I202607 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
July 1,2026
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 May 20,2026(Report#I202607)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a construction inspection at S
Averill Lane,Meridian,ID conducted by the Idaho Public Utilities Commission(IPUC)on May 12,2026,of
Intermountain Gas Company's(IGC)Boise District pursuant of Chapter 601 Title,49,United States Code.
PROBABLE VIOLATION
Idaho Statute Title 55 Chanter 22.55-2208.DAMAGE TO UNDERGROUND FACii.iTiES--DUTIES
OF EXCAVATOR AND OWNER--REPORTING OF DATA.
(1) An excavator who,in the course of excavation,contacts or damages an underground facility shall notify the
underground facility owner and the one-number notification service. If the damage causes an emergency
condition or an actual breach of an underground facility that releases gas or hazardous liquids into the
surrounding environment,the excavator causing the damage shall also alert the appropriate local public
safety agencies by,at a minimum,calling 911,and take all appropriate steps to ensure the public safety.No
damaged underground facility may be buried until it is repaired or relocated.
(2) The owner of the underground facilities damaged shall arrange for repairs or relocation as soon as is
practical or may permit the excavator to do necessary repairs or relocation at a mutually acceptable price.
(3) Any parry responsible for damages to an underground facility shall be liable for the cost of repairs.
(4) The board shall adopt by rule a procedure for the processing of claims related to damages to underground
facilities.
(5) Underground facility owners who observe or suffer damage to an underground facility and excavators who
observe or suffer excavator downtime related to a failure of one(1)or more stakeholders to comply with
applicable damage prevention regulations shall report such information to the board in accordance with the
rules promulgated by the board.Reporting of such data does not constitute a complaint provided for in
section 55-2211,Idaho Code.
49 CFR § 192,361 Service lines:Installation
(a) Depth. Each buried service line must be installed with at least 12 inches (305 millimeters)of cover in
private property and at least 18 inches(457 millimeters)of cover in streets and roads. However,where
an underground structure prevents installation at those depths,the service line must be able to
withstand any anticipated external load.
(b) Support and backfill. Each service line must be properly supported on undisturbed or well-compacted
soil, and material used for backfill must be free of materials that could damage the pipe or its coating.
OPS 307 Polvethvlene(PE) Main and Service Construction
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 of 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.
5.16.2.2. Electric separation should be discussed with all parties involved prior to
installation.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone]
5.23.3. Service lines less than two(2")inches in diameter shall have at least 18" cover on
private property and at least 24" cover in the right-of-way(ROW).
5.23.2.1. A minimum 24"of cover is preferred over service lines on private property
and in the ROW in non-rock type soil.
49 CFR 6 192,605 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.
49 CFR 6 192,703 General
No person may operate a segment of pipeline,unless it is maintained in accordance with this subpart.
49 CFR§ 192,707 Line markers for mains and transmission lines.
(c)Pipelines above ground.Line markers must be placed and maintained along each section of a main and
transmission line that is located above ground in an area accessible to the public.
49 CFR S 192.614 Damage prevention nrggram.
(c)The damage prevention program required by paragraph(a)of this section must, at a minimum:
(1)Include the identity, on a current basis, of persons who normally engage in excavation activities in
the area in which the pipeline is located.
(2)Provides for notification of the public in the vicinity of the pipeline and actual notification of the
persons identified in paragraph(c)(1)of this section of the following as often as needed to make them
aware of the damage prevention program:
(i) The program's existence and purpose; and
(ii) How to learn the location of underground pipelines before excavation activities are begun.
(3)Provide a means of receiving and recording notification of planned excavation activities.
(4) If the operator has buried pipelines in the area of excavation activity,provide for actual notification
of persons who give notice of their intent to excavate of the type of temporary marking to be provided
and how to identify the markings.
(5) Provide for temporary marking of buried pipelines in the area of excavation activity before, as far
as practical,the activity begins.
(6) Provide as follows for inspection of pipelines that an operator has reason to believe could be
damaged by excavation activities:
(i)The inspection must be done as frequently as necessary during and after the activities to verify
the integrity of the pipeline; and
(ii) In the case of blasting, any inspection must include leakage surveys.
49 CFR § 192,1007 What are the required elements of an integrity management plan?
(b)Identify threats. The operator must consider the following categories of threats to each gas
distribution pipeline: corrosion(including atmospheric corrosion),natural forces,excavation damage,
other outside force damage,material or welds,equipment failure,incorrect operations,and other issues
that could threaten the integrity of its pipeline.An operator must consider reasonably available
information to identify existing and potential threats.Sources of data may include incident and leak
history,corrosion control records(including atmospheric corrosion records),continuing surveillance
records,patrolling records,maintenance history,and excavation damage experience.
(c)Evaluate and rank risk.An operator must evaluate the risks associated with its distribution pipeline.
In this evaluation,the operator must determine the relative importance of each threat and estimate and
rank the risks posed to its pipeline.This evaluation must consider each applicable current and potential
threat,the likelihood of failure associated with each threat,and the potential consequences of such a

