I202602 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
March 12,2026
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 February 2,2026(Report#I202602)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a construction inspection
conducted in Ammon,ID by the Idaho Public Utilities Commission(IPUC)on January 26-27,2026 of
Intermountain Gas Company(IGC)pursuant of Chapter 601 Title,49,United States Code.
PROBABLE ViOLATiON
1. 49 CFR 8 192,605 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.
2. 49 CFR 8 192,756 Joining In antic one by heat fusion equipment maintenance and calibration.
Each operator must maintain equipment used in joining plastic pipe in accordance with the
manufacturer's recommended practices or with written procedures that have been proven by test and
experience to produce acceptable joints.
3. OPS 307 Pnl}ethylene(PF,I Main and Service Construction
2.Material Inspection
2.1.New Pipe and Fittings:
2.1.1.Pipe and fittings with gouges or scratches exceeding 10%of wall thickness shall not
be installed.
2.1.2.Creased or folded material(e.g.,kinked pipe)shall not be installed.
2.1.3.Each length of pipe and each fitting shall be visually inspected prior to installation to
ensure that it has no damage or defects that could impair its serviceability.
2.1.4.Materials suspected of being damaged or defective shall not be installed.Damages
or defects that did not occur during transportation,installation,or testing(e.g.,
damaged and defective material received from the manufacturer)shall be reported
via a Material and/or Component Failure Report(MCFR)JIRA ticket. Contractors
shall contact their MDUG representative(e.g.,Field Operations Coordinator,ThirdParty
Inspector,local District Management,etc.)immediately after identifying a
material failure.Refer to OPS 625—Material and Construction Failure Reporting and
Investigation.
2.1.5.Defective or damaged pipe and fittings discovered prior to being placed into service
shall be removed and discarded.
2.1.6.Refer to OPS 11 -Storage and Handling of Plastic Pipe and Components for loading,
hauling,and unloading requirements.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone]
4. Cleaning
4.1.Cleaning shall be performed per the manufacturer's instructions,or when butt fusing per TR33 Appendix
A.
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. —Generic Butt Fusion Joi Procedure for Field Joinin
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 operators can monitor the temperature before each joint is made.However,the
thermometer can be used as a general indicator because there is some heat loss from intern 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 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 in contact with the pipe should be clean,
oil-free and coated with nonstick coating as recommended by the manufacturer to prevent molten
plastic from sticking to the heater surfaces.Remain molten plastic can interfere with fusions quality
and must be removed according to the tool manufacturer's instructions.Never use chemical cleaners
or solvents to clean heating tool surfaces.
7.0 VISUAL INSPECTION
Visually inspect and compare the joint against the manufacturer's recommended appearance
guidelines.Visually,the width of the butt fusion heads should be approximately 2-2'/2 times the bead
height above the pipe and the beads should be rounded and uniformly sized all around the pipe
circumference.The v-groove between the beads should not be deeper than half the bead height above
the pipe surface.When butt fusing to molded fittings,the fitting-side bead may display shape
irregularities such as minor indentations,deflections and non-uniform bead rollover from molded part
cooling and knit lines.In such cases,visual evaluation is based mainly on the size and shape of the
pipe-side bead.(See Appendix D for bead configuration).Visually unacceptable joints should be cut
out and re-fused using the correct procedure. (See manufacturer's visual inspection guidelines)
5. McElroy Onerator's Manual —1LC Fusion Machine
Each operator must maintain equipment used in joining plastic pipe in accordance with the
manufacturer's recommended practices or with written procedures that have been proven by test and
experience to produce acceptable joints.
Clean Heater Surfaces
The hearer must be kepi dean a-,d frees of any plastic buikavp,
contannonon and:crotches 9
Salim oath Fuson is made, 4w w.face of the heate,mus,bo R
wiped wtth a cSoan, non.yr&*rsc doth.
i
�}tto:aip

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
1 LC Fusion Machine Checklist
Vern to Check 5-dslociory Need: Repair Comment;
UNIT
Mochinc is loon
Clamp knob bearings lubncoted and now frcoly
Movable jaw mama frocky
Locking cam works property
Guido rods oro not damaged
Clampng pw and mien groo ve arc clean
All nufa and bole arc tght
FACER
Check Far play in bkrd*holder
Facer does not wobble when trapped bctwoon pws
Blodee arc in good condition
Latch handle"onto guide rod fmoly
Facer mows on guide rode without eAcemivo laic*
Facer b clean and fnoo of gmaso on blade holier
svrfiacc
HEATER
Huator surface rs clean and in good condition
Mermonwler is in good working odor
Su.foce temperatvre chocked with pymm~
6. 49 CFR 8 192.53 General
Materials for pipe and components must be:
(a) Able to maintain the structural integrity of the pipe under temperature and other environmental
conditions that may be anticipated;
(b) Chemically compatible with any gas that they transport and with any other material in the
pipeline with which they are in contact;and
(c) Qualified in accordance with the applicable requirements of this subpart.
7. 49 CFR § 192.59 Plastic Pine
(a) New plastic pipe is qualified for use under this part if-
(1) It is manufactured in accordance with a listed specification;
(2) It is resistance to chemicals with which contact may be anticipated; and
(3) It is free of visible defects.
8. 49 CFR 8 192.321 installation of plastic nine
(d)Plastic pipe must have a minimum wall thickness in accordance with§ 192.121.
9. 49 CFR 8 192.121 Design of elastic nine
(2)For PE pipe produced on or after January 22,2019,a DF of.40 may be used in the design formula,
provided:
(iv)The wall thickness for a given outside diameter is not less than that listed in Table 1 to this
paragraph(c)(2)(iv):

