20250127Formal Complaint.pdf

RECEIVED
Monday, January 27, 2025 12:33:52 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION STAFF'S )
FORMAL COMPLAINT CONCERNING ) CASE NO. INT-G-25-01
INTERMOUNTAIN GAS COMPANY AND THE )
REXBURG LIQUID NATURAL GAS FACILITY )
FORMAL COMPLAINT
COMES NOW, the Staff of the Idaho Public Utilities Commission, Pipeline Safety
Division("Staff'), by and through its attorney of record, Chris Burdin, Deputy Attorney General,
file this Formal Complaint concerning Intermountain Gas Company's ("Company") pattern and
practice, of non-compliance with safety regulations at the Rexburg Liquid Natural Gas ("LNG")
facility("Facility").
Staff requests that the Idaho Public Utilities Commission ("Commission") enter an Order
requiring the Company to pay a penalty in an amount to be determined by the Commission,
consistent with the Commission's authority under Idaho Code §§ 61-501, 61-515 and 61-701 et
seq.
JURISDICTION
The Company is a gas corporation and a public utility, and the Commission has jurisdiction
over it and the issues in this case under Title 61,Idaho Code.See Idaho Code§§ 61-117, 61-129, 61-
501, 61-503, and 61-515. When a complaint is filed concerning the safety and adequacy of a public
utility's service,the Commission has the power and authority to investigate the matter and require the
FORMAL COMPLAINT-I

"public utility to maintain and operate its line, plant, system, equipment, apparatus and
premises in such manner as to promote and safeguard the health and safety of its employees,
customers and the public."Idaho Code § 61-515; see also Idaho Code § 61-302.
Idaho Code § 61-701 et. seq. provides the Commission with the authority to enforce "the
constitution and statutes of this state affecting public utilities, the enforcement of which is not
specifically vested in some other office or tribunal" and to seek the imposition of penalties for
violations of these authorities if deemed necessary.
FACTUAL HISTORY
1. Historical Incidents
On October 6, 2022, Staff completed an LNG audit consisting of procedural, records, and
field observations of the Company's Rexburg Satellite LNG facility. On October 31, 2022, Staff
sent the Company a Notice of Probable Violation("NOPV"),report No. I202204, stemming from
the October 6,2022, audit. The NOPV consisted of fourteen(14) separate code violations. On that
same date, Staff also sent the Company a Letter of Concern ("LOC"), report No. I202205,
stemming from the October 6, 2022, audit. The LOC consisted of six (6) separate code concerns.
The Company submitted corrective responses to the LOC and NOPV, which Staff accepted, and
Staff closed the LOC and NOPV on November 28, and December 20, 2022, respectively.
On October 19, 2023, Staff completed a second LNG audit consisting of procedural,
records, and field observations of the Facility. That same day Staff sent a second NOPV, report
No. I202311, stemming from the October 19,2023,audit. The NOPV consisted of two(2)separate
code violations. Staff also sent the Company a LOC, report No. I202310, stemming from the
October 19, 2023, audit. The LOC consisted of four (4) separate code concerns. The Company
submitted corrective responses to the LOC and NOPV, which Staff accepted, and Staff closed the
LOC and NOPV on November 15, 2023, and June 1, 2024, respectively.
2. Present Incidents
a. NOPV report No. I202408 (8/15/24) (ATTACHED HERETO AS
EXHIBIT 101)
On July 16, 2024, the Facility experienced an emergency shutdown and federal reportable
incident ("Incident"). On July 17, 2024, Staff mobilized and performed a post incident follow up
investigation,which included on-site observations at the Facility,record reviews, and on-site witness
FORMAL COMPLAINT-2

