20250418Stipulation and Settlement.pdf

RECEIVED
April 18, 2025
Preston N. Carter, ISB No. 8462 IDAHO PUBLIC
Megann Meier, ISB No. 11948 UTILITIES COMMISSION
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
prestoncarter@givenspursle.
memk ig venspursley.com
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION ) CASE NO. INT-G-25-01
STAFF'S FORMAL COMPLAINT )
CONCERNING INTERMOUNTAIN GAS ) STIPULATION AND
COMPANY AND THE REXBURG LIQUID ) SETTLEMENT
NATURAL GAS FACILITY )
This Stipulation and Settlement("Settlement") is entered into by and among
Intermountain Gas Company("Intermountain Gas" or"Company"), a subsidiary of MDU
Resources Group, Inc., and Staff for the Idaho Public Utilities Commission("Staff'), collectively
the "Parties" and individually"Party."
INTRODUCTION
1. The terms and conditions of this Settlement are set forth herein. The Parties agree
that this Settlement represents a reasonable compromise of the issues raised in this proceeding.
The Parties, therefore, recommend that the Idaho Public Utilities Commission ("Commission")
approve the Settlement and all of its terms and conditions. See Rules 271, 272, and 274 (IDAPA
31.01.01.271, 272, and 274).
STIPULATION AND SETTLEMENT PAGE I OF 13

BACKGROUND
2. On January 30, 2025, the Commission issued a summons regarding the formal
complaint filed by Staff in this matter. The Complaint alleges that,based on inspections
conducted by the Commission on or about August 15 (NOPV Report No. I202408), September
10 (NOPV Report No. I202415), and October 17, 2024 (NOPV Report No. I202417), the
Company violated regulations and/or standards related to the Rexburg Liquid Natural Gas
facility(Facility).
3. On February 13, 2025, Intermountain Gas and Staff stipulated to a 21-day
extension of time to answer the Complaint in order to enable discussions between the Company
and Staff related to this case. The parties subsequently agreed to a second extension, making the
Company's response due on or before April 7, 2025.
4. As a compromise of positions in this case, and for other considerations as set forth
below, the Parties stipulate and agree to the terms set forth below.
TERMS OF THE SETTLEMENT
5. Completed corrective actions. Intermountain Gas has completed the following
corrective actions to address the issues identified in the Complaint:
a. Item No. 1:Additional training of Vaporization Technicians on LNG trailer safety
and protocols. On August 14 and 28, 2024, the Company's Vaporization
Technicians received additional training from Kenan Advantage Group ("KAG"),
which included: (1) a general safety overview of the trailer; (2) an overview of the
trailer's operation; (3) Emergency Shut Down (ESD) function, testing, and
locations; (4)valve orientation for travel, loading, unloading, and a description of
each valve function; (5)vent and relief functions and operations; and(6) hose
hookup and transfer of LNG. Proof of training was submitted to the Commission
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on September 25, 2024. Additional training was also provided to the Vaporization
Technicians during the LNG delivery on October 16, 2024. This training was
conducted by the KAG Safety and Security Manager with assistance from a
qualified LNG Operator from the Company's Nampa LNG Plant. Newly hired
Vaporization Technicians will receive training on LNG trailer safety and
protocols.
b. Item No. 2: Revision of Company Procedure 4565 (Rexburg LNG Transfer
Operations). The Company revised Procedure 4565 to include: (1)the
requirement that both the Carrier driver and the Vaporization Technician verify
that all manual valves are closed prior to connecting/disconnecting hoses; (2) the
requirement that the trailer emergency shutdowns be tested prior to offloading;
(3)the requirement that a portable radio be present at the offloading skid; (4)the
requirement that certain PPE be worn during offloading, including (i)FR clothing
that covers the skin, (ii) Cryogenic gloves, (iii) a hard hat and face shield, and
(iv) safety toe boots; and (5)the requirement that a Job Safety Analysis (JSA)be
completed and reviewed with the Carrier driver prior to offloading. A copy of the
revised procedure was submitted to the Commission on September 25, 2024.
