I202417 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
November 26,2024
Mr.Jeff Brooks,Programs Manager
Idaho Public Utility Commission
PO Box 83720
Boise,ID 83720-0074
Subject:Response to Notice of Probable Violation dated October 17,2024(Report#I202417)
Dear Mr.Brooks,
This letter is intended to address 10(ten)probable violations stemming from a procedural,records,and field
inspection conducted by the Idaho Public Utilities Commission(IPUC)on October 7-9,2024,of Intermountain Gas
Company's(IGC)Rexburg LNG Plant.
PROBABLE VIOLATIONS
1. 49 CFR§ 193.2513 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 difference 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 Revisions January 30.2023
Finding(s):
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.
Intermountain Gas Reslionse
IGC acknowledges the findings brought forth by the IPUC. IGC is able to determine the specific gravity with
gas chromatograph reads of LNG loads transferred from the Nampa LNG Plant(Nampa Plant)to the Rexburg
LNG Facility (Rexburg Facility). The LNG transferred to the Rexburg Facility has been solely sourced from
the Nampa Plant since 2022. With variances typically less than 2%, the specific gravity of the LNG being
transferred is consistent. Additionally, due to boil off and vaporization for training and injection into the
distribution system, the LNG at the Rexburg Facility is constantly being replaced with 8-10 loads from the
Nampa Plant per year,minimizing stratification.
An MOC has been initiated to revise 4565—Rexburg LNG Transfer Operations to incorporate the requirement
to verify the specific gravity prior to transfer. The revised 4565 will implement on or before December 31,
2024.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX.[phone]
2. 49 CFR§ 193.2905 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 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
standards prescribed by this subpart.
(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
annual 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 Eouipment 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)(I202310)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."
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. An MOC was initiated to revise 4558 —Rexburg
LNG Fire Equipment Maintenance to incorporate the required language to test the engine and generator
annually for capacity. The revised 4558 implemented on October 15,2024(see Exhibit A).

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX.[phone]
3. 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.
(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§193,2609 Sunnort 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 April 22,2021
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 the documents or forms without properly reviewing it or knowing if the task is complete.
Intermountain Gas Resgonse
IGC acknowledges the findings brought forth by the IPUC. Notification was sent to the Vaporization
Technicians to address the identified inconsistencies on the monthly and daily checklist and provide guidance
on the continued documentation of identified deficiencies until they are resolved.
Additionally, an MOC was initiated to revise 4553 — Rexburg LNG Tank Inspection to incorporate the
requirement for Supervisor,Engineering Facilities review and sign off of inspection records. The revised 4553
will implement on or before December 31,2024. IGC is also evaluating technology solutions for the electronic
tracking and documentation of Rexburg LNG Facility maintenance. This would include automatic order
creation,tracking, and documentation of identified deficiencies.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX.[phone]
4. 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:
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 Eauinment 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.
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.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. An MOC was initiated to revise 4553 —Rexburg
LNG Tank Inspection to incorporate the requirement for Supervisor,Engineering Facilities review and sign off
of inspection records. The revised 4553 will implement on or before December 31,2024.
Additionally, IGC has reviewed the documentation from August 2023 to present to confirm the generator has
been operated monthly with no identified issues.IGC is also evaluating technology solutions for the electronic
tracking and documentation of Rexburg LNG Facility maintenance. This would include automatic order
creation,tracking, and documentation of identified deficiencies.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
5. 49 CFR§ 193,2719 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 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):
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 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 or 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.
Intermountain Gas Resgonse
IGC acknowledges the findings brought forth by the IPUC. The Supervisor, Engineering Facilities will attend
the next scheduled fire protection training in March 2025,and will receive continued training going forward at
intervals not to exceed 2 years.
The test records with missing dates and names have been verified and corrected.Vaporization Technicians will
retake the field portion of the test in December 2024.Documentation of the field observation will include points
received and a pass/fail indication for each observation.
Additionally,IGC is evaluating technology solutions for the electronic tracking and documentation of Rexburg
LNG Facility training.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
6. 49 CFR§ 193,2719 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 § 193.2717
(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 3.2801.
(b)A written plan of continuing instruction,including plant fire drills,must be conducted at intervals
of not more than two years to keep personnel current on the knowledge and skills they gained in the
instruction under paragraph(a)of the section.
(c)Plant fire drills must provide personnel hands-on experience in carrying out their duties under the
fire emergency procedures required by 19& 3.2509.
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(sl:
There is no record of immediate supervisors,of all personnel involved in maintenance and operation of
Rexburg LNG plant,completing required fire protection training.
Intermountain Gas Resilonse
IGC acknowledges the findings brought forth by the IPUC.The immediate supervisor of personnel involved in
the operation and maintenance of the Rexburg LNG Facility will attend the next scheduled fire protection
training in March 2025, and will receive continued training going forward at intervals not to exceed 2 years.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX.[phone]
7. 49 CFR§ 193,2627 Atmosilheric 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§ 193.2635 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.
Intermountain Gas Reslionse
IGC acknowledges the findings brought forth by the IPUC.An MOC has been initiated to develop a procedure
for Atmospheric Corrosion Control. The procedure will implement on or before December 31,2024.
8. 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.
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 engineering principles, analysis
of local conditions,hazards within the facility, and exposure to or from other property.
Finding(sl•
For Calendar Year 2023,no record of a Fire Protection Evaluation could be supplied to validate the Fire
Protection requirements.
Intermountain Gas Resilonse
IGC acknowledges the findings brought forth by the IPUC. In November 2023 IGC contacted Rexburg LNG
Plant designer, CHI Engineering(CHI),to obtain the original documentation of the fire protection evaluation.
In lieu of the evaluation documentation,as it was unable to be provided,IGC requested a reevaluation that was
conducted by CHI on March 26-27,2024(see Exhibit 13).As a result of the March evaluation,IGC is correcting
the following:
• Add a low temperature detection interlock on dewatering pump and verify installation meets code.
• Add a gas detector in the control room.
• Order and place Class A fire extinguishers in the shop area.
The corrections outlined above will be completed on or before July 31,2025.
Additionally,IGC is evaluating the necessary work needed to finish construction in the shop area of the control
building and fire proof the shop walls. The evaluation will be completed on or before July 31,2025.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
9. 49 CFR§ 193.2717 Training: 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 systems(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.
Findings)
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.
Intermountain Gas Resgonse
IGC acknowledges the findings brought forth by the IPUC. In November 2023 IGC contacted Rexburg LNG
Plant designer, CHI Engineering(CHI),to obtain the original documentation of the fire protection evaluation.
In lieu of the evaluation documentation,as it was unable to be provided,IGC requested a reevaluation that was
conducted by CHI on March 26-27,2024 (see Exhibit B). As a result of the March evaluation,the Emergency
Shutdown Systems(ESD) at the Rexburg LNG Facility is in compliance.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX.[phone]
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.
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.
Findings)
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.
