I202610 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
August 28,2026
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 July 22,2026(Report#I202610)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a construction inspection
conducted by the Idaho Public Utilities Commission(IPUC)on July 20,2026,at 7321 Powell Place,in Eagle,ID
(WO12678625)within the Intermountain Gas Company(IGC)Boise District pursuant of Chapter 601 Title,49,
United States Code.
PROBABLE ViOLATiON
1. 49 CFR 8192.605 Procedural Manual for Operations.Maintenance. and Emergencies
(a) 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 5192,614 Damage Prevention Program
(a)Except as provided in paragraphs(d)and€of this section,each operator of a buried pipeline
must carry out,in accordance with this section,a written program to prevent damage to that pipeline
from excavation activities.For the purposes of this section,the term`excavation activities"includes
excavation,blasting,boring,tunneling,backfilling,the removal of aboveground structures by either
explosive or mechanical means,and other earthmoving operations.
(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.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone]
3. 55-2205, PERMIT COMPLIANCE—NOTICE OF EXCAVATION—RESPONSE TO NOTICF,—
COMPFNSATION FOR FAILURE TO COMPLY—EXEMPTIONS.
(1)Before commencing excavation,the excavator shall:
(a)Comply with other applicable law or permit requirements of any public agency issuing permits;
(b)Pre-mark on-site the path of excavation with white paint or,as the circumstances require,other
reasonable means that will set out clearly the path of excavation.An excavator need not pre-mark as
required in this subsection if-
(i)The underground facility owner or its agent can determine the location of the proposed excavation
by street address or lot and block by referring to a locate ticket; or
(ii)The excavator and underground facility owner have had a meeting prior to the beginning of the
proposed excavation at the excavation site for the exchange of information required under this
subsection.
(c)Provide notice of the scheduled commencement of excavation to all underground facility owners
through a one-number notification service.If no one-number notification service is available,notice
shall be provided individually to those owners of underground facilities known to have or suspected
of having underground facilities within the area of proposed excavation.The notice shall be
communicated by the excavator to the one-number notification service or,if no one-number
notification service is available,to the owners of underground facilities not less than two(2)business
days nor more than ten(10)business days before the scheduled date for commencement of
excavation,unless otherwise agreed in writing by the parties.
(2)Upon receipt of the notice provided for in this section,the underground facility owner or the
owner's agent shall locate and mark its locatable underground facilities with reasonable accuracy,as
defined in section 55-2202,Idaho Code,by surface marking the location of the facilities.If there are
identified but unlocatable underground facilities,the owner of such facilities or the owner's agent
shall locate and mark the underground facilities in accordance with the best information available to
the owner of the underground facilities. The owner of the underground facility or the owner's agent
providing the information shall respond no later than two(2)business days after the receipt of the
notice or before the excavation time set forth in the excavator's notice,at the option of the
underground facility owner,unless otherwise agreed in writing by the parties.Excavators shall not
excavate until all known facilities have been marked.
4. IGC—Working in Excavations—SF 418
1.4.Employees and contractors shall not begin excavation until the valid start date on the locate ticket,
and/or all utility companies that are listed on the locate ticket have responded prior to beginning
excavation.
5. IGC-OPS 611 Line Locating and Markinu
2.LOCATING AND MARKING
2.18.1 All One-Call ticket documentation shall be accessible to MDUG personnel.
Finding(s)•
A contractor representing IGC excavated for service line installations with no hard copy or readily
available electronic copy of valid dig ticket.
As per the IGC Response to NOPV I202308(dated November 9t'',2023),"Effective December 11
2023,contractor and company employees will be required to have a hard copy,or a readily available
electronic copy,of the valid line locate ticket on the jobsite."IPUC staff accepted this response on
November 13',2023.
Intermountain Gas Response
Upon further review, IGC verified that the contractor was performing work under a valid locate ticket (No.
2026292962).
IGC acknowledges that a copy of the locate ticket was not available onsite,which does not align with IGC's response
to NOPV I202308. Based on the review, this appears to be an isolated issue resulting from a single work order not

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone]
being reviewed to confirm that a copy of the locate ticket was available before the work was assigned to the crew.The
Das-Co General Superintendent sent a reminder to personnel responsible for performing the review, reiterating the
requirement to have a hard copy or a readily accessible electronic copy of the locate ticket on the jobsite.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President, Engineering& Operations Services
Intermountain Gas Company