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Home My WebLink AboutI202402 NOPV Response EXECUTIVE OFFICES INTERMOUNTAIN GAS COMPANY 555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• (208)377-6000• FAX:377-6097 April 5,2024 Mr.Jeff Brooks,Programs Manager Idaho Public Utility Commission PO Box 83720 Boise,ID 83720-0074 Subject:Response to Notice of Probable Violation dated March 6,2024(Report#I202402) Dear Mr.Brooks, This letter is intended to address four(4)probable violations stemming from a field inspection conducted by the Idaho Public Utilities Commission(IPUC)on February 28,2024,of(36)Intermountain Gas Company's(IGC)High Pressure Service Sets(HPSS)in the towns of Homedale,Wilder,and Greenleaf within the Nampa District. PROBABLE VIOLATIONS 1. 49 CFR § 192,317 Protection from hazards (b)Each above ground 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 3.2.4. 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. 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 immediate risk is an AOC. Finding(s)• At 122 S 5-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 5`h 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) Intermountain Gas Resnonse IGC acknowledges the findings brought forth by the IPUC. Barricades have been installed at the following locations: • 48321-HPSS-64079- 122 S 5th St(WO11791994) 0 48321-HPSS-69588- 17623 Highway 95 (WO11791995) EXECUTIVE OFFICES INTERMOUNTAIN GAS COMPANY 555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• (208)377-6000• FAX:377-6097 • 48321-HPSS-69237-20444 Highway 95 (WO11792003) • 48321-HPSS-62284-22088 Peckham Rd(WO11792005 • 4832 1-HPSS-64665 -22762 Peckham Rd(WO11792006) • 48321-HPSS-64143 -24630 Peckham Rd(WO11792004) • 48321-HPSS-64148-24886 Peckham Rd(W011792001) Training has been provided to AC Surveyors on identifying when protection is needed for Company facilities, including HPSSs. Additionally,new procedure OPS 313—Gas Facility Protection implements on April 12, 2024. OPS 313 establishes the standards for the installation of protection and security devices to protect above ground facilities. Training will be provided to Company employees who install gas facility protection and security devices. 2. 49 CFR § 192.707 Line markers for mains and transmission lines (c)Pipelines above ground.Line markers must be placed and maintained along each section of a main and transmission line that is located above ground 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 contact information. OPS 304 and 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. Finding(sl: Multiple HPSS 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-64079 26756 Homedale Rd • 48321-HPSS-64079 122 S 5th St • 48321-HPSS-66548 153 S 51h 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 Rd • 48321-HPSS-66646 24406 Peckham Rd • 48321-HPSS-64143 24630 Peckham Rd EXECUTIVE OFFICES INTERMOUNTAIN GAS COMPANY 555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•(208)377-6000• FAX:377-6097 Intermountain Gas Response IGC acknowledges the findings brought forth by the IPUC. Pipeline markers have been installed at the following locations: • 48319-HPSS-69227 21074 Po Dunk Lane(FAID 8562815457) • 48325-HPSS-69587 17258 Batt Corner Road(FAID 6265217089) • 48325-HPSS-69589 17369 Highway 95 (FAID 9967399702) • 48325-HPSS-66719 17535 Highway 95 (FAID 2477332634) • 48325-HPSS-65862 17545 Highway 95 (FAID 6414598472) • 48325-HPSS-69228 18862 Highway 95 (FAID 7621917722) • 48325-HPSS-66673 26059 Boehner Road(FAID 6764440393) • 48325-HPSS-64079 26756 Homedale Rd(FAID 6741596229) • 48321-HPSS-64079 122 S 51'St(FAID 3319515642) • 48321-HPSS-66548 153 S 51'St(FAID 1310692733) • 48321-HPSS-69588 17623 Highway 95 (FAID 5484147941) • 48321-HPSS-1573389 20368 Highway 95(FAID 3856315562) • 48321-HPSS-69237 20444 Highway 95#A(FAID 9297418396) • 48321-HPSS-64802 24240 Peckham Rd(FAID 1928617227) • 48321-HPSS-66646 24406 Peckham Rd(FAID 5742656120) • 48321-HPSS-64143 24630 Peckham Rd(FAID 5901298290) 3. 49 CFR§ 192.739 Pressure limiting and regulating stations: Inspect 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. Finding(sl: 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. Intermountain Gas Resnonse HPSS 48321-HPSS-64091 located at 24507 Peckham Road is configured with one (1) regulator and one (1) relief, therefore, does not meet the requirements of a worker/monitor configuration. The next inspection will be performed within 10 years of the previous inspection on March 17,2020. EXECUTIVE OFFICES INTERMOUNTAIN GAS COMPANY 555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• (208)377-6000• FAX:377-6097 4. 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)• Multiple procedures reference above were not followed per the findings specified within this NOPV. Intermountain Gas Response Please see responses above. Please contact Josh Sanders at(701)222-7773 with questions or comments. Respectfully Submitted, Pat Darras Vice President,Engineering& Operations Services Intermountain Gas Company