I202204 NOPV

Idaho Public Utilities Commission Brad Little,Governor
P.O. Box 83720, Boise, ID 83720.0074 Eric Anderson,President
John Chatburn,Commissioner
John R.Hammond,Jr.,Commissioner
October 31, 2022 Report # I202204
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 4th St.
Bismarck, ND 58501
Dear Mr. Darras:
On Oct 3-6, 2022, 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.
During the inspection, Staff observed that some of the Idaho natural gas distribution system owned
and operated by IGC was out of compliance on items. 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�193.2507 Monitoring operations.
Each component in operation or building in which a hazard to persons or property could
exist must be monitored to detect fire or any malfunction or flammable fluid that could
cause a hazardous condition. Monitoring must be accomplished by watching or listening
from an attended control center for warning alarms, such as gas, temperature, pressure,
vacuum, and flow alarms, or by conducting an inspection or test at intervals specified in
the operating procedures.
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 (incorporated by reference,
see 19§ 3.2013). However, LNG plants existing on March 31, 2000, need not comply with
provisions on emergency shutdown systems, water delivery systems, detection systems,
and personnel qualification and training until September 12, 2005.
NFPA 59A Standard for the Production, Storage, and Handling of Liquified Natural
Gas (LNG) 2001 Edition.
9.3 Fire and Leak Control.
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise,ID 83714
Telephone:[phone] Facsimile:[phone]

9.3.1 Those areas, including enclosed buildings, that have a potential for flammable gas
concentrations, LNG or flammable refrigerant spills, and fire shall be monitored as
required by the evaluation in 9.1.2.
9.3.2 Continuously monitored low-temperature sensors or flammable gas detection
systems shall sound an alarm at the plant site and at a constantly attended location if the
plant site is not attended continuously. Flammable gas detection systems shall activate an
audible and visual alarm at not more than 25 percent of the lower flammable limit of the
gas or vapor being monitored.
9.3.3 Fire detectors shall sound an alarm at the plant site and at a constantly attended
location if the plant site is not attended continuously. In addition, if so determined by an
evaluation in accordance with 9.1.2, fire detectors shall be permitted to activate portions of
the ESD system.
9.3.4 The detection systems determined from the evaluation in 9.1.2 shall be designed,
installed, and maintained in accordance with NFPA 72, National Fire Alarm Code, or
NFPA 1221, Standard for the Installation, Maintenance, and Use of Emergency Services
Communications Systems, as applicable.
Finding(s)
Staff observed that the calibration gas used to test the Lower Explosive Limit (LEL)
detection alarm had an expiration date of 2014, rendering the tests on the LEL alarm
invalid. Additionally, when tested, audible and strobe warning alarms were not working
because they were disconnected in the main control box.
2. 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 (incorporated by reference,
see 19� 3.2013). However, LNG plants existing on March 31, 2000, need not comply with
provisions on emergency shutdown systems, water delivery systems, detection systems,
and personnel qualification and training until September 12, 2005.
NFPA 59A Standard for the Production, Storage, and Handling of Liquified Natural
Gas (LNG) 2001 Edition.
9.7 Personnel Safety.
9.7.4* At least three portable flammable gas indicators shall be readily available.
Findings)
Staff found that there was only one portable flammable gas detector at the LNG site, and
it was in the service technician's truck.
IGC REXBURG LNG NOTICE OF PROBABLE VIOLATION(S)-PAGE 2

