I202101 LOC Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
February 18,2021
Mr.Darrin Ulmer,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to Area of Concern dated January 26,2021 (Report#I202101)
Dear Mr.Ulmer,
This letter is intended to address one area of concern stemming from a January 25,2021 on-site construction
inspection of the 318-57FS-123 project located at 605 North 7t'Street,Parma,Idaho in Intermountain Gas
Company's(IGC)Nampa District. Specifically,we are addressing how we plan to bring the area of concern into full
compliance.
AREA OF CONCERN
1. 49 CFR§192.605(a)(1)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.
Finding:
During the inspection it was noted that the DAS-CO welding crew employed by IGC,when asked about
preheating prior to welding,did not have a operational and calibrated infrared pyrometer to check the
preheat temperature at the weld groove and weld area as required by IGC Operations and Maintenance
Manual procedure 4106.1 (1.16.1). This area of concern has been a previous issue brought to your
company's attention.
Intermountain Gas Resgonse
IGC acknowledges the Das-co of Idaho crew working at 605 North 7th Street in Parma on January 25,2021 had
an infrared pyrometer with an expired calibration date. Das-co was performing an in-service weld using
Welding Procedure Specification(WPS)6A which does not require preheat. (See Figure 1.) Step 1.15. of IGC
standard operating procedure 4106 —Welding General Standards states, "Preheating shall be in accordance
with the WPS;"therefore, step 1.16.1. was not required for this in-service weld.
To immediately address this area of concern,a Critical—Compliance Message has been resent to MDU Utilities
Group personnel and Contractors from the Director, Operations Services. (See Figure 2.)
To determine the root cause of the area of concern and what additional remedial action is required, IGC is
performing a comprehensive review of current construction inspection practices, Quality Control inspection
practices, and Contractor equipment calibration tracking practices. IGC will respond in writing by May 28,
2021 with the results of this review and a schedule of the required remedial action(s).

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD•P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
Figure 1
Welding Procedure Specifications 6A
EWi
WELDING PROCEDURE SPECIFICATION NO.: WPS OA REVISION 4
DATE August 21.2012
STANDARD- API 1104 20'"Edrbon Appendix B
SUPPORTING PROCEDURE QUALIFICATION NO.(s). 6A POR REVISION 4
WELDING PROCESS AND TECHNIQUE
WELDING PROCESS Manual SMAW
WELDING CURRENT AND POLARITY Drect Current Reverse Polarity(DCRP)
VOLTS.CURRENT AND TRAVEL SPEED RANGES Table 1
MINIMUM REQUIRED HEAT INPUT Table 1
SHIELD GAS AND FLOW RATE NIA
WELDING POSITION AY Posrnons
WELDING PROGRESSION Vertical-up
WELDING SEQUENCE Figure 1
TIME BETWEEN PASSES ImaxlnlUM)- 10 minutes
TECHNIQUE(strtngerrvreave) Either
NUMBER OF PASSES(srngiatmule) Mu1u-pass(as required)
INITUILRNTERPASS CLEANING- Power Brushing or Grinding as Required
PROCEDURE THERMAL SEVERITY LEVEL See Pages 3 and 4 for Procedure Appleabrlrty
BASE MATERIAL
PIPESLEEVE GRADE All Pipe Grades Assuming Msx rnum Allowable CE A is not Exceeded-See
Pages 3_and 4 for Procedure Appkcabwty,
PIPErSLEEVE MATERIAL CEmv See Pages 3 and 4'or Procedure Appl"b.Lty
PIPE DIAMETER All Diameters
PIPE WALL THICKNESS AN Wall Thicknesses Provided that Appropriate Wall Thickness Group is
Selected-See Pages 3 and 4 lior Procedure App6catx1ity
1111 Bumthrough risk shall oe evaluated if the pipe war is<025-m (E.4•mm I
FILLER MATERIAL
AWS CLASSIFICATION. E7018
ELECTRODE DIAMETER 3132-m to 118-rn. (2 4-mm to 3.2-mm)
FILLER METAL GROUP. 3
AWS SPECIFICATION AS S
PREHEAT AND POST WELD HEAT TREATMENT
PREHEAT TEMPERATURE(mmenuml None
POST WELD HEAT TREATMENT TEMPERATURE AND TIME. None
12) 150OF I004C)A required'or moisture removal only
JOMT PREPARATION AND CLAMPING
JOINT TYPE Fillet Weld and Sod*-Seam Groove Weld IFpure 1)or Branch Connection
BACKING III6-m (1 6-mm)x 314-m (19-mm)Mdd SMel for Side-Seam Groove Weld
TYPE OF LINE-UP CLAMP External(as required)
REMOVAL OF LINE-UP CLAMP After Srde-Seam Tacks are Completed
'%?S 6A-Page 1 of 6

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
Figure 2
MDUG Critical—Compliance Message
CRITICAL - Compliance Message
Compliance Department-Ubliry Group
The following Compliance Message was previously sent to MDUG personnel and Contractors in 2020.A recent field inspection indicated that measures
have not been taken in all areas of MDUG's service territory to adequately review and follow company specific heat fusion and welding preheat
standards.The severity of this Compliance Message has been upgraded to CRITICAL.Please review with all affected personnel.
Subject:PLASTIC JOINING AND WELDING PROCEDURES
Description:A Utilities Group Contractor recently failed to check the heating tool surface temperature priorto making a butt fusion.A second Utilities
Group Contractor failed to check the pre-heat temperature at the weld groove and/or weld area.This compliance message is intended to raise
awareness of heat fusion and welding preheat guidelines.
Action Required:Review and follow your company specific heat fusion and welding preheat guidelines.
CNG IGC MDU/GPNG
CP 607-PE Main and Service 4027-Plastic Qualifications and Joinna Gas Distribution Standards
Construction Pyrometers are the preferred method to assure Pyrometers are the preferred method to assure
Before fusing for the day,check the proper heating tool face temperature. proper heating tool face temperature.
actual surface temperature of the "Temperature sticks"are acceptable if used in
heater plate or adapter surface with an accordance with manufacturer
accurate pyrometer. recommendations and it within their shelf life.
When using temperature sticks,take
precautions to prevent tool face contamination.
CNG 760-Welding Standards 4106-Weldina General Standards 1229-Weldina General Standards
CNG welding procedure specifications Preheat temperature shall be checked with a contact 1230-In-Service Welding Procedure
that require preheat include the pyrometer or infrared pyrometer at the weld groove Preheat temperature shall be checked with a
phrase"or wane to the touch"and and weld area. contact pyrometer or infrared pyrometer at the
therefore do not require a pyrometer weld groove and weld area.
or temperature sticks.
Please ensure that a calibrated pyrometer with current calibration records is used for heat fusion and welding preheat applications where required per
company procedures.
Temperature Sticks may only be used where permitted.
MDU Utilities Group integrated plastic joining and welding procedures are tentatively slated for implementation in 2021.
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