I202406 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
May 8,2024
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 April 16,2024(Report#I202406)
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 April 15,2024,on service line 9064-367 of
Intermountain Gas Company(IGC)pursuant of Chapter 601 Title,49,United States Code.
PROBABLE VIOLATION
1. 49 CFR§ 192.281 Plastic Pi"
(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§ 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.
3. OPS 307 Polyethylene(PE)Main and Service Construction
REFERENCES—
ASTM 2620-19—Standard Practice for Heat Fusion Joining 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 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 '/2 times the bead
height above pipe and the beads should be rounded and uniformly sized all around the pipe
circumference.
S. 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.
Finding(s)•
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.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
Intermountain Gas Resilonse
IGC acknowledges the findings brought forth by the IPUC. After contact from the IPUC on April 15, 2024,
IGC responded to the jobsite. Upon investigation, the butt fusions were cut out, and operator qualifications
were suspended for the employee who performed the butt fusion. While onsite, it was also discovered the
machine used for the butt fusion had loose screws and one jaw installed backwards.As a result,all Das-Co butt
fusion machines used for IGC installs were inspected on April 16,2024. This was determined to be an isolated
incident. All other machines were found with the clamps in good working condition.
The employee who performed the butt fusion had fused a total of twelve service lines since he was originally
qualified. Initially, IGC inspected three out of the twelve service lines. As a result of the number of findings
during IGC's inspection,it was decided that all twelve service lines would be excavated and inspected.All butt
fusions that failed visual inspection were cut out and replaced, and the service line was re-pressure tested per
procedure. Operator qualifications were also suspended for the employee's foreman.
Operator qualifications will remain suspended for the employee and the foreman until they retake the plastic
joining class with the IGC Technical Training department which is scheduled for May 23, 2024.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
DC1�
Pat Darras
Vice President,Engineering& Operations Services
Intermountain Gas Company