I202502 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
June 13,2025
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to the Notice of Probable Violation dated April 29,2025 (Report#I202502)
Dear Mr.Brooks,
This letter is intended to address three(3)notices of probable violation stemming from a field audit conducted by the
Idaho Public Utilities Commission(IPUC)on March 31 through April 2,2025,in the Boise district of Intermountain
Gas Company(IGC)pursuant of Chapter 601 Title,49,United States Code.
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§ 192,739(a) (4) 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 is---
(1) In good mechanical condition;
(4)Properly installed and protected from dirt,liquids,or other conditions that might prevent proper
operation.
OPS 500 Regulator Inspection and Maintenance
3. GENERAL INPSECTION AND MAINTENANCE
3.16 Inspect and maintain valves that are part of the regulator station per the inspection and
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 INPSECTION 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(sl•
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.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. The primary regulator was disassembled, cleaned,
and reassembled onsite. The primary regulator locked up as expected during the 2025, 2024, and 2023 annual
inspections. IGC is continuing to monitor the application of filtration devices for regulator stations that fail
lock-up two or more times in a three-year period.A follow up inspection to check for the presence of dithiazine
has been scheduled for July 2025.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
The secondary regulator failed lock up due to the throttle plate not seating properly. The regulator was
dissembled,the throttle plate was readjusted,and the regulator was reassembled onsite.The secondary regulator
locked up as expected during the 2025,2024, and 2023 annual inspections.
3. 49 CFR§ 192.707 Line markers for mains and transmission lines
(c)Pipelines aboveground. Line markers must be placed and maintained along each section of 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 Sets(HPSS)
2. GENERAL INPSECTION 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 the visibility.
Finding(s):
During the 2025 Boise 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
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC.
48375-HPSS-68950- 102 W Hubbard Rd:A pipeline marker was installed June 4,2025(WO12222803).
48375-HPSS-68981 - 150 E Hubbard Rd:Upon further review of the site location,the HPSS is highly visible.A
marker is not required by procedure to be installed.
48375-HPSS-64801 -575 E Hubbard Rd:A pipeline marker was installed on June 04,2025(WO12222804)
48375-HPSS-62243 - 1420 W Hubbard Rd:Upon further review of the site location,the HPSS is highly visible.A
marker is not required by procedure to be installed.
48375-HPSS-62332- 1530 W Hubbard Rd:Upon further review of the site location,the HPSS is highly visible.A
marker is not required by procedure to be installed.
48375-HPSS-68971 -2291 E Hubbard Rd:A pipeline marker was installed on April 30,2025(WO12119811).
48375-HPSS-69004-2460 E Hubbard Rd:IGC conducted a routine atmospheric corrosion survey on February 24,
2025,per the requirements of OPS 403—Atmospheric Corrosion Monitoring.During the survey,a landscape
deficiency(i.e.,overgrown vegetation)and paint deficiency were identified and documented. The deficiencies were

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]•FAX:[phone]
mitigated,within the required time frame,on April 30,2025(WO12041173 and WO12041174).A pipeline marker
was installed on May 6,2025(WO12119811).
48375-HPSS-62244-0 Ten Mile Rd:A pipeline marker was installed on June 04,2025 (WO12222810)
48375-HPSS-66683 - 8815 S Ten Mile Rd:A pipeline marker was installed on April 24,2025(WO12120247).
48375-HPSS-68982-3205 E Hubbard Rd:The overgrown vegetation was mitigated on April 30,2025
(WO 12132471).Additionally,a pipeline marker was installed on April 24,2025(WO12120234)
48375-HPSS-68986-3801 E Hubbard Rd:The overgrown vegetation was mitigated on April 30,2025
(WO12132472).Additionally,a pipeline marker was installed on April 30,2025(WO12120246).
IGC's Quality Control department is conducting an evaluation of HPSS pipeline markers for all districts.Based on
the evaluation,IGC will determine the need to revise applicable procedures to provide additional guidance on the
placement of pipeline markers at HPSS locations.
4. 49 CFR§ 192.181 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 purposed 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 Maintenance
4.Valves that require maintenance(see Section 3.)found inaccessible and/or inoperable must be
remedied.The radiation 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.
Finding(s)•
During the 2025 Boise Field Audit,IPUC Inspectors observed three emergency valves that were unable to
be operated due to ice buildup.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.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
Intermountain Gas Reslionse
IGC acknowledges the findings brought forth by the IPUC.
48375-VLV-30214: On April 10, 2025, the ice was removed, and the valve was operated (WO12122000).
Additionally, annual maintenance was conducted on May 12, 2025 with no issues identified(WO12130577).
48375-VLV-34549: On April 10, 2025, the ice was removed, and the valve was operated (WO12122006).
Additionally, annual maintenance was conducted on May 8,2025 with no issues identified(WO12125930).
48375-VLV-32826: On April 10, 2025, the ice was removed, and the valve was operated. (WO12122008).
Additionally, annual maintenance was conducted on May 8,2025 with no issues identified(WO125919).
Training was provided to the employees performing the valve maintenance on the notification requirements for
inaccessible and inoperable emergency valves per OPS 703—Valve Inspection and Maintenance.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company