I201807 NOPV

y , Idaho Public Utilities Commission Gov.C.L."Butch'"otter,Governor
P.O.Box 83720 Boise,ID 93720-0074 Paul KJeBander,Commissioner
Kristine Raper,Commissioner
Eric Anderson,Commissioner
December 4,2018 CERTIFIED MAIL
Pat Darras
Intermountain Gas Company 61
400 N 41'St. U
Bismarck, ND 58501
Dear Mr. Darras:
On November 14,2018,the Idaho Public Utilities Commission, Pipeline Safety Division, pursuant to
Chapter 601 of Title 49, United States Code,conducted a Procedural Audit on the Liquefied Natural Gas
(LNG)facility of Intermountain Gas Company's(IGC)equipment in the Owyhee District.
The inspection showed IGC's LNG system was out of compliance on certain items, resulting in probable
violations of the pipeline safety regulations at Title 49,Code of Federal Regulations, Parts 191 and 193.
See 49 CFR§ 190.207. The probable violations are as follows:
PROBABLE VIOLATIONS
1. 49 CFR§193.2011 Reporting.
Incidents,safety-related conditions, and annual pipeline summary data for LNG plants or
facilities must be reported in accordance with the requirements of Part 191 of this subchapter.
49 CFR§191.15(d) I...I LNG(...1 Incident report.
Supplemental report. Where additional related information is obtained after a report is
submitted under paragraph(a), (b)or(c)of this section, the operator must make a supplemental
report as soon as practicable with a clear reference by date to the original report.
Finding:
IGC's LNG facility procedures do not contain a supplemental reporting requirement in line with
49 CFR§§ 191.15(d) and 193.2011.
2. 49 CFR§ 191.22(c)National Registry of Pipeline and LNG Operators.
Changes. Each operator of a gas pipeline, gas pipeline facility, underground natural gas storage
facility, LNG plant, or LNG facility must notify PHMSA electronically through the National
Registry of Pipeline, Underground Natural Gas Storage Facility, and LNG Operators at
http://opsweb.phmso.dot.gov of certain events.
IGC LNG FACILITY PROBABLE VIOLATIONS LETTER—PAGE 1

Finding:
The LNG facility procedures do not contain notification requirements required by 49 CFR§
191.22(c).
3. 49 CFR§ 193.2619(c)(2)Control systems.
Control systems that are intended for fire protection must be inspected and tested at regular
intervals not to exceed 6 months.
Finding:
IGC's Procedure 4508 Section(s)2.7.1.3 and 2.7.2.3 do not include the"not to exceed 6 months"
requirement.
4. 49 CFR§ 193.2629 Buried or Submerged Components.
a. Each buried or submerged component that is subject to external corrosive attack must be
protected from external corrosion by. . . .
b. Where cathodic protection is applied, components that are electrically interconnected must
be protected as a unit.
49 CFR§ 193.2633 Interference Currents
a. Each component that is subject to electrical current interference must be protected by a
continuing program to minimize the detrimental effects of currents.
b. Each cathodic protection system must be designed and installed so as to minimize any
adverse effects it might cause to adjacent metal components.
c. Each impressed current power source must be installed and maintained to prevent adverse
interference with communications and control systems.
Finding:
The inspection showed that the above corrosion and interference requirements are being
managed by the corrosion technician in the Nampa District. This fact must be mentioned in a
procedure pertaining to the LNG plant.
5. 49 CFR§193.2801 Fire Protection.
Each operator must provide and maintain fire protection at LNG plants according to sections 9.1
through 9.7 and section 9.9 of NFPA-59A-2001.
NFPA-59A,Section 9.9.1
Manual emergency depressurizing means shall be provided where necessary for safety. Portions
of the plant that can be isolated from storage tanks or other sources of supply can be
depressurized by venting to the atmosphere. The discharge shall be directed so as to minimize
exposure to personnel or equipment.
NFPA-59A,Section 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.
IGC LNG FACILITY PROBABLE VIOLATIONS LETTER—PAGE 2

Findin :
The inspection showed that Section 9.9.1 of NFPA 59A could be covered by actions of plant
employees but this is not stated in any procedure. Further,Section 9.9.2 of NFPA 59A is not
listed or covered in any procedure.
REQUESTED ACTION
A reply to this letter,as outlined below, is required no later than 45 days from the date of this letter.
Please send all documents to our office at P.O. Box 83720-0074, Boise, Idaho 83720-0074. Be advised
that all material you submit in response to this enforcement action may be a public record,subject to
disclosure under Idaho's Public Records Law. See Idaho Code§74-101-126.
You have a right to appear before the Pipeline Safety Division in an informal conference before March 1,
2019,at the Commission's offices at 472 W.Washington St, Boise. You have the right to present
relevant documents to the Commission at that conference. The Commission will make available to you
any evidence which indicates that you may have violated the law, and you will have the opportunity to
rebut this evidence. See IDAPA 31.01.01.21-26. If you intend to request an informal conference, please
contact the Pipeline Safety Division no later than January 18,2019.
If you wish to dispute the allegations in this notice,but do not want an informal conference,you may
send the Pipeline Safety Division a written reply to this notice. This written reply must be filed with the
Commission on or before January 18,2019,and must be signed by a Company Official. The reply must
include a complete statement of all relevant facts including a complete description of the corrective
action(s)taken and any and all actions to be taken to prevent future failures in these areas of concern.
If you do not respond to this notice, as specified above, by January 18, 2019,you may be subject to
statutory civil penalties and further enforcement, as allowed by law. Idaho Code§61-712A states that
"[a]ny person who violates or fails to comply with,or who procures,aids or abets any violation of title
61, Idaho Code,governing safety of pipeline facilities and the transportation of gas,or of any order,
decision, rule or regulation duly issued by the Idaho public utilities commission governing the safety of
pipeline facilities and the transportation of gas,shall be subject to a civil penalty of not to exceed two
thousand dollars($2,000)for each violation for each day that the violation persists. However,the
maximum civil penalty shall not exceed two hundred thousand dollars($200,000)for any related series
of violation."
If you have any questions concerning this notice, please contact me at(208) 334-0321.Also all written
responses should be addressed to me at the above address or you may fax your response to (208) 334-
4045. We ppreciate your attention to this matter and your effort to promote pipeline safety.
Sincerel
D n M. UI er
Pipeline Safety, Program Manager
Idaho Public Utility Commission
IGC LNG FACILITY PROBABLE VIOLATIONS LETTER—PAGE 3