L202601 NOPV Response

Jeff Brooks July 24, 2026
Idaho Public Utilities Commission
Pipeline Safety Division
11331 W.Chinden Blvd., Suite 201-A
Boise,Idaho 83714-1021
Subject:Notice of Probable Violation,Report#L202601 —Lower Valley Energy
Dear Mr.Brooks:
Here is the response to the probable violations identified during the Drug&Alcohol Program
Inspection of Lower Valley Energy's Idaho natural gas facilities, conducted July 14-15,2026(Report
#L202601).
Probable Violation(s):
1. Post-accident alcohol testing determinations were not documented as required(49 CFR§
199.225(a)(3)).
2. No records were available showing that all designated supervisors had completed training on
recognizing reasonable suspicion of alcohol misuse(49 CFR§ 199.241).
3. No records were available showing that all designated supervisors had completed training on
recognizing probable drug use(49 CFR§ 199.105(d)).
Response: LVE recognizes each probable violation.
1. We reviewed our post-accident alcohol testing process and found we did not have a
standardized form for documenting testing determinations.No post-accident alcohol test was
required during the review period,but we have created a Post-Accident Alcohol Testing
Documentation Form for our DER to fill out after every reportable accident,showing the time
of the incident,the employee's availability,the testing decision and the reason for it,and
when testing was attempted or completed. This will be in place within 60 days,and the
records will be kept on file per our retention schedule.
2. We found that our designated supervisors had not completed training on recognizing
reasonable suspicion of alcohol misuse. We have scheduled training for all designated
supervisors in our safety meetings mid-September, covering the physical,behavioral,speech,
and performance indicators of probable alcohol use. We will also have sign-in sheets for that
training.
3. The same gap existed for training on recognizing probable drug use.This will be covered in
the same training at our September safety meeting.
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We continue to work on making sure our Drug&Alcohol Program records are accurate and complete,
and we are adding a review step so testing documentation and training records are checked by the
DER before being filed.
Thanks for working with Lower Valley to help us be compliant with the federal code and more
effective in our responsibilities of working safely and according to best practices.LVE is confident
that we will continue to create a safe working environment and to comply with all regulations at our
facilities.Give me a call if you have questions at 307-885-6151 or my cell at 307-248-2885.Hope you
have a nice day.
Sincerely,
t �G�i
Craig Cole
Director—Gas Operations
cc:Bear Prairie