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Home My WebLink AboutI202505 NOPV 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 August 20, 2025 Report# I202505 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. Staff observed that some of the Idaho natural gas system(s) owned and operated by IGC ("Company")was out of compliance on item(s). This results in probable violations of the pipeline safety regulations Title 49, Code of Federal Regulations, Part 192. The probable violations are as follows: PROBABLE VIOLATIONS) 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 PROBABLE VIOLATIONS LETTER— Page 1 of 5 2. 49 CFR 092.739 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 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 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. 3. 49 CFP 092.317 Protection from hazards. (b)Each aboveground transmission line or main,not located offshore or in 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 known 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 INSPECTION 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. IGC IDAHO FALLS FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 2 of 5 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 4. 49 CFR 4 192.707 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. OPS 610 Pipeline Patrolliny- and Continuing Surveillance 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 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. 2.15.2 Check that pipeline markers are visible and legible with correct contact information. Findinds)• 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 IGC IDAHO FALLS FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 3 of 5 • 48747-HPSS-67863 —Needs Carsonite • 48747-HPSS-67864—Needs Carsonite • 48747-HPSS-67862 —Needs Carsonite • 48747-HPSS-67861 —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 REOUESTED ACTIONS A reply to this correspondence is required no later than 45 days from the date of this letter. Please submit a written reply providing a statement of all relevant facts including a complete description of the corrective action(s) taken with respect to the above referenced probable violations, and all actions to be taken to prevent future failures in these areas of concern. This written reply must be signed by a Company official with authority to bind the Company. Please send all documents to our office at 11331 W. Chinden Blvd, Boise, Idaho 83714-1021. Be advised that all material you submit in response to this enforcement action may be a public record and subject to disclosure under Idaho's Public Records Law. See Idaho Code §§74-101 et seq. If you wish to dispute any of the above referenced potential violations,you have the right to appear before the Pipeline Safety Division in an informal conference before September 19, 2025, at the above address. You have the right to present relevant documents and evidence to the Pipeline Safety Division at that conference. The Pipeline Safety Division will make available to you any evidence which indicates that you may have violated the law, and you will have the opportunity to rebut this evidence. See Commission Orders 35095 and 35334, which can be found at https://puc.idaho.gov/. If you intend to request an informal conference,please contact the Pipeline Safety Division no later than October 4,2025. If you wish to dispute any of the allegations in this Notice,but do not want an informal conference, you may send the Pipeline Safety Division a written reply to this Notice. This written reply must be filed with the Commission on or before September 19,2025,and must be signed by a Company official with authority to bind the Company. The reply must include a complete statement of all relevant facts, and all documentation, evidence, and argument the Company submits to refute any of the above referenced probable violations. These violations may be subject to any Commission enforcement action as allowed under Idaho law including, but not limited to, potential civil penalties in accordance with 49 CFR 190.223(a). IGC IDAHO FALLS FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 4 of 5 If you have any questions concerning this Notice,please contact me at(208) 334-0333.All written responses should be addressed to me at the above address, or you may fax your response to (208) 334-3762. 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:(208)334-0300 Facsimile:(208)334-3762 IGC IDAHO FALLS FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 5 of 5