I202302 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
May 22,2023
Mr.Jeff Brooks,Programs Manager,Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to Notice of Probable Violation dated April 10,2023(Report#1202302)
Dear Mr.Brooks,
This letter is intended to address two(2)probable violations stemming from a records inspection conducted by the
Idaho Public Utilities Commission(IPUC)on March 27-30,2023,at Intermountain Gas Company(IGC).
PROBABLE VIOLATIONS
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.
2. 49 CFR§ 192,605 Procedural manual for operations, maintenance, and emergencies.
(b)Whenever any pipe is removed from a pipeline for any reason,the internal surface must be
inspected for evidence of corrosion.
IGC—Inspection,Evaluation,and Repair of Pipelines—OPS 327
3.9 Whenever the internal surface of steel pipe is exposed(damage,repair,replacement,etc.)the
internal surface shall be inspected for evidence of internal corrosion.
Finding(s)•
Project#583-0342 Report#600-9050 at 168 Bonny Dr.Twin Falls had 13'of steel pipe replaced.The form
457 indicates that there was no internal inspection completed on the removed pipe section as required by 49
CFR§192.475 and IGC OPS Procedure 327.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. While it was not indicated on the 457 form that an
internal inspection was completed, an internal inspection was completed on the removed pipe section and was
documented on Form 21722 — Pipeline Condition Report per the requirements of OPS 327 — Inspection,
Evaluation, and Repair of Pipelines. IGC acknowledges the documentation error and has provided training to
Company personnel who are responsible for completing and reviewing 457 forms.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
3. 49 CFR§ 192,605 Procedural manual for operations.maintenance.and emergencies.
(b) 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.
4. 49 CFR § 192,192,727 Abandonment or deactivation of facilities
(b)Each pipeline abandoned in place must be disconnected from all sources and supplies of gas;
purged of gas;in the case of offshore pipelines,filled with water or inert materials;and sealed at the
ends.However,the pipeline need not be purged when the volume of gas is so small that there is no
potential hazard.
IGC—Pipeline Purging and Cleaning—OPS 603
4.0 Purging out of service.
4.1.When purging large diameter mains,or longs distances of pipelines when there is a significant
probability of odor calls,contact local emergency services and Scheduling,a minimum of two(2)
hours prior to commencing.
4.2.Purging out of service may be required when existing mains and services are taken out of
service and the removal of residual natural gas is necessary.
4.3.Mains and services four inches(4")and smaller in diameter,do not require purging out of
service provided they do not exceed the maximum allowable lengths shown in Table 2 below.
Finding(sl:
Project#421-0625 at E 41"St in Garden City and Project#425-9831 at Eisenman and Gowen in Boise
where pipelines were abandoned were not purged as required by 49§CFR 192.727 and IGC OPS Procedure
603.
Intermountain Gas Reslionse
IGC acknowledges the findings brought forth by the IPUC.While it was not accurately documented on the 319
forms that the abandoned pipelines were purged,a purge was completed for the projects outlined above per the
requirements of OPS 603 —Pipeline Purging and Cleaning. The purge is indicated on the 319 forms with the
documented use of a bottle of nitrogen and an air compressor during the project at E 41 st St in Garden City,and
the use of an air compressor during the project at Eisenman and Gowen in Boise. IGC acknowledges the
documentation errors and has provided training to Company personnel responsible for completing and
reviewing 319 forms.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Q
Pat Darras
Vice President,Engineering&Operations Services,Intermountain Gas Company