I202420 NOPV

Idaho Public Utilities Commission Brad Little,Governor
` �- P.O.Box 83720,Boise,ID 83720.0074 Eric Anderson,President
John IL Hammond,Jr.,Commissioner
Edward Lodge,Commissioner
December 5, 2024 Report# I202420
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 4" St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On December 2, 2024, the Idaho Public Utilities Commission ("Commission"), (IPUC), Pipeline
Safety Division ("Staff'), conducted a Records and Field inspection of Intermountain Gas
Company's("IGC")Nampa 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 193. The probable violations are as
follows:
PROBABLE VIOLATIONS)
1. 49 CFR 4193.2507 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.
Procedure 4506 LNG Plant Fire Prevention Plan
Section 2.7 - Plant Operator(s) shall verify and ensure a minimum of three (3) portable
combustible gas detectors (CGI) capable of measuring the lower explosive limits (LEL) are
available, operable and calibrated for use at all times.
2. 49 CFR 4193.2801 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 §
193.2013). 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.
IGC NAMPA LNG PROBABLE VIOLATIONS LETTER—Page 1 of 3

3. 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.
A.9.7.4 Natural gas, LNG, and hydrocarbon refrigerants within the process equipment
are usually not odorized, and the sense of smell cannot be relied on to detect their
presence. Two portable detectors should be available for monitoring when required
with a third detector for backup. This provides a spare detector in the event of failure
of one of the primary detectors and also allows verification if the two primary detectors
provide different readings.
Findings:
Staff identified that the calibration gas used to calibrate portable gas detection equipment had been
expired since November 2023.
REOUESTED 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 January 19, 2025, 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 January 4, 2025.
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 January 19, 2025, 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.
IGC NAMPA LNG PROBABLE VIOLATIONS LETTER—Page 2 of 3

These violations 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(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.
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sincerely,
Jeff Brooks
Program Manager, Regulated Utilities
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
IGC NAMPA LNG PROBABLE VIOLATIONS LETTER—Page 3 of 3