I202310 LOC

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
Letter of Concern
October 19, 2023 Report# I202310
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 4t' St.
Bismarck, ND 58501
Dear Mr. Darras:
On Oct 16 & 18, 2023, 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 2022.
The item(s) listed below are of concern:
1. 49 CFR �193.2607 Foreign Material .
(b) LNG plant grounds must be free from rubbish, debris, and other material which
present a fire hazard. Grass areas on the LNG plant grounds must be maintained in a
manner that does not present a fire hazard.
Finding(s)-
Weeds within the facility need to be sprayed and pulled to prevent fire hazards.
2. 49 CFR 4193.2609 Support Systems .
Each support system or foundation of each component must be inspected for any
detrimental change that could impair support.
Findin2(s)•
All tank saddles/supports are showing signs of cracking and measures to prevent further
degradation need to be taken.
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

3. 49 CFR 4193.2613 AuxWary power sources .
Each auxiliary power source must be tested monthly to check its operational capability
and tested annually for capacity. The capacity test must take into account the power
needed to start up and simultaneously operate equipment that would have to be served by
that power source in an emergency.
Finding(s)
Procedure 4558 Rexburg LNG Fire Equipment Maintenance Step 2.5.4. The engine and
generator will be started and run once per month. The verbiage"and tested annually for
capacity" needs to be added as required.
4. 49 CFR &193.2505 Cooldown .
(b) After cooldown stabilization is reached, cryogenic piping systems must be checked
for leaks in areas of flanges, valves, and seals.
Findings)
This verbiage needs to be added to the Daily Plant checklist(b) After cooldown
stabilization is reached, cryogenic piping systems must be checked for leaks in areas of
flanges, valves, and seals.
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(208) 334-0333. 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