I201806 NOPV Response

M=LIT IVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD•P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone] ;i b Pi ; t}
December 21,2018
Mr.Joe Leckie
Executive Director
Idaho Public Utilities Commission
P.O. Box 83720-0074
Boise,ID 83720-0074
Subject: Response to November 16,2018 Notice of Probable Violations—Teton District
Dear Mr. Leckie,
This letter is intended to address the November 16,2018 Notice of Probable Violations identified by Idaho Public Utilities
Commission(IPUC)during the September 10-12,2018 field inspection of Intermountain Gas Company(IGC)equipment
in the Teton District.
PROBABLE VIOLATIONS
1. 49 C_FR 4192.707(a)(1)Line markers for mains and transmission lines.
...a line marker must be placed and maintained as close as practical over each buried main and transmission
line: At each crossing of a public road and railroad;and...
Finding:
During the inspection it was noted that along crossroads adjacent to regulator stations 70127,70130,70134 and
70136 there were no visual line markers.
Intermountain Gas Response
IGC installed Carsonite line markers near Regulator Stations 70127, 70130, 70134 and 70136. (See Figure 1, Figure 2,
Figure 3, and Figure 4 respectively.) IGC also added line markers on the high pressure and distribution road crossings
upstream and downstream of these stations.
2. 4192.739(a)(1)Pressure limiting and regulating station:Inspection and testing.
Each pressure limiting station, relief device(except rupture discs),and pressure regulating station and its
equipment must be subject at intervals not exceeding 15 months,but at least once each calendar year,to
inspection and tests to determine that it is(1)In good mechanical condition.
Finding•
During the inspection it was noted that 9 regulator stations on the list were not plumbed for lock-up. Meter
inspector was unable to demonstrate that the regulators were functioning properly and were able to lock-up
when the necessity arrives.
Intermountain Gas Response
While performing the 2018 Annual Regulator Station Inspections, IGC inspected and verified the correct set-point of each
regulator at the stations identified as not plumbed for lock-up during the September 12,2018 exit interview. The identified
regulator stations were 70121, 70123, 70120, 70130, 70127, 70129, 70124, 70131 and 70133. Please note that as of
November 21,2018,Regulator Station 70124 has been retired. Upon inspection,each regulator functioned at its set point.
Additionally, each relief valve was tested for lock-up. Therefore, IGC maintains that since each station was left in good
mechanical condition,we have remained compliant with§192.739(a)(1).

3. 49 CFR U92.479(a)(b)Atmospheric corrosion control: General
a) Each operator must clean and coat each pipeline or portion of pipeline that is exposed to the atmosphere...
b) Coating material must be suitable for the prevention of atmospheric corrosion.
Findings:
During the inspection it was noted that regulator stations 70070 and 70129 had some coating issues and were in
need of paint to cover bare steel that was showing.
Intermountain Gas Response
IGC personnel painted the worn and/or bare areas of Regulator Station 70129 on September 14, 2018. (See Figure 5.)
Regulator Station 70070 was painted by a contractor on September 21,2018.(See Figure 6.)
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
/&A 0-44-0--2—
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company
Page 2 of 5

Figure 1:Line Markers Near Regulator Station 70127
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Figure 2:Line Markers Near Regulator Station 70130
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Figure 3:Line Markers Near Regulator Station 701343
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Figure 4:Line Marker Near Regulator Station 70136
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Figure 5:Regulator Station 70129
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