I202507 LOC Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
September 16,2025
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to the Letter of Concern dated August 20,2025(Report#I202507)
Dear Mr.Brooks,
This letter is intended to address three(3)areas of concern stemming from a Control Room Management audit
conducted by the Idaho Public Utilities Commission(IPUC)on August 11-14,of Intermountain Gas Company
(IGC)pursuant of Chapter 601 Title,49,United States Code.
AREAS OF CONCERN
1. 49 CFR§192,605 Procedural manual for onerations.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§192.631 Control room management.
(b) Roles and responsibilities. Each operator must define the roles and responsibilities of a controller
during normal,abnormal,and emergency operating conditions. To provide for a controller's prompt and
appropriate response to operating conditions,an operator must define each of the following:
(1) A controller's authority and responsibility to make decisions and take actions during normal
operations;
(2)A controller's role when an abnormal operating condition is detected,even if the controller is not the
first to detect the condition, including the controller's responsibility to take specific actions and to
communicate with others;
(3)A controller's role during an emergency,even if the controller is not the first to detect the emergency,
including the controller's responsibility to take specific actions and to communicate with others;
(4) A method of recording controller shift-changes and any hand-over of responsibility between
controllers;and
(5) The roles, responsibilities and qualifications of others with the authority to direct or supersede the
specific technical actions of a controller.
OPS 631 Control Room Management
4.ROLES AND RESPONSIBILITIES
4.1. MDUG GC are responsible for safely operating the MDUG distribution system 24 hours-a-day;
seven(7)days-a-week.The MDUG CR is located in a secure area and is staffed with one(1)MDUG
GC.Only qualified MDUG GC are permitted to sign-on to the SCADA console using their individual
SCADA log-on credentials.
4.8. MDUG GC who are signed into the SCADA system assume the leadership role during normal,
abnormal,and emergency situations,and have the authority to direct other MDUG GC in the MDUG
CR and Field Operations personnel to provide assistance,as required.
Findin6s)•
Section 4.1. and 4.8. of OPS 631 omits any reference to the presence of a back up controller on duty
during weekday dayshift hours (Monday through Friday). IPUC inspectors recommend the following
revisions:
• Acknowledge the presence of a back up controller during dayshift hours.
• Include the term"primary"when referring to the designated controller to clearly distinguish roles
and responsibilities.
• Strengthen the language to affirm that no individual may override or supersede the actions or
decisions of the primary controller.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]•FAX:[phone]
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. An MOC has been initiated to discuss needed
revisions to OPS 631 —Control Room Management. Revised OPS 631 will implement on or before December
31, 2025.
3. 49 CFR§192.631 Control room management.
(c)Provide adequate information. Each operator must provide its controllers with the information,tools,
processes and procedures necessary for the controllers to carry out the roles and responsibilities the
operator has defined by performing each of the following:
(1) Implement sections 1, 4, 8, 9, 11.1, and 11.3. of API RP 1165 (incorporated by reference, see §
192.7)whenever a SCADA system is added,expanded or replaced,unless the operator demonstrates
that certain provisions of sections 1,4, 8,9, 11,.1,and 11.3. of API RP 1165 are not practival for the
SCADA system used;
(3) Test and verify an internal communication plan to provide adequate means for manual operation of
the pipeline safely,at least once each calendar year,but at intervals not to exceed 15 months;
Findina(s)•
In OPS 631,specifically when referencing API RP 1165,IPUC inspectors recommend adding the revision
number or incorporated by reference(IBR)per 192.7.The SCADA Screen Design Verification Form and
the Gas Control Loss of SCADA Communication Test Plan should also be referenced in OPS 61 where
applicable.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. An MOC has been initiated to discuss needed
revisions to OPS 631 —Control Room Management. Revised OPS 631 will implement on or before December
31, 2025.
4. 49 CFR§192,631 Control room management.
(g) Operating experience. Each operator must assure that lessons learned from its operating experience
are incorporated, as appropriated, into its control room management procedures by performing each of
the following:
(1) Review incidents that must be reported pursuant to 49 CFR part 191 to determine if control room
actions contributed to the event and,if so,correct,where necessary,deficiencies related to:
(i)Controller fatigue;
OPS 631 Control Room Management
9.OPERATING EXPERIENCE
9.1.The MDUG Gas Control Management Team will review any significant incidents to determine if
MDUG CR actions contributed to the incident. These incidents may include:
9.1.1.Controller Fatigue.
9.1.2.Field Equipment Failure.
9.1.3.Incorrect Procedures.
9.1.3. SCADA system configuration issues.
9.1.4. SCADA system performance issues.
Finding(s)•
IPUC Inspectors recommend the removal of"significant"from section 9.1. so that control room actions
are considered when reviewing any incident that must be reported pursuant to 49 CFR part 191.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. An MOC has been initiated to discuss needed
revisions to OPS 631 —Control Room Management. Revised OPS 631 will implement on or before December

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
31, 2025.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President, Engineering& Operations Services
Intermountain Gas Company