E202601 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
March 4, 2026 Report#E202601
Mr. Judd Cook
VP & General Manager, Western Distribution
Enbridge Gas
PO Box 45360
Salt Lake City, UT 84145-0360
Dear Mr. Judd Cook,
On February 23-25,2026,the Idaho Public Utilities Commission("Commission"),Pipeline Safety
Division ("Staff'), conducted a Control Room Management (CRM) audit of Enbridge Gas
pursuant to Chapter 601 of Title 49, United States Code.
Staff identified that some of the Idaho natural gas system(s) owned and operated by Enbridge Gas
("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 emerEencies.
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 W2.631 Control Room Management.
(c) Provide adequate information. Each operator must provide its controllers with the
information, tools, processes and procedures necessary for the controllers to carry out the
roles and responsibilities the operator has defined by performing each of the following:
(2) Conduct a point-to-point verification between SCADA displays and related
field equipment when field equipment is added or moved and when other changes
that affect pipeline safety are made to field equipment or SCADA displays;
NOTICE OF PROBABLE VIOLATION—E202601 Page 1 of 4

3. 49 CFR 4192.631 Control Room Management.
(g) Operating experience. Each operator must assure that lessons learned from its
operating experience are incorporated, as appropriate,into its control room management
procedures by performing each of the following:
(2) Include lessons learned from the operator's experience in the training program
required by this section.
4. Control Room Management Plan
5.3 Point to Point Verification
192.631(c)(2)
Points defined as safety related are associated with safety related alarms as discussed
in the Alarm Management Plan.
The company conducts a point-to-point verification between the SCADA displays and
related field equipment when:
• Field equipment is added, moved, replaced and/or repaired.
• SCADA equipment is added, moved, replaced and/or repaired.
• Any other change that affects pipeline safety is made to field equipment or
SCADA displays.
Examples of changes in the field or on SCADA that require the point-to-point verification
procedure to be made for:
• Changes to existing SCADA displays (additions or deletions)with no change in
• field equipment
• Transmitter replacement
• RTU replacement
• Conversion to a new SCADA system provided the old SCADA system and new
• SCADA system will not run in parallel operation to verify SCADA data is
accurate
• New installations (regulating, metering)
• Replacement of equipment(regulating or metering)
• Retirement of equipment
The company has no set interval to repeat a point-to-point test unless equipment has
been added, moved, or changed.
The SCADA IT Support Team maintains the procedure for this point-to-point
verification and corresponding documentation.
For more details refer to Gas SCADA Point to Point Verification Procedure for
192.631(c)(2).
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Finding(s)•
Enbridge staff were unable to produce documentation verifying that all required elements of the
point-to-point verification process had been completed, including but not limited to functional
confirmation of the High-High, High, Low, and Low-Low alarm setpoints.
Enbridge staff failed to provide adequate documentation demonstrating that training materials
incorporate lessons learned from near misses,post-rupture investigations, operational or
maintenance errors, emergency response exercises,or applicable industry best practices,and
therefore could not show that such information had been integrated into training programs and
operating procedures as required.
NOTICE OF PROBABLE VIOLATION—E202601 Page 3 of 4

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 April 18,2026, 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 April 3, 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 April 18, 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]
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