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HomeMy WebLinkAbout20220301_tb1.pdfDECISION MEMORANDUM 1 I:\Legal\GAS\INT-G-22-01 Urzua\Memos\INTG2201_dec_tb.docx DECISION MEMORANDUM TO: COMMISSIONER ANDERSON COMMISSIONER CHATBURN COMMISSIONER HAMMOND COMMISSION SECRETARY COMMISSION STAFF LEGAL FROM: TAYLOR R. BROOKS DEPUTY ATTORNEY GENERAL DATE: MARCH 1, 2022 SUBJECT: IN THE MATTER OF COMMISSION STAFF’S FORMAL COMPLAINT CONCERNING INTERMOUNTAIN GAS COMPANY’S PRACTICES OF ALLOWING UNQUALIFED OPERATORS TO PERFORM LIVE METER EXCHANGES; CASE NO. INT-G-22-01 On April 23, 2021, Jesse Urzua (“Urzua”) contacted the Idaho Public Utilities Commission expressing concern that he was an unqualified operator who was performing live residential meter exchanges as directed by the Company’s Lead Service Technician, Jason Wixom. Through investigation and self-reporting by the Company, the Idaho Public Utility Commission Staff (“Staff”) determined that the Company has violated pipeline safety requirements by discovering that 1,847 work orders were issued and performed by unqualified operators. Staff requests the Commission accept its formal complaint (attached) and issue a summons to Intermountain Gas Company (“Company”). Staff additionally requests this matter be processed through modified procedure. STAFF RECOMMENDATION Staff recommends the Commission issue a summons to the Company and require it to respond to the allegations contained in Staff’s Complaint within twenty-one (21) days. COMMISSION DECISION 1. Does the Commission wish to accept Staff’s formal Complaint as written? 2. Does the Commission wish to issue a summons to the Company requiring it to respond to Staff’s formal Complaint within twenty-one (21) days? ______________________________ Taylor R. Brooks Deputy Attorney General FORMAL COMPLAINT - 1 TAYLOR R. BROOKS, ISB # 11542 DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 taylor.brooks@puc.idaho.gov Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION OWING UNQUALIFED INT-G-22-01 COMPLAINT COMES NOW, the Staff of the Idaho Public Utilities Commission, Pipeline Safety Division (“Staff”), by and through its attorney of record, Taylor R. Brooks, Deputy Attorney General, to file this Formal Complaint concerning Intermountain Gas Company’s (“Company”) practices of allowing unqualified operators to perform live residential meter exchanges. Staff and the Company have engaged in informal discussions concerning the matters set forth in this Formal Complaint. These discussions with the Company have been productive and the Company has been responsive and transparent regarding the issues set forth below. However, due to the scope and seriousness of matters addressed herein Staff believes resolution of the issues must be addressed through a formal proceeding. Staff requests that the Idaho Public Utilities Commission (“Commission”) enter an Order, consistent with its authority under Idaho Code §§ 61-501, 61-515 and 61-701 et seq. to require the Company to pay a penalty to be determined based on the facts of this case which could FORMAL COMPLAINT - 2 be reduced or suspended dependent on the Company producing and filing a plan with the Commission that provides how the Company will ensure that all personnel performing live meter exchanges are operator qualified; that the Company file quarterly reports of its safety briefings and operator qualification trainings verifying each employee that has been trained and operator qualified; and that all employees of the Company are qualified and fully trained to perform the work asked of them. JURISDICTION 1. The Company is a gas corporation and a public utility, and the Commission has jurisdiction over it and the issues in this case under Title 61, Idaho Code. See Idaho Code §§ 61-117, 61-129, 61-501, 61-503, and 61-515. 2. When a complaint is filed concerning the safety and adequacy of a public utility’s service the Commission has the power and authority to investigate the matter and require the “public utility to maintain and operate its line, plant, system, equipment, apparatus and premises in such manner as to promote and safeguard the health and safety of its employees, customers and the public[.]” See Idaho Code § 61-515; see also Idaho Code § 61-302. 3. During the time period in which these safety incidents occurred, the Commission followed the Idaho Administrative Procedures Act (“IDAPA”), specifically, section 31.11.01 which governed safety and accident reporting rules for regulated utilities. a. Pursuant to Idaho Code § 61-515 on June 30, 2021, the Commission issued Order No. 35095, in Case No. GNR-U-21-01 adopting the Commission’s Safety and Accident Report Rules for Utilities Regulated by the Idaho Public Utilities Commission. See Order No. 35095 at 2. Rule 201 of these Rules incorporates by reference Part 260.9, Title 18 and Parts 191, 192, 193, 195, and 199, Title 49 of the Code of Federal Regulations concerning pipeline safety. 4. Idaho Code § 61-701 et. seq. provides the Commission with the authority to enforce “the constitution and statutes of this state affecting public utilities, the enforcement of which is not specifically vested in some other office or tribunal” and to seek the imposition of penalties for violations of these authorities if deemed necessary. 5. All acts complained of herein took place in the State of Idaho. FORMAL COMPLAINT - 3 BACKGROUND 6. Paragraphs 1 through 5 above are incorporated herein by this reference as though fully set forth in this paragraph. 7. On April 23, 2021, Jesse Urzua, (“Urzua”) a former employee of the Company, contacted Darrin Ulmer, Pipeline Program Manager at the Idaho Public Utilities Commission (“Commission”) and expressed concern that he was an unqualified operator who was performing live residential meter exchanges as directed by the Company’s Lead Service Technician, Jason Wixom. Affidavit of Maria Barratt-Riley at 2, ¶ 7. 8. On April 26, 2021, Mr. Ulmer spoke with Urzua and asked for further documentation and a formal statement regarding his concerns. Id. at ¶ 8. 9. On April 28, 2021, Urzua sent Mr. Ulmer his official statement about completing residential meter exchanges as well as supporting documentation. Id. at ¶ 9. 10. On May 7, 2021, Maria Barratt-Riley, Executive Director and Head of Pipeline Safety at the Commission, contacted Patrick Darras—the Vice President of Operations at the parent corporation of the Company (“MDU”)—and notified him of Urzua’s complaint. Id. at ¶ 10. Ms. Barratt-Riley requested a written response within twenty-one (21) days from the Company. Id. 11. On May 28, 2021, the Company responded to Ms. Barratt-Riley and informed the PUC that “it was possible” that Urzua had performed 97 live residential meter exchanges while not being fully qualified and/or “operating with another qualified individual under span of control.” Id. at ¶ 11. 12. On July 29, 2021, Ms. Barratt-Riley replied to the Company and requested additional information regarding the Company’s response. Id. at ¶ 12. 13. On August 31, 2021, the Company replied to Ms. Barratt-Riley and stated that through its own investigation, Urzua was not operator-qualified for 124 of the 912 work orders he completed during his employment with the Company. Id. at ¶ 13. Additionally, the Company reported that from August 3, 2020, through June 23, 2021, 15,940 work orders were completed by Apprentice Service Technicians—1,847 of which were not completed by operator-qualified technicians. Id. 14. The Company has put these 1,847 work orders in review with its Safety Management and Quality Assurance Teams. Id. This review was scheduled to be completed by FORMAL COMPLAINT - 4 September 24, 2021. Id. The Company titled this review “OPS 800,” which is a program for implementing training that prevents technicians from performing work they are unqualified for. Id. 15. On October 21, 2021, the Company notified Ms. Barratt-Riley that its’ safety recommendation team (“ACE”) had completed its’ initial review process and included several further recommendations that required the Company to delay implementing OPS 800. Id. at ¶ 14. 16. The revised deadline is now June 30, 2022. However, the Company has met with its Field Operations Directors and Managers to ensure that management is verifying employee Operator Qualification statuses and complying with all current safety recommendations. Id. VIOLATIONS Violations of Idaho Code § 61-302, Maintenance of Adequate Service 17. Paragraphs 1 through 16 above are incorporated herein by this reference as though fully set forth in this paragraph. 18. The Company failed to maintain service of gas meters in a manner that promotes the safety, health, and comfort of its customer by allowing unqualified personnel to perform at least 1,847 live gas meter exchanges has failed to maintain service of gas meters in a manner that promotes the safety, health, and comfort of its customers. See Idaho Code § 61-302 19. As a direct and proximate result of the Company’s failures it could be subject to a penalty of up to $2,000.00 for each of the 1,847 violations of Idaho Code § 61-302 for each day that the violation persisted up to a maximum amount of $200,000.00. See Idaho Code § 61-712A. Violations of IDAPA 31.11.01 20. Paragraphs 1 through 19 above are incorporated by reference herein as though fully set forth in this paragraph. 21. The Commission’s Safety and Accident Reporting Rules for Utilities Regulated by the Idaho Public Utilities Commission were in effect when the Company allowed unqualified personnel to perform at least 1,847 live gas meter exchanges. See IDAPA 31.11.01 (2020 version).1 IDAPA 31.11.01 adopted by reference all federal pipeline safety regulations.2 Federal pipeline safety regulations are contained in Title 49 of the Code of Federal Regulations. The Company failed to comply with federal pipeline safety regulations, and thereby failed to comply with IDAPA 31.11.01 1 The Commission adopted the rules promulgated in IDAPA 31.11.01 by Special Order in 2021. See Order No. 35095. 2 See Rule 201. (https://adminrules.idaho.gov/rules/2018%20Archive/31/311101.pdf). FORMAL COMPLAINT - 5 by allowing personnel to perform 1,847 work orders while failing to have the proper qualifications to do so. 22. The Company violated federal pipeline safety regulations, by allowing 1,847 work orders—which includes live gas meter exchanges—to be completed by unqualified operators. See 49 C.F.R. § 192.805 et seq. 23. The Company has violated federal pipeline safety regulations by failing to follow and obey its own written procedures known as OPS 800 concerning live meter exchanges— namely, that each individual performing live meter exchanges be fully qualified. See 49 C.F.R. § 192.605 et seq. 24. The Company failed to timely report the existence of possible safety conditions that could have caused an imminent hazard and a 20% or more reduction in operating pressure or shutdown of a pipeline. See 49 C.F.R. § 191.23(a)(9). 25. As a direct and proximate result of the Company’s failures it could be subject to a penalty of up to $2,000.00 for each of the 1,847 violations for each and every day that the violation persisted without correction, up to a maximum amount of $200,000.00. See Idaho Code § 61-712A. PRAYER FOR RELIEF WHEREFORE, the Plaintiffs pray for entry of a Commission order: 1. Imposing penalties on the Company pursuant to Idaho Code § 61-712A for its violations of Commission’s authorities and rules in the amount of $200,000.00; or 2. Require the Company to submit its ACE review plan that clearly defines ownership and delineation of roles and responsibilities related to operator qualifications to the Commission and submit quarterly reports that demonstrate the Company is following the ACE review safety recommendations. 3. For such other and further relief as the Court may deem just and proper in these premises. DATED this ____ day of February, 2022. _______________________________ Taylor R. Brooks Deputy Attorney General I:\Legal\GAS\INT-G-22-01 Urzua\Memos\Complaint\INTG2201_complaint_tb_final.docx TAYLOR R. BROOKS, ISB # 11542 DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION Po BOX83720 BOISE, IDAHO 83720-0074 (208)334-0320tay lor. brooks@puc.idaho.gov Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF INTERMOUNTAIN GAS ) COMPANY'S INFORMAL COMPLAINT ) REGARDING UNQUALIFIED OPERA TORS ) PERFORMING LIVE RESIDENTIAL METER ) EXCHANGES ) ) ) ) ___________________) STA TE OF IDAHO ) ss. County of Ada ) CASE NO. INT-G-22-01 AFFIDAVIT OF MARIA BARRATT­RILEY IN SUPPORT OF THE IDAHO PUBLIC UTILITY COMMISSION STAFF'S PETITION TO CREATE A FORMAL COMPLAINT I, Maria Barratt-Riley, being first duly sworn under oath, depose and state as follows: 1.I have personal knowledge of the facts stated in this affidavit. 