I202514 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
December 9,2025
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 November 4,2025 (Report#I202514)
Dear Mr.Brooks,
This letter is intended to address one(1)notice of probable violation stemming from a 2024 Procedural,Records,
and Observation Audit conducted by the Idaho Public Utilities Commission(IPUC)on October 27-28,2025,of
Intermountain Gas Company(IGC) liquified natural gas(LNG)facility located in Rexburg,Idaho,pursuant of
Chapter 601 Title,49,United States Code.
PROBABLE VIOLATION
L 49 CFR 8193.2503 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).
Policy Statement.Iob Safety Analvsis/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 i.NG Transfer Onerat Uj1 (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.
Finding(s)•
On July 17, 2024, the Idaho Public Utilities Commission(IPUC) conducted a failure investigation and
follow-up site inspection related to incident NRC#1 404942/1405150.As a result of this investigation,on
August 15,2024,the IPUC issued a Notice of Probable Violation(NOPV),reference number 1202408.
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.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O. BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
On September 25,2024,the IPUC received a formal response from Intermountain Gas Company(IGC)
regarding the NOPV dated August 15,2024(Report#1202408).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 B).
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
C).
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.
Intermountain (Cas Resnonse
The truck offload conducted on July 30,2024,was completed prior to IGC receiving NOPV Report#1202408 on
August 15,2024,and prior to the revision of procedure 4565—Rexburg LNG Transfer Operations and the Truck
Offloading Operations Checklist.The revised procedure and checklist implemented on September 10,2024,
included the requirement for a JSA to be completed and reviewed with the Carrier driver.The revisions also
included the requirement to obtain the Carrier driver's signature on the checklist.The revised procedure and
checklist were included as exhibits in IGC's response to NOPV Report#1202408,that was submitted to the IPUC on
September 25,2024.
On March 10,2025,upon request from the IPUC,IGC provided the JSA that was completed on December 19,2024,
prior to beginning truck offloading.
On March 11,2025,upon request from the IPUC,IGC provided the Truck Offloading Operations Checklists for the
truck offloads that were conducted on December 19,2024.While IGC acknowledges that the drivers did not sign the
completed JSA,the JSA was reviewed with each Carrier driver prior to beginning offloading. The reviews were
documented on the offload checklists,complete with signatures from the Carrier drivers.
On March 18,2025,a follow-up discussion was held with Jeff Brooks(IPUC),Josh Sanders(IGC),and Colby
Lundstrom(IGC).Based on the discussion,IGC made further revisions to 4565—Rexburg LNG Transfer
Operations and the Truck Offloading Operations Checklist to clarify the requirement to obtain the Carrier driver's
signature on the JSA. The revised procedure and checklist were implemented on April 24,2025.JSAs completed
after April 24,2025,have received the Carrier driver's signature.
Additionally,to further enhance safety precautions at IGC's LNG facilities,an MOC has been initiated to create a
new JSA form specific to LNG operations. The new form will be implemented on or before February 27,2026.
Please contact Josh Sanders at(701) 222-7773 with questions or comments.
Respectfully Submitted,
Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company