I202206NOPV Response.pdf

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD• P.O. BOX 7608 • BOISE, IDAHO 83707 • [phone] • FAX: [phone]

January 24, 2023 Mr. Jeff Brooks, Programs Manager
Idaho Public Utility Commission PO Box 83720 Boise, ID 83720-0074 Subject: Response to Notice of Probable Violations dated December 20, 2022 (Report # I202206)
Dear Mr. Brooks, This letter is intended to address one probable violation stemming from an Operator Qualification inspection conducted by the Idaho Public Utilities Commission (IPUC) on December 19, 2022 of Intermountain Gas
Company’s (IGC) Operator Qualification Plan. PROBABLE VIOLATION

Each operator shall have and follow a written qualification program. That program shall include provisions to:
(a) Identify covered tasks;
(b) Ensure through evaluation that individuals performing covered tasks are qualified; (c) Allow individuals that are not qualified pursuant to this subpart to perform a covered task if directed and observed by an individual that is qualified;
(d) Evaluate an individual if the operator has reason to believe that the individual’s
performance of a covered task contributed to an incident as defined in Part 191;
(e) Evaluate an individual if the operator has reason to believe that the individual is no
longer qualified to perform a covered task; (f) Communicate changes that affect covered tasks to individuals performing those covered tasks;
(g) Identify those covered asks and the intervals at which evaluation of the individual’s
qualifications is needed;
(h) After December 16, 2004, provide training as appropriate, to ensure that the
individuals performing covered tasks have the necessary knowledge and skills to perform the tasks in a manner that ensures the safe operation of pipeline facilities; and (i) After December 16, 2004, notify the Administrator or a state agency participating
under 49 U.S.C Chapter 601 if an operator significantly modifies the program after the
administrator or state agency has verified that it complies with this section.
Notifications to PHMSA must be submitted in accordance with §192.18.
2. 49 CFR §192.807 Recordkeeping
Each operator shall maintain records that demonstrate compliance with this subpart.
(a) Qualification records shall include:
(1) Identification of qualified individual(s);
(2) Identification of the covered tasks the individual if qualified to perform;
(3) Date(s) of current qualifications; and
(4) Qualification method(s). (b) Records supporting an individual’s current qualification shall be maintained while the
individual is performing the covered task. Records of prior qualification and records of
individuals no longer performing covered tasks shall be retained for a period of five
years.
EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD• P.O. BOX 7608 • BOISE, IDAHO 83707 • [phone] • FAX: [phone]

Intermountain Gas Response
Intermountain Gas Company (IGC) acknowledges the findings brought forth from the IPUC as outlined above.
An MOC was initiated to re-write OPS 800 – Operator Qualification Plan. The revised OPS 800 defines
responsibilities by department and outlines plan details such as the identification of covered tasks, reviews and
plan updates, the assigning and unassigning of qualifications for MDU Utilities Group (MDUG) employees
and contractors, evaluations and evaluation methods, reevaluation intervals, performance evaluation criteria
and Span of Control (SOC) clarifications. Training for the revised OPS 800 was conducted over a three (3)
week period and consisted of eight (8) sessions to accommodate employee schedules. Training was designed
for all departments with plan responsibilities, Directors, Managers, Supervisors of employees who perform
covered tasks, and employees who are, or will be operator qualified to perform Covered Tasks. Training
concluded June 15, 2022, and the revised OPS 800 implemented June 24, 2022. Subsequent training on OPS
800 will be provided annually through EWN. OPS 800 will also be included in Service Technician apprentice
training.

Additionally, OPS procedure training has been converted to Computer Base Training (CBT) modules in EWN.
Performance Evaluations (PE) are unable to be completed prior to the completion of CBT/Classroom training.
EWN has been updated to expand hierarchical notifications for review of assigned tasks.

Please contact Josh Sanders at [phone] with questions or comments.

Respectfully Submitted,

Pat Darras
Vice President, Engineering & Operations Services
Intermountain Gas Company

Finding(s):
Through investigation and self-reporting by the Company, Commission Staff (“Staff”) learned that the Company had violated pipeline safety requirements by allowing 1,847 work
orders to be issued and performed by unqualified operators.