I202613 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 August 06,2026(Report#I202613)
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 6,2026 at 1146 N Leatherwood Way in Star,
ID(WO12609726)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. 49 CFR 5192,614 Damage Prevention Program
(a) Except as provided in paragraphs(d)and(e)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 purpose 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 the underground pipelines before excavation activities
are begun.
(3) Provide a means of receiving and recording notifications 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.
3. 55-2205. PERMIT COMPLIANCE —NOTICE OF EXCAVATION—RESPONSE TO NOTICE—
COMPENSATION FOR FAIL.URF, 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 Premark as required in this
subsection i£

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone]
(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
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 no 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 of 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.
S. IGC-OPS 611 Line Locating and Markin¢
2.LOCATING AND MARKING
2.18.1 All One-Call ticket documentation shall be accessible to MDUG personnel.
Finding(s):
An IGC employee excavated for a service line installation with no hard copy or readily available electronic
copy of a valid dig ticket.
As per the IGC Response to NOPV I202308 (dated November 9th,2023),"Effective December 1st,
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 13th,2023.
Intermountain Gas Response
Upon further review, IGC verified that the employee was performing work under a valid locate ticket (No.
2026320357).
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 poor cellular connection
prohibiting access to an electronic copy of the locate.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President, Engineering& Operations Services
Intermountain Gas Company