interviews. Staff determined that the Incident was caused by operator error and a failure to follow
procedures resulting in 8900 gallons of LNG being released.
On August 15, 2024, Staff sent the Company a NOPV related to the Incident, report No.
I202408, which consisted of five (5) separate code violations. On August 15, 2024, the Company
substantiated Staff s determination of operator error and failure to follow procedures, in box F7-
"Incorrect Operation"of Incident Report#20240005-39919 to the Pipeline and Hazardous Materials
Safety Administration("PHMSA").
b. NOPV report No. I202415 (9/18/24) (ATTACHED HERETO AS
EXHIBIT 102)
On September 10, 2024, Commission Staff sent the Company an email requesting the
newest versions of the Rexburg LNG Manuals for an upcoming 2024 audit. On September 11,
2024,the Company self-reported that the Rexburg LNG Emergency Manual had not been revised or
reviewed since 2014. On September 18, 2024, Staff issued NOPV report No. 1202415 for a code
violation for failure to follow procedures and annually review the Rexburg LNG Emergency Manual.
c. NOPV report No. I202417 (10/17/24) (ATTACHED HERETO AS
EXHIBIT 103)
On October 9, 2024, Staff completed a third LNG audit consisting of procedural, records,
and field observations of the Company's Facility. On October 17, 2024, Staff sent the Company a
NOPV, report No. 1202417, stemming from the October 9, 2024, audit. The NOPV consisted of
ten (10) separate code violations. On that same date Staff sent an LOC, report No. 1202418,
stemming from the October 9, 2024, audit. The LOC consisted of six (6) separate code concerns.
VIOLATIONS
A. NOPV report No.I202408(8/15/24)
The Company has violated the pertinent rules, codes, and procedures as follows:
a. 49 CFR § 193.2503 and Company Procedure 4565
i. The Vaporization Technician did not verify that the valves were in the
proper position for operations.
ii. The carrier/driver did not verify that the valves were in the proper position
for operations.
iii. The Vaporization Technician did not accurately complete items on the
Rexburg LNG Truck Off Loading Operations Checklist prior to beginning
transfer operations.
FORMAL COMPLAINT-3

iv. The Rexburg LNG Truck Off Loading Operations Checklist dated 7/16/24
was checked that Tasks #1, #3 and #8 were completed prior to startup.
However, (#1) the transfer system was not verified that it was safe to
conduct transfer operations; (#3) the carrier/driver and LNG Plant
Operator did not visually check the LNG truck and trailer for safety
violations and hazardous conditions; and (#8) the Valve (V-6) fill line
bleed/vent valve on the LNG trailer(83110149)was not verified as closed
before connecting/disconnecting hoses.
v. The Vaporization Technicians did not know the locations of the
Emergency Shutdown Valves on the trailer,prior to the Incident.
vi. The Vaporization Technician at the off-loading skid stated that the
Procedure 4565 was not located/present for cargo transfer.
vii. The Vaporization Technician did not visually check the trailers for leaks
or other signs of hazardous conditions (V-6 fill line bleed/vent valve left
open)before making any connections.
viii. The carrier/driver did not inspect the valves,valve box,and pressure build
coil on the trailer to ensure all components were damage free and in the
proper position for operation.
ix. The Vaporization Technician did not ensure that the carrier/driver
performed the following task(s)prior to beginning transfer operation:
1. The carrier/driver shall connect liquid and vapor hoses to the
proper LNG trailer connections.
2. The carrier/driver shall begin pressure building in the trailer with
a target of 60 PSIG.
b. NFPA 59A Standard for the Production, Storage, and Handling of Liquified
Natural Gas (LNG) 2001 Edition and Company Procedure 4565
i. Personnel were not familiar with the correct positions of the valves prior
to commencing off-load operations.
c. 49 CFR§ 193.2503,49 CFR§ 193.251,NFPA 59A Standard for the Production,
Storage, and Handling of Liquified Natural Gas (LNG) 2001 Edition, and
Company Procedure 4565
i. The Vaporization Technician at the off-loading skid was not wearing
the intrinsically safe portable radio provided for verbal communication
at workstations, or in emergency situations.
d. NFPA 59A Standard for the Production, Storage, and Handling of Liquified
Natural Gas (LNG) 2001 Edition and Company Procedure IGC Fire Manual for
Rexburg Satellite LNG Facilities
i. The Vaporization Technician personnel were in short sleeve shirts
during the off-load of — -263°F liquid natural gas and during the
incident.
FORMAL COMPLAINT-4

