I202514 NOPV

f'
Idaho Public Utilities Commission Brad Little,Governor
P.O.Box 83720, Boise,ID 83720-0074 Edward Lodge,President
John IL Hammond,Jr.,Commissioner
Dayn Hardie,Commissioner
November 4, 2025, Report # I202514
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck,ND 58501
Dear Mr. Pat Darras,
On October 27-28, 2025, the Pipeline Safety Division ("Staff') of the Idaho Public Utilities
Commission ("Commission") conducted a 2024 Procedural, Records, and Observation Audit at
the Intermountain Gas Company ("IGC") liquefied natural gas (LNG) facility located in Rexburg,
Idaho, pursuant to Chapter 601 of Title 49, United States Code.
Staff observed that some of the Idaho natural gas system(s) owned and operated by IGC
("Company") was out of compliance on item(s). This results in probable violations of the pipeline
safety regulations Title 49, Code of Federal Regulations, Part 193. The probable violations are as
follows:
PROBABLE VIOLATION(S)
1. 49 CFR W3.2503 Operating Procedures.
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.
SF 422 Job Safety Analysis/Tailgate Meetings
Instructions: on JSA Form 23023
Review the job or task to be performed and associated potential hazards with all individuals
participating/Observing in, or affected by,the work activity prior to START of each job or
when significant changes in the work occur. Fill in the upper section of the form, then,
review the applicable sections in the table below, provide details as requested and ensure
each individual sign form 23023 (Rev 3/2020).
IGC REXBURG LNG AUDIT PROBABLE VIOLATIONS LETTER— Page 1 of 3

Policy Statement Job Safety Analysis/Tailgate Meetings (Rev Date: 1/19/2021)
2. Employee Responsibilities
2.2 Employees shall assess their work area, adjust the JSA (Job Safety Analysis)
form, and communicate any additional changes, after the following occurrences:
2.2.3 If new individuals are entering the work area, verify they have been
notified of the existing hazards and controls by having them sign onto the
current JSA form.
IGC Procedure 4565.4 Rexburg LNG Transfer Operations (Rev Date: 9/10/2024)
2.4 Prior to beginning offloading:
2.4.7. A JSA shall be completed and reviewed with the Carrier driver.
Rexburg LNG Truck OFF LOADING OPERATIONS CHECKLIST(Rev Date:
9/10/2024)
Item#20 Complete JSA and review with Carrier driver.
Findin(s)•
On July 17, 2024, the Idaho Public Utilities Commission (IPUC) conducted a failure
investigation and follow-up site inspection related to incident NRC#1404942/1405150. As
a result of this investigation, on August 15, 2024, the IPUC issued a Notice of Probable
Violation (NOPV), reference number I202408. Item #5 of the NOPV identified the
following finding: the driver was not informed of existing hazards and associated controls
and failed to sign the required Form 23023.
On September 25, 2024, the IPUC received a formal response from Intermountain Gas
Company (IGC) regarding the NOPV dated August 15, 2024 (Report #I202408). In its
response, IGC acknowledged the findings presented by the IPUC and stated that it had
taken corrective action.
Specifically, IGC revised Procedure 4565 — Rexburg LNG Transfer Operations — to
mandate the completion and review of a Job Safety Analysis (JSA)with the Carrier driver
prior to the commencement of offloading activities (see Exhibit 13).
Additionally, the Rexburg LNG Truck Offloading Operations Checklist was amended to
incorporate the JSA review requirement and to include a designated field for the Carrier
driver's signature. (see Exhibit Q.
On July 30, 2024, and again on December 19, 2024, during the tank truck off-loading
operation, the driver(s) were not adequately informed of the existing site-specific hazards
and applicable control measures. The required Form 23023 Job Safety Analysis/Tailgate-
Gas was not presented to the driver for review or signature, resulting in non-compliance.
IGC REXBURG LNG AUDIT PROBABLE VIOLATIONS LETTER— Page 2 of 3

REQUESTED ACTIONS
A reply to this correspondence is required no later than 45 days from the date of this letter. Please
submit a written reply providing a statement of all relevant facts including a complete description
of the corrective action(s) taken with respect to the above referenced probable violations, and all
actions to be taken to prevent future failures in these areas of concern. This written reply must be
signed by a Company official with authority to bind the Company.
Please send all documents to our office at 11331 W. Chinden Blvd, Boise, Idaho 83714-1021. Be
advised that all material you submit in response to this enforcement action may be a public record
and subject to disclosure under Idaho's Public Records Law. See Idaho Code §§74-101 et seq.
If you wish to dispute any of the above referenced potential violations, you have the right to appear
before the Pipeline Safety Division in an informal conference before December 19, 2025, at the
above address. You have the right to present relevant documents and evidence to the Pipeline
Safety Division at that conference. The Pipeline Safety Division will make available to you any
evidence which indicates that you may have violated the law, and you will have the opportunity to
rebut this evidence. See Commission Orders 35095 and 35334, which can be found at
https://puc.idaho.gov/. If you intend to request an informal conference,please contact the Pipeline
Safety Division no later than December 4,2025.
If you wish to dispute any of the allegations in this Notice,but do not want an informal conference,
you may send the Pipeline Safety Division a written reply to this Notice. This written reply must
be filed with the Commission on or before December 19,2025,and must be signed by a Company
official with authority to bind the Company. The reply must include a complete statement of all
relevant facts, and all documentation, evidence, and argument the Company submits to refute any
of the above referenced probable violations.
These violations may be subject to any Commission enforcement action as allowed under Idaho
law including, but not limited to,potential civil penalties in accordance with 49 CFR 190.223(a).
If you have any questions concerning this Notice,please contact me at(208) 334-0333. All written
responses should be addressed to me at the above address, or you may fax your response to (208)
334-3762.
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sincerely,
/Z----�
Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
IGC REXBURG LNG AUDIT PROBABLE VIOLATIONS LETTER— Page 3 of 3