c. Item No. 3: Revision of Rexburg LNG Truck Offloading Operations Checklist. The
Company revised its Offloading Checklist to include: (1) verification that all
manual valves are closed; (2)the testing of trailer ESDs; (3) confirmation that a
copy of Procedure 4565 is available at the offloading skid; (4) confirmation that a
portable radio is available at the offloading skid; (5) completion and review of the
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JSA; and(6) a signature from the Carrier driver. A copy of the revised Checklist
was submitted to the Commission on September 25, 2024.
d. Item No. 4:Revision and review of Rexburg LNG Emergency Manual. After self-
reporting that the Company had not updated the Rexburg LNG Emergency
Manual since 2014, the Company advised that it would review and revise the
manual and submit it to the Commission before October 4, 2024. On September
23, the Company revised its OPS 8—Administration of Company Procedures and
Forms to include LNG procedures and manuals. A copy of OPS 8 was provided to
the Commission. Then, on October 3, 2024, the Company submitted its updated
Emergency Manual to the Commission. To prevent problems moving forward, the
Company has created annual review tasks in its scheduling system.
e. Item No. 5:Additional revisions to Company Procedure 4565 (Rexburg LNG
Transfer Operations Checklist). The Company further revised its procedure to
incorporate the specific gravity prior to transfer. The revised procedure was
implemented on December 30, 2024, and a copy was provided to the Commission
on December 31, 2024.
f. Item No. 6:Revision of Company Procedure 4558 (Rexburg LNG Fire Equipment
Maintenance). The Company revised its Rexburg LNG Fire Equipment
Maintenance procedure to incorporate required language for testing the engine
and generator annually for capacity. The revised procedure was submitted to the
Commission on November 26, 2024.
g. Item No. 7:Revision of Company Procedure 4553 (Rexburg LNG Tank
Inspection). The Company revised its Rexburg LNG Tank Inspection Procedure
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to incorporate the requirement that the Supervisor of Engineering Facilities
review and approve inspection records. The revised procedure was implemented
on December 30, 2024, and a copy was submitted to the Commission on
December 31, 2024.
h. Item No. 8:Development of an Atmospheric Corrosion Control procedure. The
Company developed an Atmospheric Corrosion Control procedure, Procedure
4568, and implemented it on December 30, 2024. A copy of Procedure 4568 was
submitted to the Commission on December 31, 2024.
i. Item No. 9:Fire Protection Evaluation. In its October 17, 2024 NOPV Report,
the Commission indicated that, for Calendar Year 2023, there was not a Fire
Protection Evaluation to validate the Fire Protection requirements. On November
26, 2024, the Company submitted a Fire Protection Evaluation for the Rexburg
LNG Facility.
j. Item No. 10:Reinstallation of stainless steel mesh on LNG PSV flanges. During
the fire evaluation, it was identified that originally installed stainless steel mesh
was missing from LNG PSV flanges. The Company conducted a review of the
Rexburg LNG Facility and placed stainless steel mesh at the location identified by
CHI, in addition to other areas identified by the Vaporization Technicians during
the review. The installation of stainless steel mesh on the LNG PSV flanges was
completed on January 7, 2025.
k. Item No. 11:Placement of propane and gasoline in cabinet designed for
flammable materials. During the fire evaluation, it was identified that propane
cylinders and gasoline cans on the mezzanine floor could facilitate a fire. It was
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recommended that the Company purchase and install a cabinet for flammable
materials. However, upon further review, it was discovered that a flammable-
materials closet is located in a safe location within the Control Building. The
Company has moved all flammable materials into that cabinet.
1. Item No. 12: Confirmation of the number of Manual Pull Stations (MPSs) in the
shop area. As part of the fire evaluation, the Company was asked to confirm if
there are two MPSs in the shop area, as identified on the plan drawings. On
January 16, 2025, the Company located and verified the two MPS locations.
m. Item No. 13:Installation of Class Afire extinguishers in the shop area. During the
fire evaluation, it was identified that ABC fire extinguishers should be available
in the shop area. In addition to the CO2 fire extinguishers already available in the
shop area, the Company obtained and placed Class A fire extinguishers in the
shop area on February 4, 2025.
n. Item No. 14:Fire extinguisher near boil off heater stairs. During the fire
evaluation, it was identified that a fire extinguisher should be added near the boil
off heater stairs. The Company installed the fire extinguisher on February 27th,
2025.
o. Item No. 15: Training of the Engineering Services Supervisor and immediate
personnel supervisors pursuant to Company Procedure 4557. The Company's
Engineering Facilities Supervisor and immediate personnel supervisors involved
in the maintenance and operation of the Rexburg LNG Facility attended fire
protection training on March 6, 2025. Continued training will be received at
intervals not to exceed 2 years.
