I202311 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
November 30,2023
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to Notice of Probable Violation dated October 19,2023 (Report#I202311)
Dear Mr.Brooks,
This letter is intended to address two(2)probable violations stemming from a procedural,records,and field
inspection conducted by the Idaho Public Utilities Commission(IPUC)on October 16,2023,and October 18,2023,
of Intermountain Gas Company's(IGC)Rexburg LNG Plant.
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 controlled 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 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 would be provided.
Intermountain Gas Resnonse
IGC acknowledges the findings brought forth by the IPUC. IGC contacted the Rexburg LNG plant designer,
CHI Engineering (CHI), to obtain the original documentation of the fire protection evaluation. In lieu of the
evaluation documentation, as it was unable to be provided, IGC has requested a reevaluation that will be
conducted by CHI.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707•[phone]• FAX:[phone]
2. 49 CFR 8 193.2503 nnerating Procedures
Each operator all 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 Eauinment 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.
Finding(
The month of June handheld fire extinguisher checks were not completed as required by procedure 4558.3.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. Training will be provided to the Vaporization
Technicians on the importance of performing required fire extinguisher checks to ensure they are in good
working condition and ready for use in the event of an emergency.
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