I202416 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
October 28,2024
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 September 19,2024(Report#I202416)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a construction inspection
conducted by the Idaho Public Utilities Commission(IPUC)on September 19,2024,on service line 413-04818 of
Intermountain Gas Company(IGC)pursuant of Chapter 601 Title,49,United States Code.
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.
2. 49 CFR§ 192,273 General
The pipeline must be designed and installed so that each joint will sustain that longitudinal
pullout or thrust forces caused by contraction or expansion of the piping or by anticipated
external or internal loading.
Each joint must be made in accordance with written procedures that have been proven by test or
experience to produce strong gastight joints.
Each joint must be inspected to insure compliance with this subpart.
3. OPS 204 Qualifying Plastic Joiners
External Compressions Ring Mechanical Fittings: 192-1005.03 Joining of Plastic Pipe Met-Fit
2.6.1.A section of three-fourths inch(3/4")IPS,one and one-fourth inch(1 1/4")IPS,or two inch
(2")IPS will be joined with an external compression ring fitting per manufacturer's procedure
and/or instructions.
4. JM Eagle Met Fit
Per manufacture recommendations:
• Series 200 Hydraulic Tool System Figure 3 on PDF Pg.7(attached below)
PIPE READ*TO INSERT INTO FITTING RING POSITIONED ON PIPE.
ntung plpc Hng nano
Figure 1

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
TOOL POSITIONED OVER PIPE AND FITTING.
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ered down over fittings,as adapterlaws allgned with should on Iltgng
3.Note the location of the
adapter jaws over the shout-
,and the front moveable set
in the back of the ring flange.
Figure 2
TOOL BEING LOWERED OVER FITTING AND RING.
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with adapterlaws
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adapterlaws ring narge adapterlaws
Figure 3
f.After the ring has been installed past the fitting's locking rib.g.Inspect to insure rings are bottomed out sufficiently
to pass release the hydraulic pump by turning the pump valve shown the locking rib on the fitting.If this is not the
case,rotate in Figure 1 and remove the tool from the installed ring—the tool 90 degrees and repeat the crimping
procedure-
Finding(sl
An IGC crew was observed not following the manufacturer's recommendations while installing a 2"met-
fit coupler.Per Figure 3(Pg.7)of JM Eagle's 2"Met-Fit manufacturer's recommendations,the movable
part of the hydraulic tool shall be placed on the compression ring side of the Met-fit coupler.IGC crew
installed the 2"Met-Fit coupler with the tool turned in the opposite orientation of what is recommended in
Figure 3 movable part not on ring side).
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. Upon further investigation, the manufacturers
recommendations indicate the same orientation of the hydraulic installation tool for Met-Fit tees and elbows.
The instructions also state to rotate the hydraulic machine 90 degrees to complete the installation if the initial
attempt does not completely seat the ring flange.After further field testing,it has been discovered that rotation
of the hydraulic machine is not possible when installing a tee or elbow.The hydraulic machine works as directed
when installing couplers.
Notification was sent to Company and Contractor personnel to immediately suspend the use of 1 '/a" and 2"
Met-Fit tees and elbows. The continued installation of couplers is allowed, and notification has been sent to
Company and Contractor personnel that the instructions direct the hydraulic installation machine to be installed
with the rear stationary adapter jaw over the shoulder of the fitting and the front mobile jaw to be place over
the ring flange.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
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Pat Darras
Vice President,Engineering& Operations Services
Intermountain Gas Company