I202503 NOPV

Idaho Public Utilities Commission Brad Little,Governor
P.O. Box 83720,Boise,ID 83720-0074 Edward Lodge,President
John R.Hammond,Jr.,Commissioner
Dayn Hardie,Commissioner
June 17, 2025 Report# I202503
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 4" St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On May 14, 2025, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a construction inspection in Kuna, ID 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 VIOLATIONS)
1. 49 CFR U92.605 Procedural manual for operations, maintenance, and emergencies.
General. Each operator shall prepare and follow for each pipeline, a manual of written
procedures for conducting operations and maintenance activities and for emergency
response. For transmission lines, the manual must also include procedures for handling
abnormal operations. This manual must be reviewed and updated by the operator at
intervals not exceeding 15 months,but at least once each calendar year. This manual must
be prepared before operations of a pipeline system commence. Appropriate parts of the
manual must be kept at locations where operations and maintenance activities are
conducted.
2. 49 CFR 4192.614 Damage prevention program.
c. The damage prevention program required by paragraph (a) of this section must, at a
minimum:
(6) Provide as follows for inspection of pipelines that an operator has reason to believe
could be damaged by excavation activities:
(i) The inspection must be done as frequently as necessary during and after the
activities to verify the integrity of the pipeline; and
(ii) In the case of blasting, any inspection must include leakage surveys.
IGC KUNA CONSTRUCTION AUDIT PROBABLE VIOLATIONS LETTER— Page 1 of 5

3. 49 CFR 4192.805 Oualification program.
Each operator shall have and follow a written qualification program. The program shall
include provisions to:
(e) Evaluate an individual if the operator has reason to believe that the individual is no
longer qualified to perform a covered task;
OPS 800 Operator Oualification Plan
1. PLAN RESPONSIBILITIES
1.1. General
1.1.1. When an employee or contractor witnesses or is made aware of incidents or ADCs
caused by an individual(s) performance, they shall report the incident or AOC to their
supervisor.
OPS 619 Reporting Abnormal Operating Conditions and other Deficiencies
Requiring Remediation
1. General
1.1 Identified AOCs shall be reported at the time of discovery. Immediately contact
applicable Manager, or Supervisor, and proceed to step 1.3.
1.1.1 Contractors shall contact their MDUG representative (e.g., Field
Operations Coordinator, third-party Inspector, local District Management,
etc.) immediately after identifying an AOC. If an AOC is identified after
hours and contact cannot be made with the MDUG representative,
immediately call the 24-Hour Emergency Contact Number.
4. 49 CFR 4192.361 Service lines: Installation.
a. Depth. Each buried service line must be installed with at least 12 inches (305
millimeters)of cover in private property and at least 18 inches (457 millimeters) of
cover in streets and roads. However, where an underground structure prevents
installation at those depths, the service line must be able to withstand any
anticipated external load.
b. Support and backfill. Each service line must be properly supported on undisturbed
or well-compacted soil, and material used for backfill must be free of materials that
could damage the pipe or its coating.
OPS 307 Polyethylene WE) Main and Service Construction
5.16.2. At least 12" separation should be maintained when crossing or paralleling electric
(direct bury or in conduit).
5.16.2.1. When 12" separation cannot be maintained, mechanical protection is to
be used to limit the likelihood of detrimental heat transfer to gas facilities.
Examples of protective measures are placing sandbags, rock shield, PVC, or FRP
half sleeve between the pipe and the foreign utility to prevent contact and wear.
5.16.2.2. Electric separation should be discussed with all parties involved prior to
installation.
IGC KUNA CONSTRUCTION AUDIT PROBABLE VIOLATIONS LETTER— Page 2 of 5

5.23.2 Service lines less than two (2") inches in diameter shall have at least 18" cover on
private property and at least 24" cover in the right-of-way (ROW).
5.23.2.1 A minimum 24"of cover is preferred over service lines on private property
and in the ROW in non-rock type soil.
Finding(s):
At 1317 S Sabrina Ave, Kuna, ID, IPUC inspectors observed—6 feet of live 3/" PE pipe installed
above grade and tied to a live electric meter by the associated tracer wire. Das-Co employees
properly identified and reported the Abnormal Operation Condition(AOC)to their supervisor and
to IGC District Operations Coordinators, yet no IGC personnel responded to the jobsite. IPUC
inspectors notified IGC Compliance Personnel. The ELM employee responsible for the locates
failed to appropriately recognize and react to the AOC's.
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 August 1,2025, 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:Hpue.idaho.gov/.
If you intend to request an informal conference, please contact the Pipeline Safety Division no
later than July 17,2025.
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 August 1, 2025, 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.
These violations may be subject to any Commission enforcement action as allowed under Idaho
law including, but not limited to, potential civil penalties in accordance with 49 CFR 190.223(a).
IGC KUNA CONSTRUCTION AUDIT PROBABLE VIOLATIONS LETTER— Page 3 of 5

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.
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sincerely,
OL-
JeffBrooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
IGC KUNA CONSTRUCTION AUDIT PROBABLE VIOLATIONS LETTER— Page 4 of 5

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IGC KUNA CONSTRUCTION AUDIT PROBABLE VIOLATIONS LETTER— Page 5 of 5