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]•FAX:[phone]
failure.An operator may subdivide its pipeline into regions with similar characteristics(e.g.,
contiguous areas within a distribution pipeline consisting of mains,services and other appurtenances;
areas with common materials or environmental factors),and for which similar actions likely would be
effective in reducing risk.
OPS 1000 Distribution Integrity Management
3.2.3. Excavation Damage
Excavation damage is damage to pipeline facilities caused by earth moving or other equipment,tools,
or vehicles,including damage done by operator's personnel,contractor,or people not associated with
the operator.All buried facilities in MDUG's distribution system face the threat of being damaged by
excavation activities. Consideration is given to piping within protective casings,inside underground
structures such as basins or vaults which may be shielded or protected from excavation damage.
Excavation damage can also be due to previous unknown damage on pipelines that were not repaired
and result in corrosion.
5.1. Overview
This section describes the existing and proposed measures to address the threats and
associated risk to MDUG's distribution system as outlined in Sections 3.0: Threat Identification
and 4.0: Risk Evaluation and Ranking.
Risk management is accomplished by taking actions to reduce the likelihood of an occurrence,
by alleviating the consequences of an occurrence or both.Appropriate actions are dependent
on the group being addressed,the associated threat,whether the threat is current or potential
in the future,and the viability of the actions in managing the relevant risk factors.
5.2. Existing Programs Addressing Risk Management
This section summarizes existing plans and programs implemented by MDUG that are
currently in place to manage risks.Each established program contributes to the management
and mitigation of risk to the distribution system.Details for each program are contained in
MDUG O&M procedures and are available upon request.
5.2.1.Damage Prevention
The prevention of damage to natural gas distribution facilities by excavation is one of
the most effective ways of increasing the integrity of the gas system and improving
public safety relative to natural gas.MDUG has implemented and maintains a
Damage Prevention Program,OPS 614,that meets the following criteria:
•Meets or exceeds the requirements of§192.614—Damage Prevention Program.
•Participates in One-Call programs within service territory.
• Supports the Common Ground Alliance(CGA)efforts to reduce excavation
damage through the publication and dissemination of best practices.
Staff observed—2 feet,of live 3/a"PE piping,at a service stub,above grade,and exposed to atmosphere.There
mechanical damage near the fused-on cap. This was assumed to be due to neighboring excavation work for a
foundation. IGC QA/QC personnel were notified by staff of the as found condition.IGC advertised that a work order
would be created to fix the damaged line.Except for staff notifying IGC personnel,no notification has been made to
Intermountain Gas Company regarding the exposure,disturbance and damage of the service line. These findings
constitute a significant safety hazard and a violation of the above-mentioned codes.
These findings demonstrate fundamental deficiencies within Intermountain Gas Company's safety programs and
a failure to align with established industry best practices,including:
• IGC's Damage Prevention Program alignment with the Common Ground Alliance Best Practices for
Safe Excavation.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone]
• IGC's Distribution Integrity Management Program as it applies to identifying active threats and
applying preventative and mitigative measures which may include leveraging available tools such as
Federal OSHA complaints per 1926.20, 1926.21, 1926.651 and related provisions,and/or leveraging
the State of Idaho's Damage Complaint Process administered by the Damage Prevention Board to
support public outreach,education,and/or,when necessary,enforcement actions against bad actors.
Danage Prevention Board enforcement measures may include civil penalties of$1,000 for a Tier 1
damage and$5,000 for each subsequent Tier 1 damage.
• The ability of IGC's Safety Management System to create a positive safety culture that promotes the
collaboration of internal and external stakeholders as it relates to damage prevention.
SW W NW
3589-3601 E Vadonia
02541W(T) 61 43,32'24'N,116120'55"W t16ft ♦2778ft 02521W M ®43°32'24"N,116°20'56'W t26ft•2770ft
L' L
Intermountain Gas Response
IGC respectfully disputes that the facts establish a violation of the cited requirements. As stated in Idaho Statute Title
55 Chapter 22,55-2208,"An excavator who,in the course of excavation,contacts or damages an underground facility
shall notify the underground facility owner." IGC's records do not evidence that it received notice that its facilities
were exposed or damaged prior to the notice from the IPUC; therefore,IGC was unable to investigate or arrange for
repairs.
IGC maintains processes intended to educate excavators,contractors,and other third parties about their responsibilities
when working near underground facilities. These processes include outreach and communication regarding safe
digging practices and applicable notice obligations.Refer to OPS 614—Damage Prevention Program and OPS 616—
Public Awareness Program(see attached). However, even a robust damage prevention or public awareness program
cannot ensure compliance by independent third parties or eliminate the possibility that an excavator may fail to provide
required notice.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
�Cn�G�c-(ti0�2—
Pat Darras
Vice President, Engineering& Operations Services
Intermountain Gas Company

POLICY STATEMENT OPS 614
Cascade Natural Gas Corporation Damage Prevention Program Status: Released
Great Plains Natural Gas Co. Revision Date:October 17,2025
Intermountain Gas Company OPSMOC-1652
Montana-Dakota Utilities Co. Page 1 of 7
PURPOSE
To enhance public safety and protection of MDU Utilities Group (MDUG) gas, electric, and other owned
and operated underground facilities from excavation damages through educational outreach and
implementation of safe excavation best practices.
REFERENCES
External References:
49 CFR §192.614 Damage Prevention Program
ID 55 Chapter 22 Underground Facilities Damage Prevention
MN Chapter 216D.06 Damage to Facility
MT State Statute MCA 69-4-5 Excavations Near Underground Facilities
National Electrical Safety Code (NESC) Section 31 Rule 311
ND Century Code 49-07-01 Violation of commission order or rule - Penalty
OAR 860-024-0007 Location of Underground Facilities
OAR 952-001-0070 Operators to Mark Underground Facilities or Notify Excavator that None Exist
OSHA 29 CFR 1926.651 Excavation Requirements
PHMSA ADB-00-02
PHMSA ADB-0101
PHMSA ADB-2000-02
PHMSA ADB-99-04
RCW 19.122 Underground Facilities
SD 49-7A One-Call Notification System for Excavation Activities
W.S. 37-12 Common Ground Alliance (CGA Best Practices)
WAC 480-93-200 Reporting Requirements
Internal References:
OPS 506—Gas Loss Reporting
OPS 611 —Line Locating and Marking
OPS 616- Public Awareness Program Procedures and Forms
SF 418—Working in Excavations
Forms:
Form 23094— Public Awareness/Damage Prevention
Form 23098—Oregon Damager Letter
Form 23099—Washington Damage Letter
Form 23100— Idaho Damage Letter
Form 23101 — Montana Damager Letter
Form 23102—Wyoming Damage Letter
Form 23103— North Dakota Damage Letter
Form 23104— North Dakota Damage Letter(GP)
Form 23105—South Dakota Damage Letter
Form 23106— Minnesota Damage Letter
Form 23107— MDUG Contractor Hits Others
Form 23124— Damage Prevention Notification
TRAINING AND QUALIFICATION
Training is required for MDUG personnel. Training will be conducted by the Leak Management and
Damage Prevention (LM/DP) Department.
RECORD RETENTION
Record Retention Storage Location Responsible Party
Period

