I202613 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#I202613
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 41h 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 1146 N Leatherwod Way in Star, ID
(WO12609726) within the Intermountain Gas Company ("IGC") Nampa 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 VIOLATIONS)
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 4192.614 Damage prevention program.
(a) Except as provided in paragraphs (d) and (e) of this section, each operator of a buried
pipeline must carry out, in accordance with this section, a written program to prevent
damage to that pipeline from excavation activities. For the purposes of this section, the
term "excavation activities" includes excavation, blasting, boring, tunneling, backfilling,
the removal of aboveground structures by either explosive or mechanical means, and other
earthmoving operations.
IGC PROBABLE VIOLATIONS LETTER— Page 1 of 4

(c) The damage prevention program required by paragraph (a) of this section must, at a
minimum:
(1) Include the identity, on a current basis, of persons who normally engage in
excavation activities in the area in which the pipeline is located.
(2) Provides for notification of the public in the vicinity of the pipeline and actual
notification of the persons identified in paragraph (c)(1) of this section of the
following as often as needed to make them aware of the damage prevention
program:
(i) The program's existence and purpose; and
(ii) How to learn the location of underground pipelines before excavation
activities are begun.
(3) Provide a means of receiving and recording notification of planned excavation
activities.
(4) If the operator has buried pipelines in the area of excavation activity, provide
for actual notification of persons who give notice of their intent to excavate of the
type of temporary marking to be provided and how to identify the markings.
(5) Provide for temporary marking of buried pipelines in the area of excavation
activity before, as far as practical, the activity begins.
(6) Provide as follows for inspection of pipelines that an operator has reason to
believe could be damaged by excavation activities:
(i) The inspection must be done as frequently as necessary during and after
the activities to verify the integrity of the pipeline; and
(ii) In the case of blasting, any inspection must include leakage surveys.
3. 55-2205. PERMIT COMPLIANCE--NOTICE OF EXCAVATION-- RESPONSE
TO NOTICE-- COMPENSATION FOR FAILURE TO COMPLY--
EXEMPTIONS.
(1) Before commencing excavation, the excavator shall:
(a) Comply with other applicable law or permit requirements of any public agency
issuing permits;
(b) Pre-mark on-site the path of excavation with white paint or, as the circumstances
require, other reasonable means that will set out clearly the path of excavation. An
excavator need not pre-mark as required in this subsection if:
(i) The underground facility owner or its agent can determine the location of the
proposed excavation by street address or lot and block by referring to a locate ticket;
or
(ii) The excavator and underground facility owner have had a meeting prior to the
beginning of the proposed excavation at the excavation site for the exchange of
information required under this subsection.
(c) Provide notice of the scheduled commencement of excavation to all underground
facility owners through a one-number notification service. If no one-number
notification service is available, notice shall be provided individually to those owners
of underground facilities known to have or suspected of having underground facilities
within the area of proposed excavation. The notice shall be communicated by the
excavator to the one-number notification service or, if no one-number notification
service is available, to the owners of underground facilities not less than two (2)
business days nor more than ten (10) business days before the scheduled date for
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commencement of excavation, unless otherwise agreed in writing by the parties.
(2) Upon receipt of the notice provided for in this section, the underground facility
owner or the owner's agent shall locate and mark its locatable underground facilities
with reasonable accuracy, as defined in section 55-2202, Idaho Code, by surface-
marking the location of the facilities. If there are identified but unlocatable underground
facilities, the owner of such facilities or the owner's agent shall locate and mark the
underground facilities in accordance with the best information available to the owner
of the underground facilities. The owner of the underground facility or the owner's
agent providing the information shall respond no later than two (2) business days after
the receipt of the notice or before the excavation time set forth in the excavator's notice,
at the option of the underground facility owner, unless otherwise agreed in writing by
the parties. Excavators shall not excavate until all known facilities have been marked.
4. IGC- Working in Excavations-SF 418
1.4 Employees and contractors shall not begin excavation until the valid start date on the
locate ticket, and/or all utility companies that are listed on the locate ticket have
responded prior to beginning excavation.
5. IGC- OPS 611 Line Locating and Marking
2. LOCATING AND MARKING
2.18.1 All One-Call ticket documentation shall be accessible to MDUG personnel.
Findinds)•
An IGC employee excavated for a service line installation with no hard copy or readily available
electronic copy of a valid dig ticket.
As per the IGC Response to NOPV I202308 (dated November 9th, 2023), "Effective December
1 st, 2023, contractor and company employees will be required to have a hard copy, or a readily
available electronic copy, of the valid line locate ticket on the jobsite". IPUC staff accepted this
response on November 13th, 2023.
IGC PROBABLE VIOLATIONS LETTER— 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 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://pue.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]
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