I202515 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
December 15,2025
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 November 5,2025 (Report#1202515)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a construction inspection at
9640 Ustick Rd in Nampa,ID conducted by the Idaho Public Utilities Commission(IPUC)on November 3,2025,of
Intermountain Gas Company(IGC)pursuant of Chapter 601 Title,49,United States Code.
PROBABLE VIOLATION
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 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. 49 CFR 5192,805 Oualification Program.
(b)Ensure through evaluation that individuals performing covered tasks are qualified;
3. 192,803 Definitions.
Qualified means that an individual has been evaluated and can:
(a)Perform assigned covered tasks; and
(b)Recognize and react to abnormal operating conditions.
4. OPS 407—F,xothermic Welding Connections to Steel Pi eln fines
TRAINING AND QUALIFICATION
Safety and Technical Training,with the help of System Integrity, is responsible for the development
of training required for personnel who perform exothermic welding. Only qualified personnel shall
make wire connections to steel pipelines by exothermic welding.
Finding(s)•
IPUC staff witnessed a contractor at 9640 Ustick Rd in Nampa install exothermic welds (cad-weld)without
valid operator qualifications(OQ).
Intermountain (was Response
IGC acknowledges the findings brought forth by the IPUC. The employee intended to perform two cad-weld
connections.Following completion of the first cad-weld,it was discovered that the employee's operator
qualification(OQ)was expired. The employee immediately notified their supervisor.The supervisor,who holds the
required qualifications,authorized the second cad-weld under span of control and conducted an inspection of the
initial cad-weld.
While the OQ was expired,the task was completed by an experienced employee who has since requalified.
Furthermore,Das-Co currently has a directive in place that mandates crew foremen to verify each crew member's

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
OQs at the start of every shift.In this case,the foreman failed to adhere to the directive.In response,Das-Co
leadership issued an immediate reminder emphasizing the requirement to verify OQs prior to commencement of
work each day and held an in-person meeting to reinforce compliance with this directive and mitigate recurrence.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President, Engineering& Operations Services
Intermountain Gas Company