I202611 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone]
September 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 August 6,2026(Report#I202611)
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 August 5,2026 at 7752&7740 E Bullhead St,
Nampa,ID(WO12339649&W012339598)within the Intermountain Gas Company(IGC)Nampa 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. 192,703 General
(a)No person may operate a segment of pipeline,unless it is maintained in accordance with this subpart.
(b)Each segment of pipeline that becomes unsafe must be replaced,repaired,or removed from
service.
(c)Hazardous leaks must be repaired promptly.
3. 192.513 Test requirements for In antic es
(a)Each segment of a plastic pipeline must be tested in accordance with this section.
(b)The test procedure must ensure discovery of all potentially hazardous leaks in the segment being tested.
(c)The test pressure must be at least 150%of the maximum operating pressure or 50 psi(345 kPa)gauge,
whichever is greater.However,the maximum test pressure may not be more than 2.5 times the pressure
determined under§ 192.121 at a temperature not less than the pipe temperature during the test.
4. OPS 505 Pressure Testing
GENERAL
1.1.Pressure tests shall be performed on Company pipelines and facilities prior to being placed into service;
1.5.Pipe,fittings,joints(welds,fusions,bolted flanges,or similar),and components involved in the pressure
test shall be rated to withstand the maximum test pressure and shall be subjected to pressure tests unless it
is impractical to do so.
Finding(sl•
After the pressure test,a three-foot pup was added,but not pressure tested.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC.The contractor took corrective action by suspending the
contractor employee's pressure test operator qualifications and removing the employee from performing work on
IGC jobsites.The employee has since completed retraining and has been requalified.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
�Ua,c,t�
Pat Darras
Vice President, Engineering& Operations Services
Intermountain Gas Company