POLICY STATEMENT OPS 614
Cascade Natural Gas Corporation Damage Prevention Program Status: Released
Great Plains Natural Gas Co. Revision Date:October 17,2025
Intermountain Gas Company OPSMOC-1652
Montana-Dakota Utilities Co. Page 2 of 7
Field Operations
Damage Investigation 5 Years Electronic copy in PCAD/DOT WebApp Management, or
Reports (MDUG) Designee
Damage Investigation Field Operations
Reports (Contractor 5 Years Electronic copy in SharePoint Management, or
Locator) Designee
Damage Photographs Field Operations
(MDUG Photographs) 5 Years Electronic copy in SharePoint Management, or
Designee
Complaints Filed Against Public Awareness
Excavator 5 Years Electronic copy in SharePoint and Damage
Prevention
Damage Notification Public Awareness
Letters 5 Years Electronic copy in SharePoint and Damage
Prevention
23094 Public Public Awareness
Awareness/Damage 5 Years SharePoint and Damage
Prevention Prevention
23124 Damage Life of the SharePoint Compliance
Prevention Notification pipe.
DEFINITIONS
Refer to OPS 3 Master Glossary
SCOPE
This procedure applies to MDUG personnel.
PROCEDURE
1. GENERAL
1.1. MDUG shall participate in a qualified One-Call Notification system.
1.2. Stakeholders shall be identified and made aware of the Damage Prevention Program and
requirements per OPS 616—Public Awareness Program Procedures and Forms.
1.3. MDUG underground facilities shall be marked per the requirements of OPS 611 —Line
Locating and Marking.
1.4. If there is reason to believe that excavation could damage underground facilities, Field
Operations shall determine if monitoring an excavation is necessary per the requirements of
OPS 611 —Line Locating and Marking.
2. ADDITIONAL OUTREACH EFFORTS
2.1. LM/DP shall identify and document areas experiencing higher damage rates and high-risk
excavators within a quarterly report. Refer to OPS 616— Public Awareness Program
Procedures and Forms.
2.1.1. Field Operations can submit damage prevention concerns (e.g., high risk excavators,
areas of concern)to the LM/DP email distribution list:

POLICY STATEMENT OPS 614
Cascade Natural Gas Corporation Damage Prevention Program Status: Released
Great Plains Natural Gas Co. Revision Date:October 17,2025
Intermountain Gas Company OPSMOC-1652
Montana-Dakota Utilities Co. Page 3 of 7
MDUGLeakManagementDamagePrevention(aDwbip.com. The information submitted
shall include the following:
2.1.1.1. Address/location.
2.1.1.2. Excavator name, if applicable.
2.1.1.3. Summary or concern/incident.
2.2. In areas experiencing higher damage rates or have high risk excavators operating within the
area, LM/DP shall determine additional outreach requirements. LM/DP shall provide additional
outreach as necessary which may include, but is not limited to, additional correspondence and
local training opportunities.
2.3. Outreach efforts shall be documented in Form 23094 - Public Awareness/Damage Prevention.
3. INVESTIGATING AND REPORTING OF NEAR MISSES
3.1. MDUG personnel are responsible for reporting damage prevention near misses to Field
Operations Management as soon as possible. Examples include but are not limited to:
3.1.1. Mechanical excavation within the"tolerance zone" as outlined by the applicable state
dig law.
3.1.2. Insufficient locating practices (e.g., unmarked or incorrectly marked facilities).
3.1.3. No response from an operator listed on the locate request.
3.1.4. Excavation outside the original scope of excavation as described on the locate
request.
3.2. When damage prevention near misses are witnessed, the near miss shall be reported to Field
Operations Management as soon as possible, but no later than one (1) business day.
3.3. Field Operations Management, or designee, shall document action taken on Form 23094—
Public Awareness/Damage Prevention.
3.4. LM/DP is responsible for reviewing documented near misses and taking appropriate action.
4. DAMAGE INVESTIGATION
4.1. Field Operations shall respond to reports of damage to MDUG facilities.
4.2. Damages shall be documented on a hit line order(e.g., E-HTLN, G-HITLN) in PCAD.
4.2.1. Damage investigations should be completed prior to backfill, or disturbance, of the
accident scene.
4.3. Public awareness information shall be given and reviewed with excavator(s) involved with the
damage, including management, if on scene.
4.4. In areas that utilize contract locators, Field Operations shall notify the contracted company of
the damage.
4.4.1. Upon request, contract locators shall conduct an investigation of excavation damages
to underground facilities.
4.4.2. Field Operations shall review contract locator investigation and compare it to the
PCAD information within the DOT WebApp.
4.5. In areas that do not utilize contract locators, Field Operations shall perform a damage
investigation.
4.5.1. Hit Kits shall be utilized during the investigation. Refer to Damage Investigation Hit
Kit Training.
4.5.1.1. If line locates are not present, the damage marker of the Hit Kit shall be
used to document location of damage.
4.5.2. Photographs shall be taken and include:
4.5.2.1. The damaged facilities.
4.5.2.2. A 360' view of the site where the damage occurred.
4.5.2.3. Remaining locate marks, or lack thereof.