Intermountain Gas Resilonse
IGC acknowledges the findings brought forth by the IPUC. In November 2023 IGC contacted Rexburg LNG
Plant designer, CHI Engineering(CHI),to obtain the original documentation of the fire protection evaluation.
In lieu of the evaluation documentation,as it was unable to be provided,IGC requested a reevaluation that was
conducted by CHI on March 26-27,2024(see Exhibit 13).As a result of the March evaluation,IGC is ordering
Class A fire extinguishers that will be placed in the shop area.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
k&44'��
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company

Exhibit A
AINTERMOUNTAIN® \ Standard Operating Procedure
GAS COMPANY
A Subsld ly d MGG Resou—G-P,�Me.
In the Community to Serve`
Title: Rexburg LNG Fire Equipment Maintenance
Department: Engineering
Procedure Number: 4558.4 Revision Date: October 15, 2024
Revision Summary
Rev. 1—Updated to new Company procedure format and includes reference to the Rexburg LNG Fire
Manual (FEB 2010)
Rev. 2— Section 2.1.2. indicates two fire suits are available at the facility
Rev. 3—Replaced Teton District Manager with Supervisor, Engineering Services
Rev. 4—Revised section 2.5.4. to include annual capacity testing.
References:
Regulations
193.2445 ... Sources of Power
193.2521 ...Operating Records
193.2801 ... Fire Protection
NFPA 59A, latest edition
Procedures
Rexburg LNG Fire Manual
Purpose:
Provide guidelines for the maintenance of the firefighting equipment at the Rexburg Satellite LNG Facility
Scope:
A. This procedure shall be used in conjunction with applicable maintenance manuals located at the Rexburg
LNG Facility
B. Includes the requirements for maintenance of firefighting equipment and appropriate record keeping
Administration:
A. The Supervisor, Engineering Services and the Vaporization Technicians are responsible for the annual
review and update of this Procedure
Procedure 4558.3 Page 1 of 3

FOUNTAINStandard Operating Procedure
GAS COMPANY
A Subsidiaryd MGG Resou—G-P,�Me.
In the Community to Serve`
Procedure:
1. GENERAL
1.1. The maintenance activities on fire control equipment must be scheduled so that a minimum of
equipment is taken out of service at any one time and is returned to service in a reasonable period of
time
2. FIRE EQUIPMENT MAINTENANCE
2.1. Vaporization Technicians and/or other qualified personnel shall complete the minimum prescribed
maintenance on the following equipment:
2.2. Personnel Protective Equipment (PPE)
2.2.1. Visually check the following which are located in the Control Building:
2.2.1.1. Gloves
2.2.1.2. Hard hats
2.2.1.3. Face shields
2.2.1.4. Personal protective clothing
2.2.2. Two (2)fire suits are available at the Rexburg LNG Facility.
2.2.3. Any deterioration of PPE should be noted and replaced as needed.
2.3. Wheeled Fire Extinguishers (125 lb)
2.3.1. Maintenance of the units will be performed according to manufacturer's recommendations.
2.3.2. Each unit shall have a tag attached indicating the date of the most recent test by the
company performing such test.
2.3.3. Each unit will have operating instructions attached in the area of the controls.
2.3.4. Each unit is checked monthly by a Vaporization Technician to ensure the hoses do not have
any cracks or breaks.
2.3.5. Annual maintenance is performed on each unit by qualified personnel from a company
familiar with the fire equipment. Such maintenance shall not to exceed an interval of 15
months.
Procedure 4558.3 Page 2 of 3

FOUNTAINStandard Operating Procedure
GAS COMPANY
A Subsld ly d MGU Resou—G-P,�Me.
In the Community to Serve`
2.4. Handheld Fire Extinguishing Units
2.4.1. Maintenance of the units will be performed according to manufacturer's recommendations.
2.4.2. Each unit shall have a tag attached indicating the date of the most recent test by the
company performing such test.
2.4.3. Each unit will have operating instructions attached in the area of the controls.
2.4.4. Each unit is checked monthly by the Rexburg LNG Facility Vaporization Technicians to ensure
the hoses do not have any cracks or breaks.
2.4.5. Annual maintenance is performed on each unit by qualified personnel from a company
familiar with the fire equipment. Such maintenance shall not to exceed an interval of 15
months. 2.5. Auxiliary Power
2.5.1. The auxiliary power at the Rexburg Facility is provided by a 150 KW Caterpillar generator.
2.5.2. The engine and generator will be maintained according to practices established by
Caterpillar.
2.5.3. The generator is located outside on the east side of the Control Building and the fuel supply
is natural gas supplied from a buried pipeline that is protected from hazards.
2.5.4. The engine and generator will be started and run once per month and tested annually for
capacity.
3. RECORDS
3.1. Records pertaining to this procedure shall be retained for five (5)years
Procedure 4558.3 Page 3 of 3

Exhibit B
INTERMOUNTAIN GAS CO.
FIRE PROTECTION EVALUATION
Rexburg LNG Facility
CHE N G I N EE R I N G IMGX24012-R-01
An N V 5 Company 11/18/24 Rev 1
PROPRIETARY& CONFIDENTIAL
This document contains confidential, and proprietary information of CHI Engineering Services, Inc., and is subject to copyright,
trade secret and other intellectual property protections. All rights to the information contained in this document are reserved
by CHI Engineering Services, Inc., and such information may not be disclosed without prior written authorization from CHI
Engineering Services, Inc.
430 West Road I Portsmouth,NH 03801 1 www.NV5.com I Office 603.433.5654
CONSTRUCTION QUALITY ASSURANCE - INFRASTRUCTURE - UTILITY SERVICES - PROGRAM MANAGEMENT - ENVIRONMENTAL

CHENGINEERING INTERMOUNTAIN GAS CO. IMGx24012-R-01
REXBURG, LNG 11/18/2024
An N V 5 Company Rev: 1
FIRE PROTECTION EVALUATION 2 of 6
1. EXECUTIVE SUMMARY
CHI Engineering Services Inc. conducted a Fire Protection Evaluation of the Intermountain Gas
Company Rexburg LNG Facility on March 26-27, 2024 to determine compliance with the
applicable versions of the following:
• 49 CFR 193 - Liquefied Natural Gas, Federal Safety Standards
• NFPA 59A - Standard for Production, Storage, and Handling of Liquefied Natural Gas
(2001 Edition)
As a result of this effort, CHI has identified a list of findings. Findings are considered mandatory
actions that are required to bring the facility into compliance with the above referenced codes.
2. FACILITY OVERVIEW
The Intermountain Gas Company LNG facility located in Rexburg, ID is a peak-shaving facility.
The facility consists of a single horizontal 70,000 gallon LNG storage tank that is filled via a truck
unloading station. The tank is located within an earthen dike for spill containment. During holding
periods, boiloff from the storage tank is warmed through an ambient exchanger and electric trim
heater before being directed to a low pressure (50 psig +/-) natural gas distribution system.
