# IDAHO PIPELINE CORP — Notice of Probable Violation

**Citation:** CPF 520085036  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2008-10-17

CLOSED notice of probable violation citing 195.452(f).

## Document text

Notice of Probable Violation involving IDAHO PIPELINE CORP. PHMSA's enforcement data identifies the cited regulation as 195.452(f). The case was opened on 2008-10-17 and is reported as closed as of 2010-02-12. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520085036_Closure Letter_02122010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085036/520085036_Closure%20Letter_02122010.pdf

520085036_Final Order_04272009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085036/520085036_Final%20Order_04272009.pdf

520085036_Final Order_04272009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085036/520085036_Final%20Order_04272009_text.pdf

520085036_NOPV PCO_10172008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085036/520085036_NOPV%20PCO_10172008.pdf

520085036_nopv pco_10172008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085036/520085036_nopv%20pco_10172008_text.pdf

520085036_Operator response to Final Order_06222009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085036/520085036_Operator%20response%20to%20Final%20Order_06222009.pdf

520085036_operator response_12152008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085036/520085036_operator%20response_12152008.pdf

520085036_Closure Letter_02122010.pdf

SENT 701: •
Hardcop!...
sociromacally _2
# of Copie.i.
• in 212-10
or transportation
12300 W. Dakota Ave., Suite 110
Lakewood, CO 80228
pipeline and
Hazardous Materials Safety
Administration
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 12, 2010
Joseph LaRose
IDPC Facility Manager
Idaho Pipeline Corporation
P.O. Box 15653
Boise, ID 83715
CPF 5-2008-5036
Dear Mr. LaRose:
On April 27, 2009, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Idaho Pipeline Corporation a Final Order in the above-referenced case. This Order
included a Compliance Order requirement to take corrective actions on your pipeline. Based on
our review of the documentation you provided on January 14, 2010 which indicates Idaho
Pipeline Corporation had completed a successful hydrotest of your entire pipeline on November
24, 2009 and are continuing with your implementation of the Integrity Management (IM)
program, it has been determined that you have complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc:
PHP-60 Compliance Registry
PHP-500 H. Nguyen (#121166
•

520085036_Final Order_04272009_text.pdf

APR 27 2009
VIA CERTIFIED MAIL – RETURN RECEIPT REQUESTED [7005-1160-0001-0047-7070]
Mr. Robert Rose
President
Idaho Pipeline Corporation
P.O. Box 35236
Sarasota, FL 34232
Re: CPF No. 5-2008-5036
Dear Mr. Rose:
Enclosed is the Final Order issued in the above-referenced case. It makes findings of violation
and specifies actions that need to be taken by Idaho Pipeline Corporation to comply with the
pipeline safety regulations. When the terms of the compliance order have been completed, as
determined by the Director, Western Region, this enforcement action will be closed. Your
receipt of this Final Order constitutes service of that document under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Chris Hoidal
Director, Western Region, PHMSA
Mr. Joseph LaRose, Facility Manager
Idaho Pipeline Corporation
P.O. Box 15653
Boise, ID 83715



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
______________________________
)
In the Matter of )
)
Idaho Pipeline Corporation, ) CPF No. 5-2008-5036
)
Respondent. )
______________________________)
FINAL ORDER
On March 6, 2008, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), inspected the
Integrity Management Program (IMP) of the Idaho Pipeline Corporation (Idaho or Respondent).
Idaho is the operator of a three-mile aviation fuel pipeline in Boise, Idaho.
As a result of that inspection, on December 5, 2008, PHMSA issued a Final Order finding that
Idaho had committed certain violations of PHMSA’s integrity management regulations (Final
Order).1 Specifically, it found that Idaho had violated 49 U.S.C. § 60132(a) and (b) by failing to
submit certain geospatial data regarding its pipeline system to the National Pipeline Mapping
System (NPMS). It further found that Idaho had violated 49 C.F.R. § 194.452(a) by failing to
determine whether its pipeline system could affect a “High Consequence Area” (HCA).2
Subsequent to the March 2008 inspection, but prior to issuance of the Final Order, Idaho
submitted certain information to PHMSA indicating that the company had pipeline segments that
could affect an “Other Populated Area” near the Boise International Airport.
3
Because Idaho’s
own analysis indicated that its pipeline system could affect an HCA, the Director issued to Idaho,
1 In the Matter of Idaho Pipeline Corporation, CPF No. 5-2008-5006 (December 5, 2008), available at
http://primis.phmsa.dot.gov/comm/reports/enforce/documents/520085006/520085006_FinalOrder_12052008.pdf?no
cache=3620.
2 An HCA is defined as: (1) a commercially navigable waterway, which means a waterway where a substantial
likelihood of commercial navigation exists; (2) a high population area, which means an urbanized area, as defined
and delineated by the Census Bureau, that contains 50,000 or more people and has a population density of at least
1,000 people per square mile; (3) an other populated area, which means a place, as defined and delineated by the
Census Bureau, that contains a concentrated population, such as an incorporated or unincorporated city, town,
village, or other designated residential or commercial area; and (4) an unusually sensitive area, as defined in
§ 195.6. 49 C.F.R. § 195.450.
3 Violation Report at 3.



