I202502 NOPV

Idaho Public Utilities Commission Brad Little,Governor
P.O.Box 83720, Boise,ID 83720.0074 Edward Lodge,President
John R.Hammond,Jr.,Commissioner
Dayn Hardie,Commissioner
April 29, 2025 Report# I202502
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck,ND 58501
Dear Mr. Pat Darras:
On March 31 through April 2 of 2025, the Idaho Public Utilities Commission ("Commission"),
Pipeline Safety Division ("Staff'), conducted a field audit of the Boise District of Intermountain
Gas Company("IGC")pursuant to Chapter 601 of Title 49, United States Code.
Staff observed 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.
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 4192.739 Pressure limiting and regulating stations: Inspection 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;
(4) Properly installed and protected from dirt, liquids, or other conditions that might
prevent proper operation.
IGC BOISE FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 1 of 4

OPS 500 Regulator Inspection and Maintenance
3. GENERAL INSPECTION AND MAINTENANCE
3.16 Inspect and maintain valves that are part of the regulator station per the
inspection and maintenance criteria of OPS 703 — Valve Inspection and
Maintenance.
3.16.1 Inlet and outlet valves assigned a Maximo ID are included in a separate
valve maintenance program and documented on a Valve Annual
Maintenance Work Order in the compliance tracking software application.
Refer to OPS 703 —Valve Inspection and Maintenance.
4. REGULATOR INSPECTION AND MAINTENANCE
4.1 Regulators shall be set to lockup at the designated lockup pressure, with
some allowance for lockup fluctuation (see chart below), but the regulator shall
lockup at a pressure equal to or less than the MAOP.
Finding(s)•
During the 2025 Boise District Field Audit, IPUC Inspectors observed Regulator Station 48375-
RS-60005 fail the lock up test on both the primary and secondary regulators due to dithiazine in
the primary regulator and debris build up in the secondary regulator.
3. 49 CFR 4 192.707 Line markers for mains and transmission lines
(c) Pipelines aboveground. Line markers must be placed and maintained along each
section of a main and transmission line that is located aboveground in an area accessible to
the public.
OPS 610 Pipeline Patrolling and Continuing Surveillance
5. PIPELINE PATROL PROCESS
5.4. Pipeline Patrol Inspection:
5.4.2.7. Pipeline markers.
5.4.2.7.1. Pipeline markers shall be inspected for damage and overgrowth that
may obscure their visibility.
5.4.2.7.2. Verify that pipeline markers are visible and legible with correct
contact information.
OPS 304 High Pressure Service Set (HPSS)
2. GENERAL INSPECTION AND MAINTENANCE
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 ROW or near high traffic areas.
2.13.1.2 In vegetation that obscures visibility.
IGC BOISE FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 2 of 4

Findinds)•
During the 2025 Boise District Field Audit, IPUC Inspectors observed multiple HPSS's with
discrepancies.
• Missing line markers: 48375-HPSS-68950, 48375-HPSS-68981, 48375-HPSS-64801,
48375-HPSS-62243, 48375-HPSS-62332, 48375-HPSS-68971, 48375-HPSS-69004,
48375-HPSS-62244, 48375-HPSS-66683.
• Buried emergency shut off valve (stop): 48375-HPSS-62332.
• Overgrown Vegetation: 48375-HPSS-69004, 48375-HPSS-68982, 48375-HPSS-68986
4. 49 CFR 4192.181 Distribution Line Valves.
(a) Each high-pressure distribution system must have valves spaced so as to reduce the
time to shut down a section of main in an emergency. The valve spacing is determined
by the operating pressure, the size of the mains, and the local physical conditions.
(b) Each regulator station controlling the flow or pressure of gas in a distribution system
must have a valve installed on the inlet piping at a distance from the regulator station
sufficient to permit the operation of the valve during an emergency that might preclude
access to the station.
(c) Each valve on a main installed for operating or emergency purposes must comply with
the following:
(1) The valve must be placed in a readily accessible location so as to facilitate its
operation in an emergency.
(2)The operating stem or mechanism must be readily accessible.
OPS 703 Valve Inspection and Maintenance
4. Valves that require maintenance (see Section 3.) found inaccessible and/or inoperable
must be remedied. The remediation shall be completed prior to the compliance date for
the maintenance.
4.1. Inaccessible and inoperable valves that separate Emergency Shutdown
Sections as defined in OPS 704 — Emergency Shutdown Sections, shall have an
alternative valve that is accessible and operable designated in the place of
inoperable valves. (Legacy terms for Emergency Shutdown Sections include
Shutdown Areas, E-Valve Districts, Sectionalizing Plans, Key Valves, etc.). If
applicable, the change will be recorded in the district Emergency Shutdown Plans.
4.1.1. Personnel who discover inaccessible and inoperable Emergency
Shutdown Section valves shall contact their manager or supervisor as soon as
practical, but no later than the next business day.
4.1.2. Local Field Operation Management, or designee, shall submit an
ENGMOC to report inaccessible and inoperable Emergency Shutdown
Section valves as soon as practical, but no later than the next business day.
Findinds)•
During the 2025 Boise District Field Audit,IPUC Inspectors observed three emergency valves that
were unable to be operated due to ice build-up. Valves: 48375-VLV-30214, 48375-VLV-34549
and 48375-VLV-32826. Upon further investigation, it was confirmed through IGC Compliance
Personnel that the valve technicians did not report the inoperable emergency valve (48375-VLV-
32826)within the required timeframe as stated in OPS 703 Section 4.1.1.
IGC BOISE FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 3 of 4

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 June 13, 2025, 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 May 29, 2025.
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 June 13, 2025, 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.
These violations may be subject to any Commission enforcement action as allowed under Idaho
law including, but not limited to,potential civil penalties in accordance with 49 CFR 190.223(a).
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.
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]
IGC BOISE FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 4 of 4