I202516 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
November 4, 2025 Report#I202516
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck, ND 58501
Dear Mr. Pat Darras,
On November 4th, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division("Staff'), conducted a procedures 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 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.
IGC PROCEDURES AUDIT PROBABLE VIOLATIONS LETTER— Page 1 of 3

2. 49 CFR 4192.625 Odorization of gas.
(b) After December 31, 1976, a combustible gas in a transmission line in a Class 3 or Class
4 location must comply with the requirements of paragraph(a) of this section unless:
(1)At least 50 percent of the length of the line downstream from that location is in a
Class 1 or Class 2 location;
(2) The line transports gas to any of the following facilities which received gas without
an odorant from that line before May 5, 1975;
(i) An underground storage field;
(ii) A gas processing plant;
(iii) A gas dehydration plant; or
(iv)An industrial plant using gas in a process where the presence of an odorant:
(A) Makes the end product unfit for the purpose for which it is intended;
(B) Reduces the activity of a catalyst; or
(C) Reduces the percentage completion of a chemical reaction;
(3) In the case of a lateral line which transports gas to a distribution center, at least 50
percent of the length of that line is in a Class 1 or Class 2 location; or
Finding(s)•
IPUC staff identified a procedural violation pertaining to the odorization of transmission lines in
class 3 or class 4 locations. OPS 612 does not mention Class 3 or Class 4 odorization as required
per 192.625(b).
IGC PROCEDURES AUDIT 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 December 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 December 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 December 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,
Jef Brooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
IGC PROCEDURES AUDIT PROBABLE VIOLATIONS LETTER— Page 3 of 3