20240510Compliance Filing August 2022 - April 2024.pdf

RECEIVED
EXECUTIVE OFFICES Tuesday, August 23, 2022 8:06AM
IDAHO PUBLIC
INTERMOUNTAIN GAS COMPANY UTILITIES COMMISSION
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
August 23,2022
Ms.Maria Barratt-Riley,Executive Director Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject: Case No. INT-G-22-01 Settlement Agreement,Work Orders Audit
Dear Ms.Barratt-Riley,
This letter serves as Intermountain Gas Company's(IGC)submission of results for the initial audit of completed
work orders due August 29,2022,as outlined in the pending Settlement Agreement,Case No. INT-G-22-01,
between the Staff of the Idaho Public Utilities Commission(IPUC)and IGC.
TERMS OF SETTLEMENT
B.Action Item 2:Align the requirements of each Covered Task to coincide with Service
Technician and Service Technician Apprentice work orders and conduct and file
quarterly audits.
ii. Intermountain Gas agrees to perform quarterly audits of service orders to ensure that Service
Technician Apprentices and Service Technicians are qualified to perform the work associated with
the service orders.The audits will be conducted in a similar manner as the previous review that was
completed during the SMS review;however,the scope will not be limited to Service Technician
Apprentices but will include all Service Technicians. Order completions by all Service Technicians
or Service Technician Apprentices will be compared to the Technician's qualifications at the time
the work was completed.The first quarterly audit will include the period immediately following the
conclusion of the Company's initial audit on June 23,2021 through June 30,2022.The results of
this audit will be provided to Staff no later than August 29,2022.The results of subsequent
quarterly audits will be provided to Staff no later than 30 days after the last day of the preceding
quarter.Instances of noncompliance identified in the quarterly reports may be subject to penalty
under Idaho Code §61-712A.In determining whether to advocate for proposal of such penalties,
Commission Staff will consider the Company's self-reporting,the Company's good faith efforts to
address the violations,and the progress of the Company in decreasing the number of violations as
this Settlement is implemented.If the Company achieves twelve(12)months without any safety
violations,upon termination of the Settlement pursuant to a petition pursuant to paragraph 6.B.iii,
penalties for any violations identified in the quarterly audits will be waived.
Intermountain Gas Resilonse
Safety Management Systems (SMS) and Safety and Technical Training departments conducted an audit of
completed work orders and compared them to Service Technician qualifications at the time the work was
completed. The results concluded that 201,982 total work orders were completed by Service Technicians,
including Apprentice Service Technicians,between June 23, 2021, and June 30, 2022. It was determined that
592 orders(0.29%of the total work orders)were completed by non-qualified Service Technicians.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
lua,C4_��
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company

