E202601 NOPV Response

aNBRIDGE© Enbridge Gas
333 South State Street
Salt Lake City,Utah 84111
4/6/2026
Mr. Jeff Brooks
Pipeline Safety, Program Engineer
Idaho Public Utilities Commission
11331 W Chinden Blvd, Ste 201
Boise, Idaho 83714
Dear Mr. Brooks,
Enbridge Gas Idaho (EGI) has received your letter dated March 4, 2026, regarding the Control Room
Management(CRM) Plan records audit and appreciates the opportunity to respond. Please see below for
EGI's responses:
IDPS Probable Violation(s):
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 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.
EGI Response:
EGI maintains a written Control Room Management(CRM) Plan that complies with the requirements of
49 CFR§ 192.605, including the requirement that operating procedures be reviewed and updated at least
once each calendar year at intervals not to exceed 15 months.
In accordance with this requirement, EGI conducted annual CRM program reviews on May 31, 2024, and
June 5, 2025. These reviews are formally documented in the Annual CRM Program Review record, which
verifies continued applicability and effectiveness of the CRM Plan and identifies any required updates.
The referenced Annual CRM Program Review document is attached for the Commission's review and
serves as auditable evidence of compliance with§ 192.605 and PHMSA Control Room Management
inspection requirements

Mr. Jeff Brooks P a g e 12 April 6, 2026
2. 49 CFR§192.631 Control Room Management.
(c) Provide adequate information. Each operator must provide its controllers with the
information, tools, processes and procedures necessary for the controllers to carry out the roles
and responsibilities the operator has defined by performing each of the following: (2) Conduct a
point-to-point verification between SCADA displays and related
field equipment when field equipment is added or moved and when other changes
that affect pipeline safety are made to field equipment or SCADA displays;
EGI Response:
Under 49 CFR§ 192.631, operators must establish and follow written Control Room Management(CRM)
procedures pertaining to alarm management, adequate information, and the validation of controller
interfaces. The regulation requires that alarm systems provide the information necessary for controllers to
maintain situational awareness and to respond to abnormal operating conditions.
This regulation requires procedures to ensure alarms are properly configured, maintained, and
documented, but does not explicitly mandate functional testing of each alarm state (HighHigh, High, Low,
LowLow) during every point-to-point verification cycle. The CRM procedures implemented by EGI comply
with the explicit requirements of 49 CFR§ 192.631. The issue identified in the NOPV may reflect a
recommended enhancement to CRM expectations, rather than a defined violation of 49 CFR§ 192.631.
3. 49 CFR§192.631 Control Room Management.
(g) Operating experience. Each operator must assure that lessons learned from its operating
experience are incorporated, as appropriate, into its control room management procedures by
performing each of the following:
(2) Include lessons learned from the operator's experience in the training program required by
this section.
EGI Response:
EGI agrees that while lessons learned have been discussed and incorporated informally, available
records and standardized training materials were not sufficient to demonstrate consistent, formal
implementation.
To address this gap, EGI is taking the following corrective actions:
• Further incorporating lessons learned—based scenarios into the controller training program.
• Ensuring lessons learned include incidents, near misses, abnormal operating conditions, leaks,
and significant industry events relevant to control room operations.
• Establishing a consistent training frequency, with lessons learned content being reviewed and
documented on a recurring basis as part of required controller training.
• Implementing standardized documentation to ensure lesson inclusion, delivery, and completion
records are maintained for regulatory review.
These enhancements will ensure that operating experience review training is systematic, repeatable, and
fully compliant with§192.63 1(g)(2).

Mr. Jeff Brooks P a g e 13 April 6, 2026
4. Control Room Management Plan
5.3 Point to Point Verification
192.631(c)(2)
Points defined as safety related are associated with safety related alarms as discussed in the
Alarm Management Plan.
The company conducts a point-to-point verification between the SCADA displays and related field
equipment when:
• Field equipment is added, moved, replaced and/or repaired.
• SCADA equipment is added, moved, replaced and/or repaired.
• Any other change that affects pipeline safety is made to field equipment or SCADA
displays.
The company has no set interval to repeat a point-to-point test unless equipment has been
added, moved, or changed.
The SCADA IT Support Team maintains the procedure for this point-to-point verification and
corresponding documentation.
For more details refer to Gas SCADA Point to Point Verification Procedure for 192.63 I(c)(2).
EGI Response:
Although EGI believes its existing point-to-point(P2P) Verification Procedure satisfies the requirements of
49 CFR§ 192.631, the Commission's findings are taken seriously. PHMSA guidance encourages
operators to continually strengthen verification practices, and in that spirit, EGI has updated both its Gas
SCADA P2P Verification Procedure and its Control Room Management(CRM) Plan to require full
functional testing of each enabled alarm state during P2P verification.
The revisions are summarized below for the Commission's convenience for each respective plan.
Gas SCADA Point-to-Point Verification Procedure
Section:Preparation for Checkout
"When performing point-to-point testing, all enabled alarm states shall be verified. This testing will be
documented and maintained within the POEMS Point Manager application."
Control Room Management Plan
Section 5.3—Point-to-Point Verification
"When performing point-to-point testing, all enabled alarm states shall be verified."
Should you have any additional questions regarding our response, please contact me directly.

Mr. Jeff Brooks P a g e 14 April 6, 2026
Sincerely,
Steve Bursett
Supervisor Pipeline Compliance
Enbridge Gas Idaho
Attachments:
2024 Annual CRM Program Review
2025 Annual CRM Program Review
cc:
Luke Adkins
Matt Bartol
Rodmesia Clarke
Judd Cook
Larry Flemming
Matt Galli
Josh Hunkle