I202614 NOPV

Idaho Public Utilities Commission Brad Little,Governor
` �- P.O. Box 83720,Boise, ID 83720.0074 Edward Lodge,President
John R.Hammond,Jr.,Commissioner
Dayn Hardie,Commissioner
Letter of Concern
August 13, 2026 Report# I202614
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 4th St.
Bismarck,ND 58501
Dear Mr. Pat Darras:
On August 12, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety Division
("Staff'), conducted a construction inspection in Rexburg, Idaho of the Idaho Falls District of
Intermountain Gas Company("IGC")pursuant to Chapter 601 of Title 49, United States Code.
As a result of the inspection, it appears there are area(s) of concern that do not fully meet the
intent of the pipeline safety regulations Title 49, Code of Federal Regulations, Part 192 for
calendar year 2026.
The item(s) listed below are of concern:
1. 49 CFR M92.803 Definitions.
Qualified means that an individual has been evaluated and can:
(a) Perform assigned covered tasks; and
(b) Recognize and react to abnormal operating conditions.
2. 49 CFR -4192.605 Procedural manual for operations, maintenance, and emergencies.
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.
IGC LETTER OF CONCERN— Page 1 of 4

3. OPS 800 Operator Oualification Program.
1.3. Qualification Criteria:
1.3.1. An employee is considered qualified when the individual has been evaluated,
and is determined to be able to:
1.3.1.1. Perform specific assigned Covered Task(s), and
1.3.1.2. Recognize and react to related AOCs.
1.4. Evaluating Individuals' Ability to Perform Covered Tasks:
1.4.1. Evaluations:
1.4.1.1. The evaluation of an individual's ability to perform an identified
Covered Task shall include a documented process specific to the task. The
evaluation of qualifications shall include an individual's ability to:
1.4.1.1.1. Perform the assigned task.
1.4.1.1.2. Identify AOCs that might reasonably be anticipated in the
performance of the Covered Task and required appropriate corrective
action.
4. OPS 309 Squeeze-Off of Plastic Pipe.
26 When compressing the plastic pipe in temperature at or above 32°F,do so at a slow rate to
allow stress relaxation in the plastic pipe_A compression rate of two(2)inches per minute(2
ipm)of the inside diameter should be maintained.For example.it should take no less than 58
seconds(0 958 minutes)to fully compress two-inch(2")IPS plastic pipe(1 917 inch12ipm)
Ambient Temp>32 F RECOMMENDED COMPRESSION RATE(min:sec)
Plastic Pipe Size 1/2' 3/4" 1. 1.25" 2" 3" 4" 6°
CTS IPS IPS IPS IPS IPS IPS IPS
ID(in) 0.445 0.860 1.062 1.340 1.917 2.825 3.633 5.348
Approx time to 25%squeeze-off - - 0:08 0:10 0:14 0:21 0:27 0:40
Approx.time to 50%squeeze-off 0:06 0:13 0:16 0:20 0:29 0:42 0:55 1:20
Approx.time to 75%squeeze off 0:10 0:20 0:24 0:30 0:43 1:04 1:22 2:00
Approx time to full compression 0-13 026 0:32 0:40 0:58 125 1-49 2:40
2.7 When compressing the plastic pipe in temperature below 32°F,exercise caution because the
plastic pipe may be more susceptible to squeeze off damage.A compression rate of one(1)
inch per minute(1 ipm)of the inside diameter should be maintained.
Ambient Temp<32-F RECOMMENDED COMPRESSION RATE(min:sec)
Plastic Pipe Size 1/2" 3/4" 1" 1.25" 2" 3" 4" 6"
CTS IPS IPS IPS IPS IPS IPS IPS
ID(in) 0.445 0-860 1.062 1.340 1.917 2.825 3.633 5.348
Approx.time to 25%squeeze-off 0:06 0:12 0:16 0:20 0:28 0:42 0:54 1:20
Approx.time to 50%squeeze-off 0:12 0:26 0:32 0:40 0:58 1:24 1:50 2:40
Approx.time to 75%squeeze off 0:20 0:40 0:48 1 1:00 126 2:08 2:44 4:00
Approx.time to full compression 0:26 0:52 1:04 1:20 1:56 2:50 3:38 5:20
IGC LETTER OF CONCERN— Page 2 of 4

