I202406 NOPV

Box 83720,Boise,ID 83720-0074 Idaho Public Utilities Commission Brad Little,Governor
P.O. Eric Anderson,President
John R.Hammond,Jr,Commissioner
Edward Lodge,Commissioner
April 16, 2024 Report#I202406
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 4th St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On April 15, 2024, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division("Staff'),conducted a construction inspection in Star,Idaho on service line number 9064-
367 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 -4192.281 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 -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
IGC STAR 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 7.0
Visually inspect and compare the joint against the manufacturer's recommended
appearance guidelines. Visually, the width of butt fusion beads should be
approximately 2-2 % times the bead height above the pipe and the beads should be
rounded and uniformly sized all around the pipe circumference.
5. ASTM F2620-19 Section 8.3.7.1
8.3.7.1 Visually inspect and compare the joint against the butt fusion bead visual
inspection acceptance guideline in Fig.4.
Findinds)•
IPUC staff witnessed Dasco fuser#DC2200 fuse and accept a butt fusion joint that was not
acceptable per visual acceptance criteria in TR-33 and ASTM F2620— 19 Section 8.3.7.1.
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 May 31, 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/.
IGC STAR CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER-PAGE 2

If you intend to request an informal conference, please contact the Pipeline Safety Division no
later than May 16,2024.
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 May 31,2024 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 May 31, 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]
IGC STAR CONSTRUCTION INSPECTION PROBABLE VIOLATIONS LETTER—PAGE 3