I202404 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
April 17,2024
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 March 11,2024(Report#I202404)
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 March 7,2024,on project 371-3065 of
Intermountain Gas Company(IGC).
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.
OPS 308 Gas Joint and Provided Trench Installations
1.4.Joint trench pipelines shall be installed in an approved trench configuration and with the
minimum separation shown in Appendices 1-12.Joint trench configurations may vary with the
addition or exclusion of other utilities.The selected joint trench configuration shall meet the
requirements of the utilities sharing the trench and easement,city,county,or state requirements.
1.4.1.Unless approved by Engineering Services or System Integrity,the following are the minimum
separation distances of utilities exiting a joint trench(e.g.,horizontal/perpendicular crossings:
1.4.1.2.Plastic main or service crossing electric installed in conduit or communications(direct bury
or in conduit)is four(4")inches.
Finding(s)•
At 5143 W Canaston St,in Meridian,when installing a service line,personnel did not leave the minimum
required separation of 4"between the service line and electrical line(in conduit)as required by OPS 308.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC.Das-Co returned to 5143 W Canaston St in Meridian
on March 7, 2024, and excavated the service line. Upon exposing the service line, the separation from the
electric service, in conduit,was discovered to be four inches. Prior to backfilling, Das-Co adjusted the service
line to create approximately seven inches of separation.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company