I202511 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
October 16,2025
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 September 02,2025 (Report#1202511)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a Public Awareness 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, VIOLATinN
1. 49 CFR 8192.605 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 yar. 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. 192,616 Public Awareness.
(d)The operator's program must specifically include provisions to educate the public,appropriate
government organizations, and persons engaged in excavation related activities on:
(1) Use of a one-call notifications system prior to excavation and other damage prevention
activities;
(2)Possible hazards associated with unintended releases from a gas pipeline facility;
(3)Physical indications that such a release may have occurred;
(4) Steps that should be taken for public safety in the event of a gas pipeline release;
and
(5)Procedures for reporting such an event.
3. OPS 616 Public Awareness Program Procedures and Forms.
3.4. Excavators
Stakeholder Audience Definition List Identification
Audience
Excavators Companies who are involved with known The excavator list will be determined
excavation .%,ith MDUG territory through SIC codes,operator
recommendations.the one call
process,third-party damages,and
contractors used by MDUG.
PADP,with the help of Freld
Operations,shall review the list
annually and make needed u dates.
16 Operated Pipeline Owners
Stakeholder Audience Definition List Identification
Audience
Operated MDUG coordinates with the operated pipeline Refer to Appendix 3 of this
pipeline owners covered under this program procedure
owners.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
4.4. Excavators
Stakeholder Baseline Messaging Supplemental Enhancement
Audience
Excavators Message: Message:
Pipeline purpose and reliability_ May include,but not limited to:
Awareness of hazards and prevention State Dig Laws
measures undertaken. Safe excavation practices.
Damage prevention awareness and one call Leak recognition and response
requirements. Additional resources(e-g ,MDUG
Potential hazards of products transported contacts,Once Call Center contacts,
How to recognize a pipeline leak. Common Ground Alliance)
Response to a pipeline leak_
How to report a leak/damage. Frequency:
Liaison with emergency officials. As needed.
Pipeline marker awareness
National pipeline mapping system (NPMS). As requested by Excavators
How to get additional information.
Delivery method:
Frequency: Virtual and/or in person meetings.
Once annually
Delivered by:
Delivery method: PADP
Direct mailer.
Note:
Delivefed by: One Call Centers periodically
Third-Party Vendor provide call before you dig outreach
to excavators via advertising and/or
onlinefrn person trainin s.
4.6. Operated Pipeline Owners
Stakeholder Baseline Messaging Supplemental Enhancement
Audience
Operated MDUG coordinates with the operated pipeline NIA
pipeline owners covered under this program and list in
owners Appendix 3 to create and maintain message
content to ensure an effective Public
Awareness Program. It is anticipated that
these companies will have message types
and content similar to MDUG for each
stakeholder group for their respective
elines.
Findina(s)•
MDU personnel stated they participate in a Quarterly Meeting with PANW, which includes
representatives from Marathon and Williams. This engagement serves as an indirect outreach effort
for promoting public awareness and damage prevention initiatives. Marathon should be included in
direct outreach efforts for public awareness and advancing damage prevention initiatives as an
excavator or operated pipeline owner.
Intermountain Gas Resnnnse
Upon further review,it was verified that Marathon and Williams are included in the Excavator Mailing List(see
Exhibit A)and receive direct outreach from IGC(see Exhibit B).Marathon and Williams are also both members of
Pipeline Association for Public Awareness(PAPA).With IGC also being member of PAPA,there is collaboration
and promotion of public awareness messaging to Marathon and Williams,as well as other operators in the state.
Additionally,IGC representatives attend monthly Utility Coordinating Council(UCC)meetings which both
Williams and Marathon attend.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company