I202510 LOC

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
Letter of Concern
August 21, 2025 Report#I202510
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck, ND 58501
Dear Mr. Pat Darras,
On August 14, 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.
As a result of the inspection, it appears there are area(s) of concern that do not fully meet the
intent of the pipeline safety regulations Title 49, Code of Federal Regulations, Part 192 for
calendar year 2025.
The item(s) listed below are of concern:
1. 49 CFR 4192.491 Corrosion control records.
(c) Each operator shall maintain a record of each test, survey, or inspection required by this
subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or
that a corrosive condition does not exist. These records must be retained for at least 5 years
with the following exceptions:
(1) Operators must retain records related to §§ 192.465(a) and (e) and 192.475(b) f
or as long as the pipeline remains in service.
(2) Operators must retain records of the two most recent atmospheric corrosion
inspections for each distribution service line that is being inspected under the
interval in § 192.481(a)(2).
IGC TRANSMISSION RECORDS AUDIT LETTER OF CONCERN— Page 1 of 3

49 CFR 4192.475 Internal Corrosion control.
(b) Whenever any pipe is removed from a pipeline for any reason,the internal surface must
be inspected for evidence of corrosion. If internal corrosion is found—
(1) Operators The adjacent pipe must be investigated to determine the extent of
internal corrosion;
(2) Replacement must be made to the extent required by the applicable paragraphs
of§§ 192.485, 192.487, or 192.489; and
(3) Steps must be taken to minimize the internal corrosion.
OPS 327 Inspection, Evaluation, and Repairs of Pipelines
10. DOCUMENTATION
10.1 Existing in-service line exposure shall be documented on Form 21722—Pipeline
Condition Report when required per Section 3 of this procedure.
Findings)
The Pipe Condition Report(21722) for Work Order#297856,pertaining to the 8"Robinson Road
Repair, was not valid since there was no field operations manager signature.
IGC TRANSMISSION RECORDS AUDIT LETTER OF CONCERN— Page 2 of 3

REQUESTED ACTIONS
The above-mentioned item(s) were brought to the attention of IGC compliance
representatives during the inspection. We request that you review these matter(s) and
respond in writing within 30 days regarding the above issue(s) including any planned
corrective actions.
If you have any questions concerning this notice, please contact me at(208) 334-0333. All
written responses should be addressed to me at: 11331 W Chinden Blvd, Ste 201-A,Boise,
ID 83714 or you can fax your response to [phone].
Because of the good faith that you have exhibited up to this time, we expect that you will
take action to bring your program into compliance with pipeline safety regulations.
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sincere y,
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 AUDIT LETTER OF CONCERN— Page 3 of 3