2.The information contained herein is true and correct to the best of my knowledge. 3.I am the Executive Director and I am responsible for the Pipeline Program at the Idaho Public Utilities Commission. 4.In my position over the Pipeline Safety Program, along with Former Pipeline Program Manager, Darrin Ulmer, we investigated Jesse Urzua's ("Complainant") Complaint expressing concern that as a new employee for Intermountain Gas Company, ("the AFFIDAVIT OF MARIA BARRATT-RILEY Company") he was an unqualified operator performing live residential meter exchanges for the Company. 5.Mr. Ulmer forwarded all e-mails from the Complainant in the above-described matter to me. Therefore, I have personal knowledge that the e-mails and communications from the Complainant attached to this Affidavit are true and correct. 6.Mr. Ulmer resigned from the Idaho Public Utilities Commission in September of 2021. 7.Attached as Exhibit 1 is a true and correct copy of the Complainant's initial e-mail to Mr. Ulmer on April 23, 2021 which was forwarded to me on April 23, 2021. 8.Attached as Exhibit 2 is a true and correct copy of Mr. Ulmer's correspondence to me in which Mr. Ulmer stated that he asked the Complainant for additional documentation regarding his Complaint which was forwarded to me on April 26, 2021. 9.Attached as Exhibit 3 is a true and correct copy of all documentation from the Complainant within Exhibit 2 which was forwarded to me on April 26, 2021, and May 3, 2021. 10.On May 11, 2021, I contacted Patrick Darras-the Vice President of Engineering and Operations for the Company-and provided evidence of correspondence from the Complainant and requested a formal written response within 21 days. Attached as Exhibit 4 is a true and correct copy of this e-mail and formal request attachment. 11.On May 28, 2021, I received a written response from the Company. Attached as Exhibit 5 is a true and correct copy of this response and all attachments. 12.On August 2, 2021, I e-mailed Mr. Darras in reply to the Company's response letter and requested additional information. Attached as Exhibit 6 is a true and correct copy of this reply letter. 13.On August 31, 2021, I received the Company's written reply with all additional information that I had requested on August 2nd• Attached as Exhibit 7 are true and correct copies of appropriate attachments contained in the company's written reply. 14.On October 21, 2021, I received a follow-up letter from the Company detailing several remedies and recommendations on how to comply with pipeline safety and how to ensure that the problem described from the Complainant does not occur again. Attached as Exhibit 8 is a true and correct copy of this letter. AFFIDAVIT OF MARIA BARRATT-RlLEY 2 � Dated this � day of February 2022. Maria Barratt-Riley Executive Director Idaho Public Utilities Commission SUBSCRIBED AND SWORN to before me this 2 s-fl1 day of February 2022. I :\Legal\GASIINT-G-22--0 I Urzua\Memos\Complaint\lNTG220 I_ affidavit _tb.docx AFFIDAVIT OF MARIA BARRATT-RILEY 3 Notary Public for Idaho Residing at: Ada County, Idaho Commission expires: March 15, 2025 Exhibit I (Attached) From: Sent: To: Subject: Attachments: FYI Get Outlook for iOS Darrin Ulmer Friday, April 23, 2021 10:07 AM Bruce Perkins; Jeff Brooks; Maria Barratt-Riley Fwd: UNQUALIFIED OPERATOR PERFORMING RESIDENTIAL METER EXCHANGES Screenshot (25).png; Screenshot (26).png; Screenshot (27).png; Screenshot (30).png; Screenshot (32).png; Screens hot (33).png; Screens hot (29).png; Screens hot (31 ).png; Screens hot (28).png; Screens hot (35).png; Screenshot (36).png; Screenshot (34).png; Screenshot (38).png; Screenshot (39).png; Screenshot (40).png; Screens hot (43).png; Screens hot (44).png; Screens hot (41 ).png; Screens hot (45).png; Screens hot (37).png; Screenshot (46).png; Screenshot (47).png; Screenshot (48).png; Screenshot (42).png; Screenshot (49).png From: Jesse Urzua <jesseurzua@gmail.com> Sent: Friday, April 23, 2021 9:50:54 AM To: Darrin Ulmer <Darrin.Ulmer@puc.idaho.gov> Subject: UNQUALIFIED OPERATOR PERFORMING RESIDENTIAL METER EXCHANGES Dear Mr. Ulmer: I have enclosed documentation in support of my assertion that I was an unqualified operator that was performing live residential meter exchanges as directed by Lead Service Technician Jason Wixom on behalf of my employer, lntermountain Gas Co., in Pocatello. 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Office Review' Review Reason Meter/ERT Information -iumbe1 Meter Status 3329 ·sent>ERT Number 76451407 "ype here to search Number of Dials Temp Comoensated Delivery Pressure 1 , r Press Compensated Pressure UOM Pf11JNDS 0nve Rate Index Read 10 ERT Read 10 (ffi ome -lntermountain Gas X D mobileservices.mdu.com/PCAD X I::) New tab X l + 0 A Not secure mobileservices.mdu.com/PCAD/Cl,entln:erface.aspx?ReportNu mber= MOUG-20201202-20938I1191 &ReportName= GAS_M ETER ·Summary > Job 10 i MDUG-20201202-20938 ess 1 FA 10 I 3182540483 Se1v1ce Code \G-EXCH -------------· -Attachments· o n Taken npleteo Meter Action CGI CGI Reason Material or Billable Work? ng Meter/ERT Information 'lumber 3873 mber 883 Correct Mtr No7 'E<: Correct ERT No. 7 ional Order Information 'ork Performed Bypassable Meter Set 'nts Corrected Mt, No. Di�tennect Location Onve Rate 11 Corrected ERT No. Delivery Pressure Orrve Rate �ound 10.25 POUNDS Pipe Condition Odorant Percept,ble Company Relight? '.)( t_ock Uo-Found V \7.8 KI HOT CHANGE ·NO SERVICE INTERRUPTION. VERIFIED FLOI� OCK-UP. SOAPED METER SET ·NO LEAKS. CYCLED 3CF Otiice Review> ilev1ew Reason IED ERT/INDEX OPP. PAINTED METER SET. LEFT DH. Meter/ERT Information Meter Status 4070 ·sent?ERT Number 76449005 'ype here to search NumlJer of Dials Temo Compensareo Delivery Pressure Press Compensated '\ Pressure UOM POUNDS Onve Rate Index Read '6088 ERT Read ,6088 Lock Up-Left Index Read )0 ERT Read lo @) Punter friendly fQ ome -lntermountain Gas X � mobileservices.mdu.com/PCAD X (::I New tab XI+ 0 Not secure ; mobileservices.mdu.com/PCAO/Clientlnterface.aspx?ReportNumber= MOUG-20201202-20941 J 1191 &ReportName=GAS_METER c ompll,Jnfl' c nn�trurt1C,n f< s Mnllll(' \ lp P, /\I J · Summary ' Job ID I MDUG-20201202-20941 FA ID j 5082834951 Service Code LI G_-_E_X_C_H ___ � ess I n Taken npleted Merer Action ng Meter/ERT Information 'lumber Correct Mtr No 1 3877 Correct ERT No.7 889 ional Order Information 'ork Performed Bypassable Meter Set ------ Attachments· o CGI CGI Reason Material or Billable Work1 Corrected Mtr No. Disconnect Location Drive Rate Index Read I 1 6613 Corrected ERT No 0el1ve1y Pressure Drive Rate Founa ERT Reaa I 0.25 POUNDS i6613 Pipe Condition Odorant Perceptible Company Relight? Lock Up-Found Lock Up-Left �------r------- ,()(" ✓i::::--'JC' V I 7.8 j 1.8 KI CHANGE •NO SERVICE INTERRUPTION. VERIFIED FLOW AND UP. SOAPED METER SET ·NO LEAKS. CYCLED 2CF ·VERIFIED NDEX OPP. PAINTED METER SET. LEFT OH. Office Review' Rev,ewer Review Reason Meter/ERT Information 'lumber Meter Status 4071 ·sent7 ERT Numbe• :76449549 "ype here to search Number of Dials Temp Compensated Delivery Pressure Press Compensated Pressure UOM p,,,y�os- orive Rate Index Read IQ ERT Read ,o \ffi Pnnter fnendl� ome -lntermountain Gas X C:) mobileservices.mdu.com/PCAD X (:} New tab XI+ a A Not secure , mobileservices.mdu.com/PCAD/Clientlnterface.aspx?ReportNumber=MDUG-20201202-20919I1191 &ReportName=GAS_METER ·Summary l Job ID I MDUG-20201202-20919 FA ID \ 6936146106 Service Code \�G_-_E_X_C_H ___ � imer 1 ess -f-----------------------Attachments· o n Taken npleted Meter Action CGI CGI Reason Material or Billable Work7 ng Meter/ERT Information Correct Mtr No7 0713 mber Correct ERT No. 7 298 ional Order Information 'ork Performed Bypassable Meter Set ------ �nts Corrected Mtr No. Disconnect Location Dnve Rate 12 Corrected ERT Nu. Deilverv Pressure Drive Rate Found I 0.25 POUNDS Pipe Cond1t1on Odorant Perceptible Company Relight' ,o, '� . E::' 'JC l<Kk Up-Found 11.a ki hot change -no service interruption. verified flow ock-up. soaped meter set -no leaks. cycled 2cf -011,._e Rev1ewi Review Reason ied ert/index opp. painted meter set. Meter/ERT Information \lumbe1 Meter Status 3324 ·sent'ERT Number 76451545 -ype here to search Reviewer Number of Dials Delivery Pressurr Pressure UOM Temp Compensated Press Compensated Drive Rate Index Read 3566 ERT Read ,3566 Lock Up-Left 11.a index Read !O ERT Read fc; \HJ Printer friendly...fQ. ome -lntermountain Gas X � Tech Activity X (=' Newtab XI+ 0 A Not secure m obi leservices.md u .com/PCA D /T ec hAct1vity .as px • • ( nrnpli,mc <' ( on�tr11< t1<Hl H '> MntHI<' I Ip I'• /It, \CTIVITY I POCATELLO v I Tech I URZUAJ V ------------------ 0 0 0 0 0 0 '0201130-20685 '6511282859 I G-EXCH '0201130-20726. 9317668120 G-EXCH '0201202-20919, 6936146106 'G-EXCH '0201202-20938 3182540483 G-EXCH '0201202-20941 5082834951 G-EXCH 0 0 0 0 I Export To CSV tus Start Origin Type Address TY 00:16 CADREMOVE READY IAILABLE 08:02 CADAGENT SHOP D 08:28 CADAGENT READY TY 08:46 r ..... ,.,, ............... ·ype here to search 0 0 Day ! 12/3/2020 0 5 0 220 I I Query I 1 POCATELLO I CLEARED I 12-02-2020 10:21 US/Mountain POCATELLO I CLEARED I 12-02-2020 11 :J6 US/Mountain I l POCATELLO I CLEARED ! 12-02-2020 14:25 US/Mountain POCATELLO I CLEARED i 12-02-2020 15:49 US/Mountam POCA ELLO I CLEARED : 12-02-2020 15:57 US/Mountam I 45 I ,15 4s I 45 45 I GAS METER 68 1 IGC QmY 35 I GAS METERIGC QNLY to 361 GAS METEB IGC QNLY r I GAS METER ., l IGC QNLY 71 GAS METERIGC QNLY (a) ome -lntermountain Gas X � mobileservices.mdu.com/PCAD X (::l New tab XI+ 0 A Not secure mobileservices.mdu.com/PCAC/Clientlnterface.aspx?ReportNumber= MDUG-20201130-20685I1191 &ReportName=GAS_METER · Summary FA ID I 6511282859 Service Code I G-EXCH ess 1 Attachments· o n Taken noleted Meter Action CGI CGI Reason Material or Billable Work7 ng Meter/ERT Information -Jurnber Correct Mtr No 7 Corrected Mtr No. Disconnect Location Drive Rate 9075 11 Correct ERT No.7 Corrected ERl No. Del1ve1v Pressure Drive Rate Found 029 I 0.25 POUNDS ional Order Information 'ork Performed Bypassable Meter Ser Pipe Condition Odorant Perceptible Company Relight? Lock Up-Found ------ ed customer's permission to proceed with change out. ki hot change -no service interruption. verified flow ock up. soaped meter set -no leaks. cycled 3 cf and ied ert/index opp. Meter/ERT Information -Jurnber Meter Status 3322 ·sent'ERT Number 76451663 ·ype here to search Number of Dials Temp Compensated Office Revrew7 Delivery Pressure Press Compensated \J 17.8 Rev,ew RF.ason Pressure UOM POUNDS Drive Rate Index Read 1 3852 ERT Reaa 3852 Lock Up-Left ,7.8 index Read 10 ERT Read 10 fc, (ffi Pnnter frieodlyJQJ ome -lntermountaln Gas X � mobileservices.mdu.com/PCAD X � New tab XI+ Not secure mobileservices.mdu.com/PCAD/Cl1e11t111terface.aspx?ReportNumber= MDUG-20201130-20726I1191 &ReportName=GAS_METER ( omplt.1nc<' ( on�tructlon H '> Mo1J11,, tip I 'l i\l > ·Summary 1 Job 10 I MDUG-20201130-20726 FA ID 19317668120 Serv,ce Code I G-EXCH �------ Attachments· o n Taken noleted Meter Action CGI CGI Reason Material or Billable Work' ng Meter/ERT Information -.iumber Correct Mtr No7 2583 mber Correct ERT No.> 310 ional Order Information ·ork Performed Bypassable Meter Set------ ,nts Corrected Mtr No Disconnect Location Dnve Rate 11 Corrected ERT No. Oel1verv Pressure Dnve Rate Found I 0.25 POUNDS Pipe Condition Odoram Perc�ptible Comoany Relight? Lock Up-Found ki hot change -no interruption of service. verified and lock-up. soaped meter set -no leaks. cycled lcf -ied ert/index opp. painted meter set. :)ffice Review' Review Reason Meter/ERT Information Merer Status 3329 ·sent'ERT Number 176451407 Number of Dials Delivery Pressure Temp Compensated Press Compensated Pressure UOM Pt:UND5 Onve Rate Index Read 14909 ERT Read 14909 Lock Up-left ,7.4 Index Read ERT Read 10 \ffi Ponter friendly 1w "ype here to search ' J. ... � prmo 11 N r I •1 �'·.-t □ . I -L. ...... n : I r..J IJII ""' .