3. 49 CFR 4193.2017 Plans and procedures.
(a) Each operator shall maintain at each LNG plant the plans and procedures required for
that plant by this part. The plans and procedures must be available upon request for review
and inspection by the Administrator or any State Agency that has submitted a current
certification or agreement with respect to the plant under the pipeline safety laws (49
U.S.C. 60101 et seq.). In addition,each change to the plans or procedures must be available
at the LNG plant for review and inspection within 20 days after the change is made.
49 CFR 4193.2605 Maintenance procedures.
(c) Each operator shall include in the manual required by paragraph (b) of this section
instructions enabling personnel who perform operation and maintenance activities to
recognize conditions that potentially may be safety-related conditions that are subject to
the reporting requirements of 191.23 of this subchapter.
Finding(s)•
Staff found that the Operating Manual for the Rexburg LNG plant does not have a
procedure enabling personnel who perform operation and maintenance activities to
recognize conditions that potentially may be safety-related conditions.
4. 49 CFR 4193.2017 Plans and Procedures.
(b) Each operator shall maintain at each LNG plant the plans and procedures required for
that plant by this part. The plans and procedures must be available upon request for review
and inspection by the Administrator or any State Agency that has submitted a current
certification or agreement with respect to the plant under the pipeline safety laws (49
U.S.C. 60101 et seq.). In addition,each change to the plans or procedures must be available
at the LNG plant for review and inspection within 20 days after the change is made.
49 CFR 093.2607 Foreign Material.
(a) The presence of foreign material, contaminants, or ice shall be avoided or controlled to
maintain the operational safety of each component.
(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.
Findings)
Staff found that the Operating Manual for the Rexburg LNG plant does not require that the
facility be free from the presence of foreign material and debris.
5. 49 CFR �193.2017 Plans and Procedures.
(c) Each operator shall maintain at each LNG plant the plans and procedures required for
that plant by this part. The plans and procedures must be available upon request for review
and inspection by the Administrator or any State Agency that has submitted a current
certification or agreement with respect to the plant under the pipeline safety laws (49
U.S.C. 60101 et seq.). In addition,each change to the plans or procedures must be available
at the LNG plant for review and inspection within 20 days after the change is made.
IGC REXBURG LNG NOTICE OF PROBABLE VIOLATION(S)-PAGE 3

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 (incorporated by reference,
see §19 3.2013). However, LNG plants existing on March 31, 2000, need not comply with
provisions on emergency shutdown systems, water delivery systems, detection systems,
and personnel qualification and training until September 12, 2005.
NFPA 59A Standard for the Production, Storage, and Handling of Liquified Natural
Gas (LNG) 2001 Edition.
9.9 Other Operations.
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.
Finding(s):
Staff found that the Operating Manual for the Rexburg LNG plant does not have a
procedure for manually depressurizing the plant or venting LNG in the event of an
emergency as necessary for safety.
6. 49 CFR§193.2513 Transfer Procedures.
(a) Each transfer of LNG 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
19§ 3.2013)'
(2) Before transfer, verify that each receiving container or tank vehicle does not contain
any substance that would be incompatible with the incoming fluid and that there is
sufficient capacity available to receive the amount of fluid to be transferred.
(3) Before transfer,verify the maximum filling volume of each receiving container or tank
vehicle to ensure that expansion of the incoming fluid due to warming will not result in
overfilling or overpressure.
(4) When making bulk transfer of LNG into a partially filled (excluding cooldown heel)
container, determine any differences in temperature or specific gravity between the LNG
being transferred and the LNG already in the container and, if necessary, provide a means
to prevent rollover due to stratification.
(5) Verify that the transfer operations are proceeding within design conditions and that
overpressure or overfilling does not occur by monitoring applicable flow rates, liquid
levels, and vapor returns.
(6) Manually terminate the flow before overfilling or overpressure occurs; and
(7) Deactivate cargo transfer systems in a safe manner by depressurizing, venting, and
disconnecting lines and conducting any other appropriate operations.
IGC REXBURG LNG NOTICE OF PROBABLE VIOLATION(S)-PAGE 4