POLICY STATEMENT OPS 614
Cascade Natural Gas Corporation Damage Prevention Program Status: Released
Great Plains Natural Gas Co. Revision Date:October 17,2025
Intermountain Gas Company OPSMOC-1652
Montana-Dakota Utilities Co. Page 4 of 7
4.6. If a damage results in gas loss, refer to OPS 506—Gas Loss Reporting.
4.7. MDUG personnel, or contractors working on behalf of MDUG, damage another company's
facilities shall complete Form 23107 - MDUG Contractor Hits Others.
4.7.1. Contractor shall submit the form to the project owner.
4.7.2. The project owner shall upload the information to SharePoint no later than the tenth
day of the month that follows the end of the previous quarter(e.g., quarter end is
March, due date is April 10).
5. REPORTING
5.1. Field Operations shall upload damage information to SharePoint
5.2. Field Operations Management, or designee, is responsible for reviewing damages in the DOT
WebApp within 10 business days of when the damage occurred.
5.2.1. In Washington, Field Operations Management, or designee, shall complete Form
23124— Damage Prevention Notification when an employee or contractor of the
company observes or becomes aware of either of the following:
5.2.1.1. If an excavator digs within 35ft of transmission without line locates, or,
5.2.1.2. If it is discovered that locate marks have been intentionally damaged or
removed.
5.2.2. A copy of the completed form shall be:
5.2.2.1. Submitted to MDUGCompliance(@mdu.com, and,
5.2.2.2. Uploaded to SharePoint.
5.2.3. The Compliance department shall submit the form to the Washington Utilities
Commission (WUTC).
5.3. In Wyoming, Field Operations Management, or designee, shall file a report of underground
damages with the Wyoming One-Call Notification Center within 72 hours of the initial
notification of the damage.
5.4. LM/DP shall review and report excavation damages to MDUG underground facilities via the
Common Ground Alliance (CGA) Damage Information Reporting Tool (DIRT).
5.4.1. In Washington, the DIRT report shall be filed utilizing Washington Utilities and
Transportation Commission Virtual Private DIRT within 45 days of when the damage
occurred.
5.4.2. For all other states DIRT reports shall be filed quarterly.
5.4.2.1. In Oregon it shall be filed utilizing Oregon 811 Virtual Private DIRT.
5.4.2.2. In Idaho, Montana, Wyoming, North Dakota, South Dakota, and Minnesota,
it shall be filed utilizing CGA DIRT North America.
5.5. Field Operations shall bill at fault excavators who cause damage to MDUG facilities for costs
incurred for the damage repair in accordance with applicable State Laws. Charges may
include, but are not limited to, gas loss, personnel, and equipment.
5.5.1. In Washington, excavators can be billed three times the actual costs incurred (e.g.,
treble billing)when an excavator fails to notify known facility operators or a One-Call
Center.
5.5.2. Exceptions may apply upon approval of Field Operations Management for damages
caused by excavator(s)where State excavation laws were followed (e.g., no
evidence of negligence) and the damage did not result in gas loss (e.g., nick,
damage to wrap, broken wire, etc.).
5.6. LM/DP shall consult with Field Operations Management to determine if a complaint should be
filed against the excavator(s) responsible for damage.
5.6.1. Complaints can only be filed for excavation damages that are reviewed and have
supporting documentation.

POLICY STATEMENT OPS 614
Cascade Natural Gas Corporation Damage Prevention Program Status: Released
Great Plains Natural Gas Co. Revision Date:October 17,2025
Intermountain Gas Company OPSMOC-1652
Montana-Dakota Utilities Co. Page 5 of 7
5.6.2. For complaints filed to and against MDUG, LM/DP shall coordinate with Field
Operations Management to obtain the information.
5.7. LM/DP shall file the complaint.
5.8. LM/DP shall send a damage notification letter, as required by applicable state dig law, to
excavators that damage MDUG underground facilities.
5.9. A copy of the complaint and damage notification letter shall be uploaded to SharePoint.
5.10. LM/DP shall produce a quarterly report identifying high risk areas of excavation and related
causes.
5.10.1. LM/DP shall review the quarterly report with Field Operations.

POLICY STATEMENT OPS 614
Cascade Natural Gas Corporation Damage Prevention Program Status: Released
Great Plains Natural Gas Co. Revision Date:October 17,2025
Intermountain Gas Company OPSMOC-1652
Montana-Dakota Utilities Co. Page 6 of 7
ADMINISTRATION
The Vice President Distribution Engineering, Operations Services, & Compliance of the MDU Utilities
Group is responsible for establishing this policy.Administration of this policy is the responsibility of the
Director, Compliance, Process Improvement, & Procurement.
Reviewed: Approved: o ",
Director, Compliance. Process Improvement, & Vice President DistributivrrEngineenng,
Procurement Operations Services, & Compliance
Date: 6-9-25 Date: 6-9-25
REVISIONS
Major Revision Summary MOC Date
Initial procedure. OPSMOC-321 4/29/2022
2023 and 2024 Annual Procedure Review: Updated Public
Awareness and Damage Prevention (PADP)to Leak
Management and Damage Prevention (LM/DP)throughout.
Updated Scope. Updated forms section. Damage letters are OPSMOC-2130 6/13/2025
only required in WA and MT. Retire form 23095 - DIRT Field
Form. Remove section 1.2. Added section 1.3., 4.2.1.,
4.5.1.1., 5.9., &5.9.1. Revised section 3. Separated Damage
Investigation and Reporting into separate sections.
Minor Revision Summary MOC Date
Added OPS 506 reference to section 4.7 and removed N/A 6/3/2022
section 4.7.1. &4.7.2.
Added section 4.14, revised section 4.14.1., 4.14.2., & 15.1. OPSMOC-1614 10/18/2022
Removed mail confirmation receipts.
Removed 4.14.2. In Idaho, Oregon, Wyoming, North Dakota,
South Dakota, and Minnesota, PADP shall send a damage OPSMOC-1885 5/5/2023
notification letter to at fault excavators that damage MDUG
underground facilities via mail or email.
WAC 480-93-200 (9)- OPS 614 Damage Prevention
Program: Added new section -5.2.1. In Washington, Field OPSMOC-1652 10/17/2025
Operations Management, or designee, shall complete Form
23124— Damage Prevention Notification when an employee