-l _l 2 -'' J < ,1/', ome -lntermountain Gas X D mobileservices.mdu.com/PCAD X (::l New tab XI+ 0 .A Not secure mobileservices.mdu.com/PCAD/Clientlnterface.aspx?ReportNumber= MDUG-20201202-2091911191 &ReportName:=GAS_METER • • ( omplianc<' C.on�trurt1on f( s M,illilf' tip I', i\l> ·Summary l Job ID I MOUG-20201202-20919 FA ID I 6936146106 Service Code l�G_-_E_X_C_H ___ � ess Attachments· o n Taken noleted Meter Action CGI CGI Reason Material or Billable Work1 ng Meter/ERT Information 'lumber Correct Mtr No? 0713 'E::, mber Correct ERT No.7 298 /t:'� ional Order Information 'ork Performed Bypassable Meter Set Corrected Mtr No. Disc0nnect Location Dnve Rate 12 Corrected ERT No. Delivery Pressure Drive Rate Found I 0.25 POUNDS Pipe Condition Odorant Perceptible Comoany Relight? Loci< Up-Found V \1.8 ki hot change -no service interruption. verified flow ock-up. soaped meter set -no leaks. cycled 2cf -Office Rev1ew1 Review Reason ied ert/index opp. painted meter set. Meter/ERT Information Meter Status 3324 ERT Number 76451545 'ype here to search Number of Dials Temp Compensated Delivery Pressure ) ,._ r Press Compensated '\I Pressure UOM ;::,OUNOS Drive Rate Index Read 3566 ERT Read i3566 Lock Up-Left 11.8 Index Read 10 ERT Read lo Printer frienc:Hy...fQJ ome -lntermountain Gas X � mobileservices.mdu.com/PCAD X I=:) New tab XI+ 0 A Not secure ' mobileservices.mdu.com/PCAD/Clientlnterface.aspx?ReportNumber= MDUG-20201202-20919ji 191 &ReportName=GAS_METER • • C ompll,mn• C <H1\t111ct1011 H ', M,•llli<' I Ip Pt J\I > · Summary l Job ID I MDUG-20201202-20919 FA ID I 6936146106 Service Code I G-EXCH------- ess Attachments· o n Taken npleted Meter Action CGI CGI Reason Material or Billable Work7 ng Meter/ERT Information \lumber Correct Mtr No 7 0713 rnbe1 Correct ERT No.7 298 ional Order Information 'ark Performed Bypassable Meter Set ------ Corrected Mtr No. Disconnect Location Drive Rate 12 Corrected ERT No. Oehverv Pressure Drive Rate Found I 0.25 POUNDS Pipe Condition Odorant Percep:1IJ1e Comoany Relight? Lock Up-Found V 17.8 ki hot change -no service interruption. verified flow ock-up. soaped meter set -no leaks. cycled 2cf -Ofiice Rev1ew7 Review Reason ied ert/index opp. painted meter set. Meter/ERT Information \lumber Meter Status 3324 ·sent>ERT Number :76451545 ·ype here to search Reviewer NumlJer of Dials Delivery Pressure Temp Comoensated Press Compensated Pressure UOM Dl)IJND� Drive Rate Index Read 3566 ERT Redd :3566 Lock lJo-Lefi ,7.8 Index Read 10 ERT Read 10 I ;I -<o \ffi Printer friendly to ome -lntermountain Gas X � mobileservices.mdu.com/PCAD X l=J New tab XI+ A Not secure I mobileservices.mdu.com/PCAD/Clientlnterface.aspx?ReportNumber=MDUG-20201202-20938I1191 &ReportName=GAS_METER • • l omph.ince <.on�trurt1011 I ( � Mnhlif' lJp Pl All ·Summary J Job ID i MDUG-20201202-20938 FA ID I 3182540483 Service Code I G-EXCH ess n Taken Attachments· o noleted Meter Action CGI CGI Reason Material or Billable Work' ng Meter/ERT Information 'lumber Correct Mtr No> Corrected Mtr No. Di�connect Location Dnve Rate 3873 ,�::;: 11 mbe1 Correct ERT No.' Corrected ERT No. Delivery Pressure D11ve Rate Found 883 i::c_ I 0.25 POUNDS ional Order Information ·ork Performed Bypassable Meter Ser Pipe Condition Odorant Perceptible Company Relight> \j(' Lock Up-Found ------ KI HOT CHANGE -NO SERVICE INTERRUPTION. VERIFIED FLOW OCK-UP. SOAPED METER SET -NO LEAKS. CYCLED 3CF IED ERT/INDEX OPP. PAINTED METER SET. LEFT OH. Meter/ERT Information Slumber Meter Status 4070 ·sent> ERT Number 76449005 ·ype here to search Number of Dials Temo Compensated Office Review> Reviewer Delivery Pressure ). Press Compensated '., i7.8 Review Reason Pressure UOM P()l.lNOS Dnve Rate Index Read 6088 ERT Read 16088 lock Up-Left lnaex Read '0 ERT Read 10 \(I) Prmter tneQdly.JQ ome -lntermountain Gas X C'J mobileservices.mdu.com/PCAD X 1::1 New tab XI+ 0 A Not secure ' mobileservices.mdu.com/PCAD/Clientlnterface.aspx?ReportNumber= MDUG-20201202-20941 I 1191 &ReportName=GAS_METER ' ( ompl!,in.-C' ( on,t111ct1on f ( "I Moh1IC' I Jp 1•1 Al, ·Summary l Job ID I MDUG-20201202-20941 FA ID j 5082834951 Serv,ce Code I G-EXCH �-----� imer I ess At.tam� n Taken npleted Meter Action "'X1�..,:,,Nr;::-· '!:-E'::, CGI CGI Reason Material or Billable Work7 ng Meter/ERT Information 'lumber Conect Mtr No7 3877 '2� mbe1 Correct ERT No.? 889 ✓cs ional Order Information 'ork Performed Bypassable Meter Set Corrected Mtr No. Disconnect Location Dnve Rate Index Read 16613 Corrected ERT No. Delivery Pressure Dnve Rate Found ERT Read I 0.25 POUNDS 16613 Pipe Condition Odorant Perceptible Company RelighP Lock Up-Found Lock Up-Lett -------------�-------;om ·1Es '¥ � , 1.8 ! 1.a ints KI CHANGE -NO SERVICE INTERRUPTION. VERIFIED FLOW AND UP. SOAPED METER SET -NO LEAKS. CYCLED 2CF -VERIFIED NDEX OPP. PAINTED METER SET. LEFT DH. Meter/ERT Information 'lumber Meter Status 4071 ·sent?ERT Number i76449549 ·ype here to search Number of Dials Temo Compensated r- Office Rev1ew7 Reviewer Delivery Pressure 'l 2 l Press Compensated Review Reason Pressure UOM POUNDS Drive Rate :! Index Read lo ERT Read 0 {&') Printer friendly 1l2r ome -lntermountain Gas X I CJ Tech Activity X Energy Worldnet X + O https://www.energyworldnet.com/PROI IN ET /MyRequirements Task Code Task Name V 192-0101 Characteristics and Hazards of Natural Gas (1:3) V 192-Corrosion Monitoring (Atmospheric, External, Internal) (1:3)0401.01 V 192-Coating Maintenance (1:3)0402.01 V 192-Locate, Install, Protect Customer Meters and Regulators -Rasldentlal/Small 0701.01 Commercial (1:3) V 192-Locate, Install, Protect Customer Meters and Regulators-Large Comm/Ind 0701.02 (1:3) V 192-Customer Regulating, Limiting and Relief Devices -Residential/Small Comm 0702.01 (1:3) V 192-Customer Regulatlng, limiting and Relief Devices -Large Comm/lndust 0702.02 (1:3) V 192-Locating Plpellne (1:3)0801.01 V 192-0802 Protection During Dlstubrance of Segment Support (1:3) V 192-Inspection for Damage (1:3)0803.01 V 192-0804 Damage Prevention During Excavation (1:3) V 192-Mechanlcal Joints (1:0)1005.02 V 192-Mechanlcal Joints -Compression Couplings 2" and less (1:0)1005.03 V 192-Joining of Pipe: ThrHded Joints (1:0)1005.07 ·ype here to search ◊ CG) Current Completion Date CD Expires On Status Ce1 08/03/2020 08/03/2025 • 03/16/2021 01/25/2026 • 03/16/2021 01/25/2026 • 02/17/2021 11/20/2023 • 02/17/2021 01/25/2024 • 02/17/2021 01/26/2024 • 02/17/2021 01/26/2024 • 02/17/2021 08/06/2023 • 01/26/2021 01/26/2026 • 02/17/2021 01/25/2026 • 01/26/2021 01/26/2024 • 02/11/2021 02/11/2022 • 02/17/2021 02/11/2022 • 02/18/2021 02/17/2022 • ome -lntennountain Gas X I r) Tech ActMty X Energy Worldnet X + Ci LJ https:/ /www.energyworldnet.com/PROIINET /MyRequ1rements <C= \ffi Energy � Jesse Urzua I"' ,1. "" World net � .. Monr.,,,:i Ll1/w1,7 I/',/ l,i'S ('(('(!(' \!/)II' �\:.,I .. T : • • I . I I I ' I V 1005.02 V 192-Mechanical Joints -Compression Coupllngs 2" and lass (1:0) 02/17/2021 02/11/2022 •1005.03 V 192-Joining of Pipe: Threaded Joints (1:0) 02/18/2021 02/17/2022 •1005.07 V 192-Leakage Survey: Distribution and Transmission -Walking (1:3) 02/18/2021 • 1201.01 01/27/2024 V 192-Outside Leakage Investigation (1:3) • 1202.01 V 192-Inside Leak Investigation (1:3) • 1203.01 V 192-Leak/Strength Test -SVc/Maln/Trans. Line: Gas pressure <100 psi (1:3) • 1301.01 V 192-Leak/Strength Test -Svc/Main/Trans. Line: Soap Test (1:3) • 1301.04 V 192-1401 Abandonment or Inactivation of Facilities (1:3) 11/23/2020 11/23/2025 • V 192-1402 Backfllling (1:3) 11/23/2020 11/23/2025 • V 192-1405 Undergound Clearances (1:3) 02/17/2021 02/17/2026 • V 192-Installation of Plastlc Pipe: Direct Burial (1:3) 02/24/2021 • 1408.01 01/26/2026 V 192-Cover -Service Lines, Mains, and Transmission Lines (1:3) 11/23/2020 • 1410.01 11/23/2025 V 192-Inspection: Compliance with Procedures and Standards (1:3) 02/24/2021 01/26/2026 •1411.01 V 192-Inspection: Inspection of Materials (1:3) 02/24/2021 01/26/2026 •1411.02 V 192-1413 Line Markers (1:3) 01/26/2021 01/26/2024 • V 192- 4 .t4 A "ype here to search ome -lntermountain Gas x I D Tech Activity X Energy Worldnet X + CJ https://www.energyworldnet.com/PROI INET /MyRequirements 1-() Energy Q Jesse Urzua (" 1 {-)\ W Id t •.1onr.1rra-fl.1koi:1 l'f11•!1C's (,"PIIP (MOU\ J...J. V or ne _ - ~ype here to search V 192-Inspection: Inspection of Materials (1:3) 02/24/2021 01/26/2026 •1411.02 V 192-1413 Line Markers (1:3) 01/26/2021 01/26/2024 • V 192-Plpellne Shutdown/Startup/Pressure Change: Squeeze Off Pip• (1:3) • 1414.02 V 192-1415 Protection from Hazards (1:3) 11/23/2020 11/23/2025 • V 192-Purging: Large Vol, Segment of Main or Trans. Line, Etc. (1:3) • 1418.01 V 192-Purging: Small Vol, Short Pipe, Compressor, Etc. (1:3) • 1418.02 V 192-Valve Maintenance: Inspection/Partial Operation (1:3) • 1427.01 V 192-1434 Bypass -Regulator Stations & Meter Sets (1:3) • V 192-Bypass -Gas Mains and Services (1:3) • 1435.01 V 192-Odorlzatlon: Mains and Transmission Lints: Periodic Sampling (1:3) • 1501.01 V 192-Pressure Regulatlng Limiting , and Rellef Device Operation and 02/24/2021 01/28/2026 •1803.01 Maintenance (1:3) V 192-2011 Prevention of Accidental Ignition (1:3) 08/04/2020 08/04/2023 • V 192-2014 Service Lines Not In Use and Service Discontinuance (1:3) 11/23/2020 11/23/2025 • V 192-AOC Abnormal Operating Conditions (1:3) 08/04/2020 08/03/2023 • V CMV-1001 Commercial Motor Vehicle Safety (1:0)02/18/2021 Non-• Expiring FR Clothing (1:0) 02/19/2021 Non-• V CUST-8002 Expiring N,, ,,.,,,... . . . . . .. .. . . , 1'.;P!I m "'.:• " NJ ., '�1/f 2 Q , .:.: ,='<•(.',' ; ) /, ome -lntennountain Gas X I � Tech Activity X Energy Worldnet X + 0 El https://www.energyworldnet.com/PROI IN ET /MyRequ 1rements 'i."o Energy � Jesse Urzua Gl G)World net � .. Mflnf,1n,1-/l,lk(>l,J 1/(i/>lfi'S u(PUp IMiJIJl - V CMV-1001 Commercial Motor Vehicle Safety (1:0)02/18/2021 Non-• Expiring V CUST-8002 FR Clothlng (1:0) 02/19/2021 Non-• Expiring V CUST-8007 Return to Workplace Training (1:0) 02/17/2021 Non-• Expiring V CUST-8009 MDUG CBT • ACE Safety Management System Tier 1 Training (1:0) 02/17/2021 Non-• Expiring V ERPT-5002 Emergency Action Plan (OSHA) (1:0) 09/15/2020 09/15/2021 • V ERPT-5003 Emergency Response and Restoration of Service (1:0) 02/01/2021 02/01/2022 • V ERPT-5004 15-100 Basic Incident Command (1:0) 02/23/2021 Non-• Expiring V OSHE-6000 New Hire Orientation (1:0) 09/15/2020 Non-• Expiring V OSHE-6002 Animal Attack and Dog Awareness (1:0) 09/15/2020 09/15/2022 • V OSHE-6004 Back Safety and Proper Lifting (1:0) 08/06/2020 08/06/2022 • V OSHE-6005 carbon Monoxide Safety (1:0) 08/06/2020 08/06/2023 • V OSHE-6006 Confined Spaces Awareness (1:0) 08/07/2020 08/06/2021 • V OSHE-6009 Driver Safety (1:0) 08/07/2020 08/07/2023 • V OSHE-6010 Decision Driver (1:0) 10/16/2020 Non-• Expiring V OSHE-6011 Ergonomics (1:0) 09/15/2020 09/15/2022 • V OSHE-6012 Trenching, Excavation and Shoring Safety (1:0) 08/10/2020 08/10/2023 • V OSHE-6015 Hantavlrus (1:0) • V OSHE-6016 Heat Stress (1:0) 11/17/2020 11/17/2022 • ·ype here to search ome -lntermountain Gas X I � Tech Activity X Energy World net X + 0 Ll https://www.energyworldnet.com/PROIINEi /MyRequ,rements Energy � Jesse Urzua (" 1·, f-\\ W Id t �,f /\1onr.1•1.i fhkur, 1,11/•t1Ps i'rrup ;Milli' .L....J. 