I202601 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
January 28, 2026 Report# I202601 Rev.I
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 4th St.
Bismarck,ND 58501
Dear Mr. Pat Darras,
On January 22nd,the Idaho Public Utilities Commission("Commission"),Pipeline Safety Division
("Staff'), conducted a construction inspection 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 CFR4 192.53 General.
Materials for pipe and components must be:
(a) Able to maintain the structural integrity of the pipeline under temperature and other
environmental conditions that may be anticipated;
(b) Chemically compatible with any gas that they transport and with any other material in
the pipeline with which they are in contact; and
(c) Qualified in accordance with the applicable requirements of this subpart.
NOTICE OF PROBABLE VIOLATION I202601 REV.1— Page 1 of 3

3. 49 CM 192.59 Plastic pipe.
(a) New plastic pipe is qualified for use under this part if:
(1) It is manufactured in accordance with a listed specification;
(2) It is resistant to chemicals with which contact may be anticipated; and
(3) It is free of visible defects.
4. OPS 11 — Pipe Storage
Section 1 —Storage
1.1. Code E PE pipe as defined by ASTM D3350 (e.g., yellow pipe) and yellow PA-11
outdoor storage shall not exceed three (3)years from the date of manufacturer.
5. ASTM D2513-20 Standard Specification for Polyethylene (PE) Gas Pressure Pipe,
Tubing, and Fittings
Section 4.10 UV Resistance—PE materials shall be Code C or E as defined in
Specification D3350. Code C material shall contain 2 to 3 percent well dispersed carbon
black, and due to the absorptive properties of the carbon black, is considered to be
stabilized against deterioration from unprotected exposure to UV for not less than 10 years.
Code E material shall be stabilized and protected against deterioration from unprotected
UV exposure for not less than 3 years.
Finding(s):
IPUC staff identified expired PE piping being installed at 792 N Traquair Place. The expired
pipe was dated 12-1-2022 which conflicted with IGC OPS 11 and ASTM D2513 that stated
maximums of 3 years. No UV documentation was provided to show that the piping was
protected from exposure. The expired PE pipe was adequately replaced prior to being put in
service.
® Local— U.—de01'N(T}•4167146 116.45297E:9It 2WOH
B—cle TR0cunlilG812 YhC '
Time SlamP 1.2:1Lo_u 1 :AM
Material FE=-A. L
Sub Category Coll—
Category Rpr
Lot ..?;;of 1
Production Date 12,1':022 F
Dlameter o.4'FS -
SDR 11
Wall Thickness(in) 0-rb
Manufacturer Teel>'asUcs
Manufacturer Contact Chu sl an 1 er.
f
Pipe Data and Spool Overview
Date Close U
NOTICE OF PROBABLE VIOLATION I202601 REV.1— 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 March 14,2026, 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 February 27, 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 March 149 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]
NOTICE OF PROBABLE VIOLATION I202601 REV.1— Page 3 of 3