I202417 NOPV

�' 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
October 17, 2024 Report#I202417
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 4"' 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.
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 VIOLATION(S)
1. 49 CFR 4193.2513 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:
(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.
IGC-Rexburg LNG Transfer Operations-Procedure 4565.3 Revision January
30,2023.
Findinds):
IGC Procedure 4565.3 and Rexburg LNG Truck Off Loading Operations Checklist
(Rexburg LNG Facility) do not include the required procedures detailed in 49 CFR
§193.2513.
IGC REXBURG LNG PROBABLE VIOLATIONS LETTER—Page 1 of 8

2. 49 CFR &193.2605 Maintenance Procedures.
(a) Each operator shall determine and perform, consistent with generally accepted
engineering practice, the periodic inspections or tests needed to meet the applicable
requirements of this subpart and to verify that components meet the maintenance
standards prescribed by this subpart.
(b) Each operator shall follow one or more manuals of written procedures for the
maintenance of each component, including any required corrosion control. The
procedures must include:
(1) The details of the inspections or tests determined under paragraph (a) of this section
and their frequency of performance; and
(2) A description of other actions necessary to maintain the LNG plant according to the
requirements of this subpart.
49 CFR §193.2613 Auxiliary 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.
IGC-Rexburg LNG Fire Equipment Maintenance-Procedure 4558
2.5 Auxiliary Power
2.5.4 The engine and generator will be started and run once per month.
Finding(s)•
On October 16, 2023, the IPUC conducted a 2022 Procedures, Records and Field
inspection of the Rexburg LNG Plant. On October 19, 2023, a Letter of Concern (LOC)
(1202310) was issued, identifying the need to add the verbiage "and tested annually for
capacity" to Procedure 4558.3. On November 15, 2023, IGC acknowledged the findings
(#3)brought forth by IPUC, stating that a Management of Change has been initiated to add
additional language to procedure 4558 Rexburg LNG Fire Equipment Maintenance to
incorporate the requirements for annual capacity testing as outlined in 49 CFR §193.2613.
On October 9, 2024, a 2023 inspection of the Rexburg LNG facility, Procedures, Records
and Field inspection, it was discovered that Procedure 4558 Step 2.5.4 had not been
changed to incorporate the required verbiage"and tested annually for capacity."
3. 49 CFR 4193.2605 Maintenance Procedures
(a) Each operator shall determine and perform, consistent with generally accepted
engineering practice, the periodic inspections or tests needed to meet the applicable
requirements of this subpart and to verify that components meet the maintenance
standards prescribed by this subpart.
(b) Each operator shall follow one or more manuals of written procedures for the
maintenance of each component, including any required corrosion control. The
procedures must include:
(1) The details of the inspections or tests determined under paragraph(a) of this section
and their frequency of performance; and
(2) A description of other actions necessary to maintain the LNG plant according to the
IGC REXBURG LNG PROBABLE VIOLATIONS LETTER—Page 2 of 8

requirements of this subpart
(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.
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.
IGC-Rexburg LNG Tank Inspection 4553.2 Revision Date Apri122, 2021.
1.2 The support system or foundation for each component within the Facility shall also be
inspected.
1.3 The frequency of inspection of the tank and pipe support systems only applies when
LNG is on site stored in the tank. All facility inspections must be performed prior to any
LNG being placed into a warm tank.
1.4 The date and type of each inspection activity shall be documented and recorded along
with the results of the inspection. The records shall be maintained for the life of the facility.
Finding(s)•
For Calendar Year 2023, Monthly and Daily Checklists are inconsistent. Records show
that personnel are approving documents or forms without properly reviewing it or
knowing if the task is complete.
4. 49 CFR 4193.2605 Maintenance Procedures.
(a) Each operator shall determine and perform, consistent with generally accepted
engineering practice, the periodic inspections or tests needed to meet the applicable
requirements of this subpart and to verify that components meet the maintenance
standards prescribed by this subpart.
(b) Each operator shall follow one or more manuals of written procedures for the
maintenance of each component, including any required corrosion control. The
procedures must include:
49 CFR §193.2613 Auxiliary 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.
IGC-Rexburg LNG Fire Equipment Maintenance-Procedure 4558.3
2. Fire Equipment Maintenance
2.5 Auxiliary Power
2.5.4 The engine and generator will be started and run once per month.
3. Records
3.1 Records pertaining to this procedure shall be retained for five (5) years.
IGC REXBURG LNG PROBABLE VIOLATIONS LETTER—Page 3 of 8