IGC -Rexburg LNG Transfer Operations—Procedure 4565.2 Revision April 22,
2021
3.3 .14. Complete necessary items on LNG Transfer Operations Checklist prior to
beginning transfer operations.
3.6.4. Ensure LNG Transfer Operations Checklist is complete, signed and dated by a
Vap. Tech.
3.6.4.1. A separate checklist is required for each trailer offload.
Findin2W:
Staff found that the Operator did not utilize Rexburg LNG Truck Off Loading Operations
Checklist as required by IGC procedure 4565.2
7. 49 CFR �193.2639 Maintenance Records.
(a)Each operator shall keep a record at each LNG plant of the date and type of each
maintenance activity performed on each component to meet the requirements of this part.
For each LNG facility that is designed and constructed after March 31, 2000 the operator
shall also maintain related periodic inspection and testing records that NFPA-59A-2001
(incorporated by reference, see 193.2013) requires. Maintenance records, whether
required by this part or NFPA-59A-2001, must be kept for a period of not less than five
years.
49 CFR 093.2621 Testing transfer hoses.
(a) Tested once each calendar year, but with intervals not exceeding 15 months, to the
maximum pump pressure or relief valve setting; and
(b) Visually inspected for damage or defects before each use.
IGC -Rexburg LNG Transfer Operations—Procedure 4565.2 Revision April 22,
2021
3.3 .14. Complete necessary items on LNG Transfer Operations Checklist prior to
beginning transfer operations.
3.6.4. Ensure LNG Transfer Operations Checklist is complete, signed and dated by a
Vap. Tech.
3.6.4.1. A separate checklist is required for each trailer offload.
Findings):
Staff did not find records of transfer hose inspections being completed or recorded for each
trailer as required by 49 CFR 193.2639 Maintenance Records, 49 CFR 193.2621 Testing
Transfer Hoses,and IGC—Rexburg LNG Transfer Operations-Procedure 4565.2 Revision
April 22, 2021 Section 3.6.4.1.
8. 49 CFR &193.2719 Training: records.
(a) Each operator shall maintain a system of records which -.
(1) Provide evidence that the training programs required by this subpart have been
implemented; and
(2) Provide evidence that personnel have undergone and satisfactorily completed the
required training programs.
IGC REXBURG LNG NOTICE OF PROBABLE VIOLATION(S)-PAGE 5

49 CFR 4193.2707 Operations and maintenance.
(a) Each operator shall utilize for operation or maintenance of components only those
personnel who have demonstrated their capability to perform their assigned functions by -
(1) Successful completion of the training required by §§193.2713 and 193.2717; and
(2) Experience related to the assigned operation or maintenance function; and
(3) Acceptable performance on a proficiency test relevant to the assigned function.
49 CFR k193.2713 Training: operations and maintenance.
(a) Each operator shall provide and implement a written plan of initial training to instruct-
(1) All permanent maintenance, operating, and supervisory personnel—
(i) About the characteristics and hazards of LNG and other flammable fluids used or
handled at the facility, including, with regard to LNG, low temperatures, flammability of
mixtures with air, odorless vapor, boiloff characteristics, and reaction to water and water
spray.
(ii) About the potential hazards involved in operating and maintenance activities; and
(iii) To carry out aspects of the operating and maintenance procedures under §§§193.2503
and 193.2605 that relate to their assigned functions; and
(2) All Personnel-
(i) To carry out the emergency procedures under 19� 3.2509 that relate to their assigned
functions; and
(ii) To give first aid; and
(3) All operating and appropriate supervisory personnel -
(i) To understand detailed instructions on the facility operations, including controls,
functions, and operating procedures; and
(ii) To understand the LNG transfer procedures provided under 19§ 3.2513.
Findings)
Staff did not find any written plan of initial training, nor any records of initial training.
9. 49 CFR V93.2719 Training: records.
(a) Each operator shall maintain a system of records which -.
(1) Provide evidence that the training programs required by this subpart have been
implemented; and
(2) Provide evidence that personnel have undergone and satisfactorily completed the
required training programs.
49 CFR 093.2713 Training: operations and maintenance.
(b)A written plan of continuing instruction must be conducted at intervals of not more than
two years to keep all personnel current on the knowledge and skills they gained in the
program of initial instruction.
Findings):
Staff did not find any written plan of continuing instruction, nor any records of two-year
refresher training.
10. 49 CFR�193.2715 Training: security.
IGC REXBURG LNG NOTICE OF PROBABLE VIOLATION(S)-PAGE 6

