I202407 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
August 20,2024
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to the Notice of Probable Violation dated July 10,2024(Report#I202407)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a construction inspection
conducted by the Idaho Public Utilities Commission(IPUC)on July 9,2024,on service 016336-417 of
Intermountain Gas Company(IGC).
PROBABLE VIOLATION
1. 49 CFR§192,281 Plastic PiUee
(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.
49_CFR § 192.605 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.
OPS 307 Polyethylene(PE)Main and Services 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 TR33 equivalent to that of ASTM
2620-19.
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.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
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 IF(204-232°Q.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.
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.
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.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC.Although each butt fusion passed visual inspection,
all fittings that were installed on service 016336-417,while using a PE pipe cutter as the handle during the butt

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
fusion process, were cut out and replaced on July 9, 2024. Additionally, notification was sent to Company and
Contractor employees to reiterate that equipment shall be used as it is supplied from the manufacturer, and to not
modify or alter the equipment(see Exhibit A).
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Qa4'f- -
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]
Exhibit A
H •—•
File Message Help Acrobat 9 Tell me what you want to do
Delete Respond Shareto All Quick Move Tags Editing Immersive Translate Zoom Replywith a
Teams Apps Steps- Scheduling Poll a=
Teams Apps Quic... ru Language Zoom Find Time Add-in Phish n
Announcement: Butt Fusion Process Reminder
Sipe,Katie Reply O) Reply All ForwardElO To EI MDUG Construction Services Dir Mgr Supv; Thu 7/18/202410:30 AM
[D MDUG Engineering Service Dir Mgr Supv;+4 others
Cc •Darras,Patrick; Martuscelli,Eric; Gilchrist,Hart;
I MDUG Policy Procedure Group
Policy & Procedure Announcement
SUMMARY OF CHANGES:
As a reminder
It is accepted industry standard to butt fuse pipe with'like wall thicknesses."Like wall thickness is defined as the pipe and/or fittings
do not exceed one(1)SDR difference in wall thickness,e.g.,SDR 13.5 to SDR 11 or SDR-11 to SDR-9-
We have 4"x 1",2"x 1"and 1-1/4"x 1"Electro Fusion Fittings tapping tees with 1"outlets that are SDR-7 from George Fisher Central
Plastics(GFCP).Standard Excess Flow Valves(EFVs)and 1"pipe used at the MDUG companies are SDR-1 1.Any pipe or fittings
connected to the outlet of the tapping tees that are more than one SDR different are not to be installed using a butt fusion
connection.
The tapping tees can be installed.The connections to the tapping tee outlets shall be completed using an electrofusion coupling.
We are working to use down the inventory of tapping tees with the SDR-7 outlets.The fittings have been set to"obsolete"in JDE to
not allow the purchase of the fittings from the manufacturer.Another manufacturer has been activated to supply the electro fusion
fittings with the 1"outlets in the affected areas and a secondary supplier has been approved to minimize impacts by single sourcing.
Additionally:
When using equipment to complete butt fusions,use the equipment as it is supplied from the manufacturer.Do not alter/modify the
equipment Use the tooling/handles supplied with the equipment to complete the fusions.
ACTION REQUIRED:
Notification only.Managers and supervisors are responsible for sharing and/or reviewing this notification with personnel who complete
butt fusion.
Contact danny hoodpmdu.com for questions.
Thank you,
Katie Sipe
Operations Policy Administrator
360-224-0254 0

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
H • IE
File Message Help Acrobat Tell me what you want to do
❑� ❑� °° 7/ ❑� ® M d Ldp
Delete Respond All Quick Move Tags Editing Immersive Translate Zoom Replywith Viva Phish>
T, Apps Steps- - Scheduling Poll Insights Rel
Teams Apps Quic... ru Language Zoom Find Time Add-in Phish n
Contractor Notification: Butt Fusion Process Reminder
Sipe,Katie
Reply 0) Reply All
Forward
To p MDUG Policy Procedure Group;ED MDUG Region Directors; Ogden,Jeremy,O Jutila,Wade Thu 7/18/202410:35 AM
Kaubrey&wasningtoncrane.com'<Kaubreywwasningtoncrane.com>;'Ja [e-mail]'<[e-mail]>; ❑-
'[e-mail]'<[e-mail]>;'[e-mail]'<[e-mail]>;'[e-mail]'
<[e-mail]>;'[e-mail]'<[e-mail]>;'[e-mail]'<[e-mail]>;
'[e-mail]'<[e-mail]>;'[e-mail]'<[e-mail]>;
'[e-mail]'<[e-mail]>
Subject:Butt Fusion Process Reminder
MDU Utilities Group Contractors,
As a reminder:
It is accepted industry standard to butt fuse pipe with"like wall thicknesses."Like wall thickness is defined as the pipe and/or fittings do not exceed
one(1)SDR difference in wall thickness,e.g.,SDR 13.5 to SDR 11 or SDR-11 to SDR-9.
We have 4"x 1",2"x 1"and 1-1/4"x 1"Electro Fusion Fittings tapping tees with 1"outlets that are SDR-7 from George Fisher Central Plastics
(GFCP).Standard Excess Flow Valves(EFVs)and 1"pipe used at the MDUG companies are SDR-11.Any pipe or fittings connected to the outlet of
the tapping tees that are more than one SDR different are not to be installed using a butt fusion connection.
The tapping tees can be installed.The connections to the tapping tee outlets shall be completed using an electrofusion coupling.
We are working to use down the inventory of tapping tees with the SDR-7 outlets.The fittings have been set to"obsolete"in JDE to not allow the
purchase of the fittings from the manufacturer.Another manufacturer has been activated to supply the electro fusion fittings with the 1"outlets in
the affected areas and a secondary supplier has been approved to minimize impacts by single sourcing.
Additionally:
When using equipment to complete butt fusions,use the equipment as it is supplied from the manufacturer.Do not alter/modify the equipment.
Use the tooling/handles supplied with the equipment to complete the fusions.
If you have any questions regarding these revisions,please reply to this email and it will be forwarded to the appropriate department.
Please reply to this email as acknowledgement of receipt of this email.
Thank you,
Katie Sipe
Operations Policy Administrator
360-224-0254
Montana Dakota Utilities
[e-mail]
0
�I ____1 n