I202408 NOPV

Idaho Public Utilities Commission Brad Little,Governor
P.O. Box 83720, Boise,ID 83720-0074 Eric Anderson,President
John R.Hammond,Jr.,Commissioner
Edward Lodge,Commissioner
Aug 15, 2024 Report#I202408
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On July 17, 2024, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a failure investigation and site inspection follow-up of incident
NRC#1404942/1405150 of Intermountain Gas Company's ("IGC") Rexburg LNG (Liquified
Natural Gas) Plant pursuant to Chapter 601 of Title 49, United States Code.
Staff observed that some of the Idaho natural gas system(s) owned and operated by IGC, was out
of compliance on item(s).This results in probable violations of the pipeline safety regulations Title
49, Code of Federal Regulations,Part 193. The probable violations are as follows:
PROBABLE VIOLATION(S)
1. 49 CFR 4193.2503 Operating Procedures.
Each operator shall follow one or more manuals of written procedures to provide safety
in normal operation and in responding to an abnormal operation that would affect safety.
The procedures must include provisions for:
(b) Startup and shutdown, including for initial startup, performance testing to
demonstrate that components will operate satisfactory in service.
49 CFR §193.2513 Transfer Procedures
(a) Each transfer of LNG (Liquified Natural Gas) or other hazardous fluid must be
conducted in accordance with one or more manuals of written procedures to provide
for safe transfers.
(b) The transfer procedures must include provisions for personnel to:
(1) Before transfer, verify that the transfer system is ready for use, with
connections and controls in proper positions, including if the system could contain
a combustible mixture, verifying that it has been adequately purged in accordance
with a procedure which meets the requirements of"Purging Principles and
Practices (incorporated by reference, see § 193.2013)";
(c) In addition to the requirements of paragraph(b) of this section,the procedures for
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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cargo transfer must be located at the transfer area and include provisions for personnel to:
IGC-Rexburg LNG Transfer Operations Procedure 4565
L GENERAL
1.2. Personnel involved in LNG transfer operations must be familiar and
knowledgeable with the transfer equipment and systems including:
1.2.1. Truck Off-Loading Skid
1.2.2. Piping Systems
1.2.3. Storage Tank
1.2.4. Pump Trailer
1.2.5. Vaporizer
1.2.6. Controls System
2. SAFETY PRECAUTIONS
2.1. Personnel must wear protective clothing.
3. VAPORIZATION TECHNICIAN RESPONSIBILITIES
3.3. The Vap. Tech(Vaporization Technician) shall perform the following upon
arrival of the LNG trailer:
3.3.1. Procedure 4565 - Rexburg LNG Transfer Operations shall be located at the
Truck Offloading Skid.
3.3.2. Visually check LNG trailers for leaks or other signs of hazardous
conditions before making any connections.
3.3.13. Verify LNG trailer vent valve and fill valve are closed before
connecting/disconnecting hoses.
3.3.14. Complete necessary items on Rexburg LNG Truck Off Loading
Operations Checklist prior to beginning transfer operations.
3.4. The Carrier/driver is responsible to perform the following and provide the
requested information to the Vap.Tech prior to beginning transfer operations:
3.4.4. Connecting the fill hose and vapor return hose to the LNG trailer.
4. PROCEDURE
4.6. Carrier/driver shall inspect valves, valve box, and pressure build coil on trailer to
ensure all components are damage free and in the proper position for operation.
4.7. Carrier/driver shall begin pressure building in trailer with a target of 60 psig.
4.8. Connect liquid and vapor hoses to the proper LNG trailer connections.
Finding(s)•
Vap. Tech did not verify valves were in the proper position for operations.
Carrier/driver did not verify valves were in the proper position for operations.
Vap. Tech did not accurately complete items on Rexburg LNG Truck Off Loading
Operations Checklist prior to beginning transfer operations. (Picture(s) of checklist upon
request).
Rexburg LNG Truck Off Loading Operations Checklist dated 7/16/24 is checked
that(Tasks)#1, #3 and#8 were completed prior to startup.
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(#1) The transfer system was not verified that it was safe to conduct transfer operations.
(0) Carrier/driver and LNG Plant Operator did not visually check LNG truck and trailer
for safety violations and hazardous conditions.
(#8)Valve (V-6) fill line bleed/vent valve on LNG trailer(83110149) was not verified
that it was closed before connecting/disconnecting hoses.
Vap. Techs were unfamiliar and did not know the locations of ESV(Emergency
Shutdown Valves) (per carrier/driver) on trailer, prior to the LNG spill incident.
