I202414 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
October 11,2024
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to the Notice of Probable Violation dated September 18,2024(Report#I202414)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a review conducted by the
Idaho Public Utilities Commission(IPUC)on September 11,2024,of Intermountain Gas Company(IGC)Nampa
LNG(Liquified Natural Gas)plant Emergency Manual pursuant of Chapter 601 Title,49,United States Code.
PROBABLE VIOLATION
1. 49 CFR § 193,2503
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 Company Emergency Manual for Rexburg Nampa LNG Facility
3.2.Periodical Review
The material contained in the 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 Director of Engineering Services to review and issue any and all necessary
revisions or additions to this manual.
Finding(s): The Nampa LNG(Liquified Natural Gas)Plant Emergency Manual has not been revised or
reviewed since 2022. There is no tracking mechanism for periodic revisions or reviews in place.
Intermountain Gas Resgonse
IGC acknowledges the findings brought forth by the IPUC. An MOC was initiated to review the Nampa LNG
Plant Emergency Manual and make necessary updates. The revised emergency manual was implemented and
submitted to the IPUC on October 3,2024.
Additionally, OPS 8 — Administration of Company Procedures and Forms was revised to include LNG
procedures and manuals. Going forward,the Nampa LNG Plant Emergency Manual will be reviewed annually
and tracked in Important Dates. The revised OPS 8 was implemented and submitted to the IPUC on September
23, 2024.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering& Operations Services
Intermountain Gas Company