POLICY STATEMENT OPS 614
Cascade Natural Gas Corporation Damage Prevention Program Status: Released
Great Plains Natural Gas Co. Revision Date:October 17,2025
Intermountain Gas Company OPSMOC-1652
Montana-Dakota Utilities Co. Page 7 of 7
or contractor of the company observes or becomes aware of
either of the following: 5.2.1.1. If an excavator digs within 35ft
of transmission without line locates; or, 5.2.1.2. If it
discovered that locate marks have been intentionally
damaged or removed. 5.2.2. A copy of the completed form
shall be: 5.2.2.1. Submitted to
[e-mail]; and, 5.2.2.2. Uploaded to
SharePoint. 5.2.3. The Compliance department shall submit
the form to the WUTC.

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 1 of 16
PURPOSE
To enhance public safety, environmental protection, and property protection through continuous public
awareness (PA)outreach and education efforts throughout the MDU Utilities Group (MDUG)service
territory.
REFERENCES
External References:
49 CFR §192.614 Damage Prevention Program
49 CFR Part §192.615(c)
49 CFR Part §192.616
API RP 1162 (1st Edition)
API RP 1185
PHMSA ADB-99-04
Internal References:
OPS 611 —Line Locating and Marking
OPS 614— Damage Prevention Program
Forms:
23013 Implementation Effectiveness Audit
TRAINING AND QUALIFICATION
Initial training will be conducted by the PA Department. Training is required for MDUG personnel
responsible for tasks related to the PA Program.
RECORD RETENTION
Record Retention Storage Location Responsible Party
Period
Form 23013- 5 years SharePoint Public Awareness
Implementation/Effectiveness Audit
4-Year Effectiveness Evaluation 5 years SharePoint Public Awareness
Survey
Language Study 5 years SharePoint Public Awareness
Material Pre-Testing 5 years SharePoint Public Awareness
Mailing list used for each direct Public Awareness
mailing, materials distributed, date 5 years SharePoint
records, and U.S. Postal Service
3602 forms orequivalent
DEFINITIONS
Refer to OPS 3 Master Glossary
SCOPE
This procedure applies to natural gas and propane distribution and transmission pipelines and utility
facilities owned and/or operated by MDUG.
PROCEDURE
1. PROGRAM OBJECTIVES
1.1. Increase the awareness of the identified stakeholder audiences to the presence of pipelines in
their community.
1.2. Educate stakeholders that pipelines are a proven safe mode of transportation.

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 2 of 16
1.3. Increase stakeholder knowledge of the measures taken to prevent pipeline accidents,
accidents caused by third-party damage, and right-of-way encroachment.
1.4. Increase stakeholder understanding of how to respond to pipeline emergencies.

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 3 of 16
2. ROLES AND RESPONSIBILITIES
Title Responsibilities
Vice President, Provide financial support to develop and implement the PA Program in
Distribution accordance with API RP 1162.
Engineering,
Operations Services, Engage in and support the PA outreach efforts.
and Compliance
Vice President, Field
Operations and
Customer Experience
Chief Human
Resources,
Administration, and
Safety Officer
Director, Compliance,
Process Improvement,
and Procurement
Field Operations Serve as primary liaison for Emergency Responders and Public Officials in
Management their respective service territory, which includes delivering MDUG developed
information.
Document PA outreach activities/contacts within their service territory.
Attend/participate in PA activities, events, and trainings, as appropriate.
Actively attend and participate in local Utility Coordinating Councils (UCC)
and Local Emergency Planning Committees LEPC , if active.
PA Deptartment Implement, deliver, and pursue ongoing improvement of the PA program.
Identify stakeholders that will receive information.
Approve the materials to be used, the method of delivery, and the frequency
in which the messages will be delivered.
Identify and select the external resources that will be used to satisfy the
requirements of the program.
Coordinate internal and external resources to achieve the required tasks and
program objectives.
Ensure Company employees are provided training, communication materials
and, as appropriate, opportunities for direct involvement with the community.
Coordinate the evaluation of the program through annual program reviews,
and effectiveness evaluations.
Document PA outreach and filing as specified in the Record Retention
section.