e. 49 CFR § 193.2503, Company Policy Statement Job Safety Analysis/Tailgate
Meetings (Rev Date: 1/19/2021) and per Company Procedure SF 422
i. The carrier(KAG) driver was not notified of existing hazards, controls,
and did not sign the 23023 form as required.
B. NOPV report No.I202415 (9/18/24)
The Company has violated the pertinent rules, codes, and procedures as follows:
a. 49 CFR§ 193.2503 and per Intermountain Gas Company Emergency Manual for
Rexburg
i. The Rexburg LNG Plant Emergency Manual had not been revised or
reviewed since 2014. There was no tracking mechanism for periodic
revisions or reviews in place.
C. NOPV report No.I202417(10-17-24)
The Company has violated the pertinent rules, codes, and procedures as follows:
a. 49 CFR§ 193.2513
i. The Company's Procedure 4565.3 and Rexburg LNG Truck Off Loading
Operations Checklist do not include the required procedures detailed in 49
CFR§ 193.2513 for transfer procedures.
b. 49 CFR § 193.2605, 49 CFR §193.2613, and per IGC- Rexburg LNG Fire
Equipment Maintenance-Procedure 4558
i. Company Procedure 4558 Step 2.5.4 does not incorporate the required
verbiage"and tested annually for capacity."
c. 49 CFR §193.2605, 49 CFR §193.2609, and IGC-Rexburg LNG Tank
Inspection 4553.2 Revision Date April 22, 2021
i. For Calendar Year 2023, the Company's Monthly and Daily Checklists
are inconsistent. Records show that personnel approved documents or
forms without properly reviewing them or knowing if the tasks were
complete, as required.
d. 49 CFR§ 193.2605,49 CFR§ 193.2613,and IGC-Rexburg LNG Fire Equipment
Maintenance-Procedure 4558.3
i. 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.
e. 49 CFR § 193.2719, IGC-Rexburg LNG Vaporization Tech Training and
Qualifications-Procedure 4557.2
i. The Supervisor, Engineering Services, did not complete the initial
training of instruction as required in Company Procedure 4557.2. On
multiple Test of Initial Training for LNG Vaporization Technician,there
was no name or date completed to identify who was tested.Additionally,
there is no record of Pass/Fail by Lead Operator and no
FORMAL COMPLAINT-5

record/form/checklist by a Second Operator used to score the two points
per item on the observation portion of the test.
f. 49 CFR § 193.2719, 49 CFR § 193.2717, and IGC-Rexburg LNG Vaporization
Tech Training and Qualifications-Procedure 4557.2
i. There is no record of immediate supervisors,or of all personnel involved
in maintenance and operation of Rexburg LNG plant, completing
required fire protection training.
g. 49 CFR § 193.2627 and 49 CFR § 193.2635
i. The 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.
h. 49 CFR§ 193.2801 and NFPA 59A
i. For Calendar Year 2023, there is no record of a Fire Protection
Evaluation to validate the Fire Protection requirements.
i. 49 CFR§ 193.2801 and NFPA 59A
i. For Calendar Year 2023, there is no record of a Fire Protection
Evaluation 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 it
continued to operate.
j. 49 CFR§ 193.2801 and NFPA 59A
i. For Calendar Year 2023, there is no record of a Fire Protection
Evaluation to demonstrate the staging of fire protection equipment is
available at strategic locations, as required.
Each of the Company's above violations may be subject to a penalty of up to$2,000 pursuant
to Idaho Code § 61-302 for each day that the violation persisted up to a maximum amount of
$200,000.Idaho Code § 61-712A.
FORMAL COMPLAINT-6

REQUEST FOR RELIEF
Based upon the above violations, Staff requests that the Commission impose the maximum
civil penalty amounts available under Idaho Code as determined by the Commission, and for such
other and further relief as the Commission may deem just and appropriate.
Staff stands ready for any additional briefing, hearing, or other proceedings deemed
necessary by the Commission.
DATED this 27th day of January 2025.
zi
Chris Burdin
Deputy Attorney General
FORMAL COMPLAINT-7