During sendout operations, LNG is sent to a pump skid which consists of two, parallel, booster
pumps on a single portable trailer. These pumps provide the pressure necessary to inject into the
250 psig +/- distribution system. LNG leaving the pump skid is sent to the vaporizer. The
vaporizer is a trailer mounted water-bath unit, that is heated by two onboard natural gas burners.
The natural gas is odorized on the vaporizer trailer before leaving the plant.
The control room is located within a wood framed building, also containing electrical equipment,
storage space, and maintenance area. The facility is equipped with a natural gas fueled stand-by
generator suitable to support vaporization operations.
A common sub-impoundment is provided to collect spills from the vaporizer area, truck unloading
area and the LNG tank piping.
3. CHI'S FIRE PROTECTION PHILOSOPHY
The fire protection posture of an LNG facility is determined by analyzing the effectiveness of
prevention methods, detection systems, and operator training. Extinguishing systems, important
as they are, are secondary to prevention, detection, and training.
PROPRIETARY& CONFIDENTIAL
This document contains confidential, and proprietary information of CHI Engineering Services, Inc., and is subject to copyright,
trade secret and other intellectual property protections. All rights to the information contained in this document are reserved
by CHI Engineering Services, Inc., and such information may not be disclosed without prior written authorization from CHI
Engineering Services, Inc.
430 West Road I Portsmouth,NH 03801 1 www.NV5.com I Office 603.433.5654
CONSTRUCTION QUALITY ASSURANCE - INFRASTRUCTURE - UTILITY SERVICES - PROGRAM MANAGEMENT - ENVIRONMENTAL

CHENGINEERING INTERMOUNTAIN GAS CO. IMGx24012-R-01
REXBURG, LNG 11/18/2024
An N V 5 Company Rev: 1
FIRE PROTECTION EVALUATION 3 of 6
Fire prevention is the most important area of fire protection. To keep a fire from starting, the
facility's design must focus on controlling the key elements to supporting combustion: fuel,
ignition source, and combustion air.
Fuel control is done by controlling the LNG and LNG vapor in the event of a release by stopping
the flow with an emergency shutdown system (ESD), or by collecting and directing LNG spills
away from process equipment towards the impoundment system.
Ignition sources are controlled by proper facility design, maintenance, and procedures. Proper
design ensures that all equipment is properly specified and installed in accordance with NFPA 70
(National Electric Code) and NFPA 59A (Production, Storage and Handling on LNG). After
installation, appropriate maintenance is required to keep systems in operating condition and
prevent the development of ignition sources and/or leak points caused from degradation, damage
or improper servicing. Facility procedures ensure that processes and activities do not create or
introduce any ignition sources in the facility.
Detection systems alert operators to an abnormal situation prompting response. Combustible
vapor detection is used to detect the release of natural gas or LNG vapor generated from an LNG
release. Low temperature detection is used to identify an LNG leak. Gas detection and low
temperature detection are important parts of fuel control as they can act prior to ignition. Flame,
smoke, or heat detection is used to detect the presence of a fire condition.
Operator training is key to safe facility operation and encompasses all areas. Operators must be
trained in the function and operation of the facility so that they can identify situations that are not
normal and take corrective action. Operators must be trained to perform required maintenance
and identify preventative maintenance items to prevent a failure. Operators must be trained in the
emergency procedures to properly identify and react to the situation and direct the emergency
responders. Normally, facility personnel are not a trained fire brigade. Facility personnel and
emergency responders should jointly train on their roles and responsibilities to ensure all efforts
are coordinated in an actual emergency.
Extinguishing systems are an important part of a facility's posture and are used when life is in
danger or to protect sensitive equipment. Usually, the sources of fuel should be controlled before
extinguishing efforts are made to prevent possible violent re-ignition by insulation char, paint
char, or other ignition source.
4. COMPLIANCE MATRIX
CHI utilizes matrix format to summarize requirements and findings. It has been our experience
that matrices are easier to use and follow for both the facility personnel and regulatory agencies.
PROPRIETARY& CONFIDENTIAL
This document contains confidential, and proprietary information of CHI Engineering Services, Inc., and is subject to copyright,
trade secret and other intellectual property protections. All rights to the information contained in this document are reserved
by CHI Engineering Services, Inc., and such information may not be disclosed without prior written authorization from CHI
Engineering Services, Inc.
430 West Road I Portsmouth,NH 03801 1 www.NV5.com I Office 603.433.5654
CONSTRUCTION QUALITY ASSURANCE - INFRASTRUCTURE - UTILITY SERVICES - PROGRAM MANAGEMENT - ENVIRONMENTAL

CHENGINEERING INTERMOUNTAIN GAS CO. IMGx24012-R-01
REXBURG, LNG 11/18/2024
An N V 5 Company Rev: 1
FIRE PROTECTION EVALUATION 4 of 6
The following matrices and documents are included in the Appendix.
• NFPA 59A LNG Fire Protection Evaluation Matrix
• NFPA 59A Facility Fire Protection, Safety, and Security Requirements Matrix
• NFPA 59A Emergency Response Evaluation Matrix
• LNG Plant Truck Loading / Unloading Checklist
• Evaluation Results Summary
NFPA 59A LNG Facility Fire Protection Evaluation Matrix
This matrix breaks down the facility into areas and identifies the following specific information
outlined in Section 9.1.2 (Items 1 thru 7) of NFPA 59A for each area of the plant.
• Potential sources of flammable gases and liquids
• Potential sources of ignition
• Quantity, type and location of detection equipment
• Types and location of sensors for ESD initiation
• ESD interlock actions
• Methods of protecting equipment from fire/cryogenic exposure
• Fire protection water systems
• Fire extinguishing equipment
NFPA 59A LNG Facility Fire Protection, Safety, and Security Requirements Matrix
This matrix restates the requirements outlined in Sections 9.2 thru 9.9 of NFPA 59A for each of
the following and identifies if and how each of the requirements is met.
• Emergency Shutdown Systems
• Fire & Leak Control
• Fire Protection Water Systems
• Fire Extinguishing & Control Equipment
• Maintenance of Fire Protection Equipment
• Personnel Safety
• Security
• Other Operations
PROPRIETARY& CONFIDENTIAL
This document contains confidential, and proprietary information of CHI Engineering Services, Inc., and is subject to copyright,
trade secret and other intellectual property protections. All rights to the information contained in this document are reserved
by CHI Engineering Services, Inc., and such information may not be disclosed without prior written authorization from CHI
Engineering Services, Inc.
430 West Road I Portsmouth,NH 03801 1 www.NV5.com I Office 603.433.5654
CONSTRUCTION QUALITY ASSURANCE - INFRASTRUCTURE - UTILITY SERVICES - PROGRAM MANAGEMENT - ENVIRONMENTAL

CHENGINEERING INTERMOUNTAIN GAS CO. IMGx24012-R-01
REXBURG, LNG 11/18/2024
An N V 5 Company Rev: 1
FIRE PROTECTION EVALUATION 5 of 6
NFPA 59A Emergency Response Evaluation Matrix
This matrix restates requirements outlined in Sections 9.1.2 (8) thru 9.1.2 (9) of NFPA 59A for the
following and identifies whether or not each of the requirements is met and how it is met.
