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Home My WebLink AboutI202511 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 September 2, 2025 Report# I202511 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 Public Awareness 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 4192.605 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 4192.616 Public awareness. (d) The operator's program must specifically include provisions to educate the public, appropriate government organizations, and persons engaged in excavation related activities on: (1) Use of a one-call notification system prior to excavation and other damage prevention activities; (2) Possible hazards associated with unintended releases from a gas pipeline facility; (3) Physical indications that such a release may have occurred; (4) Steps that should be taken for public safety in the event of a gas pipeline release; IGC PUBLIC AWARENESS PROBABLE VIOLATIONS LETTER— Page 1 of 4 and (5) Procedures for reporting such an event. 3. OPS 616 Public Awareness Program Procedures and Forms 3.4_ Excavators Stakeholder Audience Definition List Identification Audience Excavators Companies who are involved with known The excavator list will be determined excavation. ith MDUG territory. through SIC codes, operator recommendations, the one call process, third-party damages, and contractors used by MDUG. PADP,with the help of Field Operations,shall review the list annually and make needed updates- 3-6- Operated Pipeline Owners Stakeholder Audience Definition List Identification Audience Operated MDUG coordinates with the operated pipeline Refer to Aftpendix 3 of this pipeline owners covered under this program. procedure. o'.vners 4.4_ Excavators Stakeholder Baseline Messaging Supplemental Enhancement Audience Excavators Message: Message: Pipeline purpose and reliability. May include,but not limited to: Awareness of hazards and prevention State Dig Laws. measures undertaken. Safe excavation practices_ Damage prevention awareness and one call Leak recognition and response. requirements. Additional resources (e.g., MDUG Potential hazards of products transported. contacts, Once Call Center contacts, How to recognize a pipeline leak. Common Ground Alliance). Response to a pipeline leak. How to report a leak/damage. Frequency: Liaison with emergency officials. As needed. Pipeline marker awareness. National pipeline mapping system (NPMS). As requested by Excavators_ How to get additional information. Delivery method: Frequency: Virtual and/or in person meetings. Once annually. Delivered by: Delivery method: PADP. Direct mailer. Note: Delivered by: One Call Centers periodically Third-Party Vendor. provide call before you dig outreach to excavators via advertising and/or onlinetin person trainin s. IGC PUBLIC AWARENESS PROBABLE VIOLATIONS LETTER— Page 2 of 4 4.6. Operated Pipeline O,.ners Stakeholder Baseline Messaging Supplemental Enhancement Audience Operated h1DUG coordinates with the operated pipeline N/A pipeline ovmers covered under this program and list in owners Apcendix 3 to create and maintain message content to ensure an effective Public Awareness Program. It is anticipated that these companies will have message types and content similar to MDUG for each stakeholder group for their respective pipelines. Findin2(s) MDU personnel stated they participate in a Quarterly Meeting with PANW, which includes representatives from Marathon and Williams. This engagement serves as an indirect outreach effort for promoting public awareness and damage prevention initiatives. Marathon should be included in direct outreach efforts for public awareness and advancing damage prevention initiatives as an excavator or operated pipeline owner. 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 October 17, 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 2, 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 October 17, 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 PUBLIC AWARENESS PROBABLE VIOLATIONS LETTER— Page 3 of 4 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:(208)334-0300 Facsimile:(208)334-3762 IGC PUBLIC AWARENESS PROBABLE VIOLATIONS LETTER— Page 4 of 4