2.8. When removing the squeeze-off tool in temperatures at or above 32°F,release the squeeze
slowly.A release rate of 0.5 inches per minute(0.5 ipm)of the inside diameter should be
maintained. For example,it should take no less than three(3)minutes,50 seconds to fully
release two(2")inch IPS plastic pipe(1.917inch/0.5ipm)_
Ambient Temp a 32 F RECOMMENDED RELEASE RATE(min:sec)
Plastic Pipe Size 1/2" 3/4" 1" 1.25" 2" 3" 4" 6'
CTS IPS IPS IPS IPS IPS IPS IPS
ID(in) 0.445 0.860 1.062 1.340 1.917 2.825 3.633 5.348
Approx.time to 25%release 0:13 0:26 0:32 0:40 0:58 1:25 1:49 2-40
Approx.time to 50%release 0:27 0:52 1:04 1:211 1:55 2:50 3:38 5:21
Approx. time to 75%release 0:40 1:17 1:36 2:01 2:53 4:14 5:27 8:00
Total time for full release 0:53 1:43 2:07 2:41 3:50 5:39 7:16 10:42
2.9. When removing the squeeze-off tool in temperatures equal to or less than 32° F,exercise
caution because the plastic pipe may be more susceptible to squeeze off damage_A release
rate of 025 inches per minutes(0.25 ipm)of the inside diameter should be maintained.
Ambient Temp<32 F RECOMMENDED RELEASE RATE(min:sec)
Plastic Pipe Size 1/2" 3/4" 1" 1 25' 2" 3" 4" 6"
CTS IPS IPS IPS IPS IPS IPS IPS
ID(in) 0.445 0.860 1.062 1.340 1.917 2.825 3.633 5.348
Approx.time to 25%release 0:26 0:52 1:04 1:20 1:56 2:50 3:38 5:20
Approx_time to 50%release 0:54 1:44 2:08 2:42 3:50 5:40 7:I6 10:42
Approx.time to 75%release 120 2:34 3:12 4:02 5:46 8:28 10:54 16:00
Approx_time for full release 1:46 3:26 414 5:22 7:40 1 1:18 14:32 21:24
5. OPS 505 Pressure Testing.
2.7 PE Pipe
2.7.2. Pressure tests shall not be performed on PE materials at more than 110°F (pipe
surface temperature, not ambient temperature) without prior evaluation and approval from
Engineering Services. The pipe should be shaded and cooled. Cold air from a compressor
on the inside will speed cooling. For exposed ends, water on the outside surface may also
be used.
Finding(s):
A contractor (EWN-167210) installing a service line for Work Order# 12686195 was unable to
answer basic Abnormal Operating Condition(AOC)questions related to the squeeze-off of plastic
pipe (outlined in OPS 309), or related temperature requirements during pressure tests of plastic
pipe in accordance with OPS 505.
IGC LETTER OF CONCERN— Page 3 of 4

REOUESTED ACTIONS
The above-mentioned item(s) were brought to the attention of IGC compliance
representatives during the inspection. We request that you review these matter(s) and
respond in writing within 30 days regarding the above issue(s) including any planned
corrective actions.
If you have any questions concerning this notice, please contact me at [phone]. All
written responses should be addressed to me at: 11331 W Chinden Blvd, Ste 201-A,Boise,
ID 83714 or you can fax your response to [phone].
Because of the good faith that you have exhibited up to this time, we expect that you will
take action to bring your program into compliance with pipeline safety regulations.
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sincerely,
/effBrooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
IGC LETTER OF CONCERN— Page 4 of 4