I202101 LOC Response.pdf

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD• P.O. BOX 7608 • BOISE, IDAHO 83707 • [phone] • FAX: [phone]

February 18, 2021 Mr. Darrin Ulmer, Programs Manager
Idaho Public Utility Commission PO Box 83720 Boise, ID 83720-0074 Subject: Response to Area of Concern dated January 26, 2021 (Report # I202101)
Dear Mr. Ulmer, This letter is intended to address one area of concern stemming from a January 25, 2021 on-site construction inspection of the 318-57FS-123 project located at 605 North 7th Street, Parma, Idaho in Intermountain Gas Company’s (IGC) Nampa District. Specifically, we are addressing how we plan to bring the area of concern into full compliance.
AREA OF CONCERN
Intermountain Gas Response
IGC acknowledges the Das-co of Idaho crew working at 605 North 7th Street in Parma on January 25, 2021 had
an infrared pyrometer with an expired calibration date. Das-co was performing an in-service weld using
Welding Procedure Specification (WPS) 6A which does not require preheat. (See Figure 1.) Step 1.15. of IGC
standard operating procedure 4106 – Welding General Standards states, “Preheating shall be in accordance
with the WPS;” therefore, step 1.16.1. was not required for this in-service weld.

To immediately address this area of concern, a Critical – Compliance Message has been resent to MDU Utilities
Group personnel and Contractors from the Director, Operations Services. (See Figure 2.)

To determine the root cause of the area of concern and what additional remedial action is required, IGC is
performing a comprehensive review of current construction inspection practices, Quality Control inspection
practices, and Contractor equipment calibration tracking practices. IGC will respond in writing by May 28,
2021 with the results of this review and a schedule of the required remedial action(s).
1. 49 CFR §192.605 (a) (1) 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. Finding: During the inspection it was noted that the DAS-CO welding crew employed by IGC, when asked about
preheating prior to welding, did not have a operational and calibrated infrared pyrometer to check the
preheat temperature at the weld groove and weld area as required by IGC Operations and Maintenance Manual procedure 4106.1 (1.16.1). This area of concern has been a previous issue brought to your company’s attention.
EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD• P.O. BOX 7608 • BOISE, IDAHO 83707 • [phone] • FAX: [phone]

Please contact Josh Sanders at [phone] with questions or comments.
Respectfully Submitted,

Pat Darras
Vice President, Engineering & Operations Services
Intermountain Gas Company

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD• P.O. BOX 7608 • BOISE, IDAHO 83707 • [phone] • FAX: [phone]

Figure 1
Welding Procedure Specifications 6A

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD• P.O. BOX 7608 • BOISE, IDAHO 83707 • [phone] • FAX: [phone]

Figure 2
MDUG Critical – Compliance Message