I202407 NOPV

Brad Little,Governor
Idaho Public Utilities Commission
P.O. Box 83720, Boise,ID 83720-0074 Eric Anderson,President
John R.Hammond,Jr.,Commissioner
Edward Lodge,Commissioner
July 10, 2024 Report#I202407
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 4ch St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On July 09, 2024, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a construction inspection in Eagle, Idaho on service line number
016336-417 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 VIOLATION(S)
1. 49 CFR 4192.281 Plastic Pipe
(c) Heat fusion joints. Each heat fusion joint on a PE pipe or component, except for
electrofusion joints, must comply with ASTM F2620 (incorporated by reference in §
192.7), or an alternative written procedure that has been demonstrated to provide an
equivalent or superior level of safety and has been proven by test or experience to
produce strong gastight joints, and the following:
(1)A butt heat-fusion joint must be joined by a device that holds the heater element
square to the ends of the pipe or component, compresses the heated ends together,
and holds the pipe in proper alignment in accordance with the appropriate
procedure qualified under § 192.283.
2. 49 CFR 092.605 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
IGC EAGLE CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER—PAGE 1

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.
3. OPS 307 Polyethylene (PE) Main and Service Construction
REFERENCES—
ASTM 2620-19 - Standard Practice for Heat Fusion Joining of Polyethylene Pipe
and Fittings Plastics Institute
Technical Report 33 (TR-33) Generic Butt Fusion Joining Procedure for Field
Joining of Polyethylene Pipe
Section 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.
4. TR-33 Section Appendix A
Butt Fusion Procedures The principle of heat fusion is to heat two surfaces to a
designated temperature, then fuse them together by application of a sufficient force.
This force causes the melted materials to flow and mix, thereby resulting in fusion.
When fused according to the proper procedures, the joint area becomes as strong as or
stronger than the pipe itself in both tensile and pressure properties. Field-site butt
fusions may be made readily by trained operators using butt fusion machines that secure
and precisely align the pipe ends for the fusion process. The six steps involved in
making a butt fusion joint are: 1. Securely fasten the components to be joined 2. Face
the pipe ends 3.Align the pipe profile 4.Melt the pipe interfaces 5.Join the two profiles
together 6. Hold under pressure.
Section 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.
Section 4.0 Melt
The surface temperatures must be in the temperature range 400-450°F (204- 232°C).
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
IGC EAGLE CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER—PAGE 2

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.
Section 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.
Section 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.
5. McElroy Operators Manual: 433901 Revision V 10/18
Page 3-3: Positioning Pipe in Machine
Page 3-3: Facing the Pipe Manually
Page 3-5: Fusing the Pipe
Page 3-6: Removing Pipe
Page 5-1: Maintenance Checklist (Unit) Lever handles are with unit.
Finding(s)•
IPUC staff observed a contractor for IGC using a PE pipe cutter as the handle to apply
force while using a McElroy 2LC Saddle(Unit# 112) during butt fusing.
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 Aug 24, 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
IGC EAGLE CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER—PAGE 3

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 Aug 09, 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 Aug 24, 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.
If you do not respond to this notice by Aug 24, 2024, you 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,
Jeff 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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