I202509 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# I202509
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 transmission 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 VIOLATIONS)
1. 49 CFR 4192.709 General provisions.
(c) A record of each patrol, survey, inspection, and test required by subparts L and M of
thi"aart must be retained for at least 5 years or until the next patrol, survey, inspection, or
test is completed, whichever is longer.
Finding(s)-
IPUC Inspectors identified in Bancroft, Idaho alone,in April of 2025,twenty-three separate HPSS
that had unsatisfactory line markers as follows:
48825-HPSS-64762, 48825-HPSS-66102, 48825-HPSS-66131, 48825-HPSS-66133, 48825-
HPSS-66552, 48825-HPSS-66636, 48825-HPSS-66639, 48825-HPSS-66894, 48825-HPSS-
66897, 48825-HPSS-66898, 48825-HPSS-66900, 48825-HPSS-66918, 48825-HPSS-66928,
48825-HPSS-66929, 48825-HPSS-66931, 48825-HPSS-66933, 48825-HPSS-66936, 48825-
HPSS-66937, 48825-HPSS-66941, 48825-HPSS-66942, 48825-HPSS-66952, 48825-HPSS-
66965, 48825-HPSS-69655.
IGC patrol records showed all Pocatello district line markers as Acceptable.
2. 49 CFP 4192.8 Protection from hazards.
(b) Each operator must determine and maintain for the life of the pipeline records
documenting the methodology by which it calculated the beginning and end points of
each onshore gathering pipeline it operates, as described in the second column of table
IGC TRANSMISSION RECORDS PROBABLE VIOLATIONS LETTER— Page 1 of 3

I to paragraph (c)(2) of this section, by:
(1)November 16, 2022, or before the pipeline is placed into operation, whichever is later;
or
(2) An alternative deadline approved by the Pipeline and Hazardous Materials Safety
Administration (PHMSA). The operator must notify PHMSA and State or local
pipeline safety authorities, as applicable, no later than 90 days in advance of the
deadline in paragraph (b)(1) of this section. The notification must be made in
accordance with § 192.18 and must include the following information:
(i) Description of the affected facilities and operating environment;
(ii)Justification for an alternative compliance deadline; and
(iii) Proposed alternative deadline. 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.
Findinp_(s)•
IPUC Inspectors identified that no methodology from System Integrity during the audit window
existed to properly identify gathering classifications. NCR non-conformance report #QIS 5183
was provided which was to create Form 23093 for analysis. Records did not properly document
any methodology that IGC used to identify and classify Type A, B, C, and R gathering pipelines
correctly and within required timeframes during the audit window.
IGC TRANSMISSION RECORDS PROBABLE VIOLATIONS LETTER— Page 2 of 3

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,
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 TRANSMISSION RECORDS PROBABLE VIOLATIONS LETTER— Page 3 of 3