I201807 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD•P.O.BOX 7608•BOISE,IDAHO 83707•[phone]•FAX:[phone]
s i i All
January 8,2019
10 ,l
Mr.Darrin Ulmer
Pipeline Safety, Programs Manager
Idaho Public Utilities Commission
P.O. Box 83720-0074
Boise,ID 83720-0074
Subject: Response to December 4,2018 Notice of Probable Violations—Nampa LNG Plant
Dear Mr. Ulmer,
This letter is intended to address the December 4,2018 Notice of Probable Violations identified by the Idaho Public Utilities
Commission(IPUC)during the November 14,2018 Procedural Audit of Intermountain Gas Company(IGC)at the Nampa
LNG Plant. Listed below are the stated probable violations and the respective corrective actions taken by IGC.
PROBABLE VIOLATIONS
1. 49 CFR& 192.2011 Reporting.
Incidents, safety-related conditions, and annual pipeline summary data for LNG plants or facilities must be
reported in accordance with the requirements of Part 191 of this subchapter.
49 CFR§ 191.15(d) 1...1 LNG 1...1 Incident report.
Supplemental report. Where additional related information is obtained after a report is submitted under
paragraph(a),(b)or(c)of this section,the operator must make a supplemental report as soon as practicable
with a clear reference by date to the original report.
Finding:
IGC's LNG facility procedures do not contain a supplemental reporting requirement in line with 49 CFR§§
191.15(d)and 193.2011.
Intermountain Gas Response
IGC created Standard Operating Procedure 4515 —Reporting Unsafe Conditions, which includes updating and specifying
the reporting requirements of incidents and safety-related conditions at the Nampa LNG Plant. Procedure 4515 is specific
to the LNG Plant. Section 2.1.4. specifically addresses the reporting requirements of a Supplemental Report.
2. 49 CFR§ 191.22(c)National Registry of Pipeline and LNG Operators.
Changes.Each operator of a gas pipeline,gas pipeline facility,underground natural gas storage facility, LNG
plant,or LNG facility must notify PHMSA electronically through the National Registry of Pipeline,
Underground Natural Gas Storage Facility,and LNG Operators at http://opsweb.phmsa.dot.gov of certain
events.
Finding:
The LNG facility procedures do not contain notification requirements required by 49 CFR§ 191.22(c).
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Intermountain Gas Response
IGC created Standard Operating Procedure 4516—National Registry of LNG Operators,which provides guidelines and
criteria for electronically notifying PHMSA of certain events through the National Registry of Pipeline, Underground
Natural Gas Storage Facility,and LNG Operators. Procedure 4516 is specific to the LNG Plant.
3. 49 CFR§ 193.2619(c)(2)Control systems.
Control systems that are intended for fire protection must be inspected and tested at regular intervals not to
exceed 6 months.
Finding:
IGC's Procedure 4508 Section(s)2.7.1.3 and 2.7.2.3 do not include the"not to exceed 6 months"requirement.
Intermountain Gas Response
IGC updated Standard Operating Procedure 4508-LNG Plant Fire Equipment Maintenance. Section 2.7-Automatic Fire
Suppression System was amended to include"not to exceed six(6)months." Procedure 4508 is specific to the LNG Plant.
4. 49 CFR& 193.2629 Buried or Submerged Components.
a. Each buried or submerged component that is subject to external corrosive attack must be protected from
external corrosion by. . . .
b. Where cathodic protection is applied, components that are electrically interconnected must be protected as
a unit.
49 CFR 4 193.2633 Interference Currents
a. Each component that is subject to electrical current interference must be protected by a continuing program
to minimize the detrimental effects of currents.
b. Each cathodic protection system must be designed and installed so as to minimize any adverse effects it
might cause to adjacent metal components.
c. Each impressed current power source must be installed and maintained to prevent adverse interference
with communications and control systems.
Finding:
The inspection showed that the above corrosion and interference requirements are being managed by the
corrosion technician in the Nampa District. This fact must be mentioned in a procedure pertaining to the LNG
Plant.
Intermountain Gas Response
A reference was added to the Cross Reference Guide stating that the corrosion control requirements of buried pipelines per
193.2629 and 193.2633 at the Nampa LNG Plant are monitored and mitigated by local corrosion personnel reporting from
IGCs Nampa District Office.
5. 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.
NFPA-59A,Section 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.
NFPA-59A,Section 9.9.2
Taking an LNG container out of service shall not be regarded as a normal operation and shall not be attempted
on any routine basis.All such activities shall require the preparation of detailed procedures.
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Finding:
The inspection showed that Section 9.9.1 of NFPA 59A could be covered by actions of plant employees but
this is not stated in any procedure.Further, Section 9.9.2 of NFPA 59A is not listed or covered in any
procedure.
Intermountain Gas Response
IGC updated Standard Operating Procedure 4502—Recognizing Abnormal Operating Conditions.Procedure 4502 is specific
to the LNG Plant.
RE:NFPA-59A,Section 9.9.1 ...added new Section 1.15 to Procedure 4502—Recognizing Abnormal Operating Conditions,
which addresses the manual depressurization and venting of Plant piping in the event of an emergency.
Section 1.15 states, "In the event of a manual and/or controlled emergency shutdown of Plant operations, the Plant
Operators will manually open the appropriate valve(s) to vent all LNG into a common vent piping system which vents the
LNG to the vent pipe stack(missile)located in the LNG Tank containment pit. The location of the missile ensures the LNG
is safely discharged away from Plant personnel and equipment in a controlled manner."
RE: NFPA-59A, Section 9.9.2 ... added verbiage in Section 7.03 in the Emergency Manual stating, "In the event of an
impending LNG storage tank failure, the tank will be emptied of all LNG as quickly as possible by creating the necessary
procedure(s)specific and pertinent to the situation or using normal vaporization procedures."
IGC made additional procedure changes related to items discussed during the November 14,2018 exit interview that are not
mentioned in your December 4,2018 Notice of Probable Violations. Standard Operating Procedure 4511—Testing of LNG
Transfer Hoses was updated in various sections identifying"each"hose rather than"the"hose.The Emergency Manual and
Fire Manual were updated to reflect facility and personnel changes. All new and revised standard operating procedures
referenced in this letter were sent to the IPUC on January 8,2019 via a secured email.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
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