I202513 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
November 5,2025
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 September 23,2025(Report#I202513)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a Compressor Station audit
conducted by the Idaho Public Utilities Commission(IPUC)on September 181,2025,of Intermountain Gas
Company(IGC)pursuant of Chapter 601 Title,49,United States Code.
PROBABLE VIOLATION
1. 49 CFR§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 yar. 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§192.709(c) Transmission lines: Record keeping.
A record of each patrol, survey, inspection, and test required by subparts L and M of this part
must be retained for at least 5 years or until the next patrol,survey,inspection,or test is completed,
whichever is longer.
Findin(s)•
No documentation was maintained or available for review prior to calendar year 2023. Per 192.709(c)
states each patrol, survey,inspection or test record must be maintained for 5 years.
Intermountain Gas Response
IGC acknowledges the finding brought forth by the IPUC pursuant to 49 CFR§192.709 Transmission lines:Record
keeping, which provides that an operator"shall maintain...records for transmission lines for the periods specified
IGC interpreted the term"transmission lines"as used in this provision to be as follows:
A pipeline or connected series of pipelines, other than a gathering line, that:
(1) Transports gas from a gathering pipeline or storage facility to a distribution center, storage facility, or
large volume customer that is not down-stream from a distribution center;
(2)Has an MAOP of 20 percent or more of SMYS;
(3) Transports gas within a storage field; or
(4)Is voluntarily designated by the operator as a transmission pipeline.Note I to transmission line.A large
volume customer may receive similar volumes of gas as a distribution center, and includes factories,power
plants, and institutional users of gas.
The facility subject to the NOPV in this situation is a compressor station,which was interpreted by IGC to not fall
into any of these categories.
Nevertheless,IGC understands the importance of system records,and implemented its current process for maintaining
records for compressor station inspection and maintenance in calendar year 2023. During the conversion of IGC
legacy procedure into OPS 106—Compressor Station Maintenance,and applicable compressor station manuals,IGC
adopted the practice of a five year record retention requirement from a peer utility company.

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