I201912 LOC Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY RECEIVED
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]ai� t2�
COMMISSION
December 20,2019
Mr.Darrin Ulmer
Pipeline Safety,
Program Manager
Idaho Public Utilities Commission
P.O.Box 83720-0074
Boise, ID 83720-0074
Subject:Response to December 11,2019 LETTER OF CONCERN—Twin Falls District(Report# 1201912)
Dear Mr.Ulmer,
This letter is intended to address the December 11,2019 Letter of Concern regarding the onsite construction
inspection of the 583-1983 project conducted by the Idaho Public Utilities Commission on December 5,2019.
ITEMS OF CONCERN
1. 4192.605 Procedural manual for operations,maintenance,and emerliencies
(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.
Finding(s):
During an inspection of a KV utilities crew,a contractor for IGC,the improper use of a squeezer was
observed by one of our inspectors.It was noted that the crew was attempting to perform a squeeze of a
service stub without the use of a ground rod per procedure 4100.1 (2.2) of IGC's Operations and
Maintenance Manual.Additionally the use of soapy burlap at the pipe to soil interface was not used.
Another concern identified is, in IGC's O&M manual the only mention of how to apply a sqeezer is
listed in 4100.1 Section 2 Abandonment of polyethlene pipe.
Intermountain Gas Response
Intermountain Gas Company (IGC) procedure 4100 Abandoning Pipeline Facilities was superseded by OPS 607
Abandonment of Underground Pipelines on October 9,2019. Moreover,a new procedure,OPS 309 Squeeze-Off of
Plastic Pipe, has been approved via Management of Change(MOC)and will be implemented on February 3, 2020.
Training for the new procedure will be conducted throughout the month of January. OPS 309 establishes guidelines
for the squeeze-off of plastic pipelines during maintenance and installation. In addition, a new guidance document
has been created and is pending approval in MOC(OPSMOC-301)that details the Wet Burlap Method for mitigating
risks involved with electrostatic discharge.
District Operations Managers met with the superintendents of Das-co of Idaho,KV Inc.and Track Utilities that perform
squeeze-offs of plastic pipe that as instructed during the Operator Qualification training provide by the Technical Training
department, they shall ground squeeze-off tools with an approved static electric grounding device before placing the
squeeze-off tool on the pipe.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD•P.O.BOX 7608• BOISE,IDAHO 83707•[phone]•FAX:[phone]
IGC believes the meetings held with the contractor superintendents in combination with the extensive OPS 309 training
scheduled for January 2020 will eliminate future occurrences of improper use of squeeze-off tools.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President, Engineering&Operations Services
Intermountain Gas Company