I202601 NOPV Response (2)

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
February 23,2026
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to the Notice of Probable Violation dated January 26,2026(Report#I202601)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a construction inspection
conducted by the Idaho Public Utilities Commission(IPUC)on January 22,2026 of Intermountain Gas Company
(IGC)pursuant of Chapter 601 Title,49,United States Code.
PROBABLE VIOLATION
1. 49 CFR 8 192.605 Procedural Manual for Operations. Maintenance. and Emer¢encies
(a) 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.
49 CFR 8 192.53 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.
49 CFR& 192.59 Plastic Pine
(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.
.UPS 11 —Pine 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.
ASTM D2513-20 Standard Specification for Polyethylene WE) Gas Pressure Pine. 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.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]•FAX:[phone]
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
replaced prior to being put in service.
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Intermountain (was Resnnnse
IGC acknowledges the findings brought forth by the IPUC.Following notification from the IPUC on January 22,2026,
Dasco initiated an immediate review of as-built records for all locations where the pipe was installed. Through this
review, Dasco identified two locations in which the expired pipe had been placed into service. As a result, Dasco
assigned a different qualified crew to both locations to remove and replace all expired pipe.This corrective work was
completed on January 23,2026.
On the morning of January 23, 2026,Dasco held a mandatory meeting to review OPS 11—Storage and Handling of
Plastic Pipe and Components.
Additionally,the crew foreman is no longer performing work on IGC job sites.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
4A&4"tL
Pat Darras
Vice President, Engineering& Operations Services
Intermountain Gas Company