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p. Item No. 16: Testing of LNG Vaporization Technicians. In its October 17, 2024,
NOPV Report, the Commission indicated that tests of initial training for LNG
Vaporization Technicians were not adequately documented with names and dates
of completion. The Company has since verified the names and dates of those
initial training tests. In addition, three of the four Vaporization Technicians retook
the field observation portion of the test on December 19, 2024. Those tests were
properly documented with points received and pass/fail indications for each
observation. The remaining Vaporization Technician was on leave until February
26, 2025, and was tested on February 28, 2025.
q. Item No. 17: Repair of ESD Station 817. The ESD station between the truck
unloading area and the control room was damaged, including a break in the
grounding cable. On January 15, 2025, the Company reattached the lug and
ground wire on the ESD. Post replacement was completed on March 28, 2025.
r. Item No. 18:Ensure the local fire department is familiar with the operation of
wheeled fire extinguishers. The Company provided training material for the
wheeled fire extinguishers to the local fire department on March 13, 2025. The
Company also extended an invitation to the local fire department to participate in
Mutual Aid Training at the Facility in 2025. Any training will include the
operation of the Facility's wheeled fire extinguishers.
s. Item No. 19: Verification that the on-board generator shuts down on ESD. During
the fire protection evaluation, the Company verified that the on-board generator
(a.k.a., vape trailer generator) shuts down upon activation of the ESD from the
vaporizer control panel. On March 12, 2025 an electrician corrected the settings
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on the on-board generator. As a result, the on-board generator shuts down upon
activation of Facility ESDs.
6. Additional corrective actions. Intermountain Gas agrees to take the following
corrective actions to address issues identified in the Complaint that have not been addressed as of
the date of this Settlement,by the deadlines indicated(as applicable).
a. Item No. 1:Additional access to ESD buttons. In its inspection report, CHI
indicated that the Company should consider adding stairs or similar up
embankment towards the ESD buttons. In lieu of adding stairs, the Company has
determined that installing an additional ESD at the bottom of the embankment is
the best solution. The Company shall complete installation on or before May 31,
2025.
b. Item No. 2:Addition of low-temperature detection interlock on the dewatering
pump. In its inspection report, CHI indicated that the Company should add a low-
temperature detection interlock on the dewatering pump and verify the installation
meets code. The Company is actively working to locate an electrician able to
purchase and install an intrinsically safe dewatering pump with a low-temperature
interlock. Because this equipment is uncommon and not in high demand, the
Company is working to identify permanent solutions. The Company shall
complete installation and verify that the installation conforms to code on or before
September 30, 2025.
c. Item No. 3: Install gas detector in control room. The control room has fuel gas for
building heat but no gas detection. The Company has already requested a quote
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for installation and programming and shall have installation complete on or before
May 31, 2025.
d. Item No. 4: Complete construction of the Control Buildings shop area. Currently
the shop area has unfinished wood with exposed insulation. The Company shall
complete construction and finish the shop walls by May 31, 2025.
e. Item No. S:Review of site security and bolstering of the perimeter fence. There
are gaps beneath the Rexburg LNG Facility's perimeter fence. After evaluating
different methods and associated costs, the Company scheduled a contractor to
add additional gravel around the fence to reduce gaps. This work was started in
February 2025 and will be completed as soon as possible, dependent on weather
conditions that allow the gravel to be effectively installed. The Company is also
evaluating the need for additional security measures (motion detection, security
cameras, etc.). This evaluation will be complete on or before July 31, 2025.
f. Item No. 6:Evaluation of technology solutions for electronic tracking and
documentation of Rexburg LNG Facility maintenance. The Company is
evaluating technology solutions for the electronic tracking and documentation of
Rexburg LNG Facility maintenance.
g. Item No. 7:Evaluation of technology solutions for electronic tracking and
documentation of Rexburg LNG Facility training. The Company is evaluating
technology solutions for the electronic tracking and documentation of Rexburg
LNG Facility training.