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I I 1• I V V OSHE-6012 Trenching, Excavation and Shoring Safety (1:0) 08/10/2020 08/10/2023 • V OSHE-6015 Hantavlrus (1:0) • V OSHE-6016 Heat Stress (1:0) 11/17/2020 11/17/2022 • V OSHE-6017 Accident and Hazard Reporting (1:0) 01/19/2021 01/19/2022 • V OSHE-6018 Job Safety Analysis (1:0) 08/10/2020 08/10/2021 • V OSHE-6019 Ladder Safety (1:0) 01/25/2021 01/25/2024 • V OSHE-6027 Personal Protective Equipment (1:0) 08/10/2020 08/10/2021 • V OSHE-6028 Public Awareness (1:0) 02/18/2021 02/18/2024 • V OSHE-6030 Security Threat Recognition and Reporting (1:0) 08/07/2020 08/07/2021 • V OSHE-6033 Walking Working Surf aces (1:0) 08/10/2020 08/10/2022 • V OSHE-6039 Materials of Trade (1:0) 02/19/2021 02/19/2023 • V OSHE-6041 Control of Hazardous Energy (1:0) 10/21/2020 10/21/2021 • V OSHE-6042 First Ald/CPR/AED/88 Pathogen (1:0) • V OSHE-6043 Asbestos Awareness (1:0) 02/18/2021 02/18/2022 • V OSHE-6045 Fire Protection and Prevention (1:0) 08/18/2020 08/18/2021 • V OSHE-6046 Hazard Communication (1:0) 08/10/2020 08/10/2022 • V OSHE-Powered Industrial lift Truck -Class I (1:0) • 6047.01 V OSHE-Powered Industrial Lift Truck -Class IV (1:0) • 6047.04 08/05/2020 Non-• V OSHE-6049 Tool Safety (1:0) Expiring "ype here to search ome • lntermountain Gas x j D Tech Activity X Energy Worldnet X + 0 CJ https://www.energyworldnet.com/PROI I NET /MyRequirements V OSHE-6041 Control of Hazardous Energy (1:0) V OSHE-6042 First Ald/CPR/AED/BB Pathogen (1:0) V OSHE-6043 Asbestos Awareness (1:0) V OSHE-6045 Fire Protection and Prevention (1:0) V OSHE-6046 Hazard Communication (1:0) V OSHE-Powered Industrial Lift Truck -Class I (1:0) 6047.01 V OSHE-Powered Industrial Lift Truck -Class IV (1:0) 6047.04 V OSHE-6049 Tool Safety (1:0) V OSHE-6050 Occupational Noise Exposure (1:0) V OSHE-Introduction to OSHA (1:0) 6051.01 V OSHE-6058 Resldental Mater Ergonomics and Safety (1:0) V OSHE-H2S Awareness (1:0) 6060.02 V OSHE-6062 Backhoe Safety -Bystander (1:0) V OSHE-6063 Voluntary Respirator Use (1:0) V OSHE-6064 Cold Stress (1:0) ·ype here to search 10/21/2020 10/21/2021 •• 02/18/2021 02/18/2022 • 08/18/2020 08/18/2021 • 08/10/2020 08/10/2022 •• • 08/05/2020 Non-• Expiring 08/10/2020 08/10/2021 • Non-• 08/04/2020 Expiring • 08/06/2020 08/06/2021 • 08/07/2020 08/07/2023 • 01/26/2021 Non-• Expiring 11/17/2020 11/17/2022 • Exhibit 2 (Attached) From: Sent: To: Darrin Ulmer Monday, April 26, 2021 5:15 PM Maria Barratt-Riley Subject: Re: UNQUALIFIED OPERATOR PERFORMING RESIDENTIAL METER EXCHANGES Maria, I have looked at the work orders (completed in Nov and Dec 2020) before he became qualified in Feb 2021. I spoke to him again today and he is going to forward photos of texts (from his work phone) and emails as documentation. He is also going to type a statement email. The stress of all this has made him resign (about a week or two ago, before he contacted us) so he no longer is an IGC employee. Thanks Darrin Get Outlook for iOS From: Maria Barratt-Riley <maria.barratt-riley@puc.idaho.gov> Sent: Monday, April 26, 2021 5:03:47 PM To: Darrin Ulmer <Darrin.Ulmer@puc.idaho.gov> Subject: RE: UNQUALIFIED OPERATOR PERFORMING RESIDENTIAL METER EXCHANGES Darrin, John Hammond has asked if you can take a look at the work orders he sent over, as well as his qualifications (I think he sent those too) and see if you feel he is/isn't qualified to do the work. Also, do you know if Mr. Urzua is still employed with IGC? Thanks, Maria From: Darrin Ulmer <Darrin.Ulmer@puc.idaho.gov> Sent: Friday, April 23, 2021 10:07 AM To: Bruce Perkins <Bruce.Perkins@puc.idaho.gov>; Jeff Brooks <jeff.brooks@puc.idaho.gov>; Maria Barratt-Riley <maria.barratt-riley@puc.idaho.gov> Subject: Fwd: UNQUALIFIED OPERATOR PERFORMING RESIDENTIAL METER EXCHANGES FYI Get Outlook for iOS From: Jesse Urzua <jesseurzua@gmail.com> Sent: Friday, April 23, 2021 9:50:54 AM To: Darrin Ulmer <Darrin.Ulmer@puc.idaho.gov> Subject: UNQUALIFIED OPERATOR PERFORMING RESIDENTIAL METER EXCHANGES Dear Mr. Ulmer: 1 I have enclosed documentation in support of my assertion that I was an unqualified operator that was performing live residential meter exchanges as directed by Lead Service Technician Jason Wixom on behalf of my employer, lntermountain Gas Co., in Pocatello. Upon receipt of this communication, kindly contact me at your earliest convenience so I can answer your questions and provide specific information for your investigation. Thank you for your attention to this matter. Sincerely, Jesse Urzua 208-284-9708 2 Exhibit 3 (Attached) Jesse Urzua 88 Princeton Avenue Pocatello, ID 83201 RE: TIMELINE AND REPORT OF UNQUALIFIED OPERATOR WORK PERFORMED I applied online for a Service Technician Apprentice position with Intermountain Gas Company (IGC) at the end of May, 2020. Between June and July, 2020, I was interviewed several times via Microsoft Teams. The IGC interview panel included former Pocatello District Manager Brandon Lance, current Pocatello District Manager James Murphy, and on occasion, Larissa Vossenkemper. At the end of one of the interviews, I asked Mr. Lance if I could be trained to do the job, since I did not have any previous gas industry experience. Mr. Lance assured me that IGC would train me to do the job. My first day of work at IGC was August 3, 2020. On August 7, 2020, I was asked to meet with Mr. Murphy. He explained to me that IGC Human Resources advised him to coach me about what they believed to be a relationship with Bill McCulloch (IGC Service Technician A). Mr. McCulloch's wife and my wife are sisters. Mr. Murphy made it clear to me that I was not in trouble because I had not violated an IGC policy, but that neither myself nor Mr. McCulloch could be the lead of the Service Technician department. IGC's position on this issue has been challenged by the union that the Service Technicians belong to because the service technician lead is more of a pay scale than an actual position and the service technician lead does not have the authority to hire, fire or discipline employees. In late November, 2020, I began performing residential meter exchanges by myself. I was not aware that I was not Operator Qualified to be performing such tasks. My training and Operator Qualifications were being overseen by Service Technician lead Jason Wixom. Mr. Wixom directed me on what tasks to perform and which technician to work with. He "signed off'' on my apprentice training handbook and also "signed off'' on my Operator Qualification performance evaluations. Mr. Wixom, on more than one occasion "signed off'' on something which he had not seen me perform. Mr. Wixom provided very little training, if any, and the limited training that he did occasionally offer was haphazard, at best, and did not follow any sort of structure. Mr. Wixom also signed off on several performance evaluations without actually conducting a performance evaluation. In one particular instance, the line locating performance evaluation, Mr. Wixom signed off on the performance evaluation but told me that I needed more training. If that was the case, he should not have signed off on the PE. On December 11, 2020, I received a text message from Service Technician Lead Jason Wixom. He was concerned about the number of meters that I was exchanging. As a result, I requested -via email-to meet with James Murphy. I met with the Pocatello District Manager James Murphy on December 11, 2020, to discuss my concerns about the lack of training and ongoing criticism from Jason Wixom. Mr. Murphy advised me that Jason Wixom was not a good coach. He also stated that I was doing fine at my job and he advised me to be patient. Despite my formal meeting with James Murphy, the situation did not improve. I did still did not receive much training from Jason Wixom. Mr. Wixom also continued his verbal criticism of the number of meter exchanges that I was completing. I was really feeling pressured and was concerned about losing my job. As a result, I tried to complete an exchange 25 minutes before a United Way luncheon that IGC was providing for the Pocatello District employees. On this particular meter exchange (in December 2020), I attempted to exchange a meter that was set on 2 pounds of pressure instead of the ¼ pound pressure that I had previously encountered. I was not aware that IGC set meters on 2 pounds of pressure. The Grunski bag I was using was blown apart by the higher pressure and the property serviced by the meter -a dentist's office-was left without gas. I called Service Technician Dave Thomson, an A level service technician for assistance in resolving the problem. Mr. Thompson turned on all the gas appliances that had lost gas. It is my understanding that either later that day or later that week, Mr. Thompson met with James Murphy and advised him that I had not been trained correctly to exchange meters and should not be performing the work by myself. Mr. Thompson himself shared this information with me at a later date. Mr. Thompson was one of several Service Technicians that spoke to Mr. Murphy about Jason Wixom's refusal to train me. It is my understanding that John Schwartz, Service Technician A; Brad Sheehan, Service Technician B; Bill McCulloch, Service Technician A,; and Dave Thompson, Service Technician A, all shared concerns about my lack of training with James Murphy. The situation, however, did not improve. I did not receive structured or organized training from Mr. Wixom. In early 2021, Mr. Wixom advised me that I was not where I needed to be in my training and that I needed to work on Operator Qualifications. I had not been previously made aware that I was falling behind -in any capacity-and had also never received any sort of job performance feedback apart from Mr. Murphy's assertion that I was doing fine at my job (during our December meeting). The focus shifted from me completing residential meter exchanges to completing OQs ( computer based training (CBT) and performance evaluations (PE) as quickly as possible. The emphasis was not on learning the material in order to perform the work safely but on completing the OQs as quickly as possible. Mr. Murphy approached me one day and apologized for not overseeing my completion of OQs and explained that he though Mr. Wixom was doing seeing to that task. On March 23, 2021, Mr. Wixom called Glen Morgan, Service Technician A, while I was riding in Mr. Morgan's work truck. Mr. Wixom was not aware that I was in the same vehicle as Mr. Morgan and could overhear their conversation clearly. Mr. Wixom asked Mr. Morgan why I was taking so long to get to a particular work order. Mr. Morgan advised Mr. Wixom that we were completing work orders. What Mr. Wixom did not know was that Mr. Morgan was actually training me and part of that training was showing me where JGC gas lines and regulator stations were located in Blackfoot, ID. I overheard Mr. Wixom ask Mr. Morgan to tell him, just between the two of them, what time I had arrived in Blackfoot. The fact that Mr. Wixom was talking about me to a fellow employee was very upsetting. As I previously stated, Mr. Wixom was not a supervisor -he merely pretended to be one. I immediately contacted my union representative, Sherman Schmidt, and he in turn requested a meeting with JGC management. Because Mr. Murphy was on vacation, Mr. Schmidt and I met with JGC Regional Director Doug Hansen and Operations Manager Phillip Colborn. During the meeting I shared my concerns about not receiving training but frequently receiving criticism from Mr. Wixom. I advised Mr. Hansen that the only task Mr. Wixom wanted me completing seemed to be exchanging meters. Mr. Hansen replied that exchanging meters was a good way to get trained. On March 31, 2021, Mr. Schmidt and I met with Mr. Murphy. We discussed the meeting that Mr. Schmidt and I had with Mr. Hansen and Mr. Colborn. Mr. Murphy stated that he wished I'd come to him more often -as of the time of this statement by Mr. Murphy, I had already met with him once formally about Mr. Wixom, once informally (when Mr. Murphy apologized for Mr. Wixom not overseeing my training and OQs ), and several service technicians had also advised him about Mr. Wixom's unwillingness to train me. Between this meeting and my resignation from JGC, I was finally given structured training. I was assigned to a Service Technician A and worked with that technician for several days in a row and on at least one occasions a complete workweek. On April, 9, 2021, Mr. Schmidt and I met with Mr. Murphy. Prior to this meeting Mr. Murphy sent me several emails indicating that he was going to put together a training plan and wanted input from me about what work tasks I needed more training on. This was the first time during my tenure with IGC that Mr. Murphy inquired about my training. Based on the conversation we were having, it was clear to me that Mr. Murphy was aware that I had not been trained by Mr. Wixom. I felt the meeting was progressing fine until Mr. Murphy advised me that I my probationary period would be extended from six months to nine months. I was actually pretty shocked by Mr. Murphy's threat of a disciplinary action. I was never counseled, warned, or even spoken to by Mr. Murphy about any issues with my job performance. At the time of this meeting, Mr. Murphy was not even aware of how long J had worked at JGC. J explained to him that J was closer to nine months of service than to six months of service. He was confused but eventually realized that J had been working at JGC for over 8 months. After the meeting with Mr. Murphy ended, J met with Mr. Schmidt to advise him that J was not going to be put back on probation by IGC. J believed the threat of an extended probation was a retaliatory act. The brashness of such an unwarranted retaliation left no doubt in my mind that IGC was committed to terminating me. As such, J decided that J would give my two-week notice on Monday, April 12, 2021. Mr. Schmidt and the Union Business Unit Manager contacted JGC and advised them that the Union disagreed with IGC's threat of an