14 Check'for needed protection from vehicular damage(e.g., barricades, bollards, or
meter guards).
2.14.1 Missing crash protection in asphalt, or concrete, shall be identified as Hard
Surface.
2.14.2 Missing crash protection that poses an immediate risk is an AOC.
Findings)
At 122 S 51h St, in Wilder, HPSS# 48321-HPSS-64079 was in the parking lot area with
vehicle damage (bent approximately 30 degrees). Below is a list of HPSS's that staff
discovered were in vehicular traffic areas that were not protected:
• 48321-HPSS-64079- 122 S 5th St(had been struck by a vehicle due to parking space
proximity and was out of plumb)
• 48321-HPSS-69588- 17623 Highway 95 (active gravel pile with heavy equipment
traffic at and near HPSS)
• 48321-HPSS-69237- 20444 Highway 95 (parking space proximity)
• 48321-HPSS-62284-22088 Peckham Rd (driveway)
• 48321-HPSS-64665- 22762 Peckham Rd(driveway)
• 48321-HPSS-64143- 24630 Peckham Rd(driveway)
• 48321-HPSS-64148-24886 Peckham Rd(driveway)
2. 49 CFR 4 192.707 Line markers for mains and transmission lines
(c) Pipelines aboveground. Line markers must be placed and maintained along each
section of a main and transmission line that is located aboveground in an area accessible to
the public.
OPS 610 Pipeline Patrolling and Continuing Surveillance
2.2.4. Pipeline markers are installed,visible, and legible with correct contact information.
OPS 403 Section 2 INSPECTION CRITERIA
2.13 Inspect pipeline markers.
2.13.1 Inspection includes the condition of existing pipeline marker or the need to add
a pipeline marker(s) for better visibility of the HPSS or farm tap. Examples include the
following:
2.13.1.1 In the right-of-way or near high traffic areas.
2.13.1.2 In vegetation that obscures visibility.
2.15 Inspect pipeline markers.
2.15.1 Inspection includes the condition of existing pipeline marker(s) or the need to
add a pipeline marker(s) for better visibility of the meter set, HPSS, or farm tap.
2.15.2 Check that pipeline markers are visible and legible with correct contact
information.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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Findinp-W:
Multiple HPSS's in the Nampa District were found to be without sufficient pipeline
markers. Below is a list of HPSS's that were discovered without adequate markings:
• 48319-HPSS-69227 21074 Po Dunk Lane
• 48325-HPSS-69587 17258 Batt Corner Road Sticker needs to be replaced
• 48325-HPSS-69589 17369 Highway 95
• 48325-HPSS-66719 17535 Highway 95
• 48325-HPSS-65862 17545 Highway 95
• 48325-HPSS-69228 18862 Highway 95
• 48325-HPSS-66673 26059 Boehner Road
• 48325-HPSS-69585 26756 Homedale RD
• 48321-HPSS-64079 122 S 5th St
• 48321-HPSS-66548 153 S 5th St
• 48321-HPSS-69588 17623 Highway 95
• 48321-HPSS-1573389 20368 Highway 95
• 48321-HPSS-69237 20444 Highway 95 #A
• 48321-HPSS-64802 24240 Peckham Road
• 48321-HPSS-66646 24406 Peckham Road
• 48321-HPSS-64143 24630 Peckham Road
3. $ 192.739 Pressure limiting and regulating stations: Inspection and testing.
(a) 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;
(2) Adequate from the standpoint of capacity and reliability of operation for the
service in which it is employed;
(3) Except as provided in paragraph(b) of this section, set to control or relieve at
the correct pressure consistent with the pressure limits of§ 192.201(a); and
(4) Properly installed and protected from dirt, liquids, or other conditions that
might prevent proper operation.
OPS 304 Section 1 Inspection Frequency
1.4 HPSSs and farm taps with a worker/monitor regulator configuration shall be inspected
every calendar year, not to exceed 15 months.
Findings)
Staff reviewed the "IGC HPSS Locations 12/12/23 Final" spreadsheet and found that
HPSS#48321-HPSS-64091 located at 24507 Peckham Road had not been inspected since
3/17/2020.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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4. 49 CFR 4192.605 Procedural manual for operations, maintenance, and emergencies.
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):
Multiple procedures referenced above were not followed per the findings specified within
this NOPV.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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REQUESTED 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 a Company 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 April 20, 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 April 5,2024.
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 April 20, 2024 and must be signed by a Company
official with authority to bind the Company. The reply must include a complete statement of all
relevant facts, and all documentation, evidence, and argument the Company submits to refute any
of the above referenced probable violations.
If you do not respond to this notice by April 20, 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 dollars ($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,
Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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