EXHIBIT 101

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
Aug 15, 2024 Report#I202408
Pat Darras—Vice President of Engineering& Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On July 17, 2024, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a failure investigation and site inspection follow-up of incident
NRC#1404942/1405150 of Intermountain Gas Company's ("IGC") Rexburg LNG (Liquified
Natural Gas) 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, 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 4193.2503 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.
The procedures must include provisions for:
(b) Startup and shutdown, including for initial startup, performance testing to
demonstrate that components will operate satisfactory in service.
49 CFR §193.2513 Transfer Procedures
(a) Each transfer of LNG (Liquified Natural Gas) 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 § 193.2013)";
(c) In addition to the requirements of paragraph(b) of this section,the procedures for
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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Page 1 of 7
Exhibit 101
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

cargo transfer must be located at the transfer area and include provisions for personnel to:
IGC-Rexburg LNG Transfer Operations Procedure 4565
L GENERAL
1.2. Personnel involved in LNG transfer operations must be familiar and
knowledgeable with the transfer equipment and systems including:
1.2.1. Truck Off-Loading Skid
1.2.2. Piping Systems
1.2.3. Storage Tank
1.2.4. Pump Trailer
1.2.5. Vaporizer
1.2.6. Controls System
2. SAFETY PRECAUTIONS
2.1. Personnel must wear protective clothing.
3. VAPORIZATION TECHNICIAN RESPONSIBILITIES
3.3. The Vap. Tech(Vaporization Technician) shall perform the following upon
arrival of the LNG trailer:
3.3.1. Procedure 4565 - Rexburg LNG Transfer Operations shall be located at the
Truck Offloading Skid.
3.3.2. Visually check LNG trailers for leaks or other signs of hazardous
conditions before making any connections.
3.3.13. Verify LNG trailer vent valve and fill valve are closed before
connecting/disconnecting hoses.
3.3.14. Complete necessary items on Rexburg LNG Truck Off Loading
Operations Checklist prior to beginning transfer operations.
3.4. The Carrier/driver is responsible to perform the following and provide the
requested information to the Vap.Tech prior to beginning transfer operations:
3.4.4. Connecting the fill hose and vapor return hose to the LNG trailer.
4. PROCEDURE
4.6. Carrier/driver shall inspect valves, valve box, and pressure build coil on trailer to
ensure all components are damage free and in the proper position for operation.
4.7. Carrier/driver shall begin pressure building in trailer with a target of 60 psig.
4.8. Connect liquid and vapor hoses to the proper LNG trailer connections.
Finding(s)•
Vap. Tech did not verify valves were in the proper position for operations.
Carrier/driver did not verify valves were in the proper position for operations.
Vap. Tech did not accurately complete items on Rexburg LNG Truck Off Loading
Operations Checklist prior to beginning transfer operations. (Picture(s) of checklist upon
request).
Rexburg LNG Truck Off Loading Operations Checklist dated 7/16/24 is checked
that(Tasks)#1, #3 and#8 were completed prior to startup.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:(208)33"300 Facsimile:[phone]
Page 2 of 7
Exhibit 101
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

(#1) The transfer system was not verified that it was safe to conduct transfer operations.
(0) Carrier/driver and LNG Plant Operator did not visually check LNG truck and trailer
for safety violations and hazardous conditions.
(#8)Valve (V-6) fill line bleed/vent valve on LNG trailer(83110149) was not verified
that it was closed before connecting/disconnecting hoses.
Vap. Techs were unfamiliar and did not know the locations of ESV(Emergency
Shutdown Valves) (per carrier/driver) on trailer, prior to the LNG spill incident.
Vap. Tech at the off-loading skid stated that Procedure 4565 was not located/present for
cargo transfer.
Vap. Tech did not visually check LNG trailers for leaks or other signs of hazardous
conditions (V-6 fill line bleed/vent valve left open) before making any connections.
Carrier/driver did not inspect valves, valve box, and pressure build coil on trailer to
ensure all components are damage free and in the proper position for operation.
Carrier/driver stated that once the truck &trailer were on the off-load skid. The
Vap. Tech ensured brakes were set and trailer wheels were chocked, truck engine
was off, keys removed from cab, and verified that carrier/driver's current
state/federal truck and trailer inspection documentation was checked.
Carrier/driver was then informed that he needed to go to the control room and
wait till off-load was completed.
Vap. Tech did not ensure that Carrier/driver performed the following task (s) and provide
the requested information to Vap. Tech prior to beginning transfer operations:
Carrier/driver shall connect liquid and vapor hoses to the proper LNG trailer
connections.
Vap. Tech stated that he connected hoses to the LNG trailer.
Carrier/driver shall begin pressure building in trailer with a target of 60 psig.
Vap. Tech performed pressure building and stated to IPUC personnel that
the desired range was between 60-65 PSI to overcome tank head pressure.
During the pressure building is when LNG started venting out of
the truck relief valves.
2. NFPA 59A Standard for the Production, Storage, and Handling of Liquified
Natural Gas (LNG) 2001 Edition
11.4.5 Loading or Unloading Operations
11.4.5.1 General
(g) The transfer system shall be checked prior to use to ensure that valves are in
the correct position. Pressure and temperature conditions shall be observed during
the transfer operation.
(h)The transfer system shall be checked prior to use to ensure that valves are in
the correct position for transfer. Transfer operations shall be commenced slowly;
if any unusual variance in pressure or temperature occurs, transfer shall be
stopped until the cause has been determined and corrected. Pressure and
temperature conditions shall be observed during the transfer operation.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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Page 3 of 7
Exhibit 101
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

