I202311 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
October 19, 2023 Report#I202311
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 4"' St.
Bismarck,ND 58501
Dear Mr. Pat Darras:
On October 16 & 18, 2023, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division("Staff'),conducted a Procedural,Records,and Field inspection of Intermountain Gas Company's
("IGC")Rexburg LNG 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("Company")was
out of compliance on item(s). This results in probable violations of the pipeline safety regulations Title 49,
Code of Federal Regulations, Part 192. The probable violations are as follows:
PROBABLE VIOLATIONS)
1. NFPA 59A Standard for the Production, Storage, and Handling of Liquified Natural Gas
(LNG) 2001 Edition
9.4 Fire Protection Water Systems.
9.4.1 A water supply and a system for distributing and applying water shall be provided for
protection of exposures; for cooling containers, equipment, and piping; and for controlling
unignited leaks and spills.
Exception: Where an evaluation in accordance with 9.1.2 indicates the use of water is
unnecessary or impractical.
Finding(s)-
No water supply and a system for distributing and applying water is installed.No evaluation
based on sound fire protection engineering principles, analysis of local conditions,hazards within
the facility, and exposure to or from other property was provided.
2. 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.
IGC-Rexburg LNG Fire Equipment Maintenance-Procedure 4558.3 Revision April 22,2021.
2.4 Handheld Fire Extinguishing Units
2.4.4 Each unit is checked monthly by the Rexburg LNG Facility Vaporization Technicians to
ensure the hoses do not have any cracks or breaks.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]

Findim(s)•
The Month of June handheld fire extinguisher checks were not completed as required by procedure
4558.3.
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 December 3, 2023, 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:Hpuc.idaho.gov/. If you intend to request an informal
conference,please contact the Pipeline Safety Division no later than November 18,2023.
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 December 3,2023 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.
If you do not respond to this notice by December 3, 2023, you 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 [phone]. 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.
Sincerely,
Jeff Brooks
Pipeline Safety,Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]