RECEIVED
EXECUTIVE OFFICES Wednesday, October 12, 2022 8:OOAM
IDAHO PUBLIC
INTERMOUNTAIN GAS COMPANY UTILITIES COMMISSION
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
October 12,2022
Ms.Maria Barratt-Riley,Executive Director
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject: Case No. INT-G-22-01 Settlement Agreement,Quarterly Report
Dear Ms.Barratt-Riley,
This letter serves as Intermountain Gas Company's(IGC)quarterly report for items outlined in the pending
Settlement Agreement,Case No. INT-G-22-01,between the Staff of the Idaho Public Utilities Commission(IPUC)
and IGC.
TERMS OF SETTLEMENT
A.Action Item 1: Evaluate and decide which department will be responsible for Operator
Qualifications. Specify roles under which the MDU Utilities Group will adhere.Define
roles and responsibilities of a cross-department partnership,with ongoing collaboration.
i. Executive management completed this action item and provided a directive to the
management team responsible for implementing the ACE Review on November
16,2021.The roles and responsibilities determined through this process will be
incorporated into OPS 800—Operator Qualification Plan by June 30,2022
Intermountain Gas Response
Executive management gave clear direction of departmental ownership of responsibilities. These
responsibilities have been incorporated into a revised OPS 800— Operator Qualification Plan. Revised OPS
800 implemented on June 24, 2022. Revised OPS 800 was submitted on July 5, 2022, with the previous
quarterly update.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
B.Action Item 2:Align the requirements of each Covered Task to coincide with Service
Technician and Service Technician Apprentice work orders and conduct and file
quarterly audits.
i. The Safety&Technical Training department is developing the list of Covered Tasks required to
perform Service Technician and Service Technician Apprentice work orders.The final list,and training
regarding its use,will be implemented by June 30,2022.Implementation will include a series of in-
person or virtual meetings with the affected Directors,Managers,and Supervisors.
ii.Intermountain Gas agrees to perform quarterly audits of service orders to ensure that Service
Technician Apprentices and Service Technicians are qualified to perform the work associated with the
service orders. The audits will be conducted in a similar manner as the previous review that was
completed during the SMS review;however,the scope will not be limited to Service Technician
Apprentices but will include all Service Technicians. Order completions by all Service Technicians or
Service Technician Apprentices will be compared to the Technician's qualifications at the time the
work was completed.The first quarterly audit will include the period immediately following the
conclusion of the Company's initial audit on June 23,2021 through June 30,2022. The results of this
audit will be provided to Staff no later than August 29,2022.The results of subsequent quarterly audits
will be provided to Staff no later than 30 days after the last day of the preceding quarter.Instances of
noncompliance identified in the quarterly reports may be subject to penalty under Idaho Code § 61-
712A.In determining whether to advocate for proposal of such penalties,Commission Staff will
consider the Company's self-reporting,the Company's good faith efforts to address the violations,and
the progress of the Company in decreasing the number of violations as this Settlement is implemented.
If the Company achieves twelve(12)months without any safety violations,upon termination of the
Settlement pursuant to a petition pursuant to paragraph 6.B.iii,penalties for any violations identified in
the quarterly audits will be waived.
iii. The quarterly audits conducted pursuant to Paragraph 6.B will continue until the issue can be resolved
by computer software that ensures work orders are assigned only to qualified service technicians or
service technician apprentices.Intermountain Gas may request that the Commission terminate its
obligation to conduct quarterly audits either 1)after two consecutive quarters that,as reflected in the
quarterly audits,indicate zero violations related to the qualifications of Service Technicians or Service
Technician Apprentices or 2)at any time beginning twenty-four(24)months after the effective date of
an Order approving this Settlement.Intermountain Gas may support such request by,among other
things,demonstrating a history of compliance and/or the presence of sufficient internal controls to
ensure that work orders are assigned to qualified service technicians.The Parties recognize that the
Commission retains the discretion to determine whether the petition and supporting materials justifies
termination of the quarterly audit requirement.
Intermountain Gas Response
(i) An MOC was initiated to align Covered Tasks with the applicable Service Technician and Service
Technician Apprentice work orders. Training regarding the use of the list concluded June 15,2022. The list is
referenced in the revised OPS 800—Operator Qualification Plan which implemented June 24,2022. Revised
OPS 800 was submitted on July 5,2022,with the previous quarterly update.
(ii) Safety Management Systems(SMS)and Safety and Technical Training departments conducted an audit of
completed work orders and compared them to Service Technician qualifications at the time the work was
completed. The previous quarter's audit results were submitted August 23,2022.
(iii)IGC continues to evaluate technology solutions to mitigate this issue.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
C.Action Item 3:Update,maintain,and provide annual training to Intermountain Gas
supervisors,focusing on Covered Tasks.
i. Initial training will be conducted prior to June 30,2022,with the implementation of the OPS 800
Operator Qualification Plan revisions and annually thereafter.
Intermountain Gas Response
Training for the revised OPS 800 — Operator Qualification Plan concluded June 15, 2022. The schedule
consisted of eight(8)sessions over a three(3)week period to accommodate employee schedules. Training was
designed or all departments with plan responsibilities, Directors, Managers, Supervisors of employees who
perform covered tasks, and employees who are, or will be operator qualified to perform Covered Tasks.
Subsequent training will be provided to these groups of employees annually.Annual training will be conducted
through EWN(Evaluation UG OPS 800—Operator Qualification Plan, ID#113738). The PowerPoint utilized
for training was submitted on July 5,2022,with the previous quarterly update.
D.Action Item 4:Further define `Expired.' Establish procedures for supervisors to follow if an Employee(a
term that includes all Intermountain employees who perform Covered Tasks)has expired qualifications.
Although there is a 90-day grace period,ensure Intermountain Gas Supervisors,Managers,and Directors
understand that the grace period exists only to allow management flexibility in resolving short-term
issues,and that issues regarding qualification should be reviewed and resolved in advance of the end of
the 90-day grace period to the extent possible.
i. The definition of`Expired' will be included in the OPS 800—Operator Qualification Plan revisions and
Intermountain Gas supervisor training.
Intermountain Gas Response
An MOC was initiated to better define `expired' in OPS 800—Operator Qualification Plan.Revised OPS 800
includes clarification that an individual is considered qualified to perform a Covered Task up to 90 calendar
days beyond the expiration date of the qualification. The 90 calendar days is intended to allow qualification
intervals to be adjusted and is not intended to be used as a grace period to extend the target finish date.Revised
OPS 800 implemented June 24, 2022. Revised OPS 800 was submitted on July 5, 2022, with the previous
quarterly update.
E.Action Item 5: Establish an annual Operator Qualification and OPS procedure calendar for supervisor
reference and support.
i. The Policy&Procedure department has implemented a policy review calendar on
SharePoint that includes OPS procedure training,effective dates of new and
revised OPS procedures,and changes to Operator Qualifications associated with
the OPS procedure change.The Safety&Technical Training department
maintains a training calendar that focusses on apprentice training and annual
support for Operator Qualification covered tasks
Intermountain Gas Response
A policy review calendar has been implemented and placed on the Company's SharePoint. This calendar is
accessible to all employees to assist in understanding when training will take place as well as when associated
procedure changes will be implemented. Similarly, the Safety and Technical Training department maintains a
training calendar that includes apprentice training and training for Operator Qualification covered tasks. This
item's completion was submitted on May 13,2022,with the previous quarterly update.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
F.Action Item 6:Establish a firm deadline for Performance Evaluations to be completed once Computer
Based Training/Classroom training has been completed.Lock-down Performance Evaluations will be
blocked or not allowed until Computer Based Training/Classroom training has been completed.
i. The revision of OPS 800—Operator Qualification Plan includes the following statement:Prior to a
Performance Evaluation,the Employee shall complete computer based or classroom training and
examination.Energy WorldNet("EWN"),Intermountain Gas' learning management system vendor,
will update their software to not allow performance evaluation in advance of computer based or
Company training and associated examinations. The EWN change will occur by June 30,2022,in
conjunction with the implementation of OPS 800—Operator Qualification Plan.
Intermountain Gas Resilonse
Safety and Technical Training has updated EWN to ensure Performance Evaluations are unable to be completed
prior to the completion of the Computer Based Training/Classroom training. This item's completion was
submitted on July 5,2022,with the previous quarterly update.
G.Action Item 7:Pursue additional hierarchical review of Operator Qualifications.Example: Regional
Director can review District Manager staff and below.
i. Operator Qualification statuses of Employees' assigned tasks are provided to Employee's direct
supervisor weekly by an email from EWN.These weekly emails include notifications regarding
expiring qualifications.The Safety&Technical Training department is coordinating with internal and
external IT personnel to connect EWN with Intermountain Gas employee management software to
expand hierarchical notifications for review.The hierarchical notifications will be implemented by June
6,2023.Until this action item is implemented,the Safety&Technical Training will provide a
comprehensive status report to all levels of supervision with Employees assigned covered tasks.
Intermountain Gas Response
Safety and Technical Training worked with IT personnel to connect EWN with IGC employee management software
to expand notifications for review.This task was completed ahead of the assigned deadline June 6,2023.Notifications
for hierarchical review implemented August 2,2022.
H.Action Item 8:Develop and review EWN Computer Based Training("CBT")modules and incorporate
with MDU Utilities Group trainings modeled after OPS Procedures.
i. Existing and future OPS procedure training is currently being converted to CBT modules that will
replace and/or supplement existing CBT modules.The converted and/or supplemental CBTs will be
implemented and available in EWN by December 31,2022.To detail this process,OPS 1—
Management of Change will be revised by December 31,2022.
Intermountain Gas Response
Safety and Technical Training continues to convert OPS procedure training to CBT modules in EWN. An MOC has
been initiated to revise OPS 1 -Management of Change to ensure OPS procedure CBTs are updated when procedure
revisions are implemented. CBT modules have been created and are in the stages of final review. CBT modules will
be available in EWN and revised OPS 1 will be implemented by December 31,2022.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
I.Action Item 9:Review MDU Utilities Group training for newly hired Employees who perform Covered
Tasks.
i. Following the completion of the action item identified in paragraph 6.B.i,the Safety&Technical
Training department will revise the Service Technician apprentice training to include an OPS 800—
Operator Qualification Plan policy review. The apprentice training will be revised by December 31,
2022.
Intermountain Gas Response
Safety and Technical Training has revised the Service Technician apprentice training to include an OPS 800—
Operator Qualification Plan policy review. This item's completion was submitted on July 5,2022,with the
previous quarterly update.
J.Action Item 10:Review and re-write OPS 800-Operator Qualification Plan to incorporate the above
recommendations.
i. OPS 800—Operator Qualification plan will be rewritten to incorporate the above
ACE Review Recommendations.The revised OPS 800—Operator Qualification
Plan will implement on June 30,2022.
Intermountain Gas Response
An MOC was initiated to re-write and incorporate ACE Review Recommendations into OPS 800—Operator
Qualification Plan. The revised OPS 800 defines responsibilities by department and outlines plan details such
as the identification of covered tasks,reviews and plan updates,the assigning and unassigning of qualifications
for MDU Utilities Group employees and contractors, evaluations and evaluation methods, reevaluation
intervals,performance evaluation criteria,and Span of Control(SOC)clarifications. The re-write also includes
requirements for post incident qualification review, qualification suspension and reinstatement, contractor
requirements, and emergency mutual assistance. Revised OPS 800 implemented June 24, 2022. Revised OPS
800 was submitted on July 5, 2022,with the previous quarterly update.
K.Action Item 11: Training provided will identify the avenues for reporting concerns regarding operator
qualifications.
Intermountain Gas Response
Training for rcviscd OPS 800—Operator Qualification Plan highlighted company reporting platforms such as
the ACE JIRA Service Desk and Vector Solutions for employees to report concerns regarding operator
qualifications. It was also emphasized that the Director, Safety and Technical Training, Director, Operations
Services, and Director, Policy and Procedure or any other leader in the organization can be contacted directly
by an employee to report concerns. The PowerPoint utilized for training was submitted on July 5, 2022, with
the previous quarterly update.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
k4a,c,t��
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company

