I202505 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
October 2,2025
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to the Notice of Probable Violation dated August 20,2025 (Report#I202505)
Dear Mr.Brooks,
This letter is intended to address three(3)notices of probable violation stemming from a field audit conducted by the
Idaho Public Utilities Commission(IPUC)on August 4-6,in the Idaho Falls district of Intermountain Gas Company
(IGC)pursuant of Chapter 601 Title,49,United States Code.
PROBABLE VIOLATIUA
1. 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.
2. 49 CFR 8 192-739 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 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 INPSECTION 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)•
IPUC Inspectors observed regulator stations 48747-RS-60805 and 48747-RS-60770 failed the lock up test on
the primary regulator due to debris on the pilot stem and diaphragm.Additionally,regulator station 48741-RS-
59810 failed to lock up on the secondary regulator due to debris found on the pilot stem.
Intermountain (was Response
IGC acknowledges the findings brought forth by the IPUC. The regulators were dissembled, cleaned, and
reassembled onsite and subsequently locked up properly. IGC is continuing to monitor the application of
filtration devices for regulator stations that fail lock-up two or more times in a three-year period.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
3. 49 CFR 8192.317 Protection from hazards.
(b)Each aboveground transmission line or main,not located offshore or inland navigable water areas,
must be protected from accidental damage by vehicular traffic or other similar causes,either by being
placed at a safe distance from the traffic or by installing barricades.
OPS 1000 Distribution Integrity Management Plan
3.2.4.Other Outside Force Damage
Other outside force damages are a result from fire or explosion,deliberate or willful acts,such as vandalism
and vehicular damage. Only aboveground facilities are considered when determining if this threat is
present. The primary concern is areas where gas piping is close enough to vehicular traffic such as
automobiles, trucks, forklifts, snowplows, construction equipment, etc., where it may be reasonably
expected that damage from vehicle movement could occur. Facilities in locations know to be subject to
vandalism, destruction, wreckage, sabotage, or other harm (e.g., unauthorized adjustment or valve
movement)may carry the other outside force damage threat.
OPS 403 Section 2 TNSPF.CTION CRITERIA
2.14 Check for needed protection from vehicular damage(e.g.,barricades,bollards, or meter guards).
2.14.1. Missing crash protection in asphalt, or concrete,shall be identified as Hard Surface.
2.14.2. Missing crash protection that poses an immediate risk is an AOC.
Finding(s)•
Below is a list of HPSS's that staff discovered were in vehicular traffic areas that were not protected:
• 48747-HPSS-67782—Needs Vehicle Protection,Installed Carsonite
• 48747-HPSS-67795—Needs Vehicle Protection,Installed Carsonite
• 48747-HPSS-67791 —Needs Vehicle Protection,Installed Carsonite
• 48747-HPSS-67836—Needs Carsonite and Vehicle Protection
• 48747-HPSS-67852—Needs Carsonite and Vehicle Protection
Intermountain (was Resnonse
IGC acknowledges the findings brought forth by the IPUC.
• 48747-HPSS-67782: Meter protection was installed September 5, 2025 (WO12335621). A pipeline
maker was installed at the time of the audit.
• 48747-HPSS-67795: Meter protection was installed September 5, 2025 (WO12335623). A pipeline
maker was installed at the time of the audit.
• 48747-HPSS-67791: Meter protection was installed September 5, 2025 (WO12335624). A pipeline
maker was installed at the time of the audit.
• 48747-HPSS-67836: Meter protection and a pipeline marker were installed September 5, 2025 (WO
12335682 and W012335683).
• 48747-HPSS-67852: Meter protection and a pipeline marker were installed September 5, 2025 (WO
12225684 and W012335865).

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
4. 49 CFR 8 192.707 Line markers for mains and transmission lines
(c)Pipelines aboveground. Line markers must be placed and maintained along each section of a
main and transmission line that is located aboveground in an area accessible to the public.
49 CFR 8 192.707 i.ine markers for mains and transmission lines
2.2.4.Pipeline markers are installed,visible,and legible with correct contact information.
OPS 403 Section 2 INSPECTION CRITERIA
2.13. Inspect pipeline markers.
2.13.1. Inspection includes condition the condition of existing pipeline marker or the need to add a
pipeline marker(s)for better visibility of the HPSS or farm tap. Examples include the following:
2.13.1.1.In the right-of-way or near high traffic areas.
2.13.1.2.In vegetation that obscures visibility.
2.15.Inspect pipeline markers.
2.15.1.Inspection includes the condition of existing pipeline marker(s)or the need to add a pipeline
marker(s)for better visibility of the meter set,HPSS or farm tap.
2.1.5.2.Check that pipeline markers are visible and legible with correct contact information.
