I202418 LOC Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
November 14,2024
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#I202418)
Dear Mr.Brooks,
This letter is intended to address six(6)areas of concern 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.
AREAS OF CONCERN
1. 49 CFR§ 193.2511 Personnel Safety
(c)Each LNG plant must be equipped with suitable first-aid material,the location of which is clearly
marked and readily available to personnel.
Finding(s):
All first aid equipment,including eyewash station are past the manufacturer expiration dates.
Intermountain Gas Resnonse
IGC acknowledges the findings brought forth by the IPUC. All first aid equipment has been replaced. The
eyewash station was removed,as it was a onetime use,and replaced with eye wash bottles.A third-party vendor
has been contracted to visit and update first aid stations twice annually.
2. 49 CFR§ 193.2907 Protective Enclosure Construction
(a)Each protective enclosure must have sufficient strength and configurations to obstruct
unauthorized access.
(b)Openings in or under protective enclosures must be secured by grates,doors,or covers of
construction and fastening of sufficient strength such that the integrity of the protective enclosure is
not reduced by any opening.
Finding(s):
There is approximately one foot of space between the bottom of the fence line and the ground which may not
adequately obstruct unauthorized access.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC.IGC is exploring all options to minimize the space
between the fence line and the ground.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
3. 49 CFR§ 191.23 Reporting Safety-Related Conditions
(a)Except as provided in paragraph(b)of this section,each operator shall report in accordance with
§ 191.25 the existence of any of the following safety-related conditions involving facilities in
service:.
(3)Unintended movement or abnormal loading by environmental causes, such as an earthquake,
landslide,or flood,that impairs the serviceability of a pipeline or the structural integrity or reliability
of a UNGSF or LNG facilities that contains,controls,or processes gas or LNG.
OPS 9 Gas Emergency Notification and Reporting
8.6.2.Unintended movement or abnormal loading by environmental causes,such as an earthquake,landslide,
or flood,which impairs the serviceability of a pipeline.
Finding(sl:
OPS 9,8.6.2.should include verbiage similar to below.Unintended movement or abnormal loading by
environmental causes,such as an earthquake,landslide,or flood,that impairs the serviceability of a pipeline
or the structural integrity or reliability of a UNGSF or LNG facilities that contains,controls,or processes gas
or LNG.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. An MOC was initiated to revise OPS 9 — Gas
Emergency Notification and Reporting. The revised OPS 9 was implemented and submitted to the IPUC on
October 28,2024.
4. 49 CFR§ 193,2713 Training: operation and maintenance
(b)A written plan of continuing instruction must be conducted at intervals of not more than two
years to keep all personnel current on the knowledge and skills they gained in the program of initial
instruction.
Finding(s):
No continuing instruction will occur until January 2025 due to initial training that began in 2023.
Intermountain Gas Response
Continued training is scheduled to be completed in January 2025.
5. 49 CFR§ 193,2715 Training: Security
(b)A written plan of continuing instruction must be conducted at intervals of not more than two
years to keep all personnel current on the knowledge and skills they gained in the program of initial
instruction.
Finding(s)•
No continuing instruction will occur until January 2025 due to initial training that began in 2023.
Intermountain Gas Response
Continued training is scheduled to be completed in January 2025.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
6. 49 CFR§ 193,2717 Training: Fire Protection
(b)A written plan of continuing instruction must be conducted at intervals of not more than two
years to keep all personnel current on the knowledge and skills they gained in the program of initial
instruction.
Finding(sl:
No continuing instruction will occur until January 2025 due to initial training that began in 2023.
Intermountain Gas Response
Continued training is scheduled to be completed in January 2025.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company