IGC-Rexburg LNG Transfer Operations Procedure 4565
L GENERAL
1.2. Personnel involved in LNG transfer operations must be familiar and
knowledgeable with the transfer equipment and systems including:
1.2.1. Truck Off-Loading Skid
1.2.2. Piping Systems
1.2.3. Storage Tank
1.2.4. Pump Trailer
1.2.5. Vaporizer
1.2.6. Controls System
Finding(s):_
Personnel were not familiar with the correct positions of the valves prior to commencing
off-load operations.
3. 49 CFR 093.251 Communication systems
Each LNG plant must have a primary communication system that provides for verbal
communications between all operating personnel at their work stations in the LNG plant.
49 CFR 093.2503 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.
The procedures must include provisions for:
IGC-Emergency Manual for Rexburg Satellite LNG Facility
4.0 PERSONNEL SAFETY
It is the purpose of this section to briefly identify those areas that directly affect a
response to an emergency. A more detailed description can be found in the Rexburg
LNG Fire Manual.
4.1 COMMUNICATION
(a) Inside fenced area (outside of control building) ... communications between
company personnel throughout the facility will be by intrinsically safe portable radios.
NFPA 59A Standard for the Production, Storage, and Handling of Liquified
Natural Gas (LNG) 2001 Edition.
11.4.6 Communications and Lighting. Communications shall be provided at loading and
unloading locations so that the operator can be in contact with other remotely located
personnel who are associated with the loading or unloading operation.
Finding(s)•
Vap. Tech at off-loading skid was not wearing the intrinsically safe portable radio
provided for verbal communication at work stations, or in emergency situations.
4. IGC-Fire Manual for Rexburg Satellite LNG Facility
4.0 EFFECTS OF EXPOSURE TO CRYOGENIC FLUIDS
4.3 Exposure to LNG
Liquified natural gas exposed to atmospheric pressure is at sub-zero temperatures,
approximately minus—-260°F and contact with skin will result in severe frostbite.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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Page 4 of 7
Exhibit 01
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

LNG spills expose the Vap. Tech to several hazards, including localized cold effects
such as cryogenic burns, frostbite and general cold effects(hypothermia, lung damage,
asphyxia. In the event of ignition and burning of the vapor cloud, thermal radiation
hazards would also exist. Direct contact with a cryogenic liquid generally produces
rapid freezing of tissue because of the high rate of heat transfer.
Keeping the liquid confined within piping and storage vessels and wearing adequate
protective apparel are the two best ways to avoid exposure of the liquid to skin. Contact
with cold gas will usually involve more body area than liquid contact. When cold gas
is released in a jet with a corresponding high rate of heat transfer,the result can be rapid
freezing of large portions of the body. Equipment and structures should also be
protected from contact with low temperature vapor to prevent embrittlement of
materials.
When handling of LNG or equipment which contains LNG, protective clothing should
be worn to protect the skin against the extremely low temperatures encountered.
Leather gloves should always be worn when handling anything that is or may have
been in contact with LNG. Gloves should be loose-fitting so that they may be easily
removed should liquid splash onto or into them. If splashing or spraying of LNG is
likely to occur, the face and eyes should be protected with a face shield. Overalls or
similar type work clothing should be worn preferably without pockets or cuffs and
trousers should be worn outside of boots. Where there is considerable risk of spilling
or spraying, special clothing which provides protection against frostbite, flash burn or
fire should be worn.
NFPA 59A Standard for the Production, Storage, and Handling of Liquified
Natural Gas (LNG) 2001 Edition.
9.7 Personnel Safety.
9.7.1* Protective clothing, which will provide protection against the effects of
exposure to LNG, shall be available and readily accessible at the facility.
9.7.2 Those employees who are involved in emergency activities, as determined
in accordance with 9.1.2, shall be equipped with the necessary protective clothing
and equipment and qualified in accordance with NFPA 600, Standard on
industrial Fire Brigades.
*Appendix A Explanatory Material
A.9.7.1 Protective clothing for normal liquid transfer operations should include
cryogenic gloves, safety glasses, face shields, and coveralls or long-sleeve shirts.
Finding(s).
Vap. Tech.personnel were in short sleeve shirts during the off-load of— -263°F liquid
natural gas. (Per photographs and statements).
5. 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.
SF 422 Job Safety Analysis/Tailgate Meetings
Instructions: on JSA Form 23023
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
Page 5 of 7
Exhibit 101
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

