I202102 NOPV Operator Response 2.pdf

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

March 30, 2021 Mr. Darrin Ulmer, Programs Manager
Idaho Public Utility Commission PO Box 83720 Boise, ID 83720-0074 Subject: Response to Notice of Probable Violation dated February 17, 2021 (Report # I202102)
Dear Mr. Ulmer, This letter is intended to address one probable violation stemming from a February 8, 2021 training program inspection which included plastic pipe joining for Intermountain Gas Company (IGC) personnel in Twin Falls,
Idaho. Specifically, we are addressing the details brought forth by the Idaho Public Utility Commission (IPUC) stated below.
PROBABLE VIOLATION
Intermountain Gas Response
IGC acknowledges that the pyrometer labeled with a calibration due date of January 31, 2021 (Pyrometer 1)
was present during the February 8, 2021 Plastic Joining Qualification Training. Twin Falls District personnel
reported that the calibration due date of Pyrometer 1 was checked prior to being used for a performance
evaluation. As such, the MDU Utilities Group (MDUG) SMS/Quality Assurance department performed an
investigation into the above finding.

The investigation included interviews with eight IGC employees directly or indirectly involved and validated
that Pyrometer 1 was not used for performance evaluations. IGC personnel mitigated the issue by purchasing a
new pyrometer (see Attachment A) to be utilized for performance evaluations; therefore, remaining compliant
with MDUG procedure, OPS 501 – Equipment Calibration, Maintenance and Testing, and moreover, 49 CFR
192.605(a).

IGC is cognizant of IPUC concerns regarding equipment calibration and is working diligently to assess and
improve calibration tracking processes for the company and its Contractors. As stated in IGC’s response to the
1. 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. Finding:
During the inspection it was noted that after the classroom training, the personnel went into the
warehouse for the hands-on evaluation. It was observed that the pyrometer being used to test the heating element was out of calibration (1/31/2021) thus in violation of OPS 501. This topic has been a previous issue brought to your company’s attention multiple times.
EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD• P.O. BOX 7608 • BOISE, IDAHO 83707 • [phone] • FAX: [phone]

IPUC Area of Concern dated January 26, 2021 (Report No. I202101), 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).

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]

Attachment A
Proof of Purchase