I202401 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
April 4,2024
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to Notice of Probable Violation dated February 28,2024(Report#I202401)
Dear Mr.Brooks,
This letter is intended to address one(1)probable violation stemming from a complaint from a concerned citizen in
regard to a meter exchange on February 13,2024.The Idaho Public Utilities Commission(IPUC)reviewed
Intermountain Gas Company's procedure and documentation related to the complaint pursuant to of Title 49,United
States Code.
PROBABLE VIOLATIONS
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 312 Gas Service Person Handbook
6.5.Using approved gas detection equipment or soap solution,check aboveground piping and
appurtenances,mechanical fittings,meter stops,caps,valves,any disturbed fittings,and other areas
for leaks.
Finding(s):
Staff discovered through IGC documentation on meter#482748375,and a complaint filed with the
Commission that a meter installed(for the replacement of meter#482611494)was not properly checked for
leaks and had to be revisited for leak repair after a customer reported and emergency gas outside odor call
through the IGC leak line.The responding technician referenced that both the inlet and outlet of the meter
were leaking and had not been properly installed/tightened.This resulted in a class 2 leak.The use of gas
detection equipment and or the use of a soap solution should have identified a leaking meter inlet and outlet
as per the requirements of IGC OPS 312 6.5.
Intermountain Gas Reslionse
IGC acknowledges the findings brought forth by the IPUC.Upon further investigation,operator qualifications
were suspended for the employee who performed the meter exchange, in addition to corrective actions to
improve the employee's performance. The employee has since been retrained and requalified. Additionally, a
compliance message has been distributed to all employees and contractors to emphasize the importance of
following procedures and training when performing work to ensure Company gas facilities are installed in a
manner that no leaks are present when leaving the site and are likely not to start leaking.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
�Ua44,o
Pat Darras
Vice President,Engineering& Operations Services
Intermountain Gas Company