7. Final report. The Company agrees to provide a report upon completion of the
corrective actions set forth in paragraph 6 to the Executive Director of Idaho Public Utilities
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Commission no later than thirty (30) days after the final corrective item with an identified
completion-date (i.e., all items except 6.f and 6.g) is completed. For items with no completion
date (i.e., items 6.f and 6.g), the Company's report will include a status report and summarize the
conclusions reached by the Company.
8. Settlement payment. Within thirty days of the Commission's unconditional
approval of this Settlement, the Company agrees to provide a payment of$15,000 to the
Commission. This payment is made in the interest of resolving the issues identified in the
Complaint and does not constitute an admission of liability by the Company; a waiver of any
arguments; or a waiver of the Company's ability to contest any future penalties that may be
sought by Staff. Upon receipt of the settlement payment, all additional fines,penalties, and
payments related to this matter will be held in abeyance and will be dismissed upon termination
of the Settlement.
9. Future disputes arising under this Agreement. If the Company violates any
term of this Settlement, Staff may request that the Commission impose a penalty pursuant to
Idaho Code § 61-712A. If the Commission awards a penalty, the amount will be offset by the
$15,000 settlement payment made pursuant to paragraph 8. Any dispute relating to the
Company's compliance with this Settlement shall be submitted to the Commission for resolution.
10. Termination of Settlement. This Settlement shall terminate upon the earlier of
(i) confirmation by the Executive Director that the final report identified in paragraph 7 has been
submitted and is complete; (ii)upon stipulation of the Parties approved by the Commission; or
(iii)upon approval by the Commission of a petition filed by Intermountain Gas.
11. Extension of deadlines. The dates set forth in paragraph 6 can be extended only
upon request of the Company, based on the occurrence of an event that cannot reasonably be
STIPULATION AND SETTLEMENT PAGE 10 OF 13

anticipated or controlled by the Company. A request to extend a deadline under this paragraph
shall be supported by an explanation of the circumstances justifying an extension and must be
approved by the Commission.
GENERAL PROVISIONS
12. The Parties agree that this Settlement represents a compromise of the positions of
the Parties on all issues in this proceeding. Other than the above-referenced positions, and except
to the extent necessary for a Party to explain before the Commission its own statements and
positions with respect to the Settlement, none of the negotiations relating to this Settlement shall
be admissible as evidence in this or any other proceeding regarding this subject matter.
13. The Parties submit this Settlement to the Commission and recommend approval in
its entirety pursuant to Rule 274. The Parties shall support this Settlement before the
Commission, and no Party shall appeal any portion or any Order approving this Settlement.
14. The Parties agree that the Settlement should be accepted, without modification,
because it is just, fair, and reasonable, in the public interest, and otherwise in accordance with
law or regulatory policy.
15. The Parties agree that no part of this Settlement or the formulae and methods used
in developing the agreements herein or a Commission order approving the same shall in any
manner be argued or considered as precedential in any future case.
16. In the event the Commission rejects any part or all of this Settlement, or imposes
any additional conditions on approval of this Settlement, each Party reserves the right, upon
written notice to the Commission and the other Parties to this proceeding, within twenty-one
days of the date of such action by the Commission, to withdraw from this Settlement. In such
case, no Party shall be bound or prejudiced by the terms of this Settlement, and each Party shall
be entitled to seek reconsideration of the Commission's final order, file testimony as it chooses,
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cross-examine witnesses, and do all other things necessary to put on such case as it deems
appropriate.
DATED: April 18, 2025
GIVENS PURSLEY LLP
olp 7-
Preston N. Carter
Attorney for Intermountain Gas Company
DATED: April 17, 2025
IDAHO PUB IC UTILITIES COMMISSION STAFF
LA IL�
Chris Burdin
Deputy Attorney General
STIPULATION AND SETTLEMENT PAGE 12 OF 13

CERTIFICATE OF SERVICE
I certify that on April 18, 2025, a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via electronic mail as indicated below:
Commission Staff Via Electronic Mail
Monica Barrios-Sanchez, Commission Secretary Monica.barriossanchez@puc.
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Chris Burdin [e-mail]
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
I �N
Preston N. Carter
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