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 4 of 16
3. STAKEHOLDER AUDIENCES AND OUTREACH EFFORTS
3.1. Affected Public:
Stakeholder Audience Definition List Identification
Audience
Residential, commercial, and industrial
End-User customers to whom MDUG currently Determined through the monthly billing
Customers distributes natural gas, propane, process.
and/or electricity.
Residences, businesses, public The list will be developed using customer
schools, hospitals, and places of lists, land records, and geographical
congregation within the buffer zone information systems (GIS) of areas where gas
Targeted along transmission pipelines. is provided. This list will include customers
Public
The buffer zone shall be no less than and non-customers.
660 feet on either side of transmission The list shall be updated every two (2)years.
pipelines.
While no list will be generated, the general
public messaging will occur in every county
within MDUG territory.
Residences, businesses, schools, and
General places of congregation where MDUG A combination of industry websites,
Public distributes natural gas, propane, and newspaper ads or articles, radio ads,
electricity. television ads, billboards, online banner ads,
social media, and/or written material. Pipeline
markers are also utilized to convey
information.
3.2. Emergency Officials:
Stakeholder Audience Definition List Identification
Audience
Local, city, county, state, or regional officials,
agencies, and organizations with emergency
response and/or public safety jurisdiction in
the areas of the pipeline. The Emergency Responders List will
be determined through Standard
Examples: Industrial Classifications (SIC) codes
Emergency • Fire/Police/Sheriff Departments and operator recommendations.
responders • County/State Emergency Management
Agencies PA, with the help of Field
• Military/Tribal authorities, etc. Operations, will review regularly and
Local Emergency Planning Commission make updates as needed.
(LEPC).
• 911 Emergency Call Centers/County
Emergency Dispatch Centers.

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 5 of 16
3.3. Public Officials:
Stakeholder Audience Definition List Identification
Audience
City, county, state, or federal officials having
land use or road jurisdiction with oversight of
decisions related to pipeline safety within
MDUG territory.
The public officials list will be
Examples: determined through SIC codes and
• Planning and zoning boards. operator recommendations.
Public officials • Land planning/community development.
• Licensing/permitting departments. PA, with the help of Field
• City and county managers. Operations, will review regularly and
• Elected Officials. make updates as needed.
• Public utility boards.
• Bureau of Land Management.
• US National Forest Service.
• Local governing councils.
3.4. Excavators:
Stakeholder Audience Definition List Identification
Audience
The excavator list will be determined
through SIC codes, operator
recommendations, the One-Call
process, third-party damages, and
Excavators Companies who are involved with known contractors used by MDUG.
excavation within the MDUG service territory.
PA, with the help of Damage
Prevention and Field Operations, will
review the list regularly and make
updates as needed.
3.5. Other Utilities:
Stakeholder Audience Definition List Identification
Audience
Companies that own and operate other
utilities in the vicinity of natural gas pipelines. Will be determined through SIC
codes and operator
MDUG also maintains active membership in recommendations.
Other utilities pipeline associations across our service
territories. This provides a platform for regular PA, with the help of Field
engagement with other pipeline operators, Operations, will review the list
facilitating the exchange of best practices, regularly and make updates as
coordinating outreach efforts and mutual needed.
awareness of infrastructure and operations.

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 6 of 16
3.6. Operated Pipeline Owners:
Stakeholder Audience Definition List Identification
Audience
Operated MDUG incorporates operated pipeline owners Refer to AAopendix 2 of this
pipeline owners within this program. procedure.
4. BASELINE OUTREACH EFFORTS
4.1. Baseline Messaging Overview:
The following core messages shall be delivered to all stakeholder audiences, tailored as
appropriate.
• Pipeline purpose and reliability.
• Awareness of hazards and prevention measures.
• Damage prevention awareness and One-Call requirements.
• Potential hazards of transported products.
• Leak recognition and response.
• Reporting procedures for leaks/damages
• Liaison with emergency officials.
• Emergency contacts and response plans (where applicable).
• Pipeline marker awareness and National Pipeline Mapping System (NPMS).
• Customer-owned piping (where applicable).
• How to obtain additional information.

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 7 of 16
4.2. Affected Public:
Stakeholder Baseline Messaging Supplemental Enhancement
Audience
Frequency:
Twice per calendar year.
Electric facility safety
End-user Delivery method: awareness is included where
customers Email/direct mail, bill Inserts. MDUG provides electric
service.
Delivered by:
Customer Communications.
Frequency:
Once per calendar year.
Targeted Delivery method:
public Direct mailer or email.
Delivered by:
Third-party vendor and/or Company.
Message:
School districts within MDUG
territory will be provided
Frequency: information on natural gas
Once per calendar year. pipeline safety program.
Delivery methods: Frequency:
General public Media, Company websites, social media, Every other year.
community events, geofencing.
Delivery method:
Delivered by: Direct mail, geofencing, and/or
Third-party vendor and/or Company email.
Delivered by:
Third-party vendor and/or
Company.

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 8 of 16
4.3. Emergency Responders:
Stakeholder Baseline Messaging Supplemental Enhancement
Audience
Message:
Baseline from 4.1. plus: Message:
Priority to Protect Life. Email communications to educate
emergency response officials on
Frequency: relevant topics.
Twice per calendar year.
Emergency Frequency:
Responders Delivery method: Once per calendar year.
Direct mailer, email newsletter.
Delivery method:
Delivered by: Email.
Third-party vendor and Field Operations.
Delivered by:
Note: Liaison is provided as outlined in Third-party vendor.
Section 6 of this procedure.
4.4. Public Officials:
Stakeholder Baseline Messaging Supplemental Enhancement
Audience
Frequency: Message:
Once every three (3)years. Webinars will be hosted to educate
public officials on relevant topics.
Delivery method: Frequency:
Public officials Direct mailer. Periodically.
Delivered by: Delivery method:
Third-party vendor. Online webinar.
Note: Liaison is provided as outlined in Delivered by:
Section 6 of this procedure. Third-party vendor or Company.

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 9 of 16
4.5. Excavators:
Stakeholder Baseline Messaging Supplemental Enhancement
Audience
Message:
May include, but not limited to:
• State Dig Laws.
• Safe excavation practices.
• Leak recognition and response.
Frequency: Frequency:
Once per calendar year. As needed or as requested.
Excavators Delivery method: Delivery method:
Direct mailer. Virtual and/or in-person meetings.
Delivered by: Delivered by:
Third-party vendor. PA.
Note: One-Call Centers periodically
provide "Call before you dig"
outreach to excavators via
advertising and/or online/in-person
trainin s.
4.6. Other Utilities:
Stakeholder Baseline Messaging Supplemental Enhancement
Audience
Message:
Baseline from 4.1. plus:
Collaboration and communication
Local training opportunities
Frequency:
Once per calendar year.
Other Utilities Delivery method: N/A
Email or direct mailer
Delivered by:
PA.
Note: Liaison is provided as outlined in Section
6 of this procedure.