From: Caldwell,Samantha
To: Maria Barratt-Riley;Jeff Brooks
Cc: Sanders,Josh; Darras,Patrick; Blattner, Lori;Schoepp,Michael
Subject: RE: 2022-10-12 Pending Settlement Agreement Update-Idaho
Date: Wednesday,October 12,2022 7:42:25 AM
Attachments: imaae001.Dna
CAUTION:This email originated outside the State of Idaho network.Verify links and attachments BEFORE you
click or open,even if you recognize and/or trust the sender.Contact your agency service desk with any
concerns.
Maria,
Yes, the audit results will be submitted separately.
Thank you,
Samantha
From: Maria Barratt-Riley<[e-mail]>
Sent: Wednesday, October 12, 2022 7:39 AM
To: Caldwell, Samantha <[e-mail]>;[e-mail]
Cc: Sanders,Josh <[e-mail]>; Darras, Patrick<[e-mail]>; Blattner,
Lori <[e-mail]>; Schoepp, Michael <[e-mail]>
Subject: Re: 2022-10-12 Pending Settlement Agreement Update - Idaho
** WARNING: EXTERNAL SENDER. NEVER click links or open attachments without positive
sender verification of purpose. DO NOT provide your user ID or password on sites or forms
linked from this email. **
Thank you. Are the audit results for July-Sept. coming separately?
Maria
Sent from my Verizon, Samsung Galaxy smartphone
Get Outlook for Android
From: Caldwell, Samantha <Samantha.Caldwell(@mdu.com>
Sent: Wednesday, October 12, 2022 7:07:05 AM
To: Maria Barratt-Riley<maria.barratt-rileyCcDpuc.idaho.gov>
Cc: Sanders,Josh <Josh.Sanders(@mdu.com>; Darras, Patrick<Patrick.Darras(@mdu.com>; Blattner,
Lori <LORL BLATTN ERCcDintgas.com>; Schoepp, Michael <Michael.SchoeppC(Dmdu.com>
Subject: 2022-10-12 Pending Settlement Agreement Update - Idaho
CAUTION:This email originated outside the State of Idaho network.Verify links and attachments BEFORE you
click or open,even if you recognize and/or trust the sender.Contact your agency service desk with any

concerns.
Maria,
Attached is Intermountain Gas Company's update for items outlined in the pending Settlement
Agreement.
Respectfully,
Samantha Caldwell
Manager, Policy and Procedure
Montana-Dakota Utilities
Office: 208-377-6034
Cell: 208-509-2140
B

RECEIVED
EXECUTIVE OFFICES Tuesday, October 25, 2022 8:06AM
IDAHO PUBLIC
INTERMOUNTAIN GAS COMPANY UTILITIES COMMISSION
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
October 25,2022
Ms.Maria Barratt-Riley,Executive Director
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject: Case No.INT-G-22-01 Settlement Agreement,Work Orders Audit
Dear Ms.Barratt-Riley,
This letter serves as Intermountain Gas Company's(IGC)quarterly submission of results for the audit of completed
work orders,as outlined in the pending Settlement Agreement,Case No.INT-G-22-01,between the Staff of the
Idaho Public Utilities Commission(IPUC)and IGC.
TERMS OF SETTLEMENT
B.Action Item 2:Align the requirements of each Covered Task to coincide with Service
Technician and Service Technician Apprentice work orders and conduct and file
quarterly audits.
ii. Intermountain Gas agrees to perform quarterly audits of service orders to ensure that Service
Technician Apprentices and Service Technicians are qualified to perform the work associated with
the service orders.The audits will be conducted in a similar manner as the previous review that was
completed during the SMS review;however,the scope will not be limited to Service Technician
Apprentices but will include all Service Technicians.Order completions by all Service Technicians
or Service Technician Apprentices will be compared to the Technician's qualifications at the time
the work was completed.The first quarterly audit will include the period immediately following the
conclusion of the Company's initial audit on June 23,2021 through June 30,2022.The results of
this audit will be provided to Staff no later than August 29,2022.The results of subsequent
quarterly audits will be provided to Staff no later than 30 days after the last day of the preceding
quarter.Instances of noncompliance identified in the quarterly reports may be subject to penalty
under Idaho Code §61-712A.In determining whether to advocate for proposal of such penalties,
Commission Staff will consider the Company's self-reporting,the Company's good faith efforts to
address the violations,and the progress of the Company in decreasing the number of violations as
this Settlement is implemented.If the Company achieves twelve(12)months without any safety
violations,upon termination of the Settlement pursuant to a petition pursuant to paragraph 6.B.iii,
penalties for any violations identified in the quarterly audits will be waived.
Intermountain Gas Response
Safety Management Systems (SMS) and Safety and Technical Training departments conducted an audit of
completed work orders and compared them to Service Technician qualifications at the time the work was
completed. The results concluded that 44,767 total work orders were completed by Service Technicians,
including Apprentice Service Technicians,between July 1, 2022, and September 30, 2022. It was determined
that 48 orders(0.11% of the total work orders)were completed by non-qualified Service Technicians.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company