• Availability During an Emergency
• Duties During an Emergency
• Protective Equipment for Emergency Response
• Special Training for Emergency Response
• Qualifications for Emergency Response Personnel
LNG Plant Truck Loading / Unloading Checklist
Due to LNG transfer operations being one of the higher risk activities from a release and fire
safety perspective, CHI includes a Truck Loading / Unloading Checklist as part of their fire
protection evaluation. This checklist focuses on a number of unique code requirements for LNG
transfer stations, intended to decrease the potential and/or severity of a release or fire incident.
Evaluation Results Summary
As a summary of CHI's conclusions, an evaluation results summary sheet is provided, clearly
responding to each of the code required topics that are to be addressed as part of the evaluation.
DOCUMENT HISTORY
REV DESCRIPTION DATE BY APPROVAL
0 Initial report 4/23/2024 MM PCD
1 Revised per customer comments 11/18/2024 EJO MM
PROPRIETARY& CONFIDENTIAL
This document contains confidential, and proprietary information of CHI Engineering Services, Inc., and is subject to copyright,
trade secret and other intellectual property protections. All rights to the information contained in this document are reserved
by CHI Engineering Services, Inc., and such information may not be disclosed without prior written authorization from CHI
Engineering Services, Inc.
430 West Road I Portsmouth,NH 03801 1 www.NV5.com I Office 603.433.5654
CONSTRUCTION QUALITY ASSURANCE - INFRASTRUCTURE - UTILITY SERVICES - PROGRAM MANAGEMENT - ENVIRONMENTAL

CHENGINEERING INTERMOUNTAIN GAS CO. IMGx24012-R-01
REXBURG, LNG 11/18/2024
An N V 5 Company Rev: 1
FIRE PROTECTION EVALUATION 6 of 6
APPENDIX
NFPA 59A LNG Facility Fire Protection Evaluation Matrix
NFPA 59A Chapter 9 Requirements
Emergency Response Evaluation
LNG Plant Truck Loading / Unloading Checklist
Evaluation Results Summary
Findings & Recommendations
PROPRIETARY& CONFIDENTIAL
This document contains confidential, and proprietary information of CHI Engineering Services, Inc., and is subject to copyright,
trade secret and other intellectual property protections. All rights to the information contained in this document are reserved
by CHI Engineering Services, Inc., and such information may not be disclosed without prior written authorization from CHI
Engineering Services, Inc.
430 West Road I Portsmouth,NH 03801 1 www.NV5.com I Office 603.433.5654
CONSTRUCTION QUALITY ASSURANCE - INFRASTRUCTURE - UTILITY SERVICES - PROGRAM MANAGEMENT - ENVIRONMENTAL

LNG Facility Fire Protection Evaluation (NFPA 59A 2001)
Project: Intermountain Gas Rexburg, ID Fire Study
Project No: IMGX24012
Area Area Description Type of Potential Sources of Unique Sources of Type,Quantity,and Location of Methods of ESD ESD Actions 9.1.2(6) Methods to Protect Fire Extinguishing and Other Methods to Adequate Safety/Other
No. Event Flammable Liquid,Gas, Ignition Detection and Monitoring Equipment Initiation 9.1.2(7) Equipment from Fire Control Equipment Protect Means of Observations
or Material 9.1.2(1)&(2) Exposure to Fire Available 9.1.2(5) Equipment from Approach/
(H20 or Physical) LNG/Cryogenic Egress
9.1.2(3) Spray
Storage Tank Flammable PSV discharge Electrical Equipment CVD Combustible Vapor Detector Detector-PLC actuation Source Isolation Water curtain 10#,30#Dry Chem Fire Ext. SS Splash Guard Yes/No PSV Discharge Locations
Containment/Spill Pit Gas Leak, Pipe,Flange,or Valve leak Instrumentation CVD point source Separate actuation Equipment Shutdown Water monitor 300#Dry Chem-Skid,Wheel Obstructed means of Egress
Vaporizer Flammable Equipment seal leak Maint,Hot Work CVD path Manual Push Button(PB)Fire Depressurization Fire Proof Insulation Foam Generator Inadequate Drainage/
Liquefier Liq Leak, LNG transfer operations Generator Low Temp Sensor Pull Station(FPS) Shielding Bldg.Sprinkler System Containment
Truck Load Fire NG actuators Vehicle Level Switch SCADA screen button Other Fire Protection Pre-Aimed Water Monitor
Sendout Compressor Odorant System Improper Grounding UV/IR Flame Detector Water Systems
Odorization/Metering Generator fuel Static Discharge IR/IR/IR Flame Detector
Process Heater/Boiler Vehicle Fuel Smoking Heat Detector
Control Building Lubrication Oil Adjacent Structures or Smoke Detector(S)
Storage/Shop Building Condensate Activities
Parking Dry Grass
Adjacent Facility Adjacent Facility
PROCESS AREAS
LNG/vapor leak from LNG tank Electrical is installed for 1x Point gas detector near tank piping,overhead None in immediate area.ESD Closes all tank valves Process end of tank has Handheld dry chemical extinguishers Stainless steel spray No concerns Access to ESD buttons
Flammable piping hazardous area buttons located to East and curbing,directing LNG located at each ESD button location gauze requires operator to climb up
Gas West in path of egress away from area to gravel slope to access(See
Leak subimpountment Rec 1)
LNG/vapor leak from LNG tank Nothing additional 1x Point gas detector near tank piping,overhead
LNG Tank Area Flammable piping
1 Liquid
LNG Tank(T-100) Leak
LNG Tank Piping
Pressure Build Coil 1x IIIR flame detector monitors process end of
tank
Fire
Notes: 70,000 gal LNG storage tank,75 PSIG MAOP Findings& (1)Consider adding stairs or similar up embankment towards ESD buttons.
