I202606 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 30, 2026 Report# I202606
Pat Darras —Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck, ND 58501
Dear Mr. Pat Darras,
On April 28-29, the Idaho Public Utilities Commission("Commission"), Pipeline Safety
Division ("Staff'), conducted a sample damage prevention and line marker audit of
Intermountain Gas Company ("IGC"), in the Boise District 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§192.605 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 CFR � 192.616 Public Awareness
(a) Except for an operator of a master meter or petroleum gas system covered under
paragraph 0) of this section, each pipeline operator must develop and implement a written
continuing public education program that follows the guidance provided in the American
Petroleum Institute's (API) Recommended Practice (RP) 1162 (incorporated by reference, see
§ 192.7).
(b) The operator's program must follow the general program recommendations of API RP
1162 and assess the unique attributes and characteristics of the operator's pipeline and
facilities.
IGC BOISE DISTRICT LINE MARKERS PROBABLE VIOLATIONS LETTER— Page 1 of 5

(c) The operator must follow the general program recommendations, including baseline and
supplemental requirements of API RP 1162, unless the operator provides justification in its
program or procedural manual as to why compliance with all or certain provisions of the
recommended practice is not practicable and not necessary for safety.
API RECOMMENDED PRACTICE 1162
Public Awareness Programs for Pipeline Operators
4.5 Damage Prevention
Because even relatively minor excavation activities can cause damage to a pipeline or its
protective coating or to other buried utility lines, it is important that operators raise the
awareness of the need to report any suspected signs of damage. Operators should keep their
damage prevention message content consistent with the key"Dig Safely" messages
developed by the Common Ground Alliance (CGA). CGA contact information is located in
Appendix A.
Table 2-1 - Summary Public Awareness Communications for Hazardous Liquids and Natural
Gas Transmission Pipeline Operators
4.6 PIPELINE LOCATION INFORMATION
4.6.1 Transmission Pipeline Markers
The audience should know how to identify a transmission pipeline ROW by recognition of
pipeline markers especially at road crossings, fence lines and street intersections
5.7 PIPELINE MARKER SIGNS
The primary purposes of aboveground transmission pipeline marker signs are to:
Mark the approximate location of a pipeline
Provide public awareness that a buried pipeline or facility exists nearby
Provide a warning message to excavators about the presence of a pipeline or pipelines
Provide pipeline operator contact information in the event of a pipeline emergency and
Facilitate aerial or ground surveillance of the pipeline ROW by providing above-ground
reference points.
3. 49 CFR 4 192.703 General
No person may operate a segment of pipeline, unless it is maintained in accordance with this
subpart
4. 49 CFR 4 192.707 Line markers for mains and transmission lines.
(a) Buried pipelines. Except as provided in paragraph(b) of this section, a line marker must
be placed and maintained as close as practical over each buried main and transmission line:
(1) At each crossing of a public road and railroad; and
(2) Wherever necessary to identify the location of the transmission line or main to reduce
the possibility of damage or interference.
(c) Pipelines aboveground. Line markers must be placed and maintained along each section
of a main and transmission line that is located aboveground in an area accessible to the
public.
5. 49 CFR 4 192.1007 What are the required elements of an integrity management plan?
(b) Identify threats. The operator must consider the following categories of threats to each
IGC BOISE DISTRICT LINE MARKERS PROBABLE VIOLATIONS LETTER— Page 2 of 5

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 BOISE DISTRICT LINE MARKERS PROBABLE VIOLATIONS LETTER— Page 3 of 5

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.
Finding(s)•
Staff identified—63 pipeline markers that were missing, damaged, faded, or otherwise illegible,
resulting in noncompliance with required visibility and identification standards for belowground
and aboveground pipelines. See Exhibit A below for example photographs and GPS-referenced
locations of the inadequate markers and Maloney posts.
IGC BOISE DISTRICT LINE MARKERS 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 June 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://pue.idaho.gov/. If you intend to request an informal conference,please contact the
Pipeline Safety Division no later than May 30, 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 June 14, 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 [phone]. All
written responses should be addressed to me at the above address, or you may fax your response
to [phone].
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 BOISE DISTRICT LINE MARKERS PROBABLE VIOLATIONS LETTER— Page 5 of 5

1 '
3271-4199 S Ten Mile Rd Meridian ID 1980 E Hubbard Rd Kuna ID 83634 2210 E Hubbard Rd Kuna ID 83634
-1'
P`
Ar
""`�vli9s+n9 signage
27 Apr 2025,15 00:42
3294 W Twin View Ln Meridian ID 3373 W Twin View Ln Meridian ID 4201-4625 S Ten Mile Rd Meridian ID
r
4626-4680 S Ten Mile Rd Meridian ID 4200-4624 S Ten Mile Rd Meridian ID 3188 W Ballard Ln Meridian ID
l
i
t.`
}

