I202419 LOC Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
November 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 November 12,2024(Report#I202419)
Dear Mr.Brooks,
This letter is intended to address one(1)area of concern stemming from a construction inspection conducted by the
Idaho Public Utilities Commission(IPUC)on November 06,2024,at 16342 Grave Ave,Caldwell,Idaho of
Intermountain Gas Company(IGC).
AREA OF CONCERN
I. 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.
49 CFR§ 192,503 General Reauirements
(a) General. Each joint used to tie in a test segment of pipeline is excepted from the specific test
requirements of this subpart,but each non-welded joint must be leak tested at not less than its
operating pressure.
OPS 505 Pressure Testing
1. General
1.1. Pressure tests shall be performed on MDU Utilities Group(MDUG)pipelines and facilities
prior to being placed into service.
1.5.Pipe,fittings,joints(welds,fusions,bolted flanges,or similar),and components involved in
the pressure test must be rated to withstand the maximum test pressure and shall be
subjected to pressure test unless it is impractical to do so.
Finding(s)•
IPUC staff observed a contractor for IGC attempt to complete the final mechanical fitting(stab-type)to the
house service line prior to pressure test when IPUC intervened.The contractor acknowledged the missed
step and then cut the EFV and stab fittings from the service line and proceeded to pressure test without
including all fittings.
Intermountain Gas Resgonse
IGC acknowledges the findings brought forth by the IPUC. Operator qualifications(OQs)were suspended for
the contractor employee and the foreman. OQs will remain suspended until retrained and requalified.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering& Operations Services
Intermountain Gas Company