I202411 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
September 25,2024
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 20,2024(Report#I202411)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a construction inspection
conducted by the Idaho Public Utilities Commission(IPUC)on August 20,2024,on service line number 371-
052855 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.
(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.
2. OPS 309 Squeeze-Off of Plastic Pine
2.3.Ground squeeze-off tool with a static electric grounding device before placing the squeeze-off tool
on the pipe,apply a soapy water solution and wet non synthetic cloth(such as cotton or burlap material)
upstream of squeeze location,or commercially available electrostatic discharge fluid to the pipe surface
on the squeeze location to provide for dissipation of static charge to the ground.
Finding(s):
During a construction inspection on Service Line#371-052855 at 1378 W Ultar Drive,Nampa,ID,a contractor
representing IGC squeezed a 3/4"service line without using a soapy water solution and wet non-synthetic cloth
(such as cotton or burlap material)upstream of squeeze location,or commercially available electrostatic
discharge fluid.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. An MOC has been initiated to revise OPS 309—
Squeeze-Off of Plastic Pipe. It was determined during the investigation of this probable violation that the
current procedure language can lead to confusion. We are in the process of engaging with our team of subject
matter experts to provide clarification. Revised OPS 309 will implement on or before October 15, 2024.
Notification of the procedure change will be provided to Company and Contractor personnel.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company