I202509 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
October 2,2025
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to the Notice of Probable Violation dated August 20,2025 (Report#I202509)
Dear Mr.Brooks,
This letter is intended to address two(2)notices of probable violation stemming from a transmission records audit
conducted by the Idaho Public Utilities Commission(IPUC)on August 14,2025,of Intermountain Gas Company
(IGC)pursuant of Chapter 601 Title,49,United States Code.
PROBABLE VIOLATIUA
1. 49 CFR 5192,709 General provisions.
(c) A record each patrol, survey, inspection, and test required by subparts L and M of this part 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 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.
Intermountain Gas Resnonse
IGC acknowledges the findings brought forth by the IPUC.
• 48825-HPSS-64762: A pipeline marker was installed April 9, 2025 (WO 12114351).
• 48825-HPSS-66102: A pipeline marker was installed April 9, 2025 (WO12114357).
• 48825-HPSS-66131: A pipeline marker was installed April 8,2025 (WO12114358).
• 48825-HPSS-66133: A pipeline marker was installed April 9,2025 (WO12114344).
• 48825-HPSS-66552: A pipeline marker was installed April 9, 2025 (WO12114354).
• 48825-HPSS-66636: A pipeline marker was installed April 9,2025 (WO12114348).
• 48825-HPSS-66639: A pipeline marker was installed April 10,2025 (WO12114362).
• 48825-HPSS-66894: A pipeline marker was installed April 9, 2025 (WO12114345).
• 48825-HPSS-66897: A pipeline marker was installed April 9, 2025 (WO12114349).
• 48825-HPSS-66898: A pipeline marker was installed April 8, 2025 (WO12114341).
• 48825-HPSS-66900: A pipeline marker was installed April 9, 2025 (WO12114342).
• 48825-HPSS-66918: A pipeline marker was installed April 9, 2025 (WO 12114331).
• 48825-HPSS-66928: A pipeline marker was installed April 9, 2025 (WO12114343).
• 48825-HPSS-66929: A pipeline marker was installed April 8,2025 (WO12114359).
• 48825-HPSS-66931: A pipeline marker was installed April 9,2025 (WO12114350).
• 48825-HPSS-66933: A pipeline marker was installed April 9, 2025 (WO12114353).
• 48825-HPSS-66936: A pipeline marker was installed April 8,2025 (WO12114339).
• 48825-HPSS-66937: A pipeline marker was installed April 9,2025 (WO12114355).

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
• 48825-HPSS-66941: A pipeline marker was installed April 8,2025 (WO12114360).
• 48825-HPSS-66942: A pipeline marker was installed April 9,2025 (WO12114352).
• 48825-BPSS-66952: A pipeline marker was installed April 10, 2025 (WO12114356).
• 48825-HPSS-66965: A pipeline marker was installed April 8,2025 (WO12114340).
• 48825-HPSS-69655: A pipeline marker was installed April 9,2025 (WO12114361).
IGC's Quality Control department conducted an evaluation of HPSS pipeline markers for all districts. Based on
the results, IGC's Safety Management Systems and Policy and Procedure departments are working with subject
matter experts to revise OPS 705 — Gas Pipeline Markers and Signs Installation and Inspection and enhance
operational controls to ensure pipeline markers are installed and maintained per the requirements of 49 CFR
§192.707 Line Markers for Mains and Transmission Lines and OPS 705.
2. 49 C'FR 6 192.8 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 1 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§192.8 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 02 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.
Finding(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.
Intermountain Comas Response
IGC acknowledges the findings brought forth by the IPUC. IGC's Engineering Services department completed
Form 23093 -Determination of Regulated Gathering Pipeline to document the methodology for identifying the
Type R gathering pipeline in Idaho (see Exhibit A). The form has been sent to GIS for retention.
Additionally, an MOC has been initiated to revise OPS 205 —Engineering Project Process to provide further
clarification on the requirements for completing Form 23093—Determination of Regulated Gathering Pipeline.
Revised OPS 205 will implement on or before December 31,2025.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company

Exhibit A
Form 23093 - MDUG Regulated Gas Gathering Line Determination
-AMPruK ?PLALS
DISTRICT: Twin Falls
Ok_ON<
TOWN/STATE: Twin Falls, Idaho
GATHERING LINE: Neo
LOCATION DESCRIPTION: 6in & 4in NEO Gathering Line
PIPELINE INFORMATION
MATERIAL: NON-METALIC
OUTSIDE DIAMETER: (ACTUAL): 6.625 in
MAOP (PSI): 100 psig
PERCENT SMYS: NA
CLASS LOCATION: Class 1 and 2
BUILDING COUNT
General Location Neo System; Southwest part of Twin Falls
Number of Buildings [Buildings for Human Occupancy] 90
Begin Station ing/Tie-Down/GPS 1+00
End Stationing/Tie-Down/GPS 452+24
REGULATED GATHERING LINE TYPE: R
COMMENTS
System is non Metallic, MAOP < 125 psig, located in a Class 1 & 2 location.
System approx. 45,200 ft long
DRAWING "Note: Drawing and measurements may be provided in space below or supplemental map
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COMPLETED BY: Mollie Hunt
ENGINEER SIGNATURE: maL�e Huvkt 9/29/2025
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