I202604 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
April 16, 2026 Report# I202604
Pat Darras—Vice President of Engineering&Operations Services
Intermountain Gas Company
400 N 0 St.
Bismarck,ND 58501
Dear Mr. Pat Darras,
On April 16th, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety Division
("Staff'), conducted a sample damage prevention and line marker audit in the Nampa District 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.
49 CFR� 192.703 General
(a) No person may operate a segment of pipeline, unless it is maintained in accordance
with this subpart.
IGC NAMPA LINE MARKERS PROBABLE VIOLATIONS LETTER— Page 1 of 10

2. 49 CFR& 192.1007 What are the required elements of an integrity management plan?
(b) Identify threats. The operator must consider the following categories of threats to each
gas distribution pipeline: Corrosion (including atmospheric corrosion), natural forces,
excavation damage, other outside force damage, material or welds, equipment failure,
incorrect operations, and other issues that could threaten the integrity of its pipeline. An
operator must consider reasonably available information to identify existing and potential
threats. Sources of data may include incident and leak history, corrosion control records
(including atmospheric corrosion records), continuing surveillance records, patrolling
records, maintenance history, and excavation damage experience.
(c) Evaluate and rank risk. An operator must evaluate the risks associated with its
distribution pipeline. In this evaluation, the operator must determine the relative
importance of each threat and estimate and rank the risks posed to its pipeline. This
evaluation must consider each applicable current and potential threat, the likelihood of
failure associated with each threat, and the potential consequences of such a failure. An
operator may subdivide its pipeline into regions with similar characteristics (e.g.,
contiguous areas within a distribution pipeline consisting of mains, services and other
appurtenances; areas with common materials or environmental factors), and for which
similar actions likely would be effective in reducing risk.
OPS 705 Gas Pipeline Markers and Signs Installation and Inspection
5. INSPECTION & MAINTENANCE
5.1. Pipeline markers shall be inspected at least every five (5) years, not to exceed 63
months. Pipeline markers shall be inspected and documented during leak surveys in
accordance with OPS 706—Leak Survey.
5.5. Pipeline markers and signs shall be inspected for damage and overgrowth that may
obscure their visibility. Damaged, worn out, or missing signs shall be marked as a
deficiency.
5.6. During the survey/inspection of signs and pipeline markers, the surveyor(s) shall
ensure that pipeline markers and signs have the following, written legibly on the sign or
pipeline marker(not applicable for Waterway Crossing or Deterrent Custom Signage):
5.6.1. "Caution," "Warning," or "Danger" followed by "Gas Pipeline" or "Natural Gas
Pipeline" in letters at least one (1") inch high with one-fourth('/") inch stroke.
5.6.2. The appropriate MDUG organization and emergency phone number:
5.7. The pipeline marker or sign shall have a background of sharply contrasting color so
that the information stated on the sign or marker is easily visible.
OPS 1000 Distribution Integrity Management Plan
3.2.3. Excavation Damage
Excavation damage is damage to pipeline facilities caused by earth moving or other
equipment, tools, or vehicles, including damage done by operator's personnel, contractor,
or people not associated with the operator. All buried facilities in MDUG's distribution
system face the threat of being damaged by excavation activities. Consideration is given to
piping within protective casings, inside underground structures such as basins or vaults
which may be shielded or protected from excavation damage. Excavation damage can also
be due to previous unknown damage on pipelines that were not repaired and result in
corrosion.
IGC NAMPA LINE MARKERS PROBABLE VIOLATIONS LETTER— Page 2 of 10

5.1. Overview
This section describes the existing and proposed measures to address the threats and
associated risk to MDUG's distribution system as outlined in Sections 3.0: Threat
Identification and 4.0: Risk Evaluation and Ranking.
Risk management is accomplished by taking actions to reduce the likelihood of an
occurrence, by alleviating the consequences of an occurrence or both. Appropriate actions
are dependent on the group being addressed, the associated threat, whether the threat is
current or potential in the future, and the viability of the actions in managing the relevant
risk factors.
5.2. Existing Programs Addressing Risk Management
This section summarizes existing plans and programs implemented by MDUG that are
currently in place to manage risks. Each established program contributes to the
management and mitigation of risk to the distribution system. Details for each program are
contained in MDUG operations and maintenance procedures and are available upon
request.
5.2.1. Damage Prevention
The prevention of damage to natural gas distribution facilities by excavation is one of the
most effective ways of increasing the integrity of the gas system and improving public
safety relative to natural gas.MDUG has implemented and maintains a Damage Prevention
Program, OPS 614, that meets the following criteria:
-Meets or exceeds the requirements of§192.614—Damage Prevention Program.
-Participates in One-Call programs within service territory.
-Supports the Common Ground Alliance (CGA) efforts to reduce excavation damage
through the publication and dissemination of best practices.
OPS 610 Pipeline Patrolling and Continuing Surveillance
2.2.4. Pipeline markers are installed, visible, and legible with correct contact information.
OPS 403 Section 2 INSPECTION CRITERIA
2.13 Inspect pipeline markers.
2.13.1 Inspection includes the condition of existing pipeline marker or the need to add
a pipeline marker(s) for better visibility of the HPSS or farm tap. Examples include the
following:
2.13.1.1 In the right-of-way or near high traffic areas.
2.13.1.2 In vegetation that obscures visibility.
2.15 Inspect pipeline markers.
2.15.1 Inspection includes the condition of existing pipeline marker(s) or the need to
add a pipeline marker(s) for better visibility of the meter set, HPSS, or farm tap.
2.15.2 Check that pipeline markers are visible and legible with correct contact
information.
IGC NAMPA LINE MARKERS PROBABLE VIOLATIONS LETTER— Page 3 of 10

Finding(s)•
Staff identified—37 pipeline markers that were missing,damaged, faded, or otherwise illegible,
resulting in noncompliance with required visibility and identification standards for underground
pipelincs. In addition, locate wires were found disconnected within multiple Maloney posts,
preventing proper tracing and identification of the buried pipeline facilities.
See Exhibit A below for example photographs and GPS-referenced locations of the affected
markers and Maloney posts.
IGC NAMPA LINE MARKERS PROBABLE VIOLATIONS LETTER— Page 4 of 10

Exhibit A
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IGC NAMPA LINE MARKERS PROBABLE VIOLATIONS LETTER— Page 9 of 10

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 May 31, 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 May 15,2026.
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 May 31, 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]
IGC NAMPA LINE MARKERS PROBABLE VIOLATIONS LETTER— Page 10 of 10