I202508 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608- BOISE,IDAHO 83707- [phone]- FAX:[phone]
October 2,2025
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 August 20,2025 (Report#I202508)
Dear Mr.Brooks,
This letter is intended to address three(3)notices of probable violation stemming from a distribution records audit
conducted by the Idaho Public Utilities Commission(IPUC)on August le,2025,of Intermountain Gas Company
(IGC)pursuant of Chapter 601 Title,49,United States Code.
PROBART,F VIOLATIONS
1. 49 CFR 8192,603 General Provisions.
(a) No person may operate a segment of pipeline unless it is operated in accordance with this subpart.
(b) Each operator shall keep records necessary to administer the procedures established under
§192.605.
49 CFR M2.725 Test requirements for reinstating service lines.
(a)Each Except as provided in paragraph (b)of this section, each disconnected service line must be
tested in the same manner as a new service line,before being reinstated.
(b) Each service line temporarily disconnected from the main must be tested from the point of
disconnection to the service line valve in the same manner as a new service line, before
reconnecting. However, if provisions are made to maintain continuous service, such as by
installation of a bypass, any part of the original service line used to maintain continuous service
need not be tested.
OPS 505 Step 2.4.and Table 2
2.4.3.Distribution Pressure Mains,Services,and Facilities:
2.4.3.1.Pressure tests for mains,services, and related facilities with an MAOP of 60 psig or less are
to follow the requirements established in Table 2.Deviation from the requirements of Table 2 shall be
approved by Engineering Servies.
Table 2—Pressure Tests for Mains, Services,and Facilities with MAOP 60 psig and Less
Nominal Pipe Minimum Test Pipe Length(ft)"
Size (in)' Test Medium
Pressure <500 500-<2,000 2,000—5,000 >5,000
Less than 2" 15 minutes 30 minutes Contact Engineering
90 Services
si Air or
2'-6' p 9 Inert Gas 30 minutes 1 hour 2 hours 4 hours
Larger than 6" 1Contact Engineering Services.
`Nominal Pipe Size is the diameter of the largest component.
"Pipe Length is the sum of pipe footages tested.
Finding(s)•
IPUC Inspectors discovered that Report 450-26473 shows a 5-minute pressure test from 10:15 to 10:20 and it
should have been 15 minutes minimum.
Intermountain Gas Resnonse
Upon further review of records,it was discovered the pressure test Time On was incorrectly transcribed from
the field copy to the final copy of Report 450-26473. It was verified by the field copy that the pressure test
was conducted from 10:05-10:20. The final report has been corrected and uploaded to GIS for retention.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
2. 49 CFR 8 192.8 Protection from hazards.
(b)Each main must be installed with enough clearance from any other underground structure to allow
proper maintenance and to protect against damage that might result from proximity to other structures.
(c) In addition to meeting the requirements of paragraph (a) or b) of this section, each plastic
transmission line or main must be installed with sufficient clearance, or must be insulated, from any
source of heat so as to prevent the heat from impairing the serviceability of the pipe.
OPS 306 Section 5 Installation
5.2.2. Unless approved by Construction Services, Engineering Services, local Field Operations
Management, or System Integrity,high-pressure mains, distribution mains, and service lines shall be
installed with at least 12"of clearance from underground metallic structures,and electric and four(4")
inches from other underground structures. Approval of less clearance shall be documented on the
installation As-Built.
OPS 307 Section 5 Installation
5.16.1. PE pipelines should be installed with at least four (4") inches of clearance from other
underground utilities, (excluding electric) and structures. For electric clearance requirements refer to
Section 5.16.2.
5.16.1.1. If minimum clearance cannot be attained, the pipeline shall be protected from damage that
might result from its proximity to other structures and utilities,excluding electric.For electric clearance
requirements refer to Section 5.16.2. 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.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 or 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.
Finding(s)•
IPUC Inspectors identified multiple Form 512's that did not specify minimum distances from underground
utilities in them. Reports# 117263-425, 11711-375, 51101-371,09372-367,20607-613,04785-575,21494-
583 had no indication of proper underground clearances.
Intermountain Gas Resnonse
IGC acknowledges the findings brought forth by the IPUC. After further review, IGC was unable to locate
supporting documentation to verify the minimum distances from the underground utilities. New technology
was implemented in January 2025. Service line installation documentation is now captured electronically,with
the minimum distance from other underground utilities being a required field that cannot be left blank.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
3. 49 CFR 8 192.727 Abandonment of deactivation of facilities.
(b)Each pipeline abandoned in place must be disconnected from all sources and supplies of gas;purged
of gas; in the case of offshore pipelines, filled with water or inert materials; and sealed at the ends.
However,the pipeline need not be purged when the volume of gas is so small that there is no potential
hazard.
(c)Except for service lines, each inactive pipeline that is not being maintained under this part must be
disconnected from all sources and supplies of gas;purged of gas;in the case of offshore pipelines,filled
with water or inert materials; and sealed at the ends. However, the pipeline need not be purged when
the volume of as is so small that there is no potential hazard.
OPS 603 Pipeline Pur2in�
4.Purging Out of Service
4.2.Purging out of service may be required when existing mains and services are taken out of service
and the removal of residual natural gas is necessary.
Findin¢(s)•
No purging was annotated while reviewing samples of abandoned mains and SL(SL-512,Main-319)#741-
3288,741-3305,741-3331,679-2539. The check boxes were not checked indicating that purge requirements
were not met.
Intermountain Gas Resnonse
IGC acknowledges the findings brought forth by the IPUC. After further review, IGC was unable to locate
supporting documentation to verify purging. New technology was implemented in January 2025. Service line
and main abandonment documentation is now captured electronically,with the purge indicator being a required
field that cannot be left blank.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
k4a-t'��
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company