(a) Personnel responsible for security at an LNG plant must be trained in accordance with
a written plan of initial instruction to:
(1) Recognize breaches of security;
(2) Carry out the security procedures under 193.2903 that relate to their assigned duties;
(3) Be familiar with basic plant operations and emergency procedures, as necessary to
effectively perform their assigned duties; and
(4) Recognize conditions where security assistance is needed.
49 CFR 093. 2719 Training: records.
(a) Each operator shall maintain a system of records which-.
(1) Provide evidence that the training programs required by this subpart have been
implemented; and
(2) Provide evidence that personnel have undergone and satisfactorily completed the
required training programs.
Findinti(s)
Staff did not find any written plan of initial training, nor any records of initial training.
11. 49 CFR �193.2715 Training: security.
(a) Personnel responsible for security at an LNG plant must be trained in accordance with
a written plan of initial instruction to:
(1) Recognize breaches of security;
(2) Carry out the security procedures under 19§ 3.2903 that relate to their assigned duties;
(3) Be familiar with basic plant operations and emergency procedures, as necessary to
effectively perform their assigned duties; and
(4) Recognize conditions where security assistance is needed.
(b)A written plan of continuing instruction must be conducted at intervals of not more than
two years to keep all personnel having security duties current on the knowledge and skills
they gained in the program of initial instruction.
49 CFR 093. 2719 Training: records.
(a) Each operator shall maintain a system of records which-.
(1) Provide evidence that the training programs required by this subpart have been
implemented; and
(2) Provide evidence that personnel have undergone and satisfactorily completed the
required training programs.
Finding(s)•
Staff did not find any written plan of continuing instruction, nor any records of two-year
refresher training.
12. 49 CFR §193.2717 Training: fire protection.
(a) All personnel involved in maintenance and operations of an LNG plant, including their
immediate supervisors, must be trained according to a written plan of initial instruction,
including plant fire drills, to:
(1) Know the potential causes and areas of fire;
(2) Know the types, sizes, and predictable consequences of fire; and
IGC REXBURG LNG NOTICE OF PROBABLE VIOLATION(S)-PAGE 7

(3) Know and be able to perform their assigned fire control duties according to the
procedures established under 19 3.2509 and by proper use of equipment provided under
§193.2801.
(c)Plant fire drills must provide personnel hands-on experience in carrying out their duties
under the fire emergency procedures required by 19§ 3.2509.
49 CFR 4193. 2719 Training: records.
(a) Each operator shall maintain a system of records which-.
(1) Provide evidence that the training programs required by this subpart have been
implemented; and
(2) Provide evidence that personnel have undergone and satisfactorily completed the
required training programs.
Findings)
Staff did not find any written plan of initial training, nor any records of initial training.
13. 49 CFR 4193.2717 Training: fire protection.
(a)All personnel involved in maintenance and operations of an LNG plant, including their
immediate supervisors, must be trained according to a written plan of initial instruction,
including plant fire drills, to:
(1) Know the potential causes and areas of fire;
(2) Know the types, sizes, and predictable consequences of fire; and
(3) Know and be able to perform their assigned fire control duties according to the
procedures established under 19§ 3.2509 and by proper use of equipment provided under
§193.2801.
(b) A written plan of continuing instruction, including plant fire drills, must be conducted
at intervals of not more than two years to keep personnel current on the knowledge and
skills they gained in the instruction under paragraph(a) of the section.
(c)Plant fire drills must provide personnel hands-on experience in carrying out their duties
under the fire emergency procedures required by 19§ 3.2509
49 CFR 093. 2719 Training: records.
(a) Each operator shall maintain a system of records which-.
(1) Provide evidence that the training programs required by this subpart have been
implemented; and
(2) Provide evidence that personnel have undergone and satisfactorily completed the
required training programs.
Finding(s)
Staff did not find any written plan of continuing instruction, nor any records of two-year
refresher training.
14. 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.
IGC-Rexburg LNG Equipment and Components—Procedure 4555.4 Revision April
22, 2021
IGC REXBURG LNG.NOTICE OF PROBABLE VIOLATION(S)-PAGE 8

2. PROCEDURE
2.1. All combustible gas detectors shall be inspected and tested at intervals not to exceed
six (6) months and repaired/replaced per manufacturer's recommendations if needed.
Findings)
Intermountain Gas Company Standard Operating Procedure 4555.4 (2.1) requires all LEL
combustible gas detectors shall be inspected and tested at intervals not to exceed six (6)
months and repaired/replaced per manufacturer's recommendations if needed. When
reviewing records, it was documented that testing took place in May 2021 and November
2021 but was not completed in May 2022 as required by procedure 4555.4.
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 an IGC 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 15, 2022,
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 November 30, 2022.
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 15, 2022, and must be signed by an IGC
official with authority to bind the company. The reply must include a complete statement of all
relevant facts, and all documentation, evidence, and argument IGC submits to refute any of the
above referenced probable violations.
If you do not respond to this notice by December 15,2022,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 ($200,000). Sea 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.
IGC REXBURG LNG NOTICE OF PROBABLE VIOLATION(S)-PAGE 9

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
IGC REXBURG LNG NOTICE OF PROBABLE VIOLATION(S)-PAGE 10