extended probation. On April 12, 2021, Mr. Murphy contacted myself and Mr. Schmidt and advised us that JGC had rescinded the extended probation disciplinary action. His words did little to overturn the damage done by the unwarranted retaliatory threat. Later that day, I submitted my written notice of resignation, via email, to Mr. Murphy. On April 13, 2021, Craig Pulley, contacted me. J believe Mr. Pulley is a Human Resources professional with either JGC or Montana Dakota Utilities. Mr. Pulley conducted an exit interview. During the interview, I explained that my resignation was due to the lack of training and because ofIGC's threat of an unwarranted disciplinary action. At one point during the conversation, Mr. Pulley stated that exchanging meters was a great training opportunity for me, do to how involved the process was. J specifically asked Mr. Pulley about whether or not J should have been performing residential meter exchanges that I was not qualified to be exchanging. He responded that that was a question for Mr. Murphy. Jesse Urzua Summary of Concerns and Timeline 4/13/21 December 2020: Jesse came to me with concerns that Jason was not happy with where he was in his training. I explained to Jesse that he was doing fine and that Covid had made this situation challenging. I told him that I would talk with Jason and explain that to him which I did. I have been trying to coach Jason since I have come into this new role, and this was another opportunity I took to ask Jason to be patient and to help Jesse get where he wanted him to be in training. March 23,2021: Jesse reached out to Sherm to after he had reached a breaking point that happened when Jason called the Tech (Glen Morgan) that was training Jesse and asked Glen when he had arrived on the job. Sherm suggested that they talk with Phil Colborn and Doug Hansen as I (JJ Murphy and Jesse's manager) was on vacation. On 3/31/21 Sherm told me that he suggested that they talk with Phil and Doug because he didn't want the situation to escalate while they waited for me to return from vacation. I have included Doug's notes and Phil's notes of the conversation that they had with Sherm and Jesse on this day. March 29, 2021: Was able to schedule a meeting with Doug and Phil to discuss the meeting that they had with Jesse and Sherm and then with Jason. March 30, 2021: Was able to schedule a meeting with Jason. Jason had concerns about Jesse's productivity. Jason stated that there were gaps in his workday that he seemed to always have an excuse for. Jason said that he had asked him to do OQ's one day and he had left without telling him and he didn't know where he went. He said that Jesse is on his personal phone all the time and had even left a training to take a call from his wife. He stated that he had asked Jesse to meet him at the office at 8am and Jesse left from his house at 8am and didn't arrive until 8:40am. Jason also stated that Jesse was acting weird around him and had tried to talk to him with his phone out like Jesse was trying to record the conversation. At that time, I told Jason to work through me on any concerns that he had with any Techs. I told him that Jesse was at that time going to continue training with him until we had the situation figured out. Jesse was already scheduled to train with Dave Thompson, so I let him go with Dave the rest of the week and then I set his training schedule for the next two weeks to ride with other Techs. March 31, 2021: Was able to schedule a meeting with Jesse and Sherm. Jesse was concerned that Jason was calling out his morality when he questioned Glen about the time that he had gotten there. Jesse said it took a little bit of time to get the orders scheduled like Jason wanted. Jesse said that he has not take lunch or breaks to try and be more productive. Jesse was frustrated because he doesn't feel he is getting the level of training that he thought he should be, and that Jason is always unhappy with his productivity. Jesse talked about a situation in which Jason was asking Jesse questions about Bill McCulloch and Jesse told him that he didn't know and that he should ask Bill. Jesse mentioned this to Bill and Bill called Jason to ask why he was asking other Techs about him and an argument ensued between Bill and Jason. After that Jason approached Jesse and was upset that he talked to Bill about it. He told Jesse that "he decided Jesse could go get fucked". Also, Jesse stated that Jason constantly trash talks each Tech to other Techs. Jesse is upset that Jason has provided no clear direction, but at the same time is expecting Jesse to just know what to do. He says that Jason would tell him that he would be training with him, but then would send him with Bill. He says that Jason would tell him to do meter exchanges and then be mad at him for not doing OQ's. April 9· 2021, I scheduled a meeting with Jesse and Sherm. I had gone through Jesse's training log and OQ's to come up with a plan for him to finish his training with employees other than Jason. I got a feel for what types of orders he still need training on so that we could try to get him to as many of those orders as possible over the next several weeks. I told him that we were going to extend his probationary period out until May 3rd to allow for accelerated training and to get him where he needed to be for a better performance review. Also, I explained that we could not have him train with Bill since they were Brother-In-Laws. Sherm called me later that day and explained that the Union thought that Jesse had fulfilled his responsibility for his probationary period, and they didn't want to extend it. I talked with Amanda and Craig and we agreed not to extend it. April 12, 2021: I called Sherm and Jesse first thing in the morning to let them know that the probationary period had not been extended and that I was close to being ready to give his performance review. Later that day I received an email notice of Jesse giving his two-week notice and resignation. I asked Jesse if he could come into the office to meet. Jesse stated that he felt that Jason was out to get him. He said that he had lost sleep and fought with his wife because of the stress over the last several months. He said that he didn't want to be unemployed in this area because there are no good jobs here and that he was moving back to the Boise area. He also said that he didn't make this decision lightly and that it would cost him about $30,000 to $40,000 in realtor and moving costs from him moving over here and back. He said that the extension of the probationary period was the last straw and that his wife is in HR and couldn't believe we would do that. Jesse stated that the other newer Techs had told him that they had similar experiences with Jason during training. Jesse stated that he thought that Jason was harassing him and that he didn't know if it was because he was older or because he was "Mexican". He then brought up a story that Jason had told him about the last time that Jason "slapped a guy" and that it was an "older dude". He brought up that it was hard to know exactly what Jason wanted because Jason would tell him stories about Jason goofing off and not working, but then would expect Jesse to do more work than he was capable of. I apologized to Jesse for not being able to fix this situation before it came to this and asked him why he hadn't kept me informed as this was going on after the last several months. He said he didn't want to be a complainer, and he knew I had a lot going on. < Yes please Jason Wixom Thu, Nov 12, 8:28 AM Good morning! Do you want me to grab th1e one read in Soda Spring·s and the one read in Montpelier? Mon, Nov 16, 7:51 AM Please head to Blackfoot. I'll get you some orders < Jason Wixom > Thu, Nov 19, 8:05 AM I'll have a couple of orders sent to you. After you are done work on OQs Sounds good! Mon, Nov 30, 8:36 AM I'm out for a while. The wife has it and I think I do to. Please work on g exchanges and respond to emergencies with other techs when you can. Thanks ue, Dec 1, 2:21 PM ArP v.n11 wnrkinn nn n < Jason Wixom > Tue, Dec 1, 2:21 PM Are you working on g exchanges? JJ had me go with Bill to Fort Hall where I assisted with a two meter manifold install and am now assisting with locates. Located in ft hall still? Locates Ok. Make sure your also working on exchanges when you can. Especially while the weather is holding. If you are assistin·g < Jason Wixom Fri, Dec 11, 10:34 AM Hey just wanted to touch base and see what ;is going on with orders.? I know there have been a few activities going on around the shop, but as far as I can tell you aren't getting much done and spending way to much time at the shop. Again, I'm on the outside looking in. But You are only averaging 2 to 3 a day on exchanges . Without an area you should easily be able to average 6 if you start from your house and do orders for more than a few hours a day. There are - < Jason Wixom > -But You are only averaging 2 to 3 a day on exchanges. Without an area you should easily be able to average 6 if you start from your house and do orders for 1more than a few hours a day. There are techs completing their daily orders while also doing several exchanges a day. We are not required to go to the shop every morning at 8. It is best to plan your day and start from home at 8. No need to drive in to the office each morning when there is nothing to do there. Just call Kendra and have orders sent. But averaging 2 and 3 orders a day isn't good. We'll talk more Monday. Mon, Dec 14, 12:39 PM Exhibit 4 (Attached) From: Sent: Darras, Patrick < Patrick.Darras@mdu.com > Tuesday, May 11, 2021 3:42 PM To: Maria Barratt-Riley Cc: Subject: Blattner, Lori; Darrin Ulmer; John Hammond RE: Message from KM_C658 Ms. Barratt-Riley, I am in receipt of this correspondence and we will provide a written response within 21 days. Should we have questions we will be sure to reach out. Thank you, Pat Darras VP, Engineering & Operations Services 400 North Fourth Street, Bismarck, ND 58501 Ph 701-222-7611 From: Maria Barratt-Riley <maria.barratt-riley@puc.idaho.gov> Sent: Tuesday, May 11, 2021 4:06 PM To: Darras, Patrick <Patrick.Darras@mdu.com> Cc: Blattner, Lori <LORI.BLATTNER@intgas.com>; Darrin Ulmer <Darrin.Ulmer@puc.idaho.gov>; John Hammond <John.Hammond@puc.idaho.gov>; Maria Barratt-Riley <maria.barratt-riley@puc.idaho.gov> Subject: FW: Message from KM_C658 ** WARNING: EXTERNAL SENDER. NEVER click links or open attachments without positive sender verification of purpose. DO NOT provide your user ID or password on sites or forms linked from this email. ** Mr. Darras, The Idaho Public Utilities Commission pipeline program recently received a complaint regarding an unqualified operator performing live residential meter exchanges. Please see the attached memo and claim documentation. We are asking for a written response within 21 days of this correspondence. Please let me know if you have any questions. Thank you, 1 Maria Barratt-Riley Executive Director Idaho Public Utilities Commission 208 334-0337 2 Idaho Public Utilities Commission PO Box 83720, Boise, ID 83720-0074 Pat Darras Intermountain Gas Company 400 N 4th St. Bismarck, ND 58501 Dear Mr. Darras: May 7, 2021 Brad Little, Governor Paul Kfellander, Commissioner Krtatine Raper, Commissioner Eric Andel"lon, Commissioner On April 23, 2021 the Commission received a complaint that an unqualified operator ("Operator") had been performing live residential meter exchanges in Pocatello between November 2020 to mid-April 2021. Enclosed, please find a copy of the complaint and documentation of meter exchanges the Operator worked on between November 2020 and mid­April 2021 lodged informally with the Commission. The complaint describes an event timeline where the Operator continually reached out to Pocatello District Manager James Murphy, with concerns about the lack of training he was being provided by Service Technician lead Jason Wixom. The complaint includes allegations that Mr. Wixom signed off on training and performance which Mr. Wixom did not personally witness nor conduct an evaluation on the work done by the Operator. The complaint includes specific work orders, and situations during the timeframe set forth above where Mr. Wixom continued to push for a higher number of meter exchanges to be completed, work the operator claimes he was not knowledgeable or qualified to perform. One such event occurred on in December and the lack of operator knowledge resulted in a Gurnski bag