I202507 LOC

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
Letter of Concern
August 20, 2025 Report#I202507
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 4th St.
Bismarck,ND 58501
Dear Mr. Pat Darras,
On August 11-14, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division("Staff'), conducted a Control Room Management audit 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 CONTROL ROOM MANAGEMENT AUDIT LETTER OF CONCERN— Page 1 of 4

2. 49 CFR 4192.631 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 appropriatc 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.
Finding(s)•
Section 4.1 and 4.8 of OPS 631 omits any reference to the presence of a backup controller on duty
during weekday dayshift hours (Monday through Friday). IPUC inspectors recommend the
following revisions:
• Acknowledge the presence of a backup 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.
IGC CONTROL ROOM MANAGEMENT AUDIT LETTER OF CONCERN— Page 2 of 4

3. 49 CFR U92.631 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 practical 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;
Finding(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 631 where applicable.
4. 49 CFR 4192.631 Control room management.
(g) Operating experience. Each operator must assure that lessons learned from its
operating experience are incorporated, as appropriate, 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.
Findings):
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.
IGC CONTROL ROOM MANAGEMENT AUDIT LETTER OF CONCERN— Page 3 of 4

REQUESTED ACTIONS
The above-mentioned item(s) were brought to the attention of IGC compliance
representativcs 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(208) 334-0333. 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,
//I---
JeffBrooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
IGC CONTROL ROOM MANAGEMENT AUDIT LETTER OF CONCERN— Page 4 of 4