Recommendations:
Leak from boiloff piping/ Electric heater in area 1x Point gas detector at skid(west side) ESD push button West of Closes LNG Tank Vapor Nothing identified Handheld dry chemical extinguishers Materials of No concerns None
Flammable equipment but it and all other skid Valve located at unloading area construction rated for
Gas Vapors from spill impoundment electrical installed for Closes LNG Tank Liquid cryogenic
Leak could reach the area during an hazardous area Valve
incident De-energizes boiloff trim Stainless steel spray
LNG leak from truck unloading Nothing additional 1x Point gas detector at skid(west side) heater gauze
Boiloff Heater Flammable piping which runs through the area
Ambient heat exchanger Liquid (minimal flanges/leak points)
2 Electric trim heater Leak Small odorant tank leak
Odorization
1x IIIR flame detector monitors area
Fire
Notes: Findings& (2)Reinstall stainless steel mesh on LNG PSV flange(s)to minimize potential spray distance should leak occur
Recommendations:
Leak from vaporizer piping or fuel Fired vaporizer None ESD Push button on Shutdown vaporizer,stops Nothing identified 1x Handheld dry chemical extinguisher Stainless steel spray No concerns None
Flammable gas piping Onboard generator vaporizer control panel LNG flow at process end of unit gauze
Gas 1x Handheld dry chemical extinguisher
Leak ESD Push button outside at burner end of unit Area is sloped/curbed
control room door 1x CO2 extinguisher at burner end for to direct spills away
Leak from LNG piping Fired vaporizer None control cabinet from equipment
Flammable Leak from small odorant tank Onboard generator ESD Push button South of 1x wheeled dry chemical extinguisher
Vaporizer Area Liquid
p Leak vaporizer on light pole (1251b)in the area
3 -Waterbath vaporizer,Natural gas fired
(trailer mounted) None
Fire
Notes: Vaporizer area attended by 2 operators during sendout Findings& (4)Verify if on-board generator will shutdown on ESD
Recommendations:
CHI Engineering Services, Inc. Page 1 of 11 Printed: 11/18/2024
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LNG Facility Fire Protection Evaluation (NFPA 59A 2001)
Area Area Description Type of Potential Sources of Unique Sources of Type,Quantity,and Location of Methods of ESD ESD Actions 9.1.2(6) Methods to Protect Fire Extinguishing and Other Methods to Adequate Safety/Other
No. Event Flammable Liquid,Gas, Ignition Detection and Monitoring Equipment Initiation 9.1.2(7) Equipment from Fire Control Equipment Protect Means of Observations
or Material 9.1.2(1)&(2) Exposure to Fire Available 9.1.2(5) Equipment from Approach I
(H2O or Physical) LNG/Cryogenic Egress
9.1.2(3) Spray
LNG/Vapor leak from piping, Electrical is installed for None ESD pushbuttons located on Shutdown LNG pumps, Nothing identified 3x handheld dry chemical extinguishers Stainless steel mesh No concerns None
Flammable flange,etc. hazardous area nearby light poles(2x) isolate LNG flow from tank in the area spray guard
Gas 1x wheeled dry chemical extinguisher
Leak (1251b)in the area
LNG leak from piping,flange,etc. Electrical is installed for None
Flammable hazardous area
LNG Pump Area Liquid
4 2x LNG pumps(Trailer mounted) Leak
Vapor separator
1x Flame Detector faces LNG pump skid
Fire
Notes: Pump area attended by operator during sendout Findings&
Recommendations:
LNG vapor from truck or station Truck engine(off by 1x Point gas detector at truck station 3x ESD pushbuttons around Isolates truck unloading 50 ft Area is sloped towards 3x handheld dry chemical extinguishers Materials of No concerns None
vents/piping leak procedure) the unloading area valve,closes LNG tank impoundment in the area construction rated for
Flammable Static discharge(if valves 1x wheeled dry chemical extinguisher cryogenic exposure
Gas grounding cable not (125 lb)in the area
Leak used) Stainless steel mesh
Electrical is hazardous spray guard
area rated
LNG from truck or station piping Nothing additional 1x Point gas detector at truck station
kNotes:
le leak
5 Truck Unloading Area
1x Flame Detector faces truck unload
Unloading is continuously attended Findings& (5)ESD station 817(between truck unloading area and control room)has been damaged,including broken grounding cable.This should be
Flame detector is at the edge of the range and may not pick up small fires. Recommendations: repaired/replaced
Leak from process area De-watering pump 1x Point gas detector along North wall Nothing additional Nothing additional N/A-containment Nothing additional N/A-containment No concerns None
Flammable designed to contain spill designed to contain
Gas to protect process spill to protect process
Leak equipment equipment
Leak from process area De-watering pump 1 x Point gas detector along North wall
Flammable
Spill Impoundment Liquid
6 -Common for Vaporizer,Truck Unloading and Leak
LNG tank piping Flame detectors may/may not register fire
depending on the size of the release
Fire
Notes: Findings& (6)Add low temperature detection interlock on dewatering pump.Verify installation meets code
Recommendations:
CHI Engineering Services, Inc. Page 2 of 11 Printed: 11/18/2024
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LNG Facility Fire Protection Evaluation (NFPA 59A 2001)
Area Area Description Type of Potential Sources of Unique Sources of Type,Quantity,and Location of Methods of ESD ESD Actions 9.1.2(6) Methods to Protect Fire Extinguishing and Other Methods to Adequate Safety/Other
No. Event Flammable Liquid,Gas, Ignition Detection and Monitoring Equipment Initiation 9.1.2(7) Equipment from Fire Control Equipment Protect Means of Observations
or Material 9.1.2(1)&(2) Exposure to Fire Available 9.1.2(5) Equipment from Approach/
(H20 or Physical) LNG/Cryogenic Egress
9.1.2(3) Spray
NON-PROCESS AREAS
Fuel gas for building heat Non-rated electrical None MPS at door will initiate ESD No impact to control building Nothing identified 1x CO2 extinguisher inside N/A No concerns None
Flammable Space heater ESD push button on RTU 1x Handheld dry chemical extinguisher
Gas,Liquid, cabinet outside door
or Material ESD push button outside
7 Control Building 1x Smoke/Heat detector at ceiling
Control Room Fire
Notes: Findings& (7)Control room has fuel gas for building heat but no gas detection
Recommendations:
Fuel gas for building heat Maintenance Activities 1x Point Gas Detector in ceiling of truck bay MPS will initiate ESD No impact to control building Nothing identified 1x CO2 extinguisher near restroom N/A No concerns None
Flammable Stored flammables,oils,etc Non-rated electrical I CO2 extinguisher near air
Gas,Liquid, compressor
or Material p
Control Building 1x Smoke/Heat detector at peak of roof
Shop Area 1x Smoke detector outside restroom
8 Restroom Fire
Transformer
Instrument Air Compressor
Notes: Findings& (8)Shop area of the control building is unfinished(wood construction with exposed insulation)
Recommendations: (9)Propane cylinder and gasoline can are stored on mezzanine floor which could facilite a fire
(12)Only CO2 fire extinguishers are available in shop area,which may not be effective for Class A fires(ordinary combustibles such as
wood,paper,etc.)
