I202504 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
July 31,2025
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to Notice of Probable Violation dated June 17,2025 (Report#1202504)
Dear Mr.Brooks,
This letter is intended to address two(2)probable violations stemming from a field audit conducted by the Idaho
Public Utilities Commission(IPUC)on May 27 and 28,2025 of Intermountain Gas Company's(IGC)Nampa
District pursuant of Chapter 601 Title,49,United States Code.
PROBABLE VIOLATinNS
L 49 CFR 8 192.605 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.
49 CFR W2.739 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 Station 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 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 the IPUC audit.
Intermountain (was Resnonse
Oil was discovered in the filter and on top of the boot during the annual inspection and maintenance performed
on March 12, 2024. The boot was replaced, and the filter and regulator body were cleaned. IGC performed a
follow up investigation on April 1, 2024, and discovered oil in the boot and pilot. The regulator was
disassembled, cleaned, and reassembled. IGC performed a follow up investigation on May 1,2024, and July 25,
2024, and found the regulator to be in good working condition with no oil present during both site inspections.
IGC discovered oil during the annual review conducted in March 2025.
IGC has been in communication with Williams to determine solutions to mitigate the oil. IGC is currently
reviewing and has recently proposed to Williams the installation of a coalescent filter at the Nampa Gate. Per

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
response from Williams,they will perform meter maintenance within the next 3-4 weeks,which will include the
collection and testing of contaminants.Based on the results,Williams will work with manufacturers to determine
the appropriate filter technology for optimum removal of contaminants (e.g., oil).
Until a mitigation plan is developed and implemented, IGC will increase the inspection frequency from annual
to quarterly at Regulator Station 48371-RS-59980.
2. 49 CFR 8 192.747 Valve Maintenance: Dostrihutinn 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 Operations Manage,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.
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 MAOP.
9.Maintenance Criteria
9.1.In addition to 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 it 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.
Finding(s)•
During the 2025 Nampa District Field Audit,IPUC inspectors identified that valves 48317-VLV-32633,
49317-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-32633,49317-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 withing one business day of notification.Per IGC Compliance Personnel,the valves were designated
"two-man"valves in Maximo and an EMGMOC was created on May 29,2025.
Intermountain (was Response
With recent technology updates,the integration between GIS and Maximo is not currently working as designed,
which provides the one or two man valve designation to personnel performing valve inspection and maintenance.
A request has been submitted to IGCs Operations Systems department for correction. The issue will be resolved
on or before September 3, 2025.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
Training was provided to all IGC managers and supervisors on their responsibilities for creating ENGMOCs
when inoperable or inaccessible valves are reported per the requirements of OPS 703 —Valve Inspection and
Maintenance.
Additionally, the IGC Safety and Technical Training department is working to enhance the technical training
program for personnel that perform valve inspection and maintenance. Training will be provided prior to the
next valve annual inspection and maintenance.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
k4a-'C���
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company