I202412 NOPV

Idaho Public Utilities Commission Brad Little,Governor
P.O.Box 83720, Boise,ID 83720-0074 Eric Anderson,President
John R Hammond,Jr.,Commissioner
Edward Lodge,Commissioner
September 4, 2024 Report# I202412
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On September 3, 2024, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division("Staff'), conducted a construction inspection in Meridian, Idaho on service line number
413-1964, Subdivision Pera Place on the corner of Daphne&N Colosseum Ave. of Intermountain
Gas Company("IGC") 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. The probable violations are as
follows:
PROBABLE VIOLATIONS)
1. 49 CFR 4192.605 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.
2. OPS 307 Polyethylene WE) Main and Service Construction
5.11. Butt fusions shall be made in accordance with TR-33 Appendix A.
NOTE: TR-33 was used to develop ASTM 2620-19, making the level of safety in TR-33
equivalent to that of ASTM 2620-19. Connections shall be made by butt fusion or
electrofusion.
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3. Generic Butt Fusion Joining Procedure for Field Joining of Polyethylene Pipe
TR- 33 (2012)
Appendix A
1.0 Secure
Clean the inside and outside of the pipe to be joined by wiping with a clean lint-
free cloth.Remove all foreign matter.Clamp the components in the machine.Check
alignment of the ends and adjust as needed.
2.0 Face
The pipe ends must be faced to establish clean, parallel mating surfaces. Most, if
not all,equipment manufacturers have incorporated the rotating planer block design
in their facers to accomplish this goal. Facing is continued until a minimal distance
exists between the fixed and movable jaws of the machine and the facer is locked
firmly and squarely between the jaw bushings. Open the jaws and remove the facer.
Remove any pipe chips from the facing operation and any foreign matter with a
clean, lint-free cotton cloth. Bring the pipe ends together with minimal force and
inspect the face off. A visual inspection of this operation should verify that faces
are square, perpendicular to the pipe centerline on each pipe end and with no
detectable gap.
3.0 Align
The pipe profiles must be rounded and aligned with each other to minimize
mismatch (high-low) of the pipe walls. This can be accomplished by tightening
clamping jaws until the outside diameters of the pipe ends match. The jaws must
not be loosened, or the pipe may slip during fusion. Re-face the pipe ends and
remove any chips from re-facing operation with a clean, lint-free cotton cloth.
4.0 Melt
Heating tools that simultaneously heat both pipe ends are used to accomplish this
operation. These heating tools are normally furnished with thermometers to
measure internal heater temperature so the operator can monitor the temperature
before each joint is made. However, the thermometer can be used only as a general
indicator because there is some heat loss from internal to external surfaces,
depending on factors such as ambient temperatures and wind conditions. A
pyrometer or other surface temperature-measuring device should be used before the
first joint of the day is made and periodically throughout the day to insure proper
temperature of the heating tool face that contacts the pipe or fitting ends.
Additionally, heating tools are usually equipped with suspension and alignment
guides that center them on the pipe ends. The heater faces that come into contact
with the pipe should be clean, oil-free and coated with a nonstick coating as
recommended by the manufacturer to prevent molten plastic from sticking to the
heater surfaces. Remaining molten plastic can interfere with fusion quality and
must be removed according to the tool manufacturer's instructions. Never use
chemical cleaners or solvents to clean heating tool surfaces.
The surface temperatures must be in the temperature range 400-450' F (204-
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2321C). Install the heater in the butt fusion machine and bring the pipe ends into
full contact with the heater. To ensure that full and proper contact is made between
the pipe ends and the heater, the initial contact should be under moderate pressure.
After holding the pressure very briefly, it should be released without breaking
contact. On larger pipe sizes, initial pressure may be maintained until a slight melt
is observed around the circumference of the pipe before releasing pressure.
Continue to hold the components in contact with each other, without force, while a
bead of molten polyethylene develops between the heater and the pipe ends. When
the proper bead size is formed against the heater surfaces all around the pipe or
fitting ends, remove the heater. Melt bead size is dependent on pipe size. See table
below for approximate melt bead sizes.
5.0 Joining
After the heater tool is removed, quickly inspect the pipe ends(NOTE: If a concave
melt surface is observed, unacceptable pressure during heating has occurred and
the joint will be low quality. Do not continue. Allow the component ends to cool
completely, and restart at the beginning. Except for a very brief time to seat the
components fully against the heater tool, do not apply pressure during heating.),
then immediately bring the molten pipe ends together with sufficient fusion force
to form a double rollback bead against the pipe wall.
6.0 Hold
Hold the joint immobile under fusion force until the joint has cooled adequately to
develop strength. Allowing proper cooling times under fusion force prior to
removal from the clamps of the machine is important in achieving joint integrity.
The fusion force should be held between the pipe ends for approximately 30-90
seconds per inch of pipe diameter or until the surface of the melt bead is cool to the
touch.
Finding(s):
IPUC staff observed a contractor make two fusions using incorrect procedures.
Fuse #1, Adjusted for alignment and did not reface prior to installing heating tool
for melt. While the pipe ends were heating and after applying moderate pressure
and releasing, IPUC inspector witnessed the fuser apply variable pressures multiple
times during the same fusion with the"dogs"set.After the heater tool was removed,
the individual did not inspect pipe ends for concave prior to joining pipe ends.
Fuse #2, While the pipe ends were heating and after applying moderate pressure
and releasing, IPUC inspector witnessed the fuser apply variable pressures multiple
times during the same fusion with the"dogs"set.After the heater tool was removed,
the individual did not inspect pipe ends for concave prior to joining pipe ends.
During both fuses the individual used the same paper towel on pipe and heating
surfaces.
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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 19, 2024, 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 October 4,2024.
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 19, 2024, 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 of up to two hundred thousand dollars
($200,000). See Idaho Code §61-712A.
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,
/eff Brooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
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