I202508 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
August 20, 2025 Report# I202508
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 4th St.
Bismarck, ND 58501
Dear Mr. Pat Darras,
On August 141h,the Idaho Public Utilities Commission("Commission"), Pipeline Safety Division
("Staff'), conducted a distribution records audit 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 092.603 General provisions.
(a) No person may operate a segment of pipeline unless it is operated in accordance with
this subpart.
(b) Each operator shall keep records necessary to administer the procedures established
under§192.605.
49 CFR 092.725 Test requirements for reinstating service lines.
(a) Each Except as provided in paragraph(b)of this section,each disconnected service line
must be tested in the same manner as a new service line, before being reinstated.
(b) Each service line temporarily disconnected from the main must be tested from the
point of disconnection to the service line valve in the same manner as a new service line,
before reconnecting. However,if provisions are made to maintain continuous service, such
as by installation of a bypass, any part of the original service line used to maintain
continuous service need not be tested.
OPS 505 Step 2.4 and Table 2
2.4.3. Distribution Pressure Mains, Services, and Facilities:
IGC DISTRIBUTION RECORDS PROBABLE VIOLATIONS LETTER— Page 1 of 4

2.4.3.1. Pressure tests for mains, services, and related facilities with an MAOP of 60 psig
or less are to follow the requirements established in Table 2. Deviation from the
requirements of Table 2 shall be approved by Engineering Services.
POLICY STATEMENT OPS 605
Cascade Natural Gas Corporation Pressure Testing Status:Released
Great Plains Natural Gas Co. Revision Date: May 2.2025
Intermountain Gas Company OPSMOC-1851
Montana-Dakota Utilities Co. Page 6 of 13
Table 2—Pressure Tests for Mains, Services, and Facilities with MAOP 60 psig and Less
Nominal Pipe Minimum Test Pipe Length (ft)**
Size (in)* Test Medium
Pressure <500 500-<2,000 2,000—5,000 >5,000
Less than 2" 15 minutes 30 minutes Contact Engineering
Air or Services
si
2 -6 90 p g Inert Gas 30 minutes 1 hour 2 hours 4 hours
Larger than 6" Contact Engineering Services.
`Nominal Pipe Size is the diameter of the largest component.
`*Pipe Length is the sum of pipe footages tested.
Findim(s)•
IPUC Inspectors discovered that Report 450-26473 shows a 5-minute pressure test from 10:15 to
10:20 and it should have been 15 minutes minimum.
2. 49 CFP W2.325 Protection from hazards.
(b) Each main must be installed with enough clearance from any other underground
structure to allow proper maintenance and to protect against damage that might result
from proximity to other structures.
(c) In addition to meeting the requirements of paragraph (a) or (b) of this section, each
plastic transmission line or main must be installed with sufficient clearance, or must be
insulated, from any source of heat so as to prevent the heat from impairing the
serviceability of the pipe.
OPS 306 Section 5 Installation
5.2.2. Unless approved by Construction Services, Engineering Services, local Field
Operations Management, or System Integrity,high-pressure mains,distribution mains, and
service lines shall be installed with at least 12" of clearance from underground metallic
structures, and electric and four (4") inches from other underground structures. Approval
of less clearance shall be documented on the installation As-Built.
OPS 307 Section 5 Installation
5.16.1 PE pipelines should be installed with at least four(4")inches of clearance from other
underground utilities, (excluding electric) and structures. For electric clearance
requirements refer to Section 5.16.2.
5.16.1.1. If minimum clearance cannot be attained, the pipeline shall be protected from
damage that might result from its proximity to other structures and utilities, excluding
IGC DISTRIBUTION RECORDS PROBABLE VIOLATIONS LETTER— Page 2 of 4

electric. For electric clearance requirements refer to Section 5.16.2. 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 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.
Finding(s)•
IPUC Inspectors identified multiple Form 512's that did not specify minimum distances from
underground utilities in them. Reports# 117263-425, 11711-375, 51101-371, 09372-367, 20607-
613, 04785-575, 21494-583 had no indication of proper underground clearances.
3. 49 CFR 4 192.727 Abandonment of deactivation of facilities.
(b) Each pipeline abandoned in place must be disconnected from all sources and supplies
of gas; purged of gas; in the case of offshore pipelines, filled with water or inert materials;
and sealed at the ends. However, the pipeline need not be purged when the volume of gas
is so small that there is no potential hazard
(c) Except for service lines, each inactive pipeline that is not being maintained under this
part must be disconnected from all sources and supplies of gas; purged of gas; in the case
of offshore pipelines, filled with water or inert materials; and sealed at the ends. However,
the pipeline need not be purged when the volume of gas is so small that there is no potential
hazard.
OPS 603 Pipeline Purging
4.Purging Out of Service
4.2 Purging out of service may be required when existing mains and services are taken
out of service and the removal of residual natural gas is necessary.
Finding(s):
No purging was annotated while reviewing samples of abandoned mains and SL (SL-512, Main-
319) # 741-3288, 741-3305, 741-3331, 679-2539. The check boxes were not checked indicating
that purge requirements were not met.
IGC DISTRIBUTION RECORDS PROBABLE VIOLATIONS LETTER— Page 3 of 4

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, 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://puc.idaho.gov/. If you intend to request an informal conference,please contact the Pipeline
Safety Division no later than October 4, 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 September 19,2025,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).
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,
f4---
JeffBrooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
IGC DISTRIBUTION RECORDS PROBABLE VIOLATIONS LETTER— Page 4 of 4