I202410 NOPV

Idaho Public Utilities Commission Brad Little,Governor
PA.Box 83720,Boise, ID 83720.0074 Eric Anderson,President
John R.Hammond,Jr.,Commissioner
Edward Lodge,Commissioner
August 5, 2024 Report#I202410
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On July 24, 2024, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a construction inspection in Rupert, Idaho on service line number
02251-621 of Intermountain Gas Company ("IGC") pursuant to Chapter 601 of Title 49, United
States Code.
Staff observed that some of the Idaho natural gas system(s) owned and operated by IGC
("Company")was out of compliance on item(s). This results in probable violations of the pipeline
safety regulations Title 49, Code of Federal Regulations, Part 192. The probable violations are as
follows:
PROBABLE VIOLATION(S)
1. 49 CFR 4192.605 Procedural manual for operations, maintenance, and
emergencies.
(a)General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include procedures
for handling abnormal operations. This manual must be reviewed and updated by the
operator at intervals not exceeding 15 months,but at least once each calendar year.This
manual must be prepared before operations of a pipeline system commence.
Appropriate parts of the manual must be kept at locations where operations and
maintenance activities are conducted.
IGC RUPERT CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER—PAGE 1

2. OPS 307 Polyethylene (PE) Main and Service Construction
5.3 Connections shall be made by butt fusion or electrofusion.
5.3.1 Mechanical fittings maybe used for connections when space does not allow
the use of a butt fusion machine or electrofusion clamp, or when
temperatures do not allow electrofusion or butt fusion.
Findinds)•
IPUC staff observed a contractor for IGC build a service line on a trailer using (3)
Continental stab fittings and a 3/4" Met Fit Tee. Per OPS 307, connections shall be made
by butt fusion or electrofusion,unless space does not allow the use of fusion machines and
clamps. The majority of the service line was built on an open trailer with adequate space
for butt fusions.
REQUESTED ACTIONS
A reply to this correspondence is required no later than 45 days from the date of this letter. Please
submit a written reply providing a statement of all relevant facts including a complete description
of the corrective action(s) taken with respect to the above referenced probable violations, and all
actions to be taken to prevent future failures in these areas of concern. This written reply must be
signed by a Company official with authority to bind the Company.
Please send all documents to our office at 11331 W. Chinden Blvd, Boise, Idaho 83714-1021. Be
advised that all material you submit in response to this enforcement action may be a public record
and subject to disclosure under Idaho's Public Records Law. See Idaho Code §§74-101 et seq.
If you wish to dispute any of the above referenced potential violations,you have the right to appear
before the Pipeline Safety Division in an informal conference before September 19, 2024, at the
above address. You have the right to present relevant documents and evidence to the Pipeline
Safety Division at that conference. The Pipeline Safety Division will make available to you any
evidence which indicates that you may have violated the law, and you will have the opportunity to
rebut this evidence. See Commission Orders 35095 and 35334, which can be found at
https://puc.idaho.gov/. If you intend to request an informal conference,please contact the Pipeline
Safety Division no later than September 4, 2024.
If you wish to dispute any of the allegations in this Notice,but do not want an informal conference,
you may send the Pipeline Safety Division a written reply to this Notice. This written reply must
be filed with the Commission on or before September 19,2024,and must be signed by a Company
official with authority to bind the Company. The reply must include a complete statement of all
relevant facts, and all documentation, evidence, and argument the Company submits to refute any
of the above referenced probable violations.
If you do not respond to this notice by September 19, 2024, you may be subject to any
Commission enforcement action as allowed under Idaho law including,but not limited to,potential
civil penalties of up to two hundred thousand dollars ($200,000). See Idaho Code §61-712A.
IGC RUPERT CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER—PAGE 2

If you have any questions concerning this Notice,please contact meat(208)334-0333. All written
responses should be addressed to me at the above address, or you may fax your response to (208)
334-3762.
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sincerely,
Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
IGC RUPERT CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER—PAGE 3