Fuel gas leak Generator 1x Point gas detector in the area None None Nothing identified 1x Handheld dry chemical extinguisher N/A No concerns None
Flammable Non-rated electrical in located around corner(control room
Gas,Liquid, the area Gas detection near generator entry)
or Material will shutdown generator
None
9 Standby Generator
Fire
Notes: Findings&
Recommendations:
Nothing additional Employee vehicles, Nothing additional ESD pushbutton located Nothing additional Facility is free of grass or Nothing additional N/A 3x man-gates None
Flammable general electrical(e.g. outside main gate/fence other vegetation inside (NE,SE&SW
Gas,Liquid, gate openers) the fence. corners)in
Interior of Site and Perimeter or Material addition to
vehicle gates
Fence Line Nothing additional (NW corner)
10 -Gates
Parking Fire
Open Area
Notes: Personnel doors are chained&locked closed which prevent emergency egress,but per procedure they are opened during plant operations. Findings&
Recommendations:
LNG Plant Area immediately surrounding LNG facility is farm land,owned by Intermountain Gas.Nearest public exposure is 400+ft from process equipment.
affect on
exterior of
site
11 Exterior of Site Exterior of Facility maintains a 20 foot+/-wide boundary outside the facility fence that covered in stone and free of vegetation,minimizing likelihood of brush fire impacting the facility.
site affect on
LNG plant
Notes: Findings&
Recommendations:
CHI Engineering Services, Inc. Page 3 of 11 Printed: 11/18/2024
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LNG Facility Fire Protection, Safety and Security Requirements, NFPA 59A (2001)
Project: Intermountain Gas Rexburg, ID Fire Study
Project No: IMGX24012
Section Title Para# Requirement Applies To:
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,
9.2.1
and shuts down equipment whose continued operation could add to or sustain an 9.1.2(6)
emergency. Any equipment, such as valves or control systems,that is specified in another 9.1.2(7) In Compliance
chapter of this standard shall be permitted to be used to satisfy the requirements of an
ESD system except where indicated in this standard.
If equipment shutdown will introduce an additional hazard or result in substantial In Compliance.
9 2 2 mechanical damage to equipment, the shutdown of such equipment or its auxiliaries shall 9.1.2(6) Air compressor, main generator, lighting
be permitted to be omitted from the ESD system provided that the effects of the continued 9.1.2(7) and gates are not effected by ESD
release of flammable or combustible fluids are controlled. (Repeat Rec No. 4
Emergency The ESD system(s)shall be of a failsafe design or shall be otherwise installed, located, or
Shutdown protected to minimize the possibility that it becomes inoperative in the event of an
Systems emergency or failure at the normal control system. ESD systems that are not of a failsafe g 1 2(6)
9.2.3 design shall have all components that are located within 50 ft(15 m)of the equipment to be 9 1 2(7) In Compliance
controlled in either of the following ways:
(1) Installed or located where they cannot be exposed to a fire
2 Protected against failure due to a fire exposure of at least 10 minutes'duration
9 2 4 Operating instructions identifying the location and operation of emergency controls shall be 9.1.2(6) In Compliance
posted conspicuously in the facility area. 9.1.2 7
Initiation of the ESD system(s)shall be either manual, automatic, or both manual and
automatic, depending on the results of the evaluation performed in accordance with 9.1.2. 9 1.2(6)
9.2.5 Manual actuators shall be located in an area accessible in an emergency, shall be at least 9 1 2(7) In Compliance
50 ft(15 m)from the equipment they serve, and shall be marked distinctly and
conspicuously with their designated function.
Those areas, including enclosed buildings,that have a potential for flammable gas 9.1.2(1)
9.3.1 concentrations, LNG or flammable refrigerant spills, and fire shall be monitored as required 9 1 2(2) (Repeat Rec No. 7)
by the evaluation in 9.1.2.
Continuously monitored low-temperature sensors or flammable gas detection systems shall
sound an alarm at the plant site and at a constantly attended location if the plant site is not 9 1.2(1)
9.3.2 attended continuously. Flammable gas detection system shall activate an audible and g 1 2(2) In Compliance
visual alarm at not more than 25 percent of the lower flammable limit of the gas or vapor
Fire and Leak being monitored.
Control Fire detectors shall sound an alarm at the plant site and at a constantly attended location if
9.3.3 the plant site is not attended continuously. In addition, if so determined by an evaluation in 9.1.2(1) In Compliance
accordance with 9.1.2, fire detectors shall be permitted to activate portions of the ESD 9.1.2(2)
s stem.
The detection systems determined from the evaluation in 9.1.2 shall be designed, installed,
9.3.4 and maintained in accordance with NFPA 72, National Fire Alarm Code, or NFPA 1221, 9.1.2(1) In Compliance
Standard for the Installation, Maintenance, and Use of Emergency Services 9.1.2(2)
Communications Systems, as applicable.
CHI Engineering Services, Inc. Page 4 of 11 Printed: 11/18/2024
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LNG Facility Fire Protection, Safety and Security Requirements, NFPA 59A (2001)
Project: Intermountain Gas Rexburg, ID Fire Study
Project No: IMGX24012
Section Title Para# Requirement Applies To:
A water supply and a system for distributing and applying water shall be provided for
9.4.1 protection of exposures;for cooling containers, equipment, and piping; and for controlling 9.1.2(3) In Compliance.
unignited leaks and spills. Exception:Where an evaluation in accordance with 9.1.2 9.1.2(4) (Deemed unnecessary)
Fire Protection indicates the use of water is unnecessary or impractical
Water Systems The design of fire water supply and distribution systems, if provided, shall provide for the
simultaneous supply of those fixed fire protection systems, including monitor nozzles, at g 1.2(3)
9.4.2 their design flow and pressure, involved in the maximum single incident expected in the g 1 2(4) N/A
plant plus an allowance of 1000 gpm (63 L/sec)for hand hose streams for not less than 2
hours.
Portable or wheeled fire extinguishers recommended by their manufacturer for gas fires
9.5.1 shall be available at strategic locations, as determined in accordance with 9.1.2,within an 9 1 2(5) In Compliance
Fire LNG facility and on tank vehicles.These extinguishers shall be provided and maintained in
Extinguishing accordance with NFPA 10, Standard for Portable Fire Extinguishers.
and Other Fire If provided, automotive and trailer-mounted fire apparatus shall not be used for any other
Control 9.5.2 purpose. Fire trucks shall conform to the applicable portions of NFPA 1901, Standard for 9.1.2(5) N/A
Equipment Automotive Fire Apparatus.
Automotive vehicles assigned to the plant shall be provided with a minimum of one portable In Compliance.
9.5.3 9.1.2(5) Company trucks are equipped with
dry chemical extinguisher having a capacity of not less than 181b(8.2 kg). extinguishers
Maintenance of In Compliance.
Fire Protection 9.6 Maintenance of Fire Protection Equipment. Facility operators shall prepare and implement 9.1.2(1)- Fire panel serviced by Simplex Grinnell,
Equipment a maintenance program for all plant fire protection equipment. 9.1.2(9) Extinguishers serviced by FSI Fire Services
of Idaho
9 7 1 Protective clothing, which will provide protection against the effects of exposure to LNG, 9.1.2(1)- In Compliance
shall be available and readily accessible at the facility. 9.1.2 9
Those employees who are involved in emergency activities, as determined in accordance 9 1.2(1)-
9.7.2 with 9.1.2,shall be equipped with the necessary protective clothing and equipment and 9 1 2 9 In Compliance
Safety
Personnel qualified in accordance with NFPA 600, Standard on Industrial Fire Brigades. ( )
9 7 3 Written practices and procedures shall be developed to protect employees from the 9.1.2(1)- In Compliance
hazards of entry into confined or hazardous spaces. 9.1.2 9
9.7.4 At least three portable flammable gas indicators shall be readily available. 9.1.2(1) In Compliance
9.1.2(9)
CHI Engineering Services, Inc. Page 5 of 11 Printed: 11/18/2024
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LNG Facility Fire Protection, Safety and Security Requirements, NFPA 59A (2001)
Project: Intermountain Gas Rexburg, ID Fire Study
Project No: IMGX24012
Section Title Para# Requirement Applies To:
9 8 1 The facility operator shall provide a security system with controlled access that is designed 9.1.2(1)- Site enclosed in fence; illuminated 24/7
to prevent entry by unauthorized persons. 9.1.2(9)
At LNG facilities, there shall be a protective enclosure including a peripheral fence, building
wall, or natural barrier enclosing major facility components, such as the following: (1) LNG
9 8 2 storage containers (2) Flammable refrigerant storage tanks(3) Flammable liquid storage 9.1.2(1)- In Compliance
tanks(4)Other hazardous materials storage areas(5)Outdoor process equipment areas 9.1.2(9)
(6) Buildings housing process or control equipment(7)Onshore loading and unloading
facilities
Security In Compliance.