2
by letter dated October 17, 2008, a Notice of Probable Violation and Proposed Compliance
Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Idaho
had violated 49 C.F.R. § 195.452(f) for failing to have an IMP and ordering the company to take
certain measures to correct the alleged violation.
Idaho responded to the Notice by letter dated December 15, 2008 (Response), but did not contest
the allegation of violation. Idaho did not request a hearing and therefore has waived its right to
one.
FINDING OF VIOLATION
In its Response, Idaho did not contest the allegation in the Notice that it violated 49 C.F.R. Part
195, as follows:
Item 1: The Notice alleged that Idaho violated 49 C.F.R. § 195.452(f), which states:
§ 195.452 Pipeline integrity management in high consequence areas.
(a) . . .
(f) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions
drawn from results of the integrity assessments, and other maintenance and
surveillance data, and evaluation of consequences of a failure on the high
consequence area. An operator must include, at minimum, each of the following
elements in its written integrity management program:
(1) A process for identifying which pipeline segments could affect a high
consequence area;
(2) A baseline assessment plan meeting the requirements of paragraph (c) of
this section;
(3) An analysis that integrates all available information about the integrity of
the entire pipeline and the consequences of a failure (see paragraph (g) of this
section);
(4) Criteria for remedial actions to address integrity issues raised by the
assessment methods and information analysis (see paragraph (h) of this section);
(5) A continual process of assessment and evaluation to maintain a pipeline’s
integrity (see paragraph (j) of this section);
(6) Identification of preventive and mitigative measures to protect the high
consequence area (see paragraph (i) of this section);
(7) Methods to measure the program's effectiveness (see paragraph (k) of this
section);
(8) A process for review of integrity assessment results and information
analysis by a person qualified to evaluate the results and information
(see paragraph (h)(2) of this section).



3
The Notice alleged that Idaho had violated § 195.452(f) by failing to have a written IMP, even
though information supplied by Respondent indicated that the company’s pipeline system could
affect an HCA. In its Response, Respondent did not contest the allegation and committed to
developing an IMP. It also pledged to incorporate its existing system of historical records,
current Facility Response Plan, and risk assessment data into the IMP. Accordingly, upon
consideration of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.452(f) by
failing to have a written IMP that addressed the minimum requirements in 49 C.F.R.
§ 195.452(f).
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to item 1 for a violation of 49 C.F.R.
§ 195.452(f). Under 49 U.S.C. § 60118(a), each person who engages in the transportation of
hazardous liquids or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C.
§ 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to
ensure compliance with the pipeline safety regulations applicable to its operations. Respondent
must—
1. Develop a written Integrity Management Plan (IMP).
2. Begin implementation of the IMP referenced in Item 1 of this Compliance Order.
3. Within 60 days of issuance of this Final Order, complete Items 1 and 2 of this
Compliance Order, and submit the required documentation and procedures to Director,
Western Region, Pipeline and Hazardous Materials Safety Administration, 12300 West
Dakota Avenue, Suite 110, Lakewood, Colorado 80228.
4. Maintain documentation of the safety improvement costs associated with fulfilling this
Compliance Order and submit the total to Director, Western Region. Costs shall be
reported in two categories: 1) total cost associated with preparation/revision of plans,
procedures, studies, and analyses; and 2) total costs associated with replacements,
additions, and other changes to pipeline infrastructure.
The Director may grant an extension of time to comply with any of the required Items upon a
written request timely submitted by the Respondent demonstrating good cause for an extension.
Failure to comply with this Order may result in administrative assessment of civil penalties not
to exceed $100,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.



4
Under 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be received within 20 days of Respondent’s receipt of this
Final Order and must contain a brief statement of the issue(s). The terms of the order, including
any required corrective action, shall remain in full force and effect unless the Associate
Administrator, upon request, grants a stay. The terms and conditions of this Final Order shall be
effective upon receipt.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520085036>
- Source ID: `phmsa-enforcement`
- SHA-256: `961b55f2f5627c8fe24dede73758e45e2d15d45f177498fe349351ee4a0ee73a`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-25T11:57:09.703Z
- Document slug: `phmsa-enforcement-520085036`

### Source metadata

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  "cpf": "520085036",
  "operator": "IDAHO PIPELINE CORP",
  "region": "Western",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
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  ],
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