I202612 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
August 6, 2026 Report#I202612
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 4th St.
Bismarck, ND 58501
Dear Mr. Pat Darras,
On August 61h, 2026, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a construction inspection at 203 E Tower Lane, Meridian, ID (W/O
12674425) within the Intermountain Gas Company ("IGC") 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 and Idaho Legislation Title 55,
Chapter 22. 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.
2. OPS 614 Damage Prevention Program.
PURPOSE
To enhance public safety and protection of MDU Utilities Group (MDUG) gas, electric,
and other owned and operated underground facilities from excavation damages through
educational outreach and implementation of safe excavation best practices.
IGC PROBABLE VIOLATIONS LETTER— Page 1 of 3

REFERENCES
External References:
49 CFR §192.614 Damage Prevention Program
ID 55 Chapter 22 Underground Facilities Damage Prevention
3. Idaho's Guide to Safe Digging 2026-2027
55-2205. PERMIT COMPLIANCE—NOTICE OF EXCAVATION RESPONSE
TO NOTICE COMPENSATION FOR FAILURE TO COMPLY—EXEMPTIONS.
(5) If the excavator, while performing the excavation, discovers underground
facilities (whether active or abandoned) that are not identified or were not located in
accordance with subsection(2) of this section, the excavator shall cease excavating in
the vicinity of the facility and immediately notify the owner or operator of such facilities,
or the one-number notification service.
Findiny_W:
During excavation to locate a 4-inch PE main, an IGC contractor struck and damaged an unmarked
purple conduit that was later identified as belonging to Lumen Technologies. Following the strike,
the operator did not immediately cease excavation activities or notify the affected utility, as
required, and instead continued excavating.
Reference Photojqaphs
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IGC PROBABLE VIOLATIONS LETTER— 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 September 20, 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 September 5, 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 September 20,2026,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 PROBABLE VIOLATIONS LETTER— Page 3 of 3