I202504 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
June 17, 2025 Report# I202504
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck,ND 58501
Dear Mr. Pat Darras:
On May 27 and 28, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a field audit of the Nampa 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.
IGC NAMPA FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 1 of 4

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.
OPS 500 Regulator Inspection and Maintenance
4. REGULATOR INSPECTION AND MAINTENANCE
1.1 Regulators shall be set to lockup at the designated lockup pressure, with some
allowance for lockup fluctuation,but the regulator shall lockup at a pressure equal
to or less than the MAOP.
Finding(s)•
During the 2025 Nampa District Field Audit, IPUC Inspectors observed Regulator Station 48371-
RS-59980 fail the lock up test on the primary regulator due to oil and metal shavings. This is the
second failure in two consecutive years during an IPUC audit.
3. 49 CFR 4192.747 Valve Maintenance: Distribution systems.
(b) Each operator must take prompt remedial action to correct any valve found inoperable,
unless the operator designates an alternative valve.
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.
4.1.2. 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.
IGC NAMPA FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 2 of 4

9. Maintenance Criteria
9.1 In addition to the inspection criteria listed in Section 8, partially operate
Transmission, Distribution, and Service Line Valves that meet the criteria of
Section 3.3 and 3.4.
9.1.6 If a plug valve does not operate or is not adequately lubricated, apply
valve sealant per the requirements of Section 7 and then partially
operate the valve. (Inability to operate without significant force is an
indication of inadequate lubrication.)
9.1.6.1 If the valve won't accept sealant or will not operate after
injecting sealant, inject a valve flush/cleaner. After
flushing/cleaning, inject new sealant. Refer to Section 7.
9.1.6.2 If after flushing/cleaning and injecting new sealant, the valve
is operational but requires two (2) persons to operate, and the
GIS Gas Valve Attribute Two Man Operate is N/A or No,
notify Field Operations Management.
Findinp(s)•
During the 2025 Nampa District Field Audit, IPUC Inspectors identified that valves 48317-VLV-
32633, 48317-VLV-32638, and 48317-VLV-32840, classified as"one-man"valves,required two
valve technicians for operation. However, these valves were not designated as "two-man" valves
in Maximo. Prior to operation, sealant was not injected, nor were the valves flushed or cleaned,
despite requiring significant force and the assistance of two technicians. These actions were not in
compliance with OPS 703 Section 9.1.6.
It was confirmed through IGC Compliance Personnel that the valve technicians reported the
inoperable emergency valves (48317-VLV-32633, 48317-VLV-32638 and 48317-VLV-32840)
within the required timeframe as stated in OPS 703 Section 4.1.1. OPS Section 4.1.2 was not
followed. An ENGMOC was not created within one business day of notification. Per IGC
Compliance Personnel,the valves were designed"two-man"valves in Maximo and an ENGMOC
was created on May 29, 2025.
IGC NAMPA 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 August 1,2025, 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 July 17, 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 August 1, 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 NAMPA FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 4 of 4