I202615 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]•FAX:[phone]
September 8,2026
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 August 13,2026(Report#I202615)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a field audit conducted by the
Idaho Public Utilities Commission(IPUC)on August 10 and 11,in the Idaho Falls district 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 prcparc and follow for each pipeline, a manual of written procedures for
conducting operations and maintcnance 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.
OPS 500 Regulator Inspection and Maintenance
4.REGULATOR INSPECTION AND MAINTENANCE
4.1.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.
2. 49 CFR§192,703 General
(a)No person may operate a segment of pipeline,unless it is maintained in accordance with this subpart.
3. 49 CFR§192,739 Pressure limiting and regulating stations: Inspection and testing.
(a) Each pressure limiting station,relief device(except rupture discs),and pressure regulating station and
is equipment must be subjected at intervals not exceeding 15 months,but at least once each calendar
year,to inspections and tests to determine that is—
(1) In good mechanical condition;
(2) Adequate from the standpoint of capacity and reliability of operation for the service in which
it is employed;
(3) Except as provided in paragraph(b) of this section, set to control or relieve at the correct
pressure consistent with the pressure limits of§ 192.201(a);and
(4) Properly installed and protected from dirt, liquids, or other conditions that might prevent
proper operation.
Findin (s)
Regulator station 48741-RS-60824 primary regulator failed due to metal shavings in the diaphragm.The
regulator locked up as normal after being disassembled and cleaned.
Intermountain Gas Resgonse
IGC respectfully disputes that this finding constitutes a violation of 49 CFR§ 192.605, § 192.703, §192.739 or OPS
500—Regulator Station Inspection and Maintenance,Section 4.1 as referenced above.
Per 192.605(a)"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."OPS 500 provides procedures for the
inspection and maintenance of regulating stations within the IGC pipeline system.IGC followed the cited requirements
of OPS 500 as outlined below.
Section 4.1 of OPS 500 addresses how a regulator must be set.In this case,the primary regulator is set to lock up at a

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone]
pressure equal to or less than the MAOP as required per OPS 500 section 4.1. The lock up pressure is set to 58 psig
and the MAOP is 60 psig. Upon inspection, metal shavings were observed in the diaphragm and appear to have
prevented proper operation of the regulator.
Per 192.703(a)"No person may operate a segment of pipeline,unless it is maintained in accordance with this subpart."
IGC records indicate regulator station 48741-RS-60824 has been maintained as required per 192 Subpart M and OPS
500. See below for further maintenance details.
Per 192.739(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;(2)Adequate from the standpoint
of capacity and reliability of operation for the service in which it is employed; (3) Except as provided in
paragraph(b)of this section,set to control or relieve at the correct pressure consistent with the pressure limits
of§192.201(a); and (4) Properly installed and protected from dirt, liquids, or other conditions that might
prevent proper operation.".
Annual inspections were conducted in 2026,2025,2024,2023,and 2022 with no regulator issues identified.The most
recent inspection completed on June 3,2026.
While onsite,the regulator was dissembled and cleaned.The regulator was then reassembled,retested for lock up,and
subsequently locked up properly. In the event it could not be repaired at the time of inspection,OPS 500, Section 7.9
allows 45 days for IGC to complete required corrective maintenance related to regulator lock up and operation issues.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Alza,64 o✓L
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company