2701-2999 W Berryman Ln Meridian ID 5975-5983 S Ten Mile Rd Kuna ID fi485 S Ten Mile Rd Kuna ID
.0
pr
fifi70 S Donaway Ave Kuna ID fi788 S Donaway Ave Kuna ID 7152-7626 S Ten Mile Rd Meridian ID
2829 N KlemmerAve Kuna ID 3003 N Ten Mile Rd Kuna ID 2201-2471 W Hubbard Rd Kuna ID
r
� r

2901-3025 W Hubbard Rd Kuna ID 2155-2289 N Ten Mile Rd Kuna ID 1513-1599 N Ten Mile Rd Kuna ID
R-
h..
-
�,
Kuna ID 292 W Boise St Kuna ID 145-199 SH-69 Kuna ID
I
605 Swan Falls Rd Kuna ID 1001-1153 Swan Falls Rd Kuna ID 1241-1399 Swan Falls Rd Kuna ID
am
-�

1807 Swan Falls Rd Kuna ID 1900-2402911 1
0 6{0°NE(T)*43°28'19"N,116°24'49"W±9ft♦2748ft 0 88-E(T)t$43'2814'N,116-24-48-W±9ft♦2753ft O 10°N(T)' 43"28'13"N,116°24'48"W±13ft•2758ft
2456 Swan Falls Rd Kuna ID 2426-2538 Swan Falls Rd Kuna ID 2452 Swan Falls Rd Kuna ID
I
ri
0 74°E(T)0 43°28'1"N,116°24'49'W±9ft•2773ft 0 63-NE(T) 43'27'56"N,116'24'49"W±6ft♦2782ft 0 68°E(T) 43°27'57"N,116"24'47"W t108ft♦2782ft
r� Noma
2541-2869 Swan Falls Rd Kuna ID 2777 Swan Falls Rd Kuna ID IF-1
2870-3106 Swan Falls Rd Kuna ID
O 171-S(T)*43'27'52"N,116°24'49"W±22ft♦27911t 0179°S(T): 43'27'49"N,116"24'49"W 122ft♦2797ft 0100"E M 43"27'46"N,116'24'49'W±6ft♦2795ft
�r

355 E Stagecoach Way Kuna ID 1920-1922 E Deer Flat Rd Kuna ID 2719-2859 E Deer Flat Rd Kuna ID
1 1 1 1 1
,,. z �
f
2961-3053 E Deer Flat Rd Kuna ID 2961-3053 E Deer Flat Rd Kuna ID 1857 N Locust Grove Rd Kuna ID
s.: r
-'wn�i i4. 'Y���.•�'"" �, �ri )..� ��i^�•E � X'+...--."'si h`eL� �. � F
- Sr , 7 .k:. .:...�.:-
1600-1742 N Locust Grove Rd Kuna ID 1600-1742 N Locust Grove Rd Kuna ID 2252-2398 N Locust Grove Rd Kuna ID
f.

2252-2398 N Locust Grove Rd Kuna ID 2400-2412 N Locust Grove Rd Kuna ID 2400-2412 N Locust Grove Rd Kuna ID
I �-
•� a a _ `
2414-2498 N Locust Grove Rd Kuna ID 3150 N Locust Grove Rd Kuna ID S Locust Grove Rd Kuna ID
P"
I
R
9217-9249 S Locust Grove Rd Kuna ID 9217-9249 S Locust Grove Rd Kuna ID 1401 E Mallory Ln Meridian ID

8940 S Locust Grove Rd Meridian ID 8475 Stewart Rd Meridian ID 83642 8801-8871 Stewart Rd Meridian ID 83642
<r fit, , Y
A �
t
,,... ., �K
3890 E Hubbard Rd Meridian ID 83642 3110 E Hubbard Rd Meridian ID 83642 3032 E Hubbard Rd Meridian ID 83642
�- ►
�.s '' �. � /...;i:���r i:�, ` :4e � �✓ acsr is far«gw.,' a,•.._..�'
K ,.se v"'a f a QK K,f � r►�,'( L, r t• � �T �y�i des a
s�J' q F'�� k tr.f¢ t 9.p" ? .UF;w •.. / � '., yx r J .
' .-�'a °� th�Z• x r w s .,; r Mlsstrig sS9 na L.,
,Z7 Ape 2026 143 5�;�
2866-3090 E Hubbard Rd Meridian ID 83642 2480 E Hubbard Rd Meridian ID 83642 2502 E Hubbard Rd Kuna ID 83634
j
1 I
K-j ,'i A{:r
elm
•