I202418 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 17, 2024 Report# I202418
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On October 7-9, 2024, the Idaho Public Utilities Commission ("Commission"), (IPUC), 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.
As a result of the inspection of natural gas system(s) owned and operated by IGC ("Company").
Staff observed areas 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 2023.
The item(s)below are of concern:
1. 49 CFR 4193.2511 Personnel Safetv.
(c) Each LNG plant must be equipped with suitable first-aid material,the location of which
is clearly marked and readily available to personnel.
Findin2(s)-
All first aid equipment, including eyewash station are past the manufacturer expiration
dates.
2. 49 CFR U93.2907 Protective Enclosure Construction.
(a) Each protective enclosure must have sufficient strength and configuration to obstruct
unauthorized access.
(b) Openings in or under protective enclosures must be secured by grates, doors or covers
of construction and fastening of sufficient strength such that the integrity of the protective
enclosure is not reduced by any opening.
Findings):
There is approximately one foot of space between the bottom of the fence line and the
ground which may not adequately obstruct unauthorized access.
IGC Rexburg LNG Letter of Concern—Page 1 of 3

3. 49 CFR 4191.23 Reporting Safety-Related Conditions.
(a) Except as provided in paragraph (b) of this section, each operator shall report in
accordance with § 191.25 the existence of any of the following safety-related conditions
involving facilities in service:.
(3) Unintended movement or abnormal loading by environmental causes, such as an
earthquake, landslide, or flood, that impairs the serviceability of a pipeline or the
structural integrity or reliability of a UNGSF or LNG facility that contains, controls, or
processes gas or LNG.
OPS 9 Gas Emergency Notification and Reporting
8.6.2 Unintended movement or abnormal loading by environmental causes, such as an
earthquake, landslide, or flood, which impairs the serviceability of a pipeline.
Findin?,W:
OPS 9, 8.6.2 should include verbiage similar to below.
Unintended movement or abnormal loading by environmental causes, such as an
earthquake, landslide, or flood, that impairs the serviceability of a pipeline or the
structural integrity or reliability of a UNGSF or LNG facility that contains, controls, or
processes gas or LNG.
4. 193.2713 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.
Finding(s): No continuing instruction will occur until January 2025 due to initial training
that began in 2023.
5. 193.2715 Training: Security.
(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.
Finding(s): No continuing instruction will occur until January 2025 due to initial training
that began in 2023.
6. 193.2717 Training: Fire Protection.
(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.
Finding(s): No continuing instruction will occur until January 2025 due to initial training
that began in 2023.
IGC Rexburg LNG Letter of Concern—Page 2 of 3

REQUESTED ACTIONS
We 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 Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:(208)33"300 Facsimile:[phone]
IGC Rexburg LNG Letter of Concem—Page 3 of 3