From: Sanders,Josh
To: Maria Barratt-Rilev
Cc: Jeff Brooks
Subject: RE: 2022-10-25 Settlement Agreement-Quarter 3 Audit Results
Date: Friday,November 4,2022 3:12:19 PM
Attachments: imaae001.Dna
CAUTION:This email originated outside the State of Idaho network.Verify links and attachments BEFORE you
click or open,even if you recognize and/or trust the sender.Contact your agency service desk with any
concerns.
Hello Maria and Jeff,
In reviewing our reported 3rd quarter audit findings we have determined that 29 of the issues were
reported in error. These 29 findings were due to non-applicable qualification being mistakenly used
to validate against service work or span of control documentation was discovered. The remaining 19
orders that failed the audit were as follows:
• 18 G-SNIFTS were failed due to a procedural change that required supervisors to individually
assign an enhanced test for periodic sampling for odorization. These orders occurred around
the Boise and Nampa communities by journey level technicians. All technicians have
completed the required test and all orders were reworked.
• 1 G-ON order completed by an apprentice on 7/1/22. He did not have the 1202.01 Outside
Gas Leak Investigation, or the 1203.01 Inside Gas Leak Investigation. He received these
qualifications on 7/6/22. His supervisor is Colten Crowley.
To answer your question if we anticipate being able to reach and maintain 100% compliance, I do.
Processes that were put into place as part of the settlement agreement have already shown a
significant improvement from last report, and we continue looking for improvements to implement
that will bring us to sustaining zero OQ issues.
If you would like to visit about any of these audit findings I would be glad to host a call to discuss the
findings and how the changes we have implemented are going to help us get to 100% compliance
and stay that way.
Respectfully,
Josh Sanders
Director of Ops Policy and Procedures
[phone] Office
[phone] Cell
From: Maria Barratt-Riley<[e-mail]>
Sent: Wednesday, October 26, 2022 5:10 PM
To: Sanders,Josh <[e-mail]>
Cc:[e-mail]
Subject: FW: 2022-10-25 Settlement Agreement-Quarter 3 Audit Results

** WARNING: EXTERNAL SENDER. NEVER click links or open attachments without positive
sender verification of purpose. DO NOT provide your user ID or password on sites or forms
linked from this email. **
Josh,
Could we please get some additional information on the 48 incidents of non-qualified techs
performing work orders (were they completed by one or two technicians or many, when
(specific dates) did each one occur, where did each one occur, what did the work orders
entail, who was the supervisor assigned to each tech per each occurrence, etc.)? Do you
anticipate being able to reach and maintain 100% compliance?
Thanks,
Maria
From: Caldwell, Samantha <Samantha.Caldwell(@mdu.com>
Sent:Tuesday, October 25, 2022 8:06 AM
To: Maria Barratt-Riley<[e-mail]>
Cc: Sanders,Josh <[e-mail]>; Darras, Patrick<Patrick.Darras(@mdu.com>;
Blattner, Lori <LORI.BLATTNERIcDintgas.com>; Schoepp, Michael
<Michael.Schoepp(@mdu.com>
Subject: 2022-10-25 Settlement Agreement- Quarter 3 Audit Results
CAUTION:This email originated outside the State of Idaho network.Verify links and attachments
BEFORE you click or open,even if you recognize and/or trust the sender.Contact your agency service
desk with any concerns.
Maria,
As outlined in the Settlement Agreement, attached is the submission of quarter 3 audit
results for work orders completed July 1, 2022 through September 30, 2022.
Respectfully,
Samantha Caldwell
Manager, Policy and Procedure
Montana-Dakota Utilities
Office: 208-377-6034
Cell: 208-509-2140