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 10 of 16
4.7. Operated Pipeline Owners:
Stakeholder Baseline Messaging Supplemental
Audience Enhancement
MDUG coordinates with the operated pipeline
owners covered under this program and listed in
Operated pipeline Appendix 2 to ensure an effective PA Program. It is N/A
owners anticipated that these companies will have message
types and content similar to MDUG for each
stakeholder group for their respective pipelines.
5. OUTREACH IMPLEMENTATION SCHEDULE
5.1. The PA Department shall maintain the PA Implementation Schedule.
5.1.1. The schedule shall include the planned outreach messaging and target delivery
dates for the upcoming year. Refer to Section 4 of this procedure for messaging
requirements.
6. LIAISON RESPONSIBILITIES
6.1. PA will work with Field Operations to establish and maintain a liaison with Emergency
Responders, Public Officials, and Other Utilities to:
6.1.1. Learn the responsibilities and resources of emergency response organizations that
may respond to a gas emergency and familiarize organizations with the operator's
ability in responding to a gas emergency.
6.1.2. Identify the types of gas pipeline emergencies that warrant notification to appropriate
organizations.
6.1.3. Plan how the operator and other organizations can engage in mutual assistance to
minimize hazards to life or property.
6.2. The Emergency Response Capabilities Database will be used to document and communicate
the availability of emergency response resources and capabilities.
6.3. PipeVision provides emergency response agencies detailed information about pipelines in
their jurisdiction. The application also includes a mechanism for agencies to collaborate with
pipeline operators by submitting information regarding populated areas (identified sites) near
pipelines.
6.4. Facilitation of this liaison will include baseline messaging requirements outlined in Section 4 of
this procedure and participation in one of the following:
6.4.1. Face to face meetings - Proactively schedule time to meet with key emergency
officials in the response area. MDUG may sponsor joint meetings where multiple
Emergency Responders participate in a meeting hosted by multiple pipeline
companies.
6.4.2. Pipeline emergency response training - Invite local Emergency Responders to
participate in training hosted by MDUG or participate in training organized by the
emergency response organization. MDUG may sponsor joint trainings where multiple
Emergency Responders participate in a training hosted by multiple pipeline
companies.
6.4.3. Involve Emergency Responders in mock drills/exercises - Involve local response
organizations in company-sponsored drills/exercises; or participate in drills/exercises
coordinated by local emergency response organizations.
6.4.4. Participation in local emergency response organizations - Involvement in a local
emergency planning committee (LEPC).

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 11 of 16
6.5. Outreach efforts and/or trainings shall be documented per the requirements of Section 7 of
this procedure.
7. PROGRAM EVALUATIONS AND CONTINUOUS IMPROVEMENT
7.1. PA is responsible for completing the following:
7.1.1. Implementation/Effectiveness Audit:
7.1.1.1. Completed as needed to evaluate the implementation, outreach, and
effectiveness of the program.
7.1.2. Supplemental Considerations Review:
7.1.2.1. Completed as needed to evaluate effectiveness of the program and
determine if additional outreach enhancements are needed.
7.1.3. Effectiveness Evaluation Survey:
7.1.3.1. A survey shall be completed at least every four(4) calendar years to
determine if current efforts are sufficient for each stakeholder.
7.1.3.2. The survey shall be completed using one (1)of the following methods: an
operator-designed and conducted survey, a pre-designed survey
administered by a third-party or industry association, or a survey conducted
by a trade association, segmented by operator, state, or other relevant
criteria to ensure results are applicable to each operator.
7.1.3.3. The survey can be conducted through voluntary means using mail-in, web-
based surveys, phone surveys, or through direct contact surveys, in which
a preset number of responses will be achieved.
7.1.3.4. The number of surveys returned, or performed, shall be tracked and
documented on the final report.
7.1.3.5. The survey shall assess:
• Outreach—Percentage of each intended audience reach with desired
message.
• Understandability of message content—Percentage of the stakeholder
audience that understood and retained the key information in the
messages.
• Changes in behavior— Percentage of perceived changes in
stakeholder behavior based upon pipeline safety outreach,
understandability, and retention.
• Whether the program achieved the intended objectives as stated based
upon the findings from the survey.
8. ADDITIONAL OUTREACH EFFORTS
8.1. Additional PA outreach efforts shall be documented on Form 23094 - Public
Awareness/Damage Prevention.
8.2. When in-person interactions take place with any stakeholder, PA and/or Damage Prevention
information should be distributed or made available.
9. MATERIAL REVIEW
9.1. When significant changes are made to materials utilized in the PA Program, PA should
arrange a material pre-test before new material is widely distributed to a stakeholder group.
9.1.1. Materials should be pre-tested for clarity, understandability, and retainability.
9.1.2. Material pre-tests can be accomplished by utilizing focus groups, surveys, or in-
person meetings with targeted stakeholders.