Finding(s)•
Below is a list of HPSS's that were discovered without adequate markings or obscured by vegetation.
• 48747-HPSS-67782—Needs Vehicle Protection,Installed Carsonite during audit.
• 48747-HPSS-67795—Needs Vehicle Protection,Installed Carsonite during audit.
• 48747-HPSS-67791 —Needs Vehicle Protection,Installed Carsonite during audit.
• 48747-HPSS-66153—Needs Carsonite
• 48747-HPSS-66179—Needs Carsonite
• 48747-HPSS-66177—Needs Carsonite
• 48747-HPSS-66153—Needs Carsonite
• 48747-HPSS-67871 —Vegetation Removal
• 48747-HPSS-66200—Needs Carsonite
• 48747-HPSS-67888—Needs Carsonite
• 48747-HPSS-67888—Needs Carsonite
• 48747-HPSS-67863—Needs Carsonite
• 48747-HPSS-67864—Needs Carsonite
• 48747-HPSS-67862—Needs Carsonite
• 48747-HPSS-68761 —Needs Carsonite
• 48747-HPSS-67886—Needs Carsonite
• 48747-HPSS-66165—Needs Carsonite
• 48747-HPSS-67810—Needs Carsonite
• 48747-HPSS-67812—Needs Carsonite
• 48747-HPSS-67851—Needs Carsonite
• 48747-HPSS-67840—Needs Carsonite and Vegetation Removal
• 48747-HPSS-67847—Needs Carsonite
• 48747-HPSS-67841 —Needs Carsonite
• 48747-HPSS-67836—Needs Carsonite and Vehicle Protection
• 48747-HPSS-67852—Needs Carsonite and Vehicle Protection
• 48747-HPSS-67842—Needs Carsonite
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC.
0 48747-HPSS-67782: Meter protection was installed September 5, 2025 (WO 12335621). A pipeline

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
marker was installed at the time of the audit.
• 48747-HPSS-67795: Meter protection was installed September 5, 2025 (WO12335623). A pipeline
marker was installed at the time of the audit.
• 48747-HPSS-67791: Meter protection was installed September 5, 2025 (WO12335624). A pipeline
maker was installed at the time of the audit.
• 48747-HPSS-66153: A pipeline marker was installed August 28, 2025 (WO12335625).
• 48747-HPSS-66179: A pipeline marker was installed August 28, 2025 (WO12335630).
• 48747-HPSS-66177: A pipeline marker was installed August 28,2025 (WO
• 48747-HPSS-67871: Vegetation was cleared September 2,2025 (WO12336211).
• 48747-HPSS-66200: A pipeline marker was installed August 28, 2025 (WO12335643).
• 48747-HPSS-67888: A pipeline marker was installed August 28, 2025 (WO12335654).
• 48747-HPSS-67863: A pipeline marker was installed August 28, 2025 (WO12335655).
• 48747-HPSS-67864: A pipeline marker was installed August 28, 2025 (WO12335659).
• 48747-HPSS-67862: A pipeline marker was installed August 28, 2025 (WO12335660).
• 48747-HPSS-68761: A pipeline marker was installed August 28, 2025 (WO12335665).
• 48747-HPSS-67886: A pipeline marker was installed August 28, 2025 (WO12335668).
• 48747-HPSS-66165: A pipeline marker was installed August 28,2025 (WO12335669).
• 48747-HPSS-67810: A pipeline marker was installed August 28,2025 (WO12335670).
• 48747-HPSS-67812: A pipeline marker was installed August 28,2025 (WO12335671).
• 48747-HPSS-67851: A pipeline marker was installed August 28,2025 (WO12335674).
• 48747-HPSS-67840: Vegetation was cleared, and a pipeline marker was installed September 2,2025
(WO12335676 and W012335677).
• 48747-HPSS-67847: A pipeline marker was installed August 28,2025 (WO12335678).
• 48747-HPSS-67841: A pipeline marker was installed August 28,2025 (WO12335679).
• 48747-HPSS-67836: Meter protection and a pipeline marker was installed September 5, 2025
(WO12335682 and W012335683).
• 48747-HPSS-67852: Meter protection and a pipeline marker was installed September 5, 2025
(WO12335684 and W012335685).
• 48747-BPSS-67842: A pipeline marker was installed August 28, 2025 (WO12335686).
IGC's Quality Control department conducted an evaluation of HPSS pipeline markers for all districts. Based
on the results, IGC's Safety Management Systems and Policy and Procedure departments are working with
subject matter experts to revise OPS 705 — Gas Pipeline Markers and Signs Installation and Inspection and
enhance operational controls to ensure pipeline markers are installed and maintained per the requirements of
49 CFR§192.707 Line Markers for Mains and Transmission Lines and OPS 705.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
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Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company