FE-1

RECEIVED
EXECUTIVE OFFICES Monday, January 9, 2023 3:23PM
IDAHO PUBLIC
INTERMOUNTAIN GAS COMPANY UTILITIES COMMISSION
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
January 9,2023
Ms.Maria Barratt-Riley,Executive Director
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject: Case No. INT-G-22-01 Settlement Agreement,Quarterly Report
Dear Ms.Barratt-Riley,
This letter serves as Intermountain Gas Company's(IGC)quarterly report for items outlined in the pending
Settlement Agreement,Case No. INT-G-22-01,between the Staff of the Idaho Public Utilities Commission(IPUC)
and IGC.
TERMS OF SETTLEMENT
A.Action Item 1: Evaluate and decide which department will be responsible for Operator
Qualifications. Specify roles under which the MDU Utilities Group will adhere.Define
roles and responsibilities of a cross-department partnership,with ongoing collaboration.
i. Executive management completed this action item and provided a directive to the
management team responsible for implementing the ACE Review on November
16,2021.The roles and responsibilities determined through this process will be
incorporated into OPS 800—Operator Qualification Plan by June 30,2022
Intermountain Gas Response
Executive management gave clear direction of departmental ownership of responsibilities. These
responsibilities have been incorporated into a revised OPS 800— Operator Qualification Plan. Revised OPS
800 implemented on June 24, 2022. Revised OPS 800 was submitted on July 5, 2022, with the previous
quarterly update.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
B.Action Item 2:Align the requirements of each Covered Task to coincide with Service
Technician and Service Technician Apprentice work orders and conduct and file
quarterly audits.
i. The Safety&Technical Training department is developing the list of Covered Tasks required to
perform Service Technician and Service Technician Apprentice work orders.The final list,and training
regarding its use,will be implemented by June 30,2022.Implementation will include a series of in-
person or virtual meetings with the affected Directors,Managers,and Supervisors.
ii.Intermountain Gas agrees to perform quarterly audits of service orders to ensure that Service
Technician Apprentices and Service Technicians are qualified to perform the work associated with the
service orders. The audits will be conducted in a similar manner as the previous review that was
completed during the SMS review;however,the scope will not be limited to Service Technician
Apprentices but will include all Service Technicians. Order completions by all Service Technicians or
Service Technician Apprentices will be compared to the Technician's qualifications at the time the
work was completed.The first quarterly audit will include the period immediately following the
conclusion of the Company's initial audit on June 23,2021 through June 30,2022. The results of this
audit will be provided to Staff no later than August 29,2022.The results of subsequent quarterly audits
will be provided to Staff no later than 30 days after the last day of the preceding quarter.Instances of
noncompliance identified in the quarterly reports may be subject to penalty under Idaho Code § 61-
712A.In determining whether to advocate for proposal of such penalties,Commission Staff will
consider the Company's self-reporting,the Company's good faith efforts to address the violations,and
the progress of the Company in decreasing the number of violations as this Settlement is implemented.
If the Company achieves twelve(12)months without any safety violations,upon termination of the
Settlement pursuant to a petition pursuant to paragraph 6.B.iii,penalties for any violations identified in
the quarterly audits will be waived.
iii. The quarterly audits conducted pursuant to Paragraph 6.B will continue until the issue can be resolved
by computer software that ensures work orders are assigned only to qualified service technicians or
service technician apprentices.Intermountain Gas may request that the Commission terminate its
obligation to conduct quarterly audits either 1)after two consecutive quarters that,as reflected in the
quarterly audits,indicate zero violations related to the qualifications of Service Technicians or Service
Technician Apprentices or 2)at any time beginning twenty-four(24)months after the effective date of
an Order approving this Settlement.Intermountain Gas may support such request by,among other
things,demonstrating a history of compliance and/or the presence of sufficient internal controls to
ensure that work orders are assigned to qualified service technicians.The Parties recognize that the
Commission retains the discretion to determine whether the petition and supporting materials justifies
termination of the quarterly audit requirement.
Intermountain Gas Response
(i) An MOC was initiated to align Covered Tasks with the applicable Service Technician and Service
Technician Apprentice work orders. Training regarding the use of the list concluded June 15,2022. The list is
referenced in the revised OPS 800—Operator Qualification Plan which implemented June 24,2022. Revised
OPS 800 was submitted on July 5,2022,with the previous quarterly update.
(ii) Safety Management Systems(SMS)and Safety and Technical Training departments conducted an audit of
completed work orders and compared them to Service Technician qualifications at the time the work was
completed. The previous quarter's audit results were submitted October 25,2022.
(iii)IGC continues to evaluate technology solutions to mitigate this issue.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
C.Action Item 3:Update,maintain,and provide annual training to Intermountain Gas
supervisors,focusing on Covered Tasks.
i. Initial training will be conducted prior to June 30,2022,with the implementation of the OPS 800
Operator Qualification Plan revisions and annually thereafter.
Intermountain Gas Response
Training for the revised OPS 800 — Operator Qualification Plan concluded June 15, 2022. The schedule
consisted of eight(8)sessions over a three(3)week period to accommodate employee schedules. Training was
designed or all departments with plan responsibilities, Directors, Managers, Supervisors of employees who
perform covered tasks, and employees who are, or will be operator qualified to perform Covered Tasks.
Subsequent training will be provided to these groups of employees annually.Annual training will be conducted
through EWN(Evaluation UG OPS 800—Operator Qualification Plan, ID#113738). The PowerPoint utilized
for training was submitted on July 5,2022,with the previous quarterly update.
D.Action Item 4:Further define `Expired.' Establish procedures for supervisors to follow if an Employee(a
term that includes all Intermountain employees who perform Covered Tasks)has expired qualifications.
Although there is a 90-day grace period,ensure Intermountain Gas Supervisors,Managers,and Directors
understand that the grace period exists only to allow management flexibility in resolving short-term
issues,and that issues regarding qualification should be reviewed and resolved in advance of the end of
the 90-day grace period to the extent possible.
i. The definition of`Expired' will be included in the OPS 800—Operator Qualification Plan revisions and
Intermountain Gas supervisor training.
Intermountain Gas Response
An MOC was initiated to better define `expired' in OPS 800—Operator Qualification Plan. Revised OPS 800
includes clarification that an individual is considered qualified to perform a Covered Task up to 90 calendar
days beyond the expiration date of the qualification. The 90 calendar days is intended to allow qualification
intervals to be adjusted and is not intended to be used as a grace period to extend the target finish date.Revised
OPS 800 implemented June 24, 2022. Revised OPS 800 was submitted on July 5, 2022, with the previous
quarterly update.
E.Action Item 5:Establish an annual Operator Qualification and OPS procedure calendar for supervisor
reference and support.
i. The Policy&Procedure department has implemented a policy review calendar on
SharePoint that includes OPS procedure training,effective dates of new and
revised OPS procedures,and changes to Operator Qualifications associated with
the OPS procedure change.The Safety&Technical Training department
maintains a training calendar that focusses on apprentice training and annual
support for Operator Qualification covered tasks
Intermountain Gas Response
A policy review calendar has been implemented and placed on the Company's SharePoint. This calendar is
accessible to all employees to assist in understanding when training will take place as well as when associated
procedure changes will be implemented. Similarly, the Safety and Technical Training department maintains a
training calendar that includes apprentice training and training for Operator Qualification covered tasks. This
item's completion was submitted on May 13,2022,with the previous quarterly update.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
F.Action Item 6:Establish a firm deadline for Performance Evaluations to be completed once Computer
Based Training/Classroom training has been completed.Lock-down Performance Evaluations will be
blocked or not allowed until Computer Based Training/Classroom training has been completed.
i. The revision of OPS 800—Operator Qualification Plan includes the following statement:Prior to a
Performance Evaluation,the Employee shall complete computer based or classroom training and
examination.Energy WorldNet("EWN"),Intermountain Gas' learning management system vendor,
will update their software to not allow performance evaluation in advance of computer based or
Company training and associated examinations. The EWN change will occur by June 30,2022,in
conjunction with the implementation of OPS 800—Operator Qualification Plan.
Intermountain Gas Response
Safety and Technical Training has updated EWN to ensure Performance Evaluations are unable to be completed
prior to the completion of the Computer Based Training/Classroom training. This item's completion was
submitted on July 5,2022,with the previous quarterly update.
G.Action Item 7:Pursue additional hierarchical review of Operator Qualifications.Example: Regional
Director can review District Manager staff and below.
i. Operator Qualification statuses of Employees' assigned tasks are provided to Employee's direct
supervisor weekly by an email from EWN.These weekly emails include notifications regarding
expiring qualifications.The Safety&Technical Training department is coordinating with internal and
external IT personnel to connect EWN with Intermountain Gas employee management software to
expand hierarchical notifications for review.The hierarchical notifications will be implemented by June
6,2023.Until this action item is implemented,the Safety&Technical Training will provide a
comprehensive status report to all levels of supervision with Employees assigned covered tasks.
Intermountain Gas Resnonse
Safety and Technical Training worked with IT personnel to connect EWN with IGC employee management software
to expand notifications for review.This task was completed ahead of the assigned deadline June 6,2023.Notifications
for hierarchical review implemented August 2,2022.
H.Action Item 8:Develop and review EWN Computer Based Training("CBT")modules and incorporate
with MDU Utilities Group trainings modeled after OPS Procedures.
i. Existing and future OPS procedure training is currently being converted to CBT modules that will
replace and/or supplement existing CBT modules.The converted and/or supplemental CBTs will be
implemented and available in EWN by December 31,2022.To detail this process,OPS 1—
Management of Change will be revised by December 31,2022.
Intermountain Gas Response
Safety and Technical Training converted OPS procedure training to CBT modules in EWN.An MOC was initiated to
revise OPS I -Management of Change to ensure OPS procedure CBTs are updated when procedure revisions are
implemented.CBT modules have been created and are available in EWN.Revised OPS I implemented December 30,
2022.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
I.Action Item 9:Review MDU Utilities Group training for newly hired Employees who perform Covered
Tasks.
i. Following the completion of the action item identified in paragraph 6.B.i,the Safety&Technical
Training department will revise the Service Technician apprentice training to include an OPS 800-
Operator Qualification Plan policy review. The apprentice training will be revised by December 31,
2022.
Intermountain Gas Response
Safety and Technical Training has revised the Service Technician apprentice training to include an OPS 800-
Operator Qualification Plan policy review. This item's completion was submitted on July 5,2022,with the
previous quarterly update.
J.Action Item 10:Review and re-write OPS 800-Operator Qualification Plan to incorporate the above
recommendations.
i. OPS 800-Operator Qualification plan will be rewritten to incorporate the above
ACE Review Recommendations.The revised OPS 800-Operator Qualification
Plan will implement on June 30,2022.
Intermountain Gas Response
An MOC was initiated to re-write and incorporate ACE Review Recommendations into OPS 800-Operator
Qualification Plan. The revised OPS 800 defines responsibilities by department and outlines plan details such
as the identification of covered tasks,reviews and plan updates,the assigning and unassigning of qualifications
for MDU Utilities Group employees and contractors, evaluations and evaluation methods, reevaluation
intervals,performance evaluation criteria,and Span of Control(SOC)clarifications. The re-write also includes
requirements for post incident qualification review, qualification suspension and reinstatement, contractor
requirements, and emergency mutual assistance. Revised OPS 800 implemented June 24, 2022. Revised OPS
800 was submitted on July 5, 2022,with the previous quarterly update.
K.Action Item 11: Training provided will identify the avenues for reporting concerns regarding operator
qualifications.
Intermountain Gas Response
Training for rcviscd OPS 800-Operator Qualification Plan highlighted company reporting platforms such as
the ACE JIRA Service Desk and Vector Solutions for employees to report concerns regarding operator
qualifications. It was also emphasized that the Director, Safety and Technical Training, Director, Operations
Services, and Director, Policy and Procedure or any other leader in the organization can be contacted directly
by an employee to report concerns. The PowerPoint utilized for training was submitted on July 5, 2022, with
the previous quarterly update.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
k4aw-���
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company