Review the job or task to be performed and associated potential hazards with all individuals -
participating/Observing in, or affected by,the work activity prior to START of each job or
when significant changes in the work occur. Fill in the upper section of the form, then,
review the applicable sections in the table below, provide details as requested and ensure
each individual sign form 23023 (Rev 3/2020).
Policy Statement Job Safety Analysis/Tailgate Meetings (Rev Date: 1/19/2021)
2. Employee Responsibilities
2.2 Employees shall assess their work area, adjust the JSA(Job Safety Analysis)
form, and communicate any additional changes, after the following occurrences:
2.2.3 If new individuals are entering the work area, verify they have been
notified of the existing hazards and controls by having them sign onto the
current JSA form.
Findings): The driver was not notified of existing hazards, controls and did not sign the
23023 form.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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Page 6 of 7
Exhibit 101
Case No. INT-G-25-01
Formal Complaint
January 27,2025

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 September 29, 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://puc.idaho.gov/. If you intend to request an informal conference,please contact the Pipeline
Safety Division no later than September 14, 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 September 29,2024,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.
Sinc ely,
Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
Page 7 of 7
Exhibit 101
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

EXHIBIT 102

Z
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
September 18, 2024 Report#I202415
Pat Darras —Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck, ND 58501
Dear Mr. Pat Darras:
On September 11, 2024, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), reviewed the Rexburg LNG (Liquified Natural Gas) plant Emergency Manual
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, 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 4193.2503 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.
Intermountain Gas Companv Emergency Manual for Rexburg Satellite LNG Facility
3.2 Periodical Review
The material contained in this Manual shall be reviewed for applicability at least once
per year, but not to exceed an interval of fifteen (15)months. However, it shall be
reviewed and updated, as necessary, to keep the procedures consistent with system
and regulatory changes. It will be the responsibility of the Teton District Operations
Manager and the Manager of Engineering Services to review and issue any and all
necessary revisions or additions to this manual.
Finding(s): The Rexburg LNG (Liquified Natural Gas) Plant Emergency Manual has not
been revised or reviewed since 2014. There is no tracking mechanism for periodic
revisions or reviews in place.
IGC REXBURG LNG PROBABLE VIOLATIONS LETTER—P a g e 1 1 2
Exhibit 102
Case No.INT—G-25-01
Formal Complaint
January 27, 2025

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 November 2, 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://puc.idaho.gov/. If you intend to request an informal conference,please contact the Pipeline
Safety Division no later than October 18, 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 November 2, 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.
Sincerel
Jeff rooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
IGC REXBURG LNG PROBABLE VIOLATIONS LETTER—P a g e 2 12
Exhibit 102
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

EXHIBIT 103

�' 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
Exhibit 103
Case No. INT-G-25-01
Formal Complaint
Ianuary 27, 2025

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
Exhibit 103
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

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 LET T %�—Page 3 of 8
Exibit 103
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

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
Exhibit 103
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

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
IGC REXBURG LNG PROBABLE VIOLATIONS LETTER—Pa e 5 of 8
Exhibi103
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

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
Exhibit 103
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

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
Exhibit 103
Case No. INT-G-25-01
Formal Complaint
January 27, 2025

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—Pa e 8 of 8
Exhibit 1 3
Case No. INT-G-25-01
Formal Complaint
January 27, 2025