I202506 LOC

Idaho Public Utilities Commission Brad Little,Governor
P.D. Box 83720, Boise,ID 83720-0074 Edward Lodge,President
John R.Hammond,Jr.,Commissioner
Dayn Hardie,Commissioner
Letter of Concern
August 20, 2025 Report# I202506
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On August 4-6, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety Division
("Staff'), conducted a field audit of the Idaho Falls District of Intermountain Gas Company
("IGC")pursuant to Chapter 601 of Title 49, United States Code.
As a result of the inspection, it appears there are area(s) of concern that do not fully meet the
intent of the pipeline safety regulations Title 49, Code of Federal Regulations, Part 192 for
calendar year 2025.
The item(s) listed below are of concern:
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 IDAHO FALLS FIELD AUDIT LETTER OF CONCERN— Page 1 of 3

2. 49 CFR 4192.481 Atmospheric corrosion control: Monitoring.
(b) During inspections the operator must give particular attention to pipe at soil-to-air
interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash
zoncs, at deck penetrations, and in spans over water.
(c) If atmospheric corrosion is found during an inspection, the operator must provide
protection against the corrosion as required by 192.479.
(d) If atmospheric corrosion is found on a service line during the most recent inspection,
then the next inspection of that pipeline or portion of pipeline must be within 3 calendar
years, but with intervals not exceeding 39 months.
OPS 403 Atmospheric Corrosion Monitoring
2. INSPECTION CRITERIA
2.3 Inspect soil-to-air interface. Refer to In-Service Protective Coating Criteria Table.
Visually examine for evidence of coating damage and confirm it is properly bonded so that
penetration of moisture between the pipe and coating is prevented.
2.3.2 Protective coating(wrap) at soil-to-air interface shall be above grade.
2.3.3 Steel risers without protective coating surrounded by concrete or other hard
surface directly in contact with metal, shall be identified as Hard Surface.
2.3.3.1 Paint is an acceptable protective coating on anodeless risers.
In rvi a Protective C2gting C ite ia Table
GOOD FAIR POOR
The protective coating Protective coating that is
The protective coating may show slight thinning peeling,cracking,
shall be adhering to the or pulling away from the pipe, or is exposing
pipe and shows no Pipe,but should not be the metal substrate.
cracking or peeling. cracked peeling,l Includes facilities only
exposingg the metal substrate. coated with primer.
3. VISUAL INSPECTION FOR ATMOSPHERIC CORROSION
3.1 Above ground steel pipe, meter sets, risers,piping in vaults, etc., shall be visually
examined for evidence of Atmospheric Corrosion. Equipment in vaults shall be inspected
in the same manner as above ground pipe.
External Pipe Condition Evaluation Criteria
Pressure Condition Criteria
Classification
•Low Pressure •Ranges from showing no trace of rust(e.g.,oxidation),
•Distribution Good corrosion pitting,or rust scale,to having some rust
Pressure spotting,but no corrosion pitting or rust scale.
•Ranges from a light coating of rust to uniformly heavy
Fair coating of rust,no scaling,slight to shallow corrosion
pitting up to 40%wall loss may be present
•Rust scaling or severe corrosion pitting(as opposed to
slight to shallow in"Fair'),either of which is greater than
Poor 40%wall loss.
•Any anomaly or defect(e_g.,gouges,notches,grooves,
dents)that may impact the overall integrity and
serviceability of the pipe.
Findings)
IPUC Inspectors observed 48747-HPSS-67800 with pitting on the low-pressure side (anodeless
riser) of the HPSS.
IGC IDAHO FALLS FIELD AUDIT LETTER OF CONCERN— Page 2 of 3

3. 49 CFR &192.747 Valve maintenance: Distribution systems.
(a)Each valve, the use of which may be necessary for the safe operation of a distribution
system, must be checked and serviced at intervals not exceeding 15 months, but at least
once each calendar year.
(b) Each operator must take prompt remedial action to correct any valve found inoperable,
unless the operator designates an alternative valve.
Findinds)•
Valve 48747-VLV-29560 was designated as a two-man valve in Maximo. However, technicians
were only able to move the valve key a few inches with significant force. This raised a concern
regarding the valve's operability,particularly in emergency situations.
REQUESTED ACTIONS
The above-mentioned item(s) were brought to the attention of IGC compliance
representatives during the inspection. We request that you review these matter(s) and
respond in writing within 30 days regarding the above issue(s) including any planned
corrective actions.
If you have any questions concerning this notice, please contact me at [phone]. All
written responses should be addressed to me at: 11331 W Chinden Blvd, Ste 201-A,Boise,
ID 83714 or you can fax your response to [phone].
Because of the good faith that you have exhibited up to this time, we expect that you will
take action to bring your program into compliance with pipeline safety regulations.
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 IDAHO FALLS FIELD AUDIT LETTER OF CONCERN— Page 3 of 3