RECEIVED
EXECUTIVE OFFICES Tuesday, January 10, 2023 12:17PM
IDAHO PUBLIC
INTERMOUNTAIN GAS COMPANY UTILITIES COMMISSION
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
January 10,2023
Ms.Maria Barratt-Riley,Executive Director
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject: Case No.INT-G-22-01 Settlement Agreement,Work Orders Audit
Dear Ms.Barratt-Riley,
This letter serves as Intermountain Gas Company's(IGC)quarterly submission of results for the audit of completed
work orders,as outlined in the pending Settlement Agreement,Case No.INT-G-22-01,between the Staff of the
Idaho Public Utilities Commission(IPUC)and IGC.
TERMS OF SETTLEMENT
B.Action Item 2:Align the requirements of each Covered Task to coincide with Service
Technician and Service Technician Apprentice work orders and conduct and file
quarterly audits.
ii. Intermountain Gas agrees to perform quarterly audits of service orders to ensure that Service
Technician Apprentices and Service Technicians are qualified to perform the work associated with
the service orders.The audits will be conducted in a similar manner as the previous review that was
completed during the SMS review;however,the scope will not be limited to Service Technician
Apprentices but will include all Service Technicians. Order completions by all Service Technicians
or Service Technician Apprentices will be compared to the Technician's qualifications at the time
the work was completed.The first quarterly audit will include the period immediately following the
conclusion of the Company's initial audit on June 23,2021 through June 30,2022.The results of
this audit will be provided to Staff no later than August 29,2022.The results of subsequent
quarterly audits will be provided to Staff no later than 30 days after the last day of the preceding
quarter.Instances of noncompliance identified in the quarterly reports may be subject to penalty
under Idaho Code §61-712A.In determining whether to advocate for proposal of such penalties,
Commission Staff will consider the Company's self-reporting,the Company's good faith efforts to
address the violations,and the progress of the Company in decreasing the number of violations as
this Settlement is implemented. If the Company achieves twelve(12)months without any safety
violations,upon termination of the Settlement pursuant to a petition pursuant to paragraph 6.B.iii,
penalties for any violations identified in the quarterly audits will be waived.
Intermountain Gas Resgonse
Safety Management Systems (SMS) and Safety and Technical Training departments conducted an audit of
completed work orders and compared them to Service Technician qualifications at the time the work was
completed. The results concluded that 38,980 total work orders were completed by Service Technicians,
including Apprentice Service Technicians, between October 1, 2022, and December 31, 2022. It was
determined that 0 orders were completed by non-qualified Service Technicians.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
�Ua.64��
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company