being blown apart and a dentist office being left without gas service. The Commission takes such allegations seriously. Please provide a written response to the allegations contained in the complaint within twenty-one (21) day of the date of this correspondence. This response can be sent either by U.S. Mail to: Maria Barratt-Riley Idaho Public Utiliteis Commission PO Box 83720 Boise, ID 83720-0074 or by email to: maria.barratt-riley@puc.idaho.gov. 11331 W. Chinden Blvd., Building 8, Suite 201-A, Boise ID 83714 Telephone: (208) 334-0300 Facsimile: (208) 334-3762 Specifically, such response should, included but not be limited to, address each meter exchange performed by the Operator between November 2020 and mid-April 2021 and whether the Operator was qualified to perform such work. If you have any questions please feel free to contact me at 208-334-0337. Sincerely, \ D--67' ) Maria Barra� {__ Executive Director Idaho Public Utilities Commission cc: John Hammond, Deputy Attorney General Darrin Ulmer, Pipeline Program Manager Jesse Urzua 88 Princeton Avenue Pocatello,ID 83201 RE:TIMELINE AND REPORT OF UNQUALIFIEDOPERATOR WORK PERFORMED I applied online for a Service Technician Apprenticeposition with Intermountain Gas Company (IGC)at the end of May,2020.Between June and July,2020,I was interviewed several times via Microsoft Teams. The IGC interview panel included former Pocatello District Manager Brandon Lance,current Pocatello District Manager James Murphy,and on occasion,Larissa Vossenkemper.At the end of one of the interviews,I asked Mr.Lance if I could be trained to do the job,since 1 did not have any previous gas industry experience.Mr.Lance assured me that IGC would train me to do the job. My first day of work at IGC was August 3,2020.On August 7,2020,I was asked to meet with Mr. Murphy.He explained to me that IGC Human Resources advised him to coach me about what they believed to be a relationship with Bill McCulloch (lGC Service Technician A).Mr.McCulloch's wife and my wife are sisters.Mr.Murphy made it clear to me that I was not in trouble because I had not violated an IGC policy,but that neither myself nor Mr.McCulloch could be the lead of the Service Technician department.IGC's position on this issue has been challenged by the union that the Service Technicians belong to becausethe service technician lead is more of a pay scale than an actual position and the service technician lead does not have the authority to hire,fire or discipline employees. In late November,2020,I began performing residential meter exchangesby myself.I was not aware that I was not Operator Qualified to be performing such tasks.My training and Operator Qualifications were being overseen by Service Technician lead Jason Wixom.Mr.Wixom directed me on what tasks to perform and which technician to work with.He "signed off'on my apprentice training handbook and also "signed off'on my Operator Qualification performance evaluations.Mr.Wixom,on more than one occasion "signed off'on something which he had not seen me perform.Mr.Wixom provided very little training,if any,and the limited training that he did occasionally offer was haphazard,at best,and did not follow any sort of structure.Mr.Wixom also signed off on several performance evaluations without actually conducting a performance evaluation.In one particular instance,the line locating performance evaluation,Mr.Wixom signed off on the performance evaluation but told me that I neededmore training. If that was the case,he should not have signed off on the PE. On December 11,2020,I received a text message from Service Technician Lead Jason Wixom.He was concerned about the number of meters that I was exchanging.As a result,I requested -via email-to meet with James Murphy.I met with the Pocatello District Manager James Murphy on December 11,2020,to discuss my concems about the lack of training and ongoing criticism from Jason Wixom.Mr.Murphy advised me that Jason Wixom was not a good coach.He also stated that I was doing fine at my job and he advised me to be patient. Despite my formal meeting with James Murphy,the situation did not improve.I did still did not receive much training from Jason Wixom.Mr.Wixom also continued his verbal criticism of the number of meter exchanges that I was completing.I was really feeling pressured and was concerned about losing my job. As a result,I tried to complete an exchange 25 minutes before a United Way luncheon that IGC was providing for the Pocatello District employees.On this particular meter exchange (in December 2020), I attempted to exchange a meter that was set on 2 pounds of pressure instead of the ¼ pound pressure that 1 had previously encountered. 1 was not aware that JGC set meters on 2 pounds of pressure. The Grunski bag I was using was blown apart by the higher pressure and the property serviced by the meter -a dentist's office-was left without gas. I called Service Technician Dave Thomson, an A level service technician for assistance in resolving the problem. Mr. Thompson turned on all the gas appliances that had lost gas. It is my understanding that either later that day or later that week, Mr. Thompson met with James Murphy and advised him that I had not been trained correctly to exchange meters and should not be performing the work by myself. Mr. Thompson himself shared this information with me at a later date. Mr. Thompson was one of several Service Technicians that spoke to Mr. Murphy about Jason Wixom's refusal to train me. It is my understanding that John Schwartz, Service Technician A; Brad Sheehan, Service Technician B; Bill McCulloch, Service Technician A,; and Dave Thompson, Service Technician A, all shared concerns about my lack of training with James Murphy. The situation, however, did not improve. I did not receive structured or organized training from Mr. Wixom. In early 2021, Mr. Wixom advised me that I was not where I needed to be in my training and that I needed to work on Operator Qualifications. I had not been previously made aware that I was falling behind -in any capacity-and had also never received any sort of job performance feedback apart from Mr. Murphy's assertion that I was doing fine at my job (during our December meeting). The focus shifted from me completing residential meter exchanges to completing OQs (computer based training (CBT) and performance evaluations (PE) as quickly as possible. The emphasis was not on learning the material in order to perform the work safely but on completing the OQs as quickly as possible. Mr. Murphy approached me one day and apologized for not overseeing my completion of OQs and explained that he though Mr. Wixom was doing seeing to that task. On March 23, 2021, Mr. Wixom called Glen Morgan, Service Technician A, while I was riding in Mr. Morgan's work truck. Mr. Wixom was not aware that I was in the same vehicle as Mr. Morgan and could overhear their conversation clearly. Mr. Wixom asked Mr. Morgan why I was taking so long to get to a particular work order. Mr. Morgan advised Mr. Wixom that we were completing work orders. What Mr. Wixom did not know was that Mr. Morgan was actually training me and part of that training was showing me where IGC gas lines and regulator stations were located in Blackfoot, ID. I overheard Mr. Wixom ask Mr. Morgan to tell him, just between the two of them, what time I had arrived in Blackfoot. The fact that Mr. Wixom was talking about me to a fellow employee was very upsetting. As I previously stated, Mr. Wixom was not a supervisor -he merely pretended to be one. I immediately contacted my union representative, Sherman Schmidt, and he in tum requested a meeting with IGC management. Because Mr. Murphy was on vacation, Mr. Schmidt and I met with IGC Regional Director Doug Hansen and Operations Manager Phillip Colborn. During the meeting I shared my concerns about not receiving training but frequently receiving criticism from Mr. Wixom. I advised Mr. Hansen that the only task Mr. Wixom wanted me completing seemed to be exchanging meters. Mr. Hansen replied that exchanging meters was a good way to get trained. On March 31, 2021, Mr. Schmidt and I met with Mr. Murphy. We discussed the meeting that Mr. Schmidt and I had with Mr. Hansen and Mr. Colborn. Mr. Murphy stated that he wished I'd come to him more often -as of the time of this statement by Mr. Murphy, I had already met with him once formally about Mr. Wixom, once infonnally (when Mr. Murphy apolobrized for Mr. Wixom not overseeing my training and OQs), and several service technicians had also advised him about Mr. Wixom's unwillingness to train me. Between this meeting and my resignation from IGC, I was finally given structured training. I was assigned to a Service Technician A and worked with that technician for several days in a row and on at least one occasions a complete workweek. On April, 9, 2021, Mr. Schmidt and I met with Mr. Murphy. Prior to this meeting Mr. Murphy sent me several emails indicating that he was going to put together a training plan and wanted input from me about what work tasks I needed more training on. This was the first time during my tenure with IGC that Mr. Murphy inquired about my training. Based on the conversation we were having, it was clear to me that Mr. Murphy was aware that I had not been trained by Mr. Wixom. I felt the meeting was progressing fine until Mr. Murphy advised me that I my probationary period would be extended from six months to nine months. I was actually pretty shocked by Mr. Murphy's threat of a disciplinary action. I was never counseled, warned, or even spoken to by Mr. Murphy about any issues with my job performance. At the time of this meeting, Mr. Murphy was not even aware of how long I had worked at IGC. I explained to him that I was closer to nine months of service than to six months of service. He was confused but eventuaJly realized that I had been working at JGC for over 8 months. After the meeting with Mr. Murphy ended, I met with Mr. Schmidt to advise him that I was not going to be put back on probation by JGC. I believed the threat of an extended probation was a retaliatory act. The brashness of such an unwarranted retaliation left no doubt in my mind that JGC was committed to terminating me. As such, I decided that I would give my two-week notice on Monday, April 12, 2021. Mr. Schmidt and the Union Business Unit Manager contacted IGC and advised them that the Union disagreed with IGC's threat of an extended probation. On April 12, 2021, Mr. Murphy contacted myself and Mr. Schmidt and advised us that IGC had rescinded the extended probation disciplinary action. His words did little to overturn the damage done by the unwarranted retaliatory threat. Later that day, I submitted my written notice of resignation, via email, to Mr.Murphy. On April 13, 2021, Craig Pulley, contacted me. I believe Mr. Pulley is a Human Resources professional with either JGC or Montana Dakota Utilities. Mr. Pulley conducted an exit interview. During the interview, I explained that my resignation was due to the lack of training and because ofJGC's threat of an unwarranted disciplinary action. At one point during the conversation, Mr. Pulley stated that exchanging meters was a great training opportunity for me, do to how involved the process was. I specifically asked Mr. Pulley about whether or not I should have been perfonning residential meter exchanges that I was not qualified to be exchanging. He responded that that was a question for Mr. Murphy. Jesse Urzua Summary of Concerns and Timeline 4/13/21 December 2020: Jesse came to me with concerns that Jason was not happy with where he was in his training. I explained to Jesse that he was doing fine and that Covid had made this situation challenging. I told him that I would talk with Jason and explain that to him which I did. I have been trying to coach Jason since I have come into this new role, and this was another opportunity I took to ask Jason to be patient and to help Jesse get where he wanted him to be In training. March 23,2021: Jesse reached out to Sherm to after he had reached a breaking point that happened when Jason called the Tech (Glen Morgan) that was training Jesse and asked Glen when he had arrived on the job. Sherm suggested that they talk with Phil Colborn and Doug Hansen as I (JJ Murphy and Jesse's manager) was on vacation. On 3/31/21 Sherm told me that he suggested that they talk with Phil and Doug because he didn't want the situation to escalate while they waited for me to return