I202205 LOC

Idaho Public Utilities Commission Brad Little,Governor
P.O. Box 83720, Boise, ID 83720-0074 Eric Anderson,President
John Chatburn,Commissioner
John R.Hammond,Jr.,Commissioner
Letter of Concern
October 31, 2022 Report# 1202205
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 411 St.
Bismarck, ND 58501
Dear Mr. Darras:
On Oct 3-6, 2022, the Idaho Public Utilities Commission, Pipeline Safety Division, pursuant to
Chapter 601 of Title 49, United States Code, conducted a Procedural, Records and Field
inspection of Intermountain Gas Company's (IGC) Rexburg LNG Plant.
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 193 for
calendar year 2021.
The item(s) listed below are of concern:
1. 49 CFR§191.15 Transmission systems; gathering systems; liquefied natural gas
facilities; and underground natural gas storage facilities: Incident report.
(d)Supplemental report. Where additional related information is obtained after an
operator submits a report under paragraph (a), (b), or u of this section, the operator
must make a supplemental report as soon as practicable, with a clear reference by date
to the original report.
Findin s :
OPS 9 Gas Emergency Notification and Reporting (3.8.1) does not contain the verbiage
as soon as practicable as required by 49 CFR §191.15.
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

2. 49 CFR§193.207 Monitoring operations.
Each component in operation or building in which a hazard to persons or property could exist
must be monitored to detect fire or any malfunction or flammable fluid that could cause a
hazardous condition. Monitoring must be accomplished by watching or listening from an
attended control center for warning alarms, such as gas,temperature, pressure,vacuum, and
flow alarms, or by conducting an inspection or test at intervals specified in the operating
procedures.
Findin s
IGC procedure 4552.2 Rexburg LNG Recognizing Abnormal Operating Conditions (Step
1.3-1.3.6) does not require Vaporization Technicians to monitor and observe both
audible or visual alarm in the Control Building during regular working hours that may
indicate abnormal operating conditions, including vacuum alarms as required by 49 CFR
§193.2707.
3. 49 CFR §193.2515 Investigation of failures.
(a) Each operator shall investigate the cause of each explosion,fire, or LNG spill or leak which
results in:
(1) Death or injury requiring hospitalization; or
(2) Property damage exceeding$10,000
(b) As a result of the investigation, appropriate action must be taken to minimize recurrence of
the incident.
(c) If the Administrator or relevant state agency under the pipeline safety laws (49 U.S.C.
60101 et seq.) investigates an incident,the operator involved shall make available all relevant
information and provide reasonable assistance in conducting the investigation. Unless necessary
to restore or maintain service, or for safety, no component involved in the incident may be
moved from its location or otherwise altered until the investigation is complete or the
investigating agency otherwise provides. Where components must be moved for operational or
safety reasons,they must not be removed from the plant site and must be maintained intact to
the extent practicable until the investigation is complete or the investigating agency otherwise
provides.
Findin s
IGC Procedure 4563 Rexburg LNG Material and/or Component Failure does not contain
the verbiage as required by 49 CFR §193.2515 (c).

4. 49 CFR §193.2617 Repairs.
(a) Repair work on components must be performed and tested in a manner which:
(1)As far as practicable, complies with the applicable requirements of Subpart D of this part;
and
(2)Assures the integrity and operational safety of the component being repaired.
(b) For repairs made while a component is operating, each operator shall include in the
maintenance procedures under§ 193.2605 appropriate precautions to maintain the safety of
personnel and property during repair activities.
Findin s :
IGC Procedure 4555 Rexburg LNG Equipment and Components (Step 2.12) does not
contain the verbiage as required by 49 CFR §193.2617 Repairs (a)
5. NFPA 59A Standard for the Production, Storage, and Handling of Liquified Natural Gas
(LNG) 2001 Edition.
9.9 Other Operations.
9.9.2 Taking an LNG container out of service shall not be regarded as a normal operation and
shall not be attempted on any routine basis.All such activities shall require the preparation
of detailed procedures.
Findin s
IGC Procedure 4554 Section 1.1 does not contain the verbiage as required by NFPA 59A
Section 9.9.2.
6. 49 CFR§193.2911 Security lighting.
Where security warning systems are not provided for security monitoring under§ 193.2913,the
area around the facilities listed under§ 193.2905(a) and each protective enclosure must be
illuminated with a minimum in service lighting intensity of not less than 2.2 lux(0.2 ft`) between
sunset and sunrise..
Findin s :
IGC Procedure 4566 (Step 4.5.2) needs to have the verbiage as required by 49 CFR
§193.2911.
The above-mentioned item(s) were brought to the attention of IGC compliance representatives
during the inspection. We would 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,
Idaho 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,
Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utility Commission