I202510 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 21,2025(Report#1202510)
Dear Mr.Brooks,
This letter is intended to address one(1)area of concern stemming from a transmission records audit conducted by
the Idaho Public Utilities Commission(IPUC)on August 141,2025,of Intermountain Gas Company(IGC)pursuant
of Chapter 601 Title,49,United States Code.
AREA OF CONCERN
1. 49 CFR§192,491 Corrosion control records.
(c) Each operator shall maintain a record of each test, survey, or inspection required by this
subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or that a
corrosive condition does not exist. These records must be retained for at least 5 years with the
following exceptions:
(1) Operators must retain records related to §§192.465(a) and(e) and 192.475(b) f or as long
as the pipeline remains in service.
(2)Operators must retain records of the two most recent atmospheric corrosion inspections for
each distribution service line that is being inspected under the interval in § 192.481(a)(2).
49 CFR§192.475 Internal Corrosion control
(b) Whenever any pipe is removed from a pipeline for any reason, the internal surface must be
inspected for evidence of corrosion.If internal corrosion is found—
(1)Operators The adjacent pipe must be investigated to determine the extent of internal corrosion;
(2)Replacement must be made to the extent required by the applicable paragraphs of§§ 192.485,
192.487, or 192.489; and
(3) Steps must be taken to minimize the internal corrosion.
OPS 327 Inspection,Evaluation,and Repairs of Pipelines
10.DOCUMENTATION
10.1. Existing in-service line exposure shall be documented on Form 21722—Pipeline Condition
Report when required per Section 3 of this procedure.
Finding(s)•
The Pipe Condition Report(21722)for Work Order#297856,pertaining to the 8"Robinson Road Repair,was
not valid since there was no field operations manager signature.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. The pipeline condition report was reviewed for
accuracy, signed by the Nampa District Manager,and has been uploaded to GIS.
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