I202303 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
June 21,2023
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to Notice of Probable Violation dated May 25,2023 (Report#I202303)
Dear Mr.Brooks,
This letter is intended to address one(1)probable violation stemming from a construction inspection conducted by
the Idaho Public Utilities Commission(IPUC)on May 17,2023,on service lines 317-24833 and 317-50850 of
Intermountain Gas Company(IGC).
PROBABLE VIOLATIONS
1. 49 CFR§ 192,605 Procedural manual for operations. maintenance. and emergencies.
(a) 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—Squeeze-Off of Plastic Pipe—OPS 309
2.2.Ground the squeeze-off tool with a static electric grounding device before placing the squeeze-
off tool on the pipe,apply a soapy water solution and wet non synthetic cloth(such as cotton or
burlap material)upstream of squeeze location,or commercially available electrostatic discharge
fluid to the pipe surface on the squeeze location to provide for dissipation of static charge to the
ground.
IGC—Equipment Calibration,Maintenance,and Testing—OPS 501
1.1.Company personnel and contractors are responsible for the calibration,maintenance,and testing
of instruments used on company facilities,and to keep appropriate records of the date and type
of calibration,maintenance,or testing performed.
6.1.Contractors completing work for MDUG shall calibrate/maintain their equipment per the
frequencies and instructions provided in the MDUG Instrument Calibration Requirements List.
6.2.Equipment calibration expiration dates of instruments and equipment used on MDUG gas
facilities shall be identified by a tag(e.g.,sticker).
Finding(s)•
During construction inspection on Service Line#317-24833&317-50850 at 11170& 11182 Newton St.
Caldwell,Idaho,a contractor representing IGC squeezed a service line without using soapy water solution
and wet non synthetic cloth(such as cotton or burlap material)upstream of squeeze location,or
commercially available electrostatic discharge fluid.Additionally,crew members were in the process of
using expired calibration fusing equipment,Cradle(1/12/23),Plate Heater(3/31/23,and Facer(1/12/23),
until IPUC inspector discovered expiration tags.Pictures available upon request of expired calibration tags.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
Intermountain Gas Resgonse
IGC acknowledges the findings brought forth by the IPUC. The contractor, Das-Co of Idaho (Das-Co),
suspended Operator Qualifications for the employee that did not utilize static suppression spray.The employee
will not perform squeeze-off of plastic pipe until retraining has been completed in EWN.
Additionally,IGC management conducted a meeting with the Das-Co Vice President,Natural Gas Operations
on June 15, 2023, regarding butt fusion equipment calibrations. Das-Co has made an enhancement to their
internal process. Each Foreman has been provided a copy of McElroy inspection protocol and will be
responsible for performing inspections and monitoring calibration stickers.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company