I202401 NOPV

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Idaho Public Utilities Commission Brad Little,Governor
O.Box 83720,Boise,ID 83720.0074 Eric Anderson,President
John R.Hammond,Jr.,Commissioner
Edward Lodge,Commissioner
February 28, 2024 Report#I202401
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 4ch St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On February 14, 2024, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), received a complaint from a concerned citizen in regard to a meter swap on
February 13, 2024. Staff reviewed Intermountain Gas Company's ("IGC") procedures and the
documentation related to the complaint pursuant to of Title 49, United States Code.
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 VIOLATIONS)
1. 49 CFR 4192.605 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.
2. OPS 312 Gas Service Person Handbook
6.5. Using approved gas detection equipment or soap solution, check
aboveground piping and appurtenances, mechanical fittings, meter stops,
caps, valves, any disturbed fittings, and other areas for leaks.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]

Findinds)•
Staff discovered through IGC documentation on meter#482748375, and a complaint filed
with the Commission that a meter installation(for the replacement of meter#482611494)
was not properly checked for leaks and had to be revisited for leak repair after a customer
reported an emergency gas outside odor call through the IGC leak line. The responding
technician referenced that both the inlet and outlet of the meter were leaking and had not
been properly installed/tightened. This resulted in a class 2 leak. The use of gas detection
equipment and or the use of a soap solution should have identified a leaking meter inlet
and outlet as per the requirements of IGC OPS 312 § 6.5.
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 13, 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 March 29,2024.
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 13, 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 13, 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.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]

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
Telephone:[phone] Facsimile:[phone]