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 12 of 16
10. LANGUAGE ASSESSMENT
10.1. PA shall perform an assessment of prevailing languages at least once every five (5)years.
This assessment ensures that PA information is communicated to prevailing language groups
as appropriately determined by demographics.
10.2. Results from the most recent U.S Census data or other available information will be utilized to
determine if the program language needs to be translated.
10.3. Program messaging shall be in English and in other languages spoken by more than 5% of
citizens that are members of a single language minority, and more than 50% limited English
language proficiency within the MDUG territory.
10.4. Materials provided to Public School Districts, Emergency Response Agencies, Public Officials,
and the One-Call Centers are provided in English.
10.5. Government proceedings and response activities are conducted in English.
11. ELECTRIC OUTREACH EFFORTS
Stakeholders Baseline Messaging Frequency Delivery Method
End-user
customers:
Residential, Overhead line safety.
commercial, and Storm safety. Twice per calendar Bill inserts.
industrial Tree trimming safety. year.
customers to Damage prevention.
whom MDUG
distributes
electricity.
General public
Residences, A combination of industry
businesses, Overhead line safety. websites, newspaper ads or
schools, and Storm safety. Once per calendar articles, radio ads, television
places of Tree trimming safety. year. ads, billboards, online
congregation Damage prevention. banner ads, social media
where MDUG accounts, or written material.
distributes
electricity.

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 13 of 16
APPENDIX 1: EXTERNAL SUPPORT RESOURCES
Vendor . ..
Pipeline Association for Baseline Mailer:
Public Awareness (PAPA) Excavators, Public Officials, http://www.pipelineawareness.org/
and Emergency Responders
Pipeline Association of the Training:
Northwest(PANW) Public Officials and https://Panw.pipelineawareness.org/
Emergency Responders
North Dakota Pipeline Training:
Association (NDPA) Public Officials and https://ndpa.pipelineawareness.org/
Emergency Responders
South Dakota Pipeline Training:
Association (SDPA) Public Officials and https://sdpa.pipelineawareness.org/
Emergency Responders
Wyoming Pipeline Training:
Association (WYPA) Public Officials, Excavators, https://wvpa.pipelineawareness.org/
and Emergency Responders
Minnesota Community Training:
Awareness Emergency Public Officials, Excavators, https://mncaer.com
Response MNCAER and Emergency Responders
Montana Liquid & Gas Training:
Pipeline Association Public Officials, Excavators, https://mlgpa.pipelineawareness.org
MLGPA and Emergency Responders
Supplemental Trainings:
PARADIGM Excavators, Public Officials, https://www.pdigm.com
and Emergency Responders
Targeted Public
Logistical Marketing Transmission Mailer: www.logisticalmarketing.com
Address List, printing,
mailing
Local IQ Online Banner Advertising, https://localig.com/
eofencin , commercials
Effectiveness Evaluation
Culver Company Survey http://www.culverco.com/
Supplement Mailer:
School Program K-6
Common Ground Alliance 811 Outreach Materials https://commongroundalliance.com/
CGA Best Practices
Dig Safely 811 Outreach Materials https://www.digsafe.com
Dig Safe Education

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 14 of 16
APPENDIX 2: OPERATED PIPELINE OWNERS
Blue Flint Ethanol
2841 3rd Street SW
Underwood, ND 58576
City of Portal, ND
25 Railway Ave
P.O. Box 37
Portal, ND 58772
Dakota Spirit Aq energy, LLC
2831 3rd St SW
Underwood, ND 58576
ProGold/Cargill
18049 County Road 8 East
Wahpeton, ND 58075
Red River Energy, LLC
P.O. Box 17
Rosholt, SD 57260
Tongue River Gas
P.O. Box 713
Dayton, Wyoming 82836
Peter Clark
307-655-2283
[e-mail]

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 15 of 16
APPENDIX 3: STATEMENT OF SUPPORT
EXECUTIVE AND SENIOR MANAGEMENT STATE OF SUPPORT
Our company fully supports the policies, goals. and objectives of API RP 1 162 and has created
this Public Awareness Program to fully comply•,vith those recommended practices. As an organization,
%ve are committed to providing safe, reliable energy. and educating the people living and%vorking near our
facilities regarding the things they can do to contribute to their personal safety. In addition, ,ve ,vill
educate the community on,.vhat we are doing as a company to ensure the safety of the communites%ve
serve. We are also committed to providing resources, including funding. necessary for implementing and
managing the program. I have shared , ith our employees my expectation of their commitment of fulfilling
our public awareness responsibilities as described in this document.
i
Eric Martuscellli
Vice President, Field Operations and Customer Experience
Z G)a4' !,aQ-
Pat Darras
Vice President Distribution Engineering, Operations Services, & Compliance
u n
Anne Jones
Chief Human Resources. Administration. & Safety Officer

POLICY STATEMENT OPS 616
Cascade Natural Gas Corporation Public Awareness Program Status: Released
Great Plains Natural Gas Co. Revision Date: March 31,2026
Intermountain Gas Company OPSMOC-2539
Montana-Dakota Utilities Co. Page 16 of 16
ADMINISTRATION
The Vice President Distribution Engineering, Operations Services, & Compliance of the MDU Utilities
Group is responsible for establishing this policy.Administration of this policy is the responsibility of the
Director, Compliance, Process Improvement, & Procurement.
Reviewed: Approved:
Director, Compliance,�ro�esslmprovement, & Vice President Distribuf8ii-�Engineer-ing,
Procurement Operations Services, & Compliance
Date: 3-31-26 Date: 3-31-26
REVISIONS
Major Revision Summary MOC Date
Initial procedure. OPSMOC-321 4/29/2022
2023 and 2024 Annual Procedure Review: Updated names
and contact information in appendices to align with
reorganization. State of support updated with new signatures. OPSMOC-2128 6/13/2025
Removed on-call as a stakeholder as that is not a
requirement of API RP 1162.
2025 Annual Review: Updated names and contact
information in appendices to align with reorganization. State
of support will be updated before implementation with new OPSMOC-2539 3/31/2026
signatures. Removed on-call as a stakeholder as that is not a
requirement of API RP 1162.
Minor Revision Summary MOC Date