2 vehicle gates located along North side of
The provisions of 9.8.2 shall be permitted to be met by either a single continuous enclosure fence; gate opener operates in power
or several independent enclosures.Where the enclosed area exceeds 1250 ft2 (116 m2), 9.1.2(1)- outage conditions
9.8.3 at least two exit gates or doors shall be provided for rapid escape of personnel in the event 9.1.2(9) 3 man doors located at NE SE&SW
of an emergency. corners- normally closed with chain and
padlock but standard operating procedures
include unlocking doors if running process
equipment
9 8 4 LNG facilities shall be illuminated in the vicinity of protective enclosures and in other areas 9.1.2(1)- In Compliance
as necessary to promote security of the facility. 9.1.2 9
Manual emergency depressurizing means shall be provided where necessary for safety.
9 9 1 Portions of the plant that can be isolated from storage tanks or other sources of supply can 9.1.2(1)- In Compliance
Other be depressurized by venting to the atmosphere.The discharge shall be directed so as to 9.1.2(9)
Operations minimize exposure to personnel orequipment.
Taking an LNG container out of service shall not be regarded as a normal operation and g 1.2(1)-
9.9.2 shall not be attempted on any routine basis.All such activities shall require the preparation 9 1 2(9) In Compliance
of detailed procedures.
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LNG Facility Emergency Response Evaluation Matrix (NFPA 59A 2001)
Project: Intermountain Gas Rexburg, ID Fire Study
Project No: IMGX24012
Duties during an
Emergency Qualifications for Emergency
9.1.2(8) Protective Equipment for Special Training for Response Personnel
Availability during Activate ESD, incipient Emergency Response Emergency Response 9.1.2(9)-NFPA 600
an Emergency fire fighting,advanced 9.1.2(9)-NFPA 600 9.1.2(9)-NFPA 600 Initial medical and annual job-
Responder 9.1.2(8) fire fighting,etc Turnout gear,SCBA,etc Training,education,and or drills related physical evaluation,etc
2 operators onsite
during trucking.
Activate ESD,trained for Operators attend Fire School
3 operators onsite for Cryo aprons and gloves,helmets every 2 years, receive general
Site Personnel vaporization. incipient level fires, and face shields, FIR clothing and LNG safety training every few Operators have annual physical to
technical advisers to FD coveralls, Fire Suits(reflective) years. confirm fitness for duty
On-Call personnel for larger incidents
can make it to site in
under 45 minutes.
Emergency response
personnel(i.e.
Rexburg FD)can
make it to site in Rexburg Fire Department
External Response approximately 15 periodically visits for site
Personnel minutes. orientation/emergency
response coordination.
Fire Department is a (Next scheduled in May 2024)
combination of full
time and volunteers
NFPA 600-Industrial Fire Brigade Limits of Duty
Incipient Stage Fire Fire progression is in the early stage and has not developed beyond that which can be extinguished using portable fire
Fighting extinguishers or handlines flowing up to 125 gpm(if interior)or 300 gpm and/or master stream(if exterior). No protective
equipment necessary.
Advanced Fire SCBA and thermal protection equipment provided. Performs offensive actions with handlines flowing up to 300 gpm, master
Fighting: Exterior, streams or similar devices.
Interior or Both
CHI Engineering Services, Inc. Page 7 of 11 Printed: 11/18/2024
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LNG Plant Loading/Unloading Checklist
Ref. NFPA 59A, 2001 Ed
Project:Intermountain Gas Rexburg, ID Fire Study
Project No:IMGX24012
Requirement Reference Comments
1 Isolation valves installed to isolate each transfer system at its extremities 8.2.1 In Compliance
2 Piping system for cold fluid has means for precooling before use 8.2.2 In Compliance
3 Check valves are provided to prevent backflow and located as close as practical to the 8.2.3,8.5.7 In Compliance
point of connection
In addition to local loading pump or compressor shutdowns, a remote shutdown shall be
4 provided a minimum of 25ft away. Remotely located pumps or compressors shall be 8.3.1 In Compliance
provided with shutdown controls at the loadin /u n loading area
5 Signal lights shall be provided at the transfer area to indicate when a remotely located g 3.2 N/A
transfer pump/compressor is in idle or in operation
6 Loading/unloading rack shall be constructed of noncombustible material 8.5.2 In Compliance
7 Transfer area shall be sufficient size to accommodate the vehicles without excessive 8.5.3 In Compliance
movement or turning
8 Transfer piping, pumps,and compressors shall be located or protected by barriers so that 8.5.4 In Compliance
they are safe from damage by vehicle movement
Isolation valves and bleed connections shall be provided at the loading or unloading
g manifold for both liquid and vapor return lines so that hoses and arms can be blocked off, 8.5.5 In Compliance
drained of liquid,and depressurized before disconnecting. Bleeds or vents shall discharge 8.6.5
Ito a safe area.
An emergency valve shall be provided in each liquid and vapor line at least 25ft but not
10 more than 100 ft from each loading or unloading area. These valves shall be readily 8.5.6 In Compliance
accessible for emergency use. A single valve shall be permitted to be installed in a
common line to multiple loading or unloading areas.
