I202413 NOPV Response

Executive Offices
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
October 11,2024
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to the Notice of Probablc Violation dated September 10,2024(Report#I202413)
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 September 5,2024,on service line 413-51534 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 611 Line Locating and Marking
2.LOCATING AND MARKING
2.1.Underground facilities within the area of proposed excavation shall be located within
reasonable accuracy per the requirements of state dig law.
2.5.Facilities shall be clearly marked using one of the following methods,taking into
consideration site conditions and weather.
2.5.1.Paint
2.5.2. Stakes/Flags/Whisker Nail—Where paint is not sufficient,line marking shall be in the
form of stakes,flags,or whisker nail.
2.5.3.Offset Marks—If marks cannot be placed directly above the facility,the locator may
use offset marks and indicate the direction and dimension of the actual facility location at the
offset location.
3. Idaho Statute: 55-2205(2)
(2)Upon receipt of the notice provided for in this section,the underground facility owner or the
owner's agent shall locate and mark its locatable underground facilities with reasonable accuracy,as
defined in section 55-2202,Idaho Code,by surface-markings the location of the facilities. If there
are identified but unlocatable underground facilities,the owner of such facilities or the owner's agent
shall locate and mark the underground facilities in accordance with the best information available to
the owner of the underground facilities.The owner of the underground facility or the owner's agent
providing the information shall respond no later than(2)business days after the receipt of the notice
or before the excavation time set forth in the excavator's notice,at the option of the underground
facility owner,unless otherwise agreed in writing by the parties.Excavators shall not excavate until
all know facilities have been marked.Once marked by the owner of the underground facility,or the
owner's agent,the excavator is responsible for maintaining the markings.Unless otherwise agreed in
writing by the parties,maintained markings shall be valid for purposes of the notified excavation for
a period of no longer that four(4)consecutive weeks following the date of notification as long as it I
reasonably apparent the site conditions have not changed so substantially as to invalidate the
markings.If excavation has not commenced within three(3)weeks from the original notice to
underground facility owners through the one-number notifications service,the excavator shall
reinitiate the notice in accordance with this section.

Executive Offices
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
4. Idaho Statute: 55-2205(5)
(5)If the excavator,while performing the excavation,discovers underground facilities(whether
active or abandoned)that are not identified or were not located in accordance with subsection(2)of
this section,the excavator shall cease excavating in the vicinity of the facility and immediately notify
the owner or operator of such facilities,or the one-number notification service. The excavator shall
have the right to receive compensation from the underground facility owner for standby cost(based
on standby rates made publicly available)incurred as a result of waiting for the underground facility
owner or the owner's agent to arrive at the work site to identify the unidentified facilities and
provided that if the underground facility owner or the owner's agent supplies the locate information
required under subsection(2)of this section within eight(8)hours of the time that the excavator
notifies the underground facility owner of facilities not previously located,the excavator's
compensation for delay of the excavation project shall be limited to actual costs or two thousand
dollars($2,000),whichever is less.
5. Idaho Statute: 55-2207 (2)
(2)An excavator shall use reasonable care to avoid damaging underground facilities.An excavator
shall:
(a)Determine by hand digging,in the area twenty-four(24)inches or less from the facilities,the
precise actual location of underground facilities that have been marked;
Findim(s)•
An IPUC inspector observed a Das-Co crew hand digging a trench in the immediate vicinity of live power.
The crew had a valid dig ticket;however,no visible markings or flags were in the area.While attempting to
locate the gas service,the crew damaged a communication conduit(unknown if the communication conduit
was live).
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC.Notification was sent to Das-Co leadership to
reiterate and remind their crew foremen of the requirements of Idaho Statute 55-2205 (5), if the excavator,
whileperforming the excavation, discovers undergroundfacilities(whether active or abandoned) that are not
identified or were not located in accordance with subsection (2) of this section, the excavator shall cease
excavating in the vicinity of the facility and immediately notify the owner or operator of such facilities, or the
one-number notification service.
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