Finding(s):
The July 2023 Monthly Checklist record shows the generator testing was "backdated to
complete compliance" and dated 10/05/2023. This generator inspection was not properly
completed or documented in July as required.
5. 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.
IGC-Rexburg LNG Vaporization Tech Training and Oualifications-Procedure
4557.2
2.3 Each Vaporization Technician responsible for maintenance and operations at the
facility, including the Supervisor, Engineering Services, must complete initial training of
instruction to obtain the following: 2.3.1-2.3.7 requirements.
Finding(s)•
The Supervisor, Engineering Services, has not completed initial training of instruction to
obtain the following: 2.3.1-2.3.7 requirements in Procedure 4557.2. On multiple Test of
Initial Training for LNG Vaporization Technician, there is no name or date completed to
identify whose test they are. In Section II of the Test of Initial Training for LNG
Vaporization Technician, it states, each observation is performed with the Lead Operator
who will determine a pass or fail. A second Operator will assist with the observations.
Each observation is worth two points each. There is no record of Pass/Fail by Lead
Operator and no record/form/checklist by a Second Operator used to score the two points
per item on the observation portion of the test.
6. 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.
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 U93.2801.
(b) A written plan of continuing instruction, including plant fire drills, must be conducted
IGC REXBURG LNG PROBABLE VIOLATIONS LETTER—Page 4 of 8

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 4193.2509.
IGC-Rexburg LNG Vaporization Tech Training and Qualifications-Procedure
4557.2
2.3 Each Vaporization Technician responsible for maintenance and operations at the
facility, including the Supervisor, Engineering Services, must complete initial training of
instruction to obtain the following: 2.3.1-2.3.7 requirements.
Finding(s)•
There is no record of immediate supervisors, of all personnel involved in maintenance
and operation of Rexburg LNG plant, completing required fire protection training.
7. 49 CFR 4193.2627 Atmospheric corrosion control.
Each exposed component that is subject to atmospheric corrosive attack must be
protected from atmospheric corrosion by—
(a) Material that has been designed and selected to resist the corrosive atmosphere
involved; or
(b) Suitable coating or jacketing
49 CFR_4193.2635 Monitoring Corrosion Control.
Corrosion protection provided as required by this subpart must be periodically monitored
to give early recognition of ineffective corrosion protection, including the following, as
applicable:
(d) Each component that is protected from atmospheric corrosion must be inspected at
intervals not exceeding 3 years.
Finding(s)•
Rexburg LNG plant does not have a procedure for Plant Atmospheric Corrosion Control,
or a record/checklist to annotate that Atmospheric Corrosion inspections have taken place
every 3 years.
8. 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.
NFPA 59A Standard for the Production, Storage, and Handling of Liquified
Natural Gas (LNG) 2001 Edition.
9.1 General
9.1.2 Fire protection shall be provided for all LNG facilities. The extent of such
protection shall be determined by an evaluation based on sound fire protection
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engineering principles, analysis of local conditions, hazards within the facility, and
exposure to or from other property.
Finding(s):
For Calendar Year 2023, no record of a Fire Protection Evaluation could be supplied to
validate the Fire Protection requirements.
9. 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.
NFPA 59A Standard for the Production, Storage, and Handling of Liquified
Natural Gas (LNG) 2001 Edition.
9 Fire Protection, Safety and Security.
9.1 General.
9.1.2* Fire protection shall be provided for all LNG facilities. The extent of such
protection shall be determined by an evaluation based on sound fire protection
engineering principles, analysis of local conditions,hazards within the facility, and
exposure to or from other property. The evaluation shall determine the following, as a
minimum:
9.2 Emergency Shutdown Systems.
9.2.1 Each LNG facility shall incorporate an ESD system(s) that, when operated, isolates
or shuts off a source of LNG, flammable liquids, flammable refrigerant, or flammable
gases, and shuts down equipment whose continued operation could add to or sustain an
emergency. Any equipment, such as valves or control systems, that is specified in another
chapter of this standard shall be permitted to be used to satisfy the requirements of an
ESD system except where indicated in this standard.
Finding(s)•
For Calendar Year 2023, no record of a Fire Protection Evaluation could be supplied to
validate that the ESD system(s), when operated isolates or shuts off sources of LNG and
all other flammable liquids or gases and shuts down equipment that adds or sustains an
emergency if continued to operate.
10. 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 § 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 REXBURG LNG PROBABLE VIOLATIONS LETTER—Page 6 of 8

NFPA 59A Standard for the Production, Storage, and Handling of Liquified
Natural Gas (LNG) 2001 Edition.
9.5 Fire Extinguishing and Other Fire Control Equipment
9.5.1* Portable or wheeled fire extinguishers recommended by their manufacturer for gas
fires shall be available at strategic locations,as determined in accordance with 9.1.2,within
an LNG facility and on tank vehicles.These extinguishers shall be provided and maintained
in accordance with NFPA 10, Standard for Portable Fire Extinguishers.
Finding(s)•
For Calendar Year 2023, no record of a Fire Protection Evaluation could be supplied to
demonstrate the staging of fire protection equipment is available at strategic locations.
IGC REXBURG LNG PROBABLE VIOLATIONS LETTER—Page 7 of 8

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 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 December 1, 2024, 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://pue.idaho.gov/. If you intend to request an informal conference, please contact the Pipeline
Safety Division no later than November 16, 2024.
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 1, 2024, 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.
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
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
IGC REXBURG LNG PROBABLE VIOLATIONS LETTER—Page 8 of 8