I202616 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 21, 2026 Report# I202616
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck,ND 58501
Dear Mr. Pat Darras,
On August 191h, 2026, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a construction inspection at 660 S Cassandra Ave in Kuna, ID
(WO12712267) 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 VIOLATIONS)
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.
IGC PROBABLE VIOLATIONS LETTER— Page 1 of 4

2. 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
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.
Once marked by the owner of the underground facility, or the owner's agent, the
excavator is responsible for maintaining the markings.
3. OPS 611 Line Locating and Marking
2.LOCATING AND MARKING
2.1. Underground facilities within the area of proposed excavation shall be marked
within reasonable accuracy and within the time limits per the requirements of the
applicable state dig law.
IGC PROBABLE VIOLATIONS LETTER— Page 2 of 4

Finding(s)•
During excavation activities for gas pipeline service installation, locate markings were not
maintained or present for the electric facilities within the excavation path for the gas line.
Reference Photos
NE E SE SW 240 W NW
0106°E(T) OO 43°28-57"N,116°25-35"W±13ft ♦2687ft ®256-W(T) OO 43-28-57"N,116°25-34"W±9ft ♦2692ft
_ �2.ti��i err - :� •4 /� '^'!: r
�' � •�� 'oft -
Active Excavation Overview Facing East Active Excavation Overview Facing West
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 October 5,2026,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 20, 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 October 5, 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,
/P-/--
JeffBrooks
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 4 of 4