I201905 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD•P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone] RECEIVED
August 9,2019 '019 AUG 12 AM 9: 45
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Mr. Darrin Ulmer
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
P.O. Box 83720-0074
Boise,ID 83720-0074
Subject: Response to July 2,2019 Notice of Probable Violations—Boise District
Dear Mr. Ulmer,
This letter is intended to address the July 2,2019 Notice of Probable Violations identified by the Idaho Public Utilities
Commission(IPUC) as a result of the May 13, 2019 specialized inspection of Intermountain Gas Company's(IGC)
contractor performing new service installations in Kuna, ID.
PROBABLE VIOLATIONS
1. 49 CFR§192.605(a)Procedural manual for operations,maintenance,and emergencies.
Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting
operations and maintenance activities and for emergency response.
2. IGC Procedure 4308 3.6 step 2.
In service stubs(i.e. stub extensions)require a short purge to remove possible debris, reference procedures
3206—Pipeline Purging and Cleaning.
3. IGC Procedures 3206 2.6.2.1.
New or replacement service lines one inch(I")or smaller in diameter under 150 feet in length do not
require the use of a CGI to verify 100%gas. Purge through service riser until a strong gas odor is smelled
and a tone shift is heard.
4. IGC Procedure 4100.1 2.8
Remove the squeezers and mark the plastic pipe in the location of the pinch to ensure a re-squeeze will not
occur in that location.
Finding•
We observed a Das-co employee performing a tie-in at 2756 W.Midnight in Kuna,ID. When we approached
the tie-in location we noticed he had the service stub already squeezed off but had wrapped the stub with
multiple wraps of electrical tape in the squeeze location prior to applying the squeezers directly on top of
the tape. He then unscrewed the cap-n-go coupling and released the squeezers to see if there was gas in the
line. He then re-squeezed the service line in the same spot to shut down the gas flow. When asked why he
did that and if it was part of the procedure,he couldn't answer if it was or wasn't in the procedure but stated
that's the way he was taught and how everyone does it. No fire extinguisher was present.
Once their supervisor arrived we had brought up our concern about the way the employee had released the
squeezers to let gas purge into the bell hole the way he did and he didn't see the concern as they've always
done it that way.
Intermountain Gas Response
IGC acknowledges that Procedures 4308—Excess Flow Valves(EFV)and 3206—Pipeline Purging and Cleaning had
conflicting statements related to the short purge completed on a stub prior to installing an EFV. Therefore,a procedure
review was conducted which resulted in minor edits that better aligned Procedures 4308 and 3206. The updated
procedure was provided to the IPUC via a secured email delivery on July 11, 1019.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD•P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
Applying the squeeze tool and then allowing it to relax in order to purge the line does not constitute removing the
squeeze tool, so this is not considered re-squeezing. Although not specifically stated in Section 11.4.9 of Procedure
3010—Natural Gas Emergency Response Plan, the intent is to mark the squeeze location after the removal of the
squeeze tool.
Any pinch off location on plastic pipe shall be marked with either a black permanent marker or black
electrical tape at the squeezed portion of the pipe to prevent additional pinch offs in that location.
Das-co management addressed the proper application of electric tape during their Monday,July 8,2019 weekly safety
meeting. Because instruction related to squeezing plastic pipe is addressed in multiple procedures, annual plastic
joining training and Operator Qualifications,the MDU Utility Group is drafting a new procedure,OPS 309—Squeeze-
Off of Plastic Pipe. OPS 309 will be provided to the IPUC once finalized,approved and implemented.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
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Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company