I202517 NOPV

Idaho Public Utilities Commission Brad Little,Governor
P.O.Box 83720, Boise,ID 83720-0074 Edward Lodge,President
John R.Hammond,Jr.,Commissioner
Dayn Hardie,Commissioner
November 18, 2025, Report# I202517
Pat Darras—Vice President of Engineering & Operations Services
Intermountain Gas Company
400 N 41h St.
Bismarck, ND 58501
Dear Mr. Pat Darras,
On November 17, 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 Nampa,
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 VIOLATIONS)
1. 49 CFR §193.2503 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.
2. 49 CFR 093.2513 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.
OPS 650 Nampa LNG Plant Operating Manual
Section 15 —Transfer Operations
SF 422 Job Safety Analysis/Tailgate Meetings.
SCOPE
This applies to jobs/tasks that shall be performed by 2 or more individuals to pre-plan and
adapt to various tasks and procedures/processes that could pose a potential hazard to
employees
IGC NAMPA LNG AUDIT PROBABLE VIOLATIONS LETTER— Page 1 of 4

Finding(s)•
On November 17, 2025, the Idaho Public Utilities Commission (IPUC) staff discovered
inadequate alignment between OPS 650 Section 15 Transfer Operations and the Truck
Transfer Checklist used at the facility. Additionally, IPUC staff recommend the
requirement be added to the transfer procedures and checklist to align with the scope of SF
422.
3. 49 CFR 4193.2521 Operating Records.
Each operator shall maintain a record of results of each inspection, test and investigation
required by this subpart.For each LNG facility that is designed and constructed after March
31, 2000 the operator shall also maintain related inspection, testing, and investigation
records that NFPA-59A-2001 (incorporated by reference, see § 193.2013) requires. Such
records,whether required by this part or NFPA-59A-2001,must be kept for a period of not
less than five years.
OPS 650 Nampa LNG Plant Operating Manual
Section 6—Equipment and Components
6.2.13. Inspection records shall be submitted to Manager, Engineering Facilities for review
and sign off. Inspection records shall be submitted as soon as possible upon completion of
inspection.
6.2.14. Equipment maintenance records shall be retained for a minimum of five(5) years.
Findinds)•
No requirement in OPS 650 to retain records of inspections, tests and investigations for 5
years.
4. 49 CFR 4193.2635 Monitoring Corrosion Control.
193.2635(d) Each component that is protected from atmospheric corrosion must be
inspected at intervals not exceeding 3 years.
OPS 650 Nampa LNG Plant Operating Manual
Section 17—Atmospheric Corrosion Control
17.1.2.2. Carbon steel pipe is used in some natural gas process pipe applications. Carbon
steel process pipe transporting natural gas shall be visually inspected for atmospheric
corrosion at intervals not exceeding three (3) years.
Finding(s):
OPS 650 Section 17 was limited to carbon steel pipe.
IGC NAMPA LNG AUDIT PROBABLE VIOLATIONS LETTER— Page 2 of 4

5. 49 CFR §193.2903 Security Procedures.
(a) A description and schedule of security inspections and patrols performed in accordance
with & 193.2913;
Finding(s)•
Staff recommend integrating descriptions and schedules in OPS 650 and the Security
Training Manual as per 193.2903(a)
6. 49 CFR 4193.2503 Operating Procedures.
CFR 193.2503(e) In the case of vaporization, maintaining the vaporization rate,
temperature and pressure so that the resultant gas is within limits established for the
vaporizer and the downstream piping.
Finding(s)•
Staff reviewed vaporization logs and vaporizer data plates,but no Data Sheets or Vaporizer
design records were provided.
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 January 2,2026, 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 18, 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 January 2, 2026, 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).
IGC NAMPA LNG AUDIT PROBABLE VIOLATIONS LETTER— Page 3 of 4

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,
J Brooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
IGC NAMPA LNG AUDIT PROBABLE VIOLATIONS LETTER— Page 4 of 4