I202420 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
January 15,2025
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 December 05,2024(Report#I202420)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a Records and Field inspection
conducted by the Idaho Public Utilities Commission(IPUC)on December 02,2024,of the Nampa LNG(Liquified
Natural Gas)plant Emergency Manual of Intermountain Gas Company(IGC)pursuant of Chapter 601 Title,49,
United States Code.
PROBABLE VIOLATION
1. 49 CFR S 193-2507 Monitoring Operations
Each component is operation or building in which a hazard to persons or property could exist must be
monitored to detect fire or any malfunction or flammable fluid that could cause a hazardous condition.
Monitoring must be accomplished by watching or listening from an attended control center for warning
alarms, such as gas,temperature,pressure,vacuum,and flow alarms,or by conducting an inspection or test
at intervals specified in the operating procedures.
Procedure 4.506 LNG Plant Fire Prevention Plan
Section 2.7—Plant Operator(s)shall verify and ensure a minimum of three(3)portable combustible gas
detectors(CGl)capable of measuring the lower explosive limits(LEL)are available,operable and
calibrated for use at all times.
2. 49 CFR 6 193.2801 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.
3. NFPA 59A Standard for the Producteon. Storage.and H ndi*ng_QL Liouffied Natural Gas (LNG) 2001
Edition,
9.7.Personnel Safety.
9.7.4.*At least three portable flammable gas indicators shall be readily available
A.9.7.4.Natural gas,LNG,and hydrocarbon refrigerants within the process equipment are
usually not odorized,and the sense of smell cannot be relied on to detect their presence.Two
portable detectors should be available for monitoring when required with a third detector for
backup.This provides a spare detector in the event of failure of one of the primary detectors and
also allows verification if the two primary detectors provide different readings.
Finding(sl•
Staff identified that the calibration gas used to calibrate portable gas detection equipment had been expired
since November 2023.
Intermountain (:as Resnonse
IGC acknowledges the findings brought forth by the IPUC. The calibration gas used to calibrate portable gas
detection equipment has been replaced. Additionally,IGC is evaluating technology solutions for the electronic
tracking and documentation of equipment maintenance at the Nampa LNG Plant.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
�C�G�G-l�t.Or/L
Pat Darras
Vice President,Engineering& Operations Services
Intermountain Gas Company