I202614 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
August 28,2026
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to the Letter of Concern dated August 13,2026(Report#I202614)
Dear Mr.Brooks,
This letter is intended to address one(1)area of concern stemming from a construction inspection conducted by the
Idaho Public Utilities Commission(IPUC)on August 12,2026,in Rexburg,ID,in the Idaho Falls District of the
Intermountain Gas Company(IGC)pursuant of Chapter 601 Title,49,United States Code.
AREA OF CONCERN
1. 49 CFR 8192,803 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 8192.605 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.
3. OPS 800 Operator Oualificatinn Program
1.3.Qualification Criteria:
1.3.1 An employee is considered qualified when the individual has been evaluated,and is determined
to able to:
1.3.1.1.Perform specific assigned Covered Task(s),and
1.3.1.2.Recognize and react to related ADCs.
1.4. Evaluating Individual's 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 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 Snueeze-Off of Plastic Pine
2.6.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 pip(1917 inch/2ipm).

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608•BOISE,IDAHO 83707•[phone]• FAX:[phone]
Ambient Temp�32 F RECOMMENDED COMPRESSION RATE(min sec)
Plastic Pipe Size 117 3/4" 1" 125' 2' 3' 4' 6'
CTS fPS IPS IPS IPS IPS IPS IPS
ID(in) 0.445 0.860 1.062 1.340 1.917 2.825 3.633 6.348
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 0:10 010 0:24 0:30 0:43 1:04 1:22 2:00
Approx-time to full compression 0.13 0:26 0:32 0:40 1 0758 1:25 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(mimsec)
Plastic Pipe Size 1/2" 3/4" 1" 125" 2" 3' 4" 6"
CTS IPS IPS IPS IPS IPS IPS IPS
ID(in) OA45 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 1 0:32 0:40 0:58 1:24 1:50 2:40
Approx time to 75%squeeze off 0:20 0:40 0:48 1:00 126 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
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 inches 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(1.917 inch/0.5 ipm).
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 013 0:26 0:32 0:40 0:58 1:25 1:49 2:40
Approx. time to 50O10 release 0:27 0:52 I-04 1: 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 0.25 inches
per minutes(0.25 ipm)of the inside diamet should be maintained.
Ambient Temp<32 F RECOMMENDED RELEASE RATE(min:sec)
Plastic Pipe Size 1/2" 314" 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.6me to 50%release O:54 1:44 1 2:08 1 2:42 3:50 5:40 7:16 10:42
Approx_time to 75%release 1:20 2:34 3:12 4;02 5:46 8:28 10:54 16:00
Approx_time for full release 146 326 4A4 5:22 7 40 1 1:18 14.32 21:24

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone]
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.
Findin6s)•
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.
Intermountain Gas Response
IGC acknowledges the finding brought forth by the IPUC as it relates to sections 1.3. and 1.4. of OPS 800 —
Operator Qualification Program as referenced above. Operator qualifications were suspended, and the employee
is no longer performing work on IGC job sites.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President, Engineering& Operations Services
Intermountain Gas Company