L202503 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
December 8, 2025 Report#L202503
James Webb—President & Chief Executive Officer
Lower Valley Energy, Inc
P.O Box 188
Afton, WY 83110
Dear Mr. James Webb,
On December 1, the Pipeline Safety Division ("Staff') of the Idaho Public Utilities Commission
("Commission" or "IPUC") issued a written request, transmitted via the attached email to Mr.
Coles, seeking information regarding the pressure test conducted on the Crow Creek Pipeline
Project operated by Lower Valley Energy ("LVE"). Said request was made pursuant to, and in
accordance with, the requirements set forth under Chapter 601 of Title 49 of the United States
Code.
On December 1, Staff received a written reply to the email correspondence (attached). Upon
review, Staff observed that certain portions of the Idaho natural gas system(s) owned and operated
by Lower Valley Energy("Company")were not in compliance with applicable requirements. Such
non-compliance constitutes probable violations of the pipeline safety regulations codified at Title
49 of the Code of Federal Regulations, Part 192. The probable violations are identified 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.
LVE CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER— Page 1 of 5

Lower Vallev Energy, Welding-Fusion-Mechanical Fitting Manual (April 17,2020)
Section H-HEAT FUSION PROCEDURES
1.0 PROCEDURES FOR HEAT FUSION
1.1 General
The appropriate manufacturer's qualification procedures and fusion procedures are
incorporated into this manual by reference.
Finding(s)•
Lower Valley Energy, Welding-Fusion-Mechanical Fitting Manual (April 17,2020)
This manual expressly incorporates by reference the applicable manufacturer's
qualification and fusion procedures required to ensure compliant installation and joining
practices. Notwithstanding the foregoing, it is hereby clarified that the procedures set
forth in the Georg Fischer Electro Fusion Installation and Training Manual Part Number
10014339 Revision 912017(attached) are not incorporated by reference and are not
included within the procedures referenced in this manual.
Lower Valley Energy, Welding-Fusion-Mechanical Fitting Manual (April 17, 2020)
Section H-HEAT FUSION PROCEDURES
5.0 JOINING PLASTIC PIPE WITH ELECTROFUSION BOX AND FITTINGS
5.1 General
This procedure is to provide instructions for fusing plastic pipe and fittings using an
Electrofusion system. This procedure will be followed by personnel trained and qualified
to operate the Electrofusion equipment.
5.3 Equipment
The equipment used for this procedure shall consist of the following:
A. Central Electrofusion Box.
B. Appropriate wattage generator(5,000 Watts minimum).
C. Clean rags or paper towels.
D. Clamps and Scrapers.
E. PE pipe cutters.
F. Under clamps (if installing tapping tee).
LVE CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER— Page 2 of 5

5.4 Procedure
For proper fusion using an electrofusion coupling, the following shall apply:
A. Select the appropriate coupling.
B. Mark one pipe end at a distance slightly more than one coupling length from the
pipe end and the joining pipe end at a distance slightly more than one half of a
coupling length from the other pipe end.
C. Ensure that the pipe surfaces are clean. (If there are gouges in the pipe fusion area,
remove the gouges using a appropriate scraping tool. If the gouges are deeper that
10% of the pipe wall, cut out the damaged section of pipe.
D. Scrape the ends of the pipe by clamping the scraper onto the pipe so that the
wheels are flush with the pipe end.
E. Rotate the scraper in the direction of the arrow located on the scraper. (As the
scraper is rotated, the scraper advances down the pipe removing the outer surface
of the pipe. Do not push the scraper to advance along pipe or areas will be
skipped.)
F. Continue until the scraper blade passes the markings on the pipe.
G. Disengage the scraper from the pipe and inspect the pipe section for complete and
uniform surface removal.
H. Remove any shavings from the pipe, being careful not to touch or contaminate the
pipe that has been scraped.
I. Insert the coupling onto one end of the pipe until the pipe end is flush with the end
of the pipe fitting. (Marks placed earlier on the pipe will help with the
measurement.)
J. Align the other pipe end with the coupling and slide the coupling over the end of
the second pipe until the coupling is centered over the gap.
K. Check the alignment of the pipe ends. (If needed, alignment clamps can be used to
assist with the alignment.)
GF Central Plastics +GF+, ELECTROFUSION INSTALLATION AND TRAINING
MANUAL.GEORG FISCHER PIPING SYSTEMS,Part Number 10014339 Revision
9/( 2017)
Page 20-Assembly Clamping
Assembly clamps are always required for saddle fusions to hold the fitting to the pipe using
the correct amount of pressure in right places. Assembly clamps for couplings are also
necessary to ensure that the area of the fusion is not subject to bending, binding, or
movement. Under ideal conditions a coupling may even feel loose between the clamps on
the pipe before fusion. Assembly clamps also offer protection from accidental movement
during the cooling cycle that will disturb the joint. Assembly clamps can also provide the
added benefit of re-rounding pipe ends. The primary goal is to ensure that the pipe and
fitting assembly are stable, free of external stresses, and immobile until the cooling time
has been achieved.
Clamping of Couplings: Clamps for couplings and reducers are designed to align and
restrain the pipe ends on either side of the coupling. The coupling itself is not clamped and
is free between the clamps:
LVE CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER— Page 3 of 5

Page 22-Coolin
Proper observation of cooling time is important. During the heating phase of the fusion
process the PE material of the pipe and fitting is heated to melting in order to allow co-
mingling of the molecular structures. As the materials cool and co-crystallize into a solid
state again the structures cannot be disturbed. PE is a thermoplastic that softens when
heated and does not regain its full strength until cooled. Cooling time is typically expressed
by three different terms in the following tables for fusion and cooling times:
1. Clamped cooling time: The minimum time the fitting must remain clamped after the
fusion cycle is complete. This is the time displayed by the control box.
Page 28-Installation Training Procedures
Electrofusion Coupling Installation Procedure
8.0 Insert the pipe ends into the coupling to the stab depth marks. Secure the pipe and fitting
assembly in an alignment clamp.
Finding(s):
Lower Valley Energy, Welding-Fusion-Mechanical Fitting Manual (April 17, 2020)
On 21 November 2025, an inspector from the Idaho Public Utilities Commission
("IPUC") witnessed the installation of a twelve-inch Georg Fischer electrofusion
coupling(Part No. 360000939) in proximity to the Williams Pipeline Tap located in
Montpelier, Idaho. The installation was conducted without the use of the assembly
clamps mandated by the applicable manufacturer's procedures and regulatory
requirements.
LVE CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER— Page 4 of 5

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 January 22, 2026, 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 January 7, 2026.
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 January 22, 2026, 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,
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 5 of 5