I202201 NOPV Response.pdf

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD• P.O. BOX 7608 • BOISE, IDAHO 83707 • [phone] • FAX: [phone]

April 29, 2022 Mr. Jeff Brooks, Programs Manager
Idaho Public Utility Commission PO Box 83720 Boise, ID 83720-0074 Subject: Response to Notice of Probable Violation dated March 17, 2022 (Report # I202201)
Dear Mr. Brooks, This letter is intended to address one probable violation stemming from a field inspection conducted by the Idaho Public Utilities Commission (IPUC) on March 14-16, 2022, in Intermountain Gas Company’s (IGC) Nampa
District. PROBABLE VIOLATION

Intermountain Gas Response
Intermountain Gas Company (IGC) acknowledges the findings brought forth by the Idaho Public Utilities
Commission on five of the six regulator stations. The regulator station listed as 48318-RS-59839 appears to be
in error. IGC information has the regulator station inspected during the March 14-16, 2022, inspection as
regulator station 48267-RS-59849. As stated in previous responses, IGC created a Failed to Lockup Mitigation
Plan that includes the following:

• Identification of regulator station regulators that failed a lockup test two or more times during calendar
years 2016-2018.
• Review of the identified stations for an appropriate mitigation option: monitor, rebuild, pilot sulfur
heat, pilot heat, stainless steel stems for pilots, line heater, or strainers.
• Creation of a ten-year schedule based on a consequence of failure rating.

IGC used the criteria of two or more failed lock up tests in a three-year period (2020-2022) to evaluate the need to add the regulator stations referenced in the inspection to the Failed Lock up Mitigation Plan. The following table was extracted from the annual inspection questions, Regulator 1 Operated Properly and Regulator 2 Operated Properly.

1. 49 CFR §192.739 (a) (4) Pressure limiting and regulating stations: Inspection and testing. Pressure limiting and regulating stations: Inspection and testing - reads: Properly installed and protected from dirt, liquids, or other conditions that might prevent proper
operation. Which is also covered in IGC OPS 500 Sec. 4.1. Finding(s): During the inspection it was noted that:
• Regulator stations 48325-RS-60738, 48321-RS-59930, 48321-RS-59936, 48318-
RS-59839, 48267-RS-59881, 48363-RS-59887 had one or both regulators fail to
EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD• P.O. BOX 7608 • BOISE, IDAHO 83707 • [phone] • FAX: [phone]

Based on the results, three of the stations identified with lock up failures in 2022, 48321-RS-59936, 48267-RS-
59849 and 48267-RS-59881 will be added to the Failed Lock up Mitigation Plan. Regulator stations 48325-
RS-60738 and 48363-RS-59887 are currently included in the Failed Lock up Mitigation plan. The information
from the latest inspections will also be used to determine if the remediations for the regulator stations currently
on the plan are appropriate, or if a change to the remediation plan is needed. Station 48321-RS-59930 will not
be added to the Failed Lock up Mitigation Plan based on its 2020-2022 annual inspection results because the
regulator was repaired after the failed lock up that occurred during the March 14-16, 2022, inspection and has
not met the criteria of failing lock two times in a three year period.

Please contact Josh Sanders at [phone] with questions or comments.

Respectfully Submitted,

Pat Darras
Vice President, Engineering & Operations Services
Intermountain Gas Company