RECEIVED
EXECUTIVE OFFICES Monday, April 17, 2023 8:OOAM
IDAHO PUBLIC
INTERMOUNTAIN GAS COMPANY UTILITIES COMMISSION
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
April 17,2023
Ms.Maria Barratt-Riley,Executive Director
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject: Case No.INT-G-22-01 Settlement Agreement,Work Orders Audit
Dear Ms.Barratt-Riley,
This letter serves as Intermountain Gas Company's(IGC)quarterly submission of results for the audit of completed
work orders,as outlined in the pending Settlement Agreement,Case No.INT-G-22-01,between the Staff of the
Idaho Public Utilities Commission(IPUC)and IGC.
TERMS OF SETTLEMENT
B.Action Item 2:Align the requirements of each Covered Task to coincide with Service
Technician and Service Technician Apprentice work orders and conduct and file
quarterly audits.
ii. Intermountain Gas agrees to perform quarterly audits of service orders to ensure that Service
Technician Apprentices and Service Technicians are qualified to perform the work associated with
the service orders.The audits will be conducted in a similar manner as the previous review that was
completed during the SMS review;however,the scope will not be limited to Service Technician
Apprentices but will include all Service Technicians. Order completions by all Service Technicians
or Service Technician Apprentices will be compared to the Technician's qualifications at the time
the work was completed.The first quarterly audit will include the period immediately following the
conclusion of the Company's initial audit on June 23,2021 through June 30,2022.The results of
this audit will be provided to Staff no later than August 29,2022.The results of subsequent
quarterly audits will be provided to Staff no later than 30 days after the last day of the preceding
quarter.Instances of noncompliance identified in the quarterly reports may be subject to penalty
under Idaho Code §61-712A.In determining whether to advocate for proposal of such penalties,
Commission Staff will consider the Company's self-reporting,the Company's good faith efforts to
address the violations,and the progress of the Company in decreasing the number of violations as
this Settlement is implemented.If the Company achieves twelve(12)months without any safety
violations,upon termination of the Settlement pursuant to a petition pursuant to paragraph 6.B.iii,
penalties for any violations identified in the quarterly audits will be waived.
Intermountain Gas Response
Safety Management Systems (SMS) and Safety and Technical Training departments conducted an audit of
completed work orders and compared them to Service Technician qualifications at the time the work was
completed. The results concluded that 31,050 total work orders were completed by Service Technicians,
including Apprentice Service Technicians, between January 1, 2023, and March 31, 2023. It was determined
that 0 orders were completed by non-qualified Service Technicians.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering& Operations Services
Intermountain Gas Company

RECEIVED
EXECUTIVE OFFICES Tuesday, July 11, 2023 8:OOAM
IDAHO PUBLIC
INTERMOUNTAIN GAS COMPANY UTILITIES COMMISSION
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
July 11,2023
Ms.Maria Barratt-Riley,Executive Director
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject: Case No.INT-G-22-01 Settlement Agreement,Work Orders Audit
Dear Ms.Barratt-Riley,
This letter serves as Intermountain Gas Company's(IGC)quarterly submission of results for the audit of completed
work orders,as outlined in the pending Settlement Agreement,Case No.INT-G-22-01,between the Staff of the
Idaho Public Utilities Commission(IPUC)and IGC.
TERMS OF SETTLEMENT
B.Action Item 2:Align the requirements of each Covered Task to coincide with Service
Technician and Service Technician Apprentice work orders and conduct and file
quarterly audits.
ii. Intermountain Gas agrees to perform quarterly audits of service orders to ensure that Service
Technician Apprentices and Service Technicians are qualified to perform the work associated with
the service orders.The audits will be conducted in a similar manner as the previous review that was
completed during the SMS review;however,the scope will not be limited to Service Technician
Apprentices but will include all Service Technicians. Order completions by all Service Technicians
or Service Technician Apprentices will be compared to the Technician's qualifications at the time
the work was completed.The first quarterly audit will include the period immediately following the
conclusion of the Company's initial audit on June 23,2021 through June 30,2022.The results of
this audit will be provided to Staff no later than August 29,2022.The results of subsequent
quarterly audits will be provided to Staff no later than 30 days after the last day of the preceding
quarter.Instances of noncompliance identified in the quarterly reports may be subject to penalty
under Idaho Code §61-712A.In determining whether to advocate for proposal of such penalties,
Commission Staff will consider the Company's self-reporting,the Company's good faith efforts to
address the violations,and the progress of the Company in decreasing the number of violations as
this Settlement is implemented.If the Company achieves twelve(12)months without any safety
violations,upon termination of the Settlement pursuant to a petition pursuant to paragraph 6.B.iii,
penalties for any violations identified in the quarterly audits will be waived.
Intermountain Gas Response
Safety Management Systems (SMS) and Safety and Technical Training departments conducted an audit of
completed work orders and compared them to Service Technician qualifications at the time the work was
completed. The results concluded that 41,367 total work orders were completed by Service Technicians,
including Apprentice Service Technicians,between April 1,2023, and June 30,2023. It was determined that 0
orders were completed by non-qualified Service Technicians.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
�Ua,c,t��
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company