Vap. Tech at the off-loading skid stated that Procedure 4565 was not located/present for
cargo transfer.
Vap. Tech did not visually check LNG trailers for leaks or other signs of hazardous
conditions (V-6 fill line bleed/vent valve left open) before making any connections.
Carrier/driver did not inspect valves, valve box, and pressure build coil on trailer to
ensure all components are damage free and in the proper position for operation.
Carrier/driver stated that once the truck &trailer were on the off-load skid. The
Vap. Tech ensured brakes were set and trailer wheels were chocked, truck engine
was off, keys removed from cab, and verified that carrier/driver's current
state/federal truck and trailer inspection documentation was checked.
Carrier/driver was then informed that he needed to go to the control room and
wait till off-load was completed.
Vap. Tech did not ensure that Carrier/driver performed the following task (s) and provide
the requested information to Vap. Tech prior to beginning transfer operations:
Carrier/driver shall connect liquid and vapor hoses to the proper LNG trailer
connections.
Vap. Tech stated that he connected hoses to the LNG trailer.
Carrier/driver shall begin pressure building in trailer with a target of 60 psig.
Vap. Tech performed pressure building and stated to IPUC personnel that
the desired range was between 60-65 PSI to overcome tank head pressure.
During the pressure building is when LNG started venting out of
the truck relief valves.
2. NFPA 59A Standard for the Production, Storage, and Handling of Liquified
Natural Gas (LNG) 2001 Edition
11.4.5 Loading or Unloading Operations
11.4.5.1 General
(g) The transfer system shall be checked prior to use to ensure that valves are in
the correct position. Pressure and temperature conditions shall be observed during
the transfer operation.
(h)The transfer system shall be checked prior to use to ensure that valves are in
the correct position for transfer. Transfer operations shall be commenced slowly;
if any unusual variance in pressure or temperature occurs, transfer shall be
stopped until the cause has been determined and corrected. Pressure and
temperature conditions shall be observed during the transfer operation.
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IGC-Rexburg LNG Transfer Operations Procedure 4565
L GENERAL
1.2. Personnel involved in LNG transfer operations must be familiar and
knowledgeable with the transfer equipment and systems including:
1.2.1. Truck Off-Loading Skid
1.2.2. Piping Systems
1.2.3. Storage Tank
1.2.4. Pump Trailer
1.2.5. Vaporizer
1.2.6. Controls System
Finding(s):_
Personnel were not familiar with the correct positions of the valves prior to commencing
off-load operations.
3. 49 CFR 093.251 Communication systems
Each LNG plant must have a primary communication system that provides for verbal
communications between all operating personnel at their work stations in the LNG plant.
49 CFR 093.2503 Operating Procedures.
Each operator shall follow one or more manuals of written procedures to provide safety
in normal operation and in responding to an abnormal operation that would affect safety.
The procedures must include provisions for:
IGC-Emergency Manual for Rexburg Satellite LNG Facility
4.0 PERSONNEL SAFETY
It is the purpose of this section to briefly identify those areas that directly affect a
response to an emergency. A more detailed description can be found in the Rexburg
LNG Fire Manual.
4.1 COMMUNICATION
(a) Inside fenced area (outside of control building) ... communications between
company personnel throughout the facility will be by intrinsically safe portable radios.
NFPA 59A Standard for the Production, Storage, and Handling of Liquified
Natural Gas (LNG) 2001 Edition.
11.4.6 Communications and Lighting. Communications shall be provided at loading and
unloading locations so that the operator can be in contact with other remotely located
personnel who are associated with the loading or unloading operation.
Finding(s)•
Vap. Tech at off-loading skid was not wearing the intrinsically safe portable radio
provided for verbal communication at work stations, or in emergency situations.
4. IGC-Fire Manual for Rexburg Satellite LNG Facility
4.0 EFFECTS OF EXPOSURE TO CRYOGENIC FLUIDS
4.3 Exposure to LNG
Liquified natural gas exposed to atmospheric pressure is at sub-zero temperatures,
approximately minus—-260°F and contact with skin will result in severe frostbite.
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LNG spills expose the Vap. Tech to several hazards, including localized cold effects
such as cryogenic burns, frostbite and general cold effects(hypothermia, lung damage,
asphyxia. In the event of ignition and burning of the vapor cloud, thermal radiation
hazards would also exist. Direct contact with a cryogenic liquid generally produces
rapid freezing of tissue because of the high rate of heat transfer.
