I202301 LOC Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
May 1,2023
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to Letter of Concern dated April 10,2023 (Report#1202301)
Dear Mr.Brooks,
This letter is intended to address one (1) area of concern from a records inspection conducted by the Idaho Public
Utilities Commission(IPUC)on March 27-30,2023,at Intermountain Gas Company.
ITEM OF CONCERN
1. 49 CFR& 192.605 Procedural manual for operations,maintenance,and emergencies.
(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.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.
Finding(s)•
Per IGC OPS 706 Leak Survey(1.1)Leak survey shall be documented in the Inspection and Survey
Application(e.g.,IQGeo)except for unodorized lines and shorted casings which will be documented in
PCAD.Prior to implementation of OPS 402—Corrosion Control,shorted casings will be documented
in legacy software applications.At a minimum,leak survey records shall contain the following
information: (1.1.3)Survey Method.After viewing 2022 Leak Survey records,the Survey Method was
not identified.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. IGC met with the Inspection and Survey
Application software provider on April 17,2023,to initiate an update to their program to add a field within the
application to capture the leak survey method.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
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Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company