from vacation. I have included Doug's notes and Phil's notes of the conversation that they had with Sherm and Jesse on this day. March 29, 2021: Was able to schedule a meeting with Doug and Phil to discuss the meeting that they had with Jesse and Sherm and then with Jason. March 30, 2021: Was able to schedule a meeting with Jason. Jason had concerns about Jesse's productivity. Jason stated that there were gaps in his workday that he seemed to always have an excuse for. Jason said that he had asked him to do OQ's one day and he had left without telling him and he didn't know where he went. He said that Jesse is on his personal phone all the time and had even left a training to take a call from his wife. He stated that he had asked Jesse to meet him at the office at 8am and Jesse left from his house at 8am and didn't arrive until 8:40am. Jason also stated that Jesse was acting weird around him and had tried to talk to him with his phone out like Jesse was trying to record the conversation. At that time, I told Jason to work through me on any concerns that he had with any Techs. I told him that Jesse was at that time going to continue training with him until we had the situation figured out. Jesse was already scheduled to train with Dave Thompson, so I let him go with Dave the rest of the week and then I set his training schedule for the next two weeks to ride with other Techs. March 31, 2021: Was able to schedule a meeting with Jesse and Sherm. Jesse was concerned that Jason was calllng out his morality when he questioned Glen about the time that he had gotten there. Jesse said it took a little bit of time to get the orders scheduled like Jason wanted. Jesse said that he has not take lunch or breaks to try and be more productive. Jesse was frustrated because he doesn't feel he is getting the level of training that he thought he should be, and that Jason is always unhappy with his productivity. Jesse talked about a situation in which Jason was asking Jesse questions about Bill McCulloch and Jesse told him that he didn't know and that he should ask Bill. Jesse mentioned this to Bill and Bill called Jason to ask why he was asking other Techs about him and an argument ensued between Bill and Jason. After that Jason approached Jesse and was upset that he talked to Bill about it. He told Jesse that "he decided Jesse could go get fucked". Also, Jesse stated that Jason constantly trash talks each Tech to other Techs. Jesse is upset that Jason has provided no dear direction, but at the same time is expecting Jesse to just know what to do. He says that Jason would tell him that he would be training with him, but then would send him with Bill. He says that Jason would tell him to do meter exchanges and then be mad at him for not doing OQ's. April 9· 2021, I scheduled a meeting with Jesse and Sherm. I had gone through Jesse's training log and OQ's to come up with a plan for him to finish his training with employees other than Jason. I got a feel for what types of orders he still need training on so that we could try to get him to as many of those orders as possible over the next several weeks. I told him that we were going to extend his probationary period out until May 3rd to allow for accelerated training and to get him where he needed to be for a better performance review. Also, I explained that we could not have him train with Bill since they were Brother-In-Laws. Sherm called me later that day and explained that the Union thought that Jesse had fulfilled his responsibility for his probationary period, and they didn't want to extend it. I talked with Amanda and Craig and we agreed not to extend it. April 12, 2021: I called Sherm and Jesse first thing in the morning to let them know that the probationary period had not been extended and that I was close to being ready to give his performance review. Later that day I received an email notice of Jesse giving his two-week notice and resignation. I asked Jesse if he could come into the office to meet. Jesse stated that he felt that Jason was out to get him. He said that he had lost sleep and fought with his wife because of the stress over the last several months. He said that he didn't want to be unemployed in this area because there are no good jobs here and that he was moving back to the Boise area. He also said that he didn't make this decision lightly and that it would cost him about $30,000 to $40,000 ln realtor and moving costs from him moving over here and back. He said that the extension of the probationary period was the last straw and that his wife is in HR and couldn't believe we would do that. Jesse stated that the other newer Techs had told him that they had similar experiences with Jason during training. Jesse stated that he thought that Jason was harassing him and that he didn't know if it was because he was older or because he was "Mexican". He then brought up a story that Jason had told him about the last time that Jason "slapped a guy'' and that it was an "older dude". He brought up that it was hard to know exactly what Jason wanted because Jason would tell him stories about Jason goofing off and not working, but then would expect Jesse to do more work than he was capable of. I apologized to Jesse for not being able to fix this situation before it came to this and asked hfm why he hadn't kept me informed as this was going on after the fast several months. 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METER Order Summary Pl All 1-,h II' 'MOUG-20201202-20938 �/I Ill !3182�-7 'lill'l\l(f"'i.r"""' .. IG-E __ x_c_H ___ _ /\(1t1ff'S� tJ!.utJmeCJS: D Action Takt!n 1i,1:1-ctca '-A._.•r IJ�I CG• r ••• �--,.t,.11r1 J..'.1•'11.111 � ;t: �11-1 .. \'Yf\f"' • ·� •rr Existing Metl'r/ERT lnlomialion Mti-t,rr N ,_.,.f',., •.-rt P.Alr Nit n,rpr,11<1 Mtr Nn Ot\ onnNt l or illt('Ml o,.,,,-R.1tr 482193873 {.CT -tJd.t,1• ._<wt'ft tftl rJa.' """'c:'.�l�f,-J ll'Y\.1 v JI, n1u"e O•wc R.Jle luund 92854883 7 vr_., 0.25POUNOS � Addillonal Order lnlormalion u�,� \i"/0111: �,rmnlt'rJ 11-;pn,,;to1� u.,_. ,�• fll.1"LC:i.-:llttlll "";Ol'.10 "' t � fl'[lhbl'+-Onl[Mfl"f f.lel,o� tock Uo• .. UUl1tf n'ff'•r-'lr""'•o:; Glll.f!Sltl HOT OWIG£ •110 SIii.VICE IHTEII.IIUPTtCIN. VERIFIED FLOtf AHO lOCK•UP. SllA'ED HETER SET ·NO LfAU. CYCLED 3CF • VEIIIFUD EkT/INOEX OPP. PAINTED MET£11 SET. LEFT DH. 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"0L 0 ,.,. 11.1:e • li!'�rl 6088 uitlill:-.ill 0088 toe� 1/IJ•lPfl H I N•...rt 0 r1tr R<-.td I OI )( to � GlJ A l'!J�Jomt.11 m I • tlolM • ln--.ln Gn ■ P Type here to search X I � Ttd, A<IMtJ X EM<Vt Wadch,.t X + C, X V V V .., .., V .., V V V V V V V V OSHE·6041 Contn>I of Haurdou1 Energy (1:0) 10/21/2020 10/21/2021 • DSHE·B042 First Ald/CPR/AE0/BB Pathogen (1:0) 0 OSHE•B0.3 Albmn AwerenHS (1:0) 02/18/2021 02/18/2022 • OSHE·8045 Fir• Prot.ctlon and PreHntlon (1:0) 01/18/2020 08/18/2021 • OSHE-41046 Hazard Communlcetloft (1:0) 01/10/2020 08/10/2022 • OSHE· Powered lndultrlal Lift Truck • Cina I (1:0) 0 6047.01 OSffE• Powered lndultrlat Uft TrUck -Cina IV (1:0) 0 8047.04 OSHE•8049 Toof S.fety (1:0) 08/05/2020 Non-• Expiring OSHE-8050 Occupetlonel NolN EKposure (1:0) 08/10/2020 08/10/2021 • OSHE· Introduction to OSHA (1:0) 01/04/2020 Non-• 8051.01 Explrltlg OSHE·B058 Resldental Meter Ergonomics and safety (1:0) 0 OSHE• H2S Aweranu1 (1:0) 08/08/2020 08/0S/2021 •604!0.02 OSHE-411112 Backhoe Sat.ty -Bystander (1:0) D8/07/2020 08/07/2023 • OSHE•B063 Voluntary ROll)lrator U.. (1:0) 01/28/2021 Non-• Ell:plrtna OSHE-8084 Cold Streu (1:0) 11/17/2020 11/17/2022 • -.., -·•1 ,,_ 0 ... n r-l lJI la . • ,..... 11,7.jt, Exhibit 5 (Attached) INTERMOUNTAIN GAS COMPANY 555 SOUTH COLE ROAD• P.O. BOX 7608 • BOISE, IDAHO 83707 (208)377-6000 • FAX: 377-6097 May 28, 2021 Ms. Maria Barratt-Riley, Executive Director Idaho Public Utility Commission PO Box 83720 Boise, ID 83720-0074 Subject: Response to Complaint to Commission of an Unqualified Operator Performing Meter Exchanges Dear Ms. Barratt-Riley: This letter is intended to address a complaint received by the Idaho Public Utilities Commission ("IPUC") on April 23, 2021 that an unqualified technician oflntennountain Gas Company ("JGC'') performed live residential meter exchanges in Pocatello between November 2020 to mid-April 2021. Specifically, we are addressing the qualifications of the technician to perform live meter exchanges and each meter exchange that was performed by this technician during the aforementioned timeframe. JGC has reviewed IGC's apprentice training and qualification program. JGC reviewed training records and work completion records for technician Jesse Urzua. JGC has determined that, while Mr. Urzua completed training, it is possible he was not fully qualified and/or operating with another qualified individual under span of control during ninety-seven meter exchanges. A list of these meter exchange addresses has been included with this letter. JGC is committed to ensuring the safe operation of its natural gas system and has implemented a plan to remedy any potential issues stemming from Mr. Urzua's allegations. The company wilt visit each location where Mr. Urzua perfonned worked to verify his work was complete and the associated equipment is operating in a safe condition. This is considered a high priority and is expected to be completed no later than July 2, 2021. Additionally, JGC wilt review Operator Qualification records of all apprentices that have had the potential to complete covered tasks without fully completed qualifications or the assistance of another qualified individual since August l, 2020. If it is detennined that work was completed by apprentice employees without proper qualifications or without assistance of another qualified individual operating under span of control, the company will visit these locations to verify work was complete and the associated equipment is operating in a safe condition. Lastly, JGC Managers and Supervisors who supervise Service Technicians will receive supplemental training related to OPS 800 -Operator Qualification Plan. This training will highlight the importance of reviewing employee records and ensuring that initial qualifications are recorded prior to an employee being assigned any covered tasks. JGC takes these allegations seriously and is committed to operating a safe and reliable natural gas system. Please feel free to contact Josh Sanders at (701) 222-7773 with your questions or comments. Respectfully Submitted, IWJ� Pat Darras Vice President, Engineering & Operations Services Intennountain Gas Company Address City 111 I ' BLACKFOOT CHUBBUCK lllli Ill a CHUBBUCK lliiil Ii I CHUBBUCK CHUBBUCK CHUBBUCK CHUBBUCK llllli I CHUBBUCK CHUBBUCK POCATELLO POCATELLO I lliili I POCATELLO POCATELLO POCATELLO UHII I .. POCATELLO POCATELLO ■filill •POCATELLO··-• POCATELLO POCATELLO Ii I a POCATELLO POCATELLO POCATELLO I Ill I I POCATELLO 511 -POCATELLO••-.II POCATELLO lili Iii 11 I POCATELLO•■ St POCATELLO POCATELLO POCATELLO II -POCATELLO POCATELLO POCATELLO iilUfill .... POCATELLO llll I I I POCATELLO llll pie. POCATELLO ¥1iliili •1 POCATELLO :illli II I I I POCATELLO.. I 111 POCATELLO 111 •• POCATELLO lilii ii 111 POCATELLO iillll 11111111, POCATELLO.. 11 lilllll I POCATELLO POCATELLO POCATELLO ... 1 ·111 POCATELLO Address ■lilil I I" ¥1 i II - i.(ii Ii II I I ie •1111 - A I I I IP!ii �I Ill pl I 101 I • •1 Id ii Iii .a fll II I I :Ullil lH�li r iii i I 11111 lll, __ � I ] L .JSilC •u1111 l � -�filii 111!1■ �ilil .I.I! I i-11 II ll I l II I. I• I 11 lllillll�III U .. J•.IMI 1.111lil 11,3 ,t11111 1111 _111 •I Ir •Ii I u, •. II 11 •i l!I! ..... ...9 ,,, 5§ 1\£§_ . ., ILi ... !.HI•2 111111 1 City Address City POCATEUO POCATELLO POCATELLO POCATELLO POCATELLO Iii •• POCATELLO POCATELLO POCATELLO POCATELLO • 1■1 POCATELLO POCATELLO iill 111 IH POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO POCATELLO Exhibit 6 (Attached) From: Maria Barratt-Riley Sent: Monday, August 2, 2021 9:56 AM To: Darras, Patrick <Patrick.Darras@mdu.com> Cc: Lori Blattner (Lori.Blattner@intgas.com) <lori.Blattner@intgas.com>; Darrin Ulmer <Darrin.Ulmer@puc.idaho.gov>; John Hammond <John.Hammond@puc.idaho.gov> Subject: RE: Request for additional information From: Maria Barratt-Riley Sent: Monday, August 2, 2021 9:54 AM To: Darras, Patrick <Patrick.Darras@mdu.com> Cc: Lori Blattner (Lori.Blattner@intgas.com) <Lori.Blattner@intgas.com>; Darrin Ulmer <Darrin.Ulmer@puc.idaho.gov>; John Hammond <John.Hammond@puc.idaho.gov> Subject: Request for additional information Mr. Darras, Please see the attached memo requesting additional information on IGC's response on May 28, 2021 to the Commission's unqualified operator complaint. Please let me know if you have any questions or concerns about any of the additional information requested. We are asking for a written response within 21 days of this correspondence. Thank you, Maria Barratt-Riley Executive Director Idaho Public Utilities Commission 208 334-0337 Idaho Public Utilities Commission PO Box 83720, Boise, ID 8372().