I202404 NOPV

Idaho Public Utilities Commission Brad Little,Governor,
P.O.Box 83720,Boise,ID 83720-0074 Eric Anderson,President
John K Hammond,Jr.,Commissioner
Edward Lodge,Commissioner
March 11, 2024 Report# I202404
Pat Darras-Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 4th St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On March 7, 2024, the Idaho Public Utilities Commission-("Commission"), Pipeline Safety
Division-("Staff'), conducted a construction inspection on project 371-3065 of Intermountain Gas
Company("IGC")pursuant to Chapter 601 of Title 49, United States Code. -
Staff observed that some of the Idaho natural gas distribution system owned and operated by IGC
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.
OPS 308 Gas Joint and Provided Trench Installations
1.4. Joint trench pipelines shall be installed in an approved trench configuration and with
the minimum separation shown in Appendices 1-12. Joint trench configurations may vary
with the addition or exclusion of other utilities. The selected joint trench configuration
shall meet the requirements of the utilities sharing the trench and easement, city, county,
or state requirements.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]

1.4.1 Unless approved by Engineering Services or System Integrity, the following are
the minimum separation distances of utilities exiting a joint trench(e.g.,
horizontal/perpendicular crossings):
1.4.1.2 Plastic main or service crossing electric installed in conduit or
communications (direct bury or in conduit) is four(4") inches.
Findinds):
At 5143 W Canaston St,in Merdian, when installing a service line,personnel did not leave
the minimum required separation of 4"between the service line and electrical line
(in conduit) as required by OPS 308.
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 April 25,2024, 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 April 10,2024.
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 April 25, 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 April 25, 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.
If you have any questions concerning this Notice,please contact me at(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.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]

We appreciate your attention to this matter and your effort to promote pipeline safety.
Sincerely,
A---
JeffBrooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]