RECEIVED
EXECUTIVE OFFICES Monday, October 9, 2023 9:31AM
IDAHO PUBLIC
INTERMOUNTAIN GAS COMPANY UTILITIES COMMISSION
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
October 9,2023
Ms.Maria Barratt-Riley,Executive Director
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject: Case No.INT-G-22-01 Settlement Agreement,Work Orders Audit
Dear Ms.Barratt-Riley,
This letter serves as Intermountain Gas Company's(IGC)quarterly submission of results for the audit of completed
work orders,as outlined in the pending Settlement Agreement,Case No.INT-G-22-01,between the Staff of the
Idaho Public Utilities Commission(IPUC)and IGC.
TERMS OF SETTLEMENT
B.Action Item 2:Align the requirements of each Covered Task to coincide with Service
Technician and Service Technician Apprentice work orders and conduct and file
quarterly audits.
ii. Intermountain Gas agrees to perform quarterly audits of service orders to ensure that Service Technician
Apprentices and Service Technicians are qualified to perform the work associated with the service orders.
The audits will be conducted in a similar manner as the previous review that was completed during the
SMS review;however,the scope will not be limited to Service Technician Apprentices but will include all
Service Technicians.Order completions by all Service Technicians or Service Technician Apprentices will
be compared to the Technician's qualifications at the time the work was completed. The first quarterly
audit will include the period immediately following the conclusion of the Company's initial audit on June
23,2021 through June 30,2022.The results of this audit will be provided to Staff no later than August 29,
2022.The results of subsequent quarterly audits will be provided to Staff no later than 30 days after the last
day of the preceding quarter.Instances of noncompliance identified in the quarterly reports may be subject
to penalty under Idaho Code§ 61-712A.In determining whether to advocate for proposal of such penalties,
Commission Staff will consider the Company's self-reporting,the Company's good faith efforts to address
the violations,and the progress of the Company in decreasing the number of violations as this Settlement is
implemented.If the Company achieves twelve(12)months without any safety violations,upon termination
of the Settlement pursuant to a petition pursuant to paragraph 6.B.iii,penalties for any violations identified
in the quarterly audits will be waived.
Intermountain Gas Resgonse
Safety Management Systems (SMS) and Safety and Technical Training departments conducted an audit of
completed work orders and compared them to Service Technician qualifications at the time the work was
completed. The results concluded that 45,025 total work orders were completed by Service Technicians,
including Apprentice Service Technicians,between July 1, 2023, and September 30, 2023. It was determined
that 0 orders were completed by non-qualified Service Technicians.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company

RECEIVED
EXECUTIVE OFFICES Thursday, January 1, 2024 1:43PM
IDAHO PUBLIC
INTERMOUNTAIN GAS COMPANY UTILITIES COMMISSION
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
January 4,2024
Ms.Maria Barratt-Riley,Executive Director
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject: Case No. INT-G-22-01 Settlement Agreement,Work Orders Audit
Dear Ms.Barratt-Riley,
This letter serves as Intermountain Gas Company's(IGC)quarterly submission of results for the audit of completed
work orders,as outlined in the pending Settlement Agreement,Case No.INT-G-22-01,between the Staff of the
Idaho Public Utilities Commission(IPUC)and IGC.
TERMS OF SETTLEMENT
B.Action Item 2:Align the requirements of each Covered Task to coincide with Service
Technician and Service Technician Apprentice work orders and conduct and file
quarterly audits.
ii. Intermountain Gas agrees to perform quarterly audits of service orders to ensure that Service
Technician Apprentices and Service Technicians are qualified to perform the work associated with
the service orders.The audits will be conducted in a similar manner as the previous review that was
completed during the SMS review;however,the scope will not be limited to Service Technician
Apprentices but will include all Service Technicians.Order completions by all Service Technicians
or Service Technician Apprentices will be compared to the Technician's qualifications at the time
the work was completed.The first quarterly audit will include the period immediately following the
conclusion of the Company's initial audit on June 23,2021 through June 30,2022.The results of
this audit will be provided to Staff no later than August 29,2022.The results of subsequent
quarterly audits will be provided to Staff no later than 30 days after the last day of the preceding
quarter.Instances of noncompliance identified in the quarterly reports may be subject to penalty
under Idaho Code§ 61-712A.In determining whether to advocate for proposal of such penalties,
Commission Staff will consider the Company's self-reporting,the Company's good faith efforts to
address the violations,and the progress of the Company in decreasing the number of violations as
this Settlement is implemented.If the Company achieves twelve(12)months without any safety
violations,upon termination of the Settlement pursuant to a petition pursuant to paragraph 6.B.iii,
penalties for any violations identified in the quarterly audits will be waived.
Intermountain Gas Response
Safety Management Systems (SMS) and Safety and Technical Training departments conducted an audit of
completed work orders and compared them to Service Technician qualifications at the time the work was
completed. The results concluded that 36,897 total work orders were completed by Service Technicians,
including Apprentice Service Technicians, between October 1, 2023, and December 31, 2023. It was
determined that 0 orders were completed by non-qualified Service Technicians.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company

RECEIVED
EXECUTIVE OFFICES Thursday,April 4, 2024 8:OOAM
IDAHO PUBLIC
INTERMOUNTAIN GAS COMPANY UTILITIES COMMISSION
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
April 4,2024
Ms.Maria Barratt-Riley,Executive Director
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject: Case No.INT-G-22-01 Settlement Agreement,Work Orders Audit
Dear Ms.Barratt-Riley,
This letter serves as Intermountain Gas Company's(IGC)quarterly submission of results for the audit of completed
work orders,as outlined in the pending Settlement Agreement,Case No. INT-G-22-01,between the Staff of the
Idaho Public Utilities Commission(IPUC)and IGC.
TERMS OF SETTLEMENT
B.Action Item 2:Align the requirements of each Covered Task to coincide with Service
Technician and Service Technician Apprentice work orders and conduct and file
quarterly audits.
ii. Intermountain Gas agrees to perform quarterly audits of service orders to ensure that Service
Technician Apprentices and Service Technicians are qualified to perform the work associated with
the service orders.The audits will be conducted in a similar manner as the previous review that was
completed during the SMS review;however,the scope will not be limited to Service Technician
Apprentices but will include all Service Technicians. Order completions by all Service Technicians
or Service Technician Apprentices will be compared to the Technician's qualifications at the time
the work was completed.The first quarterly audit will include the period immediately following the
conclusion of the Company's initial audit on June 23,2021 through June 30,2022.The results of
this audit will be provided to Staff no later than August 29,2022.The results of subsequent
quarterly audits will be provided to Staff no later than 30 days after the last day of the preceding
quarter.Instances of noncompliance identified in the quarterly reports may be subject to penalty
under Idaho Code §61-712A.In determining whether to advocate for proposal of such penalties,
Commission Staff will consider the Company's self-reporting,the Company's good faith efforts to
address the violations,and the progress of the Company in decreasing the number of violations as
this Settlement is implemented. If the Company achieves twelve(12)months without any safety
violations,upon termination of the Settlement pursuant to a petition pursuant to paragraph 6.B.iii,
penalties for any violations identified in the quarterly audits will be waived.
Intermountain Gas Response
Safety Management Systems (SMS) and Safety and Technical Training departments conducted an audit of
completed work orders and compared them to Service Technician qualifications at the time the work was
completed. The results concluded that 30,515 total work orders were completed by Service Technicians,
including Apprentice Service Technicians, between January 1, 2024, and March 31, 2024. It was determined
that 0 orders were completed by non-qualified Service Technicians.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
k4a-e,��
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company