()074 Pat Darras Intennountain Gas Company 400 N 4th St. Bismarck, ND 58501 Dear Mr. Darras: July 29, 2021 Brad Little, Governor Paul Kjellander, Comml1alon1r Krt1tine Riper, Commlulaner Eric Anderson, Comml11loner Thank you for your response letter regarding the unqualified operator ("Operator") complaint. Based on your response, I am requesting additional details on the following: 1.Copies of the initial work orders, including who signed off on the review of workperfonned.2.Copies of IGC follow up inspections of all meter exchanges and any other workperfonned by Mr. Urzua, any findings, and status of those inspections. You indicated100% completion by July 2, 2021, has this been completed?3.How or why did you select the time of August I, 2020 as the starting date for review ofOperator Qualification records? What were the results of this review? If anything wasfound, who signed off on those work orders? Status of any potential findings.4.Please provide a copy of, or access to the supplemental training provided to managersand supervisors who supervise Service Technicians. Have all managers/supervisorscompleted this training? Has this training resulted in any new findings of not fullyqualified technicians perfonning any work independently? If so, please provide acomplete list of addresses and any followup inspection reports IGC has completed sincethe finding. I want to stress the Commission takes this situation very seriously. The lack of training and internal oversight for new employees is a major failing of IGC to promote public safety. Whereas, the fonner employee tried to bring the situation to light with his supervisors and then up the chain of command to no avail, we are quite concerned that IGC put in place a mechanism for future new employees claims are taken seriously. I welcome any additional comments you may have regarding any process changes IGC has put in place to help with this situation. 11331 W. Chlnden Blvd., Building 8, Suite 201-A, Boise ID 83714 Telephone: (208) 334-0300 Facsimile: 1208) 334-3762 Please provide the requested infonnation within twenty-one (21) day of the date of this correspondence. This response can be sent either by U.S. Mail to: Maria Barratt-Riley Idaho Public Utiliteis Commission PO Box 83720 Boise, ID 83720-0074 or by email to: maria.barratt-riley@puc.idaho.gov. If you have any questions please feel free to contact me at 208-334-0337. Sincerely, Maria Barratt-Riley Executive Director Idaho Public Utilities Commission cc: John Hammond, Deputy Attorney General Darrin Ulmer, Pipeline Program Manager Exhibit 7 (Attached) From: Sent: Watkins, Greg <GREG.WATKINS@mdu.com> Tuesday, August 31, 2021 4:43 PM To: Maria Barratt-Riley Cc: Darras, Patrick; Sanders, Josh; Schoepp, Michael; Blattner, Lori Subject: IGC Response to Request for Additional Information dated 7/29/2021 Attachments: CONFIDENTIAL Attachement 1 -Apprentice Service Technician PCAD Order Review.xlsx; CONFIDENTIAL Attachment 2 -Urzua Meter Exchange Review.xlsx; Confidentiality Letter re Informal Complaint.pdf; 2021-07-29 IPUC Concern of Complaint -IGC Follow-Up Response.pdf Follow Up Flag: Follow up Flag Status: Flagged Maria, Attached is the lntermountain Gas Company response to Request for Additional Details RE: Complaint to Commission of an Unqualified Operator Performing Meter Exchanges. We truly appreciate you meeting this afternoon to discuss the response and the path going forward. Also attached are the requested and referenced documents that are marked confidential due to customer addresses and employee names. Respectfully, Greg Watkins Manager, Policy and Procedure 555 South Cole Road I Boise, ID 83709 Email: greg.watkins@mdu.com Direct: 208-377-6032 Cell: 208-890-2300 � .i. INTERMOUNTAIN1fl GAS COMPANY._,. ___ a.a __ t1111ec-nr,1as.n.• 1 GIVENS PURSLEY LLPAttorneys and Counselors at Law 601 W. Bonnock Slreet PO &ox2720 Boise, ID 83701 Telephone: 206-388-1200 Facslmlle: 206-388-1300 www.glvenspvnley.com Preston N. Corter [)fejfgncorter@givensowex.com 206-388-1222 Via hand delivery and email Ms. Maria Barratt-Riley Idaho Public Utilities Commission P.O. Box 83720 Boise, ID 83720-0074 Re: Intermountain Gas Company Informal Complaint Dear Ms. Barratt-Riley: Gory G. Allen Chor1le S. Boser Christopher J. BeeS00 Joson J. Blakley Clint R. Bolinder JelfW.Bower Preston N Carter Jeremy C. Chou Michael c. Oeomer Amber N. Dino Brodley J. Olxon fhomos E. Dvorak Deboro Kristensen Gm1hom Dof1<lld Z. Groy llrion J, Holleran Kersll H. Kennedy August 31, 2021 Ellzabe1h A. Koecker11? Rondell A. Peterman Neot A. Koskena Blake w. Ringer Michael P. Lowrence Michael O. Roe Fronklln G. lee Cameron D. Warr Dovld R. Lombardi Robert B. While lCB E. Lundberg Michael V. Woodhouse Kimberly D. Moloney Kenneth R. McClure Alex P, Mcloughlin WHIiom C. Cole (Of Counsel! Melodie A. McQuode Ctvistopher H. Meyer L Edward MOier renneth L Pursley 119�20151 Judson B. Montgomery Jomes A. McClure (1924-20111 Deborah E. Nelson Raymond 0. Givens 11917-2006) W. Hugh O'Rlordon, ll.M. Somuet F. POfTY Accompanying this letter is Intermountain Gas Company's response to the Commission Staff's requests regarding the informal complaint filed by Mr. Urzua. The attachments to the response contain information such as customer names and addresses. This information is confidential, as indicated by entitling the files "CONFIDENTIAL." Pursuant to Idaho PUC Rules of Procedure, IDAPA31.0I.0l.067, 31.01.01.233, and 31.02.01.005.07, the enclosed information is confidential, proprietary and trade secret information of Inlennountain and is protected by law from public inspection, examination or copying, pursuant to Idaho Code Sections 74-106, 107, and 48-801 et seq. lntermountain therefore requests that the enclosed information be protected from inspection, examination or copying by any person other than the Commissioners and PUC Staff. In accordance with IPUC Rule 67.02.a, the enclosed information is marked "Confidential -Trade Secrets" and submitted on yellow paper. Electronically conveyed data is identified as confidential by the use of CONFIDENTIAL in the file name. Thank you for your cooperation. If you should have comments or questions regarding this request, please contact Lori A. Blattner (208-377-6015) or me (208-388-1222). Sincerely, ,,P �-,.,., Preston N. Carter Givens Pursley LLP Attorney for Intermountain Gas Company EXECUTIVE OFFICES INTERMOUNTAIN GAS COMPANY 556 SOUTH COLE ROAD• P.O. BOX 7608 • BOISE, IDAHO 83707 • (208) 377-6000 • FAX: 377-6097 August 31, 2021 Idaho Public Utility Commission Attn: Maria Barratt-Riley, Executive Director PO Box 83720 Boise, ID 83720-0074 Subject: Response to Request for Additional Details RE: Complaint to Commission of an Unqualified Operator Performing Meter Exchanges Dear Ms. Barratt-Riley: On behalf of Intermountain Gas Company (JGC), this letter is intended to provide additional infonnation relating to the complaint received by the Idaho Public Utilities Commission (IPUC) on April 23, 2021, that an unqualified technician had been performing live residential meter exchanges in Pocatello from November 2020 to mid-April 2021. Specifically, JGC is responding to the IPUC request for additional details dated July 29, 2021. Jesse Urzua completed 912 work orders while employed for JGC as an Apprentice Service Technician, as shown in Attachment 1.1 Mr. Urzua was not operator qualified for covered tasks required to complete 124 of these work orders. As a matter of course, JGC does not review completed work orders for non-emergency tasks completed by Service Technicians. As stated in IGC's previous response letter, operator qualified Service Technicians reviewed the 97 meter exchanges completed by Mr. Urzua while not under span-of-control. This review was completed by June 21, 2021, as shown in Attachment 2. Below is a list of items identified and mitigated during the review. Please note, the identified items did not jeopardize public safety and, as such, would not have required immediate action. •A non-hazardous leak on a meter set fitting was found at two locations. •Two regulators were found with lock-up pressure as found above the 8.25 inches water column (w.c.) Company standard. One found at 11.2 inches w.c., and the other found at 10.3 inches w.c. •One regulator was found with delivery pressure found at 6.5 inches w.c., which is below the 6.75 inches w.c. minimum. •One meter set was identified as in a bind. •A non-hazardous leak on the service stop was found at one location. Because Mr. Urzua was hired on August I, 2020, that date was selected as the starting date of the Apprentice Service Technician Operator Qualification review. From August 3, 2020 through June 23, 2021, 15,940 work orders were completed by Apprentice Service Technicians, as shown in Attachment I. In addition to the meter exchanges completed by Mr. Urzua, the Apprentice Service Technicians were not operator qualified for covered tasks required for 1,847 of the work orders. The Safety Management Systems (SMS) and Quality Assurance (QA) department is in the process of reviewing these 1,847 work orders to determine required follow up actions based on the type of work completed and risk. The SMS/QA department is also reviewing the operator qualification process for Apprentice Service Technicians for gaps and improvement opportunities. This review will be completed by September 24, 2021. 1 All attachments contain customer addresses and are filed confidentially under Commission Rules. Exhibit 7 (Attachment 1 to Exhibit 7 is CONFIDENTIAL) Exhibit 7 (Attachment 2 to Exhibit 7 is CONFIDENTIAL) Exhibit 8 (Attached) EXECUTIVE OFFICES INTERMOUNTAIN GAS COMPANY 555 SOUTH COLE ROAD• P.O. BOX 7608 • BOISE, IDAHO 83707 • (208) 377-6000 • FAX: 377-6097 October 21, 2021 Idaho Public Utility Commission Attn: Maria Barratt-Riley, Executive Director PO Box 83720 Boise, ID 83720-0074 Subject: Follow-up Response to the August 31, 2021 Response to Request for Additional Details RE: Complaint to Commission of an Unqualified Operator Performing Meter Exchanges Dear Ms. Barratt-Riley: In the August 31, 2021 letter titled Response to Request for Additional Details RE: Complaint to Commission of an Unqualified Operator Performing Meter Exchanges, Intermountain Gas Company (IGC) stated, "the Policy & Procedure Department has created a supplemental OPS 800 training for directors and managers. The training is being reviewed and will be revised based on the SMSIQA findings at which time the training and will be implemented before October 22, 2021." The ACE Review Recommendations, provided via email on October 11, 2021, includes several recommendations that require IGC to delay the implementation of the OPS 800 -Operator Qualification Plan training for directors and managers. (See Attachment A). To allow the incorporation of the ACE recommendations, the revised deadline to conduct training with supervisors of personnel who perform covered tasks is June 30, 2022. As previously stated to the IPUC, the Vice President of Field Operations, Director of Safety & Technical Training, and Director of Ops Policy & Procedures met with Field Operations Directors and Managers on August 3, 2021 to review OPS 800 - Operator Qualification Plan and to ensure management is verifying employee Operator Qualification statuses as complete in Energy WorldNet prior to performing Covered Tasks. Since then, IGC has adhered to the requirements set forth in that meeting and by OPS 800. Implementing the ACE recommendations and improving our operator qualification program is a high priority. As such, IGC will assign deadlines for each recommendation. The progress and due dates of the recommendations will be tracked by the Safety Management Systems and Quality Assurance department. Please contact Josh Sanders at (701) 222-7773 with any additional questions or comments. Respectfully Submitted, /2f!J� Pat Darras Vice President, Engineering & Operations Services lntermountain Gas Company Exhibit 8 (Attachment to Exhibit 8 is CONFIDENTIAL)