Keeping the liquid confined within piping and storage vessels and wearing adequate
protective apparel are the two best ways to avoid exposure of the liquid to skin. Contact
with cold gas will usually involve more body area than liquid contact. When cold gas
is released in a jet with a corresponding high rate of heat transfer,the result can be rapid
freezing of large portions of the body. Equipment and structures should also be
protected from contact with low temperature vapor to prevent embrittlement of
materials.
When handling of LNG or equipment which contains LNG, protective clothing should
be worn to protect the skin against the extremely low temperatures encountered.
Leather gloves should always be worn when handling anything that is or may have
been in contact with LNG. Gloves should be loose-fitting so that they may be easily
removed should liquid splash onto or into them. If splashing or spraying of LNG is
likely to occur, the face and eyes should be protected with a face shield. Overalls or
similar type work clothing should be worn preferably without pockets or cuffs and
trousers should be worn outside of boots. Where there is considerable risk of spilling
or spraying, special clothing which provides protection against frostbite, flash burn or
fire should be worn.
NFPA 59A Standard for the Production, Storage, and Handling of Liquified
Natural Gas (LNG) 2001 Edition.
9.7 Personnel Safety.
9.7.1* Protective clothing, which will provide protection against the effects of
exposure to LNG, shall be available and readily accessible at the facility.
9.7.2 Those employees who are involved in emergency activities, as determined
in accordance with 9.1.2, shall be equipped with the necessary protective clothing
and equipment and qualified in accordance with NFPA 600, Standard on
industrial Fire Brigades.
*Appendix A Explanatory Material
A.9.7.1 Protective clothing for normal liquid transfer operations should include
cryogenic gloves, safety glasses, face shields, and coveralls or long-sleeve shirts.
Finding(s).
Vap. Tech.personnel were in short sleeve shirts during the off-load of— -263°F liquid
natural gas. (Per photographs and statements).
5. 49 CFR &193.2503 Operating Procedures.
Each operator shall follow one or more manuals of written procedures to provide safety
in normal operation and in responding to an abnormal operation that would affect safety.
SF 422 Job Safety Analysis/Tailgate Meetings
Instructions: on JSA Form 23023
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Review the job or task to be performed and associated potential hazards with all individuals -
participating/Observing in, or affected by,the work activity prior to START of each job or
when significant changes in the work occur. Fill in the upper section of the form, then,
review the applicable sections in the table below, provide details as requested and ensure
each individual sign form 23023 (Rev 3/2020).
Policy Statement Job Safety Analysis/Tailgate Meetings (Rev Date: 1/19/2021)
2. Employee Responsibilities
2.2 Employees shall assess their work area, adjust the JSA(Job Safety Analysis)
form, and communicate any additional changes, after the following occurrences:
2.2.3 If new individuals are entering the work area, verify they have been
notified of the existing hazards and controls by having them sign onto the
current JSA form.
Finding(s): The driver was not notified of existing hazards, controls and did not sign the
23023 form.
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REQUESTED ACTIONS
A reply to this correspondence is required no later than 45 days from the date of this letter. Please
submit a written reply providing a statement of all relevant facts including a complete description
of the corrective action(s) taken with respect to the above referenced probable violations, and all
actions to be taken to prevent future failures in these areas of concern. This written reply must be
signed by a Company official with authority to bind the Company.
Please send all documents to our office at 11331 W. Chinden Blvd, Boise, Idaho 83714-1021. Be
advised that all material you submit in response to this enforcement action may be a public record
and subject to disclosure under Idaho's Public Records Law. See Idaho Code §§74-101 et seq.
If you wish to dispute any of the above referenced potential violations,you have the right to appear
before the Pipeline Safety Division in an informal conference before September 29, 2024, at the
above address. You have the right to present relevant documents and evidence to the Pipeline
Safety Division at that conference. The Pipeline Safety Division 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 Commission Orders 35095 and 35334, which can be found at
https://puc.idaho.gov/. If you intend to request an informal conference,please contact the Pipeline
Safety Division no later than September 14, 2024.
If you wish to dispute any of 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 September 29,2024,and must be signed by a Company
official with authority to bind the Company. The reply must include a complete statement of all
relevant facts, and all documentation, evidence, and argument the Company submits to refute any
of the above referenced probable violations.
These violations may be subject to any Commission enforcement action as allowed under Idaho
law including, but not limited to, potential civil penalties of up to two hundred thousand dollars
($200,000). See Idaho Code §61-712A.
If you have any questions concerning this Notice,please contact me at(208) 334-0333. All written
responses should be addressed to me at the above address, or you may fax your response to (208)
334-3762.
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sinc ely,
Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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