I202503 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
July 16,2025
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to Notice of Probable Violation dated June 17,2025 (Report#I202503)
Dear Mr.Brooks,
This letter is intended to address one(1)probable violation stemming from a construction inspection conducted by
the Idaho Public Utilities Commission(IPUC)on May 14,2025 in Kuna of Intermountain Gas Company(IGC)
pursuant of Chapter 601 Title,49,United States Code.
PRORARTY VIOLATinNS
L 49 CFR 8 192.605 Procedural manual for operations. maintenance, and emergencies.
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.
49 W2.614 Damage prevention program.
c. The damage prevention program required by paragraph(a)of this section must,at a
mm 1 mum:
(6)Provide as follows for inspection of pipelines that an operator has reason to believe
could be damaged by excavation activities:
(i)The inspection must be done as frequently as necessary during and after the
activities to verify the integrity of the pipeline; and
(ii)In the case of blasting,any inspection must include leakage surveys.
49 092.805 Oualification Program
Each operator shall have and follow a written qualification program. The program shall include
provisions to:
(e)Evaluate an individual if the operator has reason to believe that the individual is no longer
qualified to perform a covered task.
OPS 800 Operator Oualification Plan
1.PLAN RESPONSIBILITIES
1.1. General
1.1.1.When an employee or contractor witnesses or is made aware of incidents or AOCs caused by
an individual(s)performance,they shall report the incident or AOC to their supervisor.
OPS 61OR n en rating Conditions and other Deficiencies Renuiring
Rem edi ation
1. General
1.1. Identified AOCs shall be reported at the time of discovery. Immediately contact applicable
Manager, or Supervisor, and proceed to step 1.3.
1.1.1. Contractors shall contact their MDUD representative(e.g., Field Operations Coordinator,
third party Inspector, local District Management, etc.)immediately after identifying an AOC. If an

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
AOC is identified after hours and contact cannot be made with the MDUG representative,
immediately call the 24-Hour Emergency Contact Number.
49 092.361 Service lines:Installation.
a.Depth.Each buried service line must be installed with at least 12 inches(305 millimeters)of cover
in private property and at least 18 inches(457 millimeters)if cover in streets and roads.However,
where an underground prevents installation at those depths,the service line must be able to
withstand any anticipated external load.
b. Support and backfill.Each service line must be properly supported on undisturbed or well-
compacted soil,and material used for backfill must be free of materials that could damage the pipe
or its coating.
OPS 307 Polyethylene(PE)Main and Service Construction
5.16.2.At least 12"separation should be maintained when crossing or paralleling electric(direct
bury or in conduit).
5.16.2.1.When 12"separation cannot be maintained,mechanical protection is to be used to limit the
likelihood of detrimental heat transfer to gas facilities.Examples of protective measures are placing
sandbags,rock shield,PVC,or FRP half sleeve between the pipe and the foreign utility to prevent
contact and wear.
5.16.2.2.Electric separation should be discussed with all parties involved prior to installation.
5.23.2. Service lines less that two(2")inches in diameter shall have at least 18"cover on private
property and at least 24"cover in the right-of-way(ROW).
5.23.2.1.A minimum of 24"of cover is preferred over service lines on private property and in the
ROW of in non-rock type soil.
Finding(s)•
At 1317 S Sabrina Ave,Kuna,ID,IPUC inspectors observed 6 feet of live 3/a"PE pipe installed above grade
and tied to a live electric meter by the associated tracer wire.Das-Co employees properly identified and
reported the Abnormal Operating Condition(AOC)to their supervisor and to IGC District Operations
Coordinators,yet no IGC personnel responded to the jobsite. IPUC inspectors notified IGC Compliance
Personnel.The ELM employee responsible for the locates failed to appropriately recognize and react to
AOC's.
Intermountain Gas Resnonse
On May 14, 2025, Das-Co arrived at 1317 S Sabrina Ave to extend the service stub. Upon arrival, it was
discovered that the stub was exposed and strapped to a temporary power meter.Das-Co contacted an IGC District
Operations Coordinator (DOC). Das-Co advised the DOC they were going to inspect the service stub and cut
out any signs of damage before extending the service to the meter. Due to the abnormal operating condition
(AOC)being mitigated by extending the stub, a site visit by the DOC was not needed.
Per OPS 611 — Line Locating and Marking section 1.9., In gas only districts, MDUG first- and second party
contractors should locate gas facilities within the scope of the line locate ticket for the MDUG project they are
constructing. With Das-Co performing the stub extension on behalf of IGC, ELM did not perform the line
locates for gas facilities.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company