I202516 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
December 3,2025
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 November 4,2025 (Report#I202516)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a procedures audit conducted
by the Idaho Public Utilities Commission(IPUC)on November 4,2025,of Intermountain Gas Company(IGC)
pursuant of Chapter 601 Title,49,United States Code.
PROBABLE VIOLATIUA
1. 49 CFR 8192.605 Procedural manual for onerations.maintenance. and emergencies.
General.Each operator shall prepare and follow for each pipeline,a manual 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 §l92.625 Odorization of gas.
(b)After December 31, 1976,a combustible gas in a transmission line in a Class 3 or Class 4 location
must comply with the requirements of paragraph(a)of this section unless:
(1)At least 50 percent of the length of the line downstream from that location is in a Class 1 or Class
2 location;
(2)The line transports gas to any of the following facilities which received gas without an odorant
from that line before May 5, 1975;
(i)An underground storage field;
(ii)A gas processing plant;
(iii)A gas dehydration plant; or
(iv)An industrial plant using gas in a process where the presence of an odorant:
(A) Makes the end product unfit for the purpose for which it is intended;
(B) Reduces the activity of a catalyst; or
(C) Reduces the percentage completion of a chemical reaction;
(3)In the case of a lateral line which transports gas to a distribution center,at least 50 percent of the
length of the line is in a Class 1 or Class 2 location;or
Finding(
IPUC staff identified a procedural violation pertaining to the odorization of transmission lines in class 3
or class 4 locations.OPS 612 does not mention Class 3 or Class 4 odorization as required per 192.625(b).

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
Intermountain Gas Resnonse
The current version of OPS 612—Odorization of Gas and Odorizer Equipment Maintenance scope statement reads
"This procedure applies to pipelines and related facilities used to transport and distribute natural gas". The intent of
this statement covers all pipelines and related facilities,including transmission.All IGC-owned transmission
pipelines are currently odorized in all class locations,as required by OPS 612.
Due to the findings of this inspection,an MOC has been initiated to clarify the purpose statement of OPS 612 to
include the word"transmission".The revised OPS 612 will be implemented on or before December 31,2025.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company