I201803 NOPV

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Idaho Public Utilities Commission Gov.C.L."Butch"Otter,Governor
P.O.Box 83720 Boise,ID 837244074 Paul Kjallander,Commissioner
`../ K&Une Raper,Commissioner
Eric Anderson,Commissioner
November 16,2018 CERTIFIED MAIL
Pat Darras f g o/ 0.3
Intermountain Gas Company
400 N V'St.
Bismarck, ND 58501
Dear Mr. Darras:
On May 15,2018 the Idaho Public Utilities Commission, Pipeline Safety Division, pursuant to Chapter
601 of Title 49, United States Code, conducted an HPSS specialized inspection of your Sawtooth district
in Paul, Idaho.
During the inspection it was observed that some of the Idaho natural gas distribution system owned and
operated by IGC was out of compliance on four items. This results in probable violations of the pipeline
safety regulations Title 49,Code of Federal Regulations, Part 192. Those probable violations are listed
below:
PROBABLE VIOLATIONS
1. 49 CFR§192.479(a)(b)Atmospheric corrosion control.
Each operator must clean and coat each pipeline or portion of pipeline that is exposed to the
atmosphere... Coating material must be suitable for the prevention of atmospheric corrosion.
2. IGC's Standard Operating Procedure 4803 Atmospheric Corrosion Control 4.Color(4.1).
Small Meter Sets and High Pressure Service Sets(HPSS) will be gray unless otherwise specified.
3. IGC's Standard Operating Procedure 4803 Atmospheric Corrosion Control S.Color(5.1).
Apply the coating to ensure a uniform protective coating sufficient to prevent atmospheric
corrosion and promote safe operation of the pipeline facility.
4. 49 CFR§192.605(b)(1)(2)Procedural manual for operations,maintenance,and emergencies.
Operating, maintaining, and repairing the pipeline in accordance with each of the requirements
of this subpart and subpart M of this part. Controlling corrosion is accordance with the
operations and maintenance requirements of subpart l of this subpart.

IGC's Standard Operating Procedure 4803 Atmospheric Corrosion Control 1.Color(1.11
IGC facilities geographically exist in a dry, and climate that experiences only light oxide
formation on exposed piping. This oxide layer is considered to be protective coating to above
ground pipe and does not affect the safe operation of the pipeline if it is not at soil to air
interfaces,pipe supports,disbanded coatings and other conditions that could create an active
corrosion cell.
Authority
49 CFR 192 and 195& Inspector Web-Based Training Terms(2015) by U.S. Department of
Transportation&Pipeline and Hazardous Materials Safety Administration(PHMSA). Defines
light surface oxide as a non-damaging form of corrosion.
In PHMSA Pipeline Safety Stakeholder Communications dates September 24 2018 labeled
Fact Sheet Corrosion:
Corrosion can result in gradual and usually localized metal loss resulting in reduction of the wall
thickness of the pipe. If not prevented or mitigated effectively,the result can be through-wall
pinholes in the pipe material or a loss of pipe strength at threat location that can cause a crack
or split in the pipe wall. The result is either leakage from the pipe(typical)or an open break
failure(rupture)of the pipe (much less typical) unless the corrosion is repaired,the affected
pipe section is replaced,or the operating pressure of the pipeline is reduced.
Finding•
During the inspection it was noted that HPSS(#00395-625)located at 114 S 600 West in Paul,
Idaho had corrosion issues beyond what is considered light surface oxide,as a result it had
numerous leaks as seen in attached photos 1-3. A contributing cause of the leaks is the lack of a
uniform protective coating sufficient to prevent atmospheric corrosion.
Under Title 6, Idaho Statutes,You are subject to civil penalty under 61-712A.Civil penalty for violation.
Any person who violates or fails to comply with,or who procures,aids or abets any violation of Title 61
of Idaho Code,governing safety of pipeline facilities and the transportation of gas,or of any order,
decision, rule or regulation duly issued by the Idaho public utilities commission governing the safety of
pipeline facilities and the transportation of gas,shall be subject to a civil penalty of not to exceed two
thousand dollars($2,000)for each violation for each day that the violation persists. However,the
maximum civil penalty shall not exceed two hundred thousand dollars($200,000)for any related series
of violation.
A reply to this letter is required no later than 45 days from the date of this letter.Please send all
documents to our office at P.O. Box 83720-0074, Boise, Idaho 83720-0074. Be advised that all material
you submit in response to this enforcement action is subject to being made publicly available.
You have a right to appear before the Pipeline Safety Division in an informal conference before January
11, 2019 at the Commission's offices at 472 W.Washington St, Boise. You have the right to present
relevant documents to the Commission at the conference. At the informal conference,the Commission
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. If you intend to request an informal conference, please
contact the Pipeline Safety Division no later than December 28,2018.
If you wish to dispute the allegations in this notice, but do not want the informal conference,you may
send to the Pipeline Safety Division at the above address a written reply to this notice. This written
reply must be filed with the Commission on or before January 4,2019,and must be signed by a
Company Official. The reply must include a complete statement of all relevant facts including a
complete description of the corrective action you took to correct the non-compliance and actions to be
taken to prevent future repeat failures in these areas of concern.
If you do not respond to this notice,as specified above, by January 4,2019,you will be deemed to have
admitted the allegations and will be subject to statutory civil penalties.
If you have any questions concerning this notice, please contact me at(208)334-0331.Also 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 o this matter and your effort to promote pipeline safety.
Since ,
V.Joe Le le
Executive Director
Idaho Public Utility Commission

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Photo 2, 15 May 2018. 114 S. 600 W. Paul, ID.
Hess # 00395 -625. Leaking Gas and Atmops eric
orrosion. Photo taken by Inspector ULmer

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to #3 f 1 a,1/�t 2018. 14 S. 600 W. Paul, ICE.
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0 3 5-625. Leafing Gas and Atmospheric
o can. Photo taken by Inspector Ulmer