L202502 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 22, 2025 Report#L202502
James Webb—President& Chief Executive Officer
Lower Valley Energy, Inc
P.O Box 188
Afton, WY 83110
Dear Mr. James Webb,
On September 15th& 16th,the Idaho Public Utilities Commission("Commission"),Pipeline Safety
Division ("Staff'), conducted a construction inspection on the Crow Creek Pipeline Project of
Lower Valley Energy ("LVE")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 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 4192.756 Joining plastic pipe by heat fusion equipment maintenance and
calibration.
Each operator must maintain equipment used in joining plastic pipe in accordance with the
manufacturer's recommended practices or with written procedures that have been proven
by test and experience to produce acceptable joints.
LVE CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER— Page 1 of 3

3. Lower Valley Energy, Weld inP,-Fusion-Mechanical Fitting Manual (June 7, 2017)
Section H-HEAT FUSION PROCEDURES
2.3 Procedure
B. Both surfaces of the heating tool should be free of any accumulation of carbon and
plastic residue
Findings):
LVE contracted employees fused with a dirty heater surface on both fast fusion machines.
Per the Lower Valley Energy, Welding-Fusion-Mechanical Fitting Manual, "both surfaces of the
heating tool should be free of any accumulation of carbon and plastic residue".
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 November 6, 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://pue.idaho.gov/. If you intend to request an informal conference,please contact the Pipeline
Safety Division no later than October 22, 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 November 6,2025, 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.
LVE CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER— Page 2 of 3

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,
;o--
Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
LVE CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER— Page 3 of 3