In installation where the loading or unloading area is closer than 25ft to the sending or
11 receiving container,a valve that can be operated remotely from a point 25 ft to 100 ft from 8.5.6 N/A
the area shall be permitted to be used
12 Pipelines used for liquid unloading only shall be provided with a check valve at the manifold 8 5.7 In Compliance
adjacent to the manifold isolation valve
13 Isolation valves shall be provided at all points where transfer systems connect into pipeline g 6.1 In Compliance
systems
14 Provisions shall be made to ensure that transfers into pipeline delivery systems cannot g 6.2 In Compliance
exceed the pressure or temperature limitations of the pipeline system
In Compliance
15 Loading and unloading areas shall be posted with signs that read"No Smoking" 8.6.3 (18)Add no smoking
11.4.5.1(d) sign specifically at
unloading station
Where multiple products are loaded or unloaded at the same location,loading arms,hoses, 8.6.4
16 or manifolds shall be identified or marked to indicate the product or products to be handled 11.4.5.1(e) N/A
by each system
17 If vented to a safe location,gas or liquid shall be permitted to be vented to the atmosphere 8.6.6 In Compliance
to assist in transferring the contents of one container to another
Hoses or arms used for transfer shall be designed for the temperature and pressure
18 conditions encountered.Hoses shall be approved for the service and shall be designed for 8.7.1 In Compliance
a burstina pressure of not less than 5 times the working pressure
19 Flex metallic hose or pipe and swivel joints shall be used where operating temperatures are 8 7 2 In Compliance
expected to be below-60°F
20 Provisions shall be made for adequately supporting the loading hose or arm. Counter 8 7 4 N/A
weights shall take into consideration and ice formation on uninsulated hoses or arms
21 Hoses shall be tested at least annually to the maximum pump pressure or relief valve 8 7 5 In Compliance
setting and shall be inspected visually before each use for damage or defects
Communication shall be provided at transfer locations so that the operator can be in
22
contact with other remotely located personnel who are associated with the loading or 8.8.1
unloading operation. Communications shall be permitted to be by means of telephone, 11.4.E In Compliance
public address system,radio or signal lights.
23 Facilities transferring LNG during the night shall have lighting in the transfer area. 8.8.2 In Compliance
24 Transfer operations must be attended by operators 11.4.5.1 In Compliance
25 While tank car vehicle transfer operations are in progress, rail and vehicle traffic shall be 11.4.5.2(a) In Compliance
prohibited within 25 ft of LNG facilities
28 Prior to transfer,a tank vehicle shall be position so that it can exit the area without backing 11.4.5.2(e) In Compliance
up when the transfer operation is complete
CHI Engineering Services,Inc. Page 8 of 11 Printed:11/18/2024
Truck Loading R-01 Fire Protection Eval Matrix(required only).xlsx

LNG Facility Fire Protection Evaluation Results
Project: Intermountain Gas Rexburg, ID Fire Study Ref. NFPA 59A, 2001 Ed
Project No: IMGX24012
Per§9.1.2, the fire protection evaluation shall determine the following: Evaluation Results
(1) Is the type quantity and location of equipment adequate to detect and control (6), (7)
fires, leaks and spills of LNG, and flammable refrigerants and gases?
(2) Is the type quantity and location of equipment adequate to detect and control In Compliance
potential non-process and electrical fires?
(3) Are adequate methods in place to protect equipment and structures from the (8)
effects of fire or cryogenic exposure?
(4) Is the fire protection water system determined to be adequate (or unnecessary or In Compliance
impractical if not present)? (Not Necessary)
(5) Are portable/wheeled fire extinguishers (or other fire control equipment)of the (12)
appropriate type and size located in strategic locations?
Is the ESD system adequate? Does it shutdown and/or isolate and/or
(6) depressurize appropriate vessels and equipment duringa fire emergency? In Compliance
Are the method(s)to initiate the ESD system (manual/automatic/both)
(7) satisfactory? If automatic, are the sensors the necessary type and in the proper In Compliance
locations?
Is the availability of external emergency response personnel satisfactory? During
(8) an emergency, are plant personnel adequately available (number and In Compliance
skill/training level) and properly equipped to perform expected duties?
(9) Is an Industrial Fire Brigade (NFPA 600) necessary at the facility, and if so to In Compliance
what level? Is that level currently met or exceeded by the facility? (Not Necessary)
CHI Engineering Services, Inc. Page 9 of 11 Printed: 11/18/2024
Results R-01 Fire Protection Eval Matrix (required only).xlsx

LNG Plant Findings, Recommendations and Actions
Project: Intermountain Gas Rexburg, ID Fire Study
Project No: IMGX24012
Finding I Mandatory NFPA 59A,
No. Findings & Recommendations Comments Action 2001 ed. Ref
1 Consider adding stairs or similar up embankment towards ESD buttons. In an emergency, depending on the conditions, operators may struggle to access the ESD buttons x 9.2.5
quickly and safely from the tank area.
2 Reinstall stainless steel mesh on LNG PSV flange(s)to minimize potential spray distance should Generally most were installed, suggest a review to ensure LNG flanges and similar leak sources are x
leak occur wrapped with stainless steel gauze to minimize spray distance.
3 Reserved
4 Verify if on-board generator will shutdown on ESD This could not be confirmed onsite. If not stopped on ESD, this would result in the presence of an x
ignition source
5 ESD station 817 (between truck unloading area and control room) has been damaged, including x 7
broken grounding cable. This should be repaired/replaced
Pump shutdown on low temperature is required by NFPA to prevent inadvertent pumping of LNG if
6 Add low temperature detection interlock on dewatering pump. Verify installation meets code pump operates automatically. Existing installation does not appear to meet hazardous area x 10.8.4
requirements
7 Control room has fuel gas for building heat but no gas detection Consider gas detection inside control room to monitor for fuel gas leak x 9.3.1
8 Shop area of the control building is unfinished (wood construction with exposed insulation) Consider adding fire proofing to shop walls (currently insulation paper exposed). Damage to the x
building would render the facility unusable.
9 Propane cylinder and gasoline can are stored on mezzanine floor which could facilite a fire Consider storing in flammables cabinet x
10 Reserved
11 Reserved
12 Only CO2 fire extinguishers are available in shop area,which may not be effective for Class A fires Consider adding ABC type extinguishing in shop area x
(ordinary combustibles such as wood, paper, etc.)
13 Reserved
14 Reserved
15 Reserved
16 Reserved
17 Reserved
18 Install no smoking sign specifically at unloading station x 10.15.3.6.1 (d)
19 Reserved
20
CHI Engineering Services, Inc Page 10 of 11 Printed: 11/18/2024
Findings-Actions R-01 Fire Protection Eval Matrix (required only).xlsx

Facility Shutdown Summary
MEANS OF ACTIVATION SYSTEM ACTIONS
ESD - Emergency Shutdown EQUIPMENT ACTIONS STOP START NO CHANGE
Any Push Button (Qty 8) LNG Vaporizer(HX-301) x
Any Building Smoke/ Heat(Qty 2) LNG Pumps (P-200 &201) x
Any Building Manual Pull Station (Qty 2) Boiloff Heater(HTR-509) x
Instrument Air Compressor(CP-701) x
Standby Generator(G-301) x
OTHER ACTIONS CLOSE OPEN NO CHANGE
LNG Tank Top Fill Valve (FCV-106) x
LNG Tank Bottom Fill Valve (FCV-109) x
LNG Tank Liquid Witdrawal Isolation (FCV-114) x
LNG Pump Vent Isolation (FCV-116) x
LNG Tank Pressure Build Liquid Isolation (FCV-121) x
LNG Tank Vapor Isolation (FCV-127) x
LNG Truck 50ft Valve (FCV-517) x
Boiloff Heater Outlet Isolation (TCV-510) x
CHI Engineering Services, Inc. Page 11 of 11 Printed: 11/18/2024
Shutdown R-01 Fire Protection Eval Matrix (required only).xlsx