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
PE pipe:minimum wall thickness and SDR values
Pipe size Minimum wall thickness Corresponding dimension
(inches) (inches) ratio (values)
1/2" CTS 0.090 7
1/2" IPS 0.090 9.3
3/4" CTS 0.090 9.7
3/4" IPS 0.0951 11
10. = 327 inspection-Evaluation. and Repair of Pi eln ines
6.PLASTIC(MDPE,HDPE)REPAIRS
6.1.Refer to OPS 309—Squeeze-Off of Plastic Pipe prior to performing a squeeze-off.
6.2.Refer to OPS 301 —Excess Flow Valves for EFV requirements on service line repairs.
6.3. Sections of pipe with gouges or scratches on pipe and fittings greater than 10%wall loss,pipe
with creases or folds(e.g.,kinked pipe),or any anomaly or defect that may impact the overall
integrity and serviceability of plastic pipe shall be removed and replaced.
6.4.Damaged pipeline segments shall be taken out of service and a cylindrical section of pipe
shall be removed and replaced with new pipe section of equal or greater design strength.
6.4.1.HDPE pipe with a MAOP of 60 psig or less may be repaired with MDPE pipe.
6.5. Standard repair methods for the replaced section include:
6.5.1. Stab type mechanical fittings shall not be installed after December 31,2026.
6.5.2.One-half(1/2")inch CTS should be repaired with a one-half(1/2")inch CTS X threefourths
(3/4")inch IPS external compressions ring mechanical fittings and threefourths(1/4")inch IPS pipe.
6.5.3.Three-fourths(1/4")inch IPS should be repaired with external compressions ring
mechanical fittings or electrofusion couplers.
Finding(sl•
• Staff witnessed contractors butt fusing with a dirty heater surface at 3062 and 3076 Elixir Rd Ammon,Idaho
(split service).Upon staff identification,the employees were told by their manager to stop fusing until the
heater could be cleaned or replaced.A second contaminated heater was then used. The third iron did not
have as much plastic contamination,but scratches and gouges were visible.
• Mechanical damages(shovel strike gouges)were identified on the service stub.The damaged stub was then
put into service.
• Contractor employees perform and accept fusions with inadequate roll back on 1/4"butt fusions at 3043
Elixir Rd,Ammon,ID.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608- BOISE,IDAHO 83707-[phone]- FAX:[phone]
Reference Photographs—
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EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
O 92'E M ,*43027'21"N,111058'21"W t13ft •4707ft O 1020E(T) *43027'21"N,11.1058'21'W t16ft •4710ft
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Damaged Pipe—E"-215700

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
O 1°N M 0 43°27'23"N,111°58'24"`N t45R •4715ft O 266°W(T) 43'27'23'N,111°58'24'W t45ft •4708ft
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hiadequatc Rollback on 3/." PE Butt Fusion —EWN-515107
Intermountain Gas Resnnnse
IGC acknowledges the findings brought forth by the IPUC. The heater plates were removed from service and were
replaced or cleaned. A compliance message was distributed to company employees and contractors to reiterate that
equipment used in joining plastic pipe shall be maintained in accordance with manufacturer's recommended practices
and to verify equipment is in good working condition prior to use.
The damaged section of pipe,with shovel strike gouges,was replaced.
The operator qualifications of the employee who conducted the fusions were immediately suspended, and the
employee is not permitted to be on an IGC job site until requalified.All fusions completed the day of the construction
inspection,and the day prior,were cut out and replaced by a different qualified individual.
Upon further review, 125 locations were identified where fusions were completed by the employee since becoming
qualified.IGC performed a leak survey at all locations.One underground leak was discovered during the survey.The
cause of the leak was unrelated to fusions,and the leak was repaired upon discovery. No other leaks were identified
during the survey.
IGC's Quality Control department developed a sample plan for the visual inspection of fusions completed by the
employee. Fusions were exposed and visually inspected at eleven(11)locations. Three(3)locations were identified
to have inadequate fusions, which were cut out and replaced. The visual inspections and fusion replacements were
completed by the contractor with onsite supervision from IGC Field Operations Management. As a result of the
sample,all fusions at the remaining 114 locations will be exposed and visually inspected.
Additionally,to enhance the oversight of construction activities,new procedure OPS 27—Construction Management
has been developed and is scheduled to implement March 13,2026.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD•P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President, Engineering & Operations Services
Intermountain Gas Company