202517 NOPV Response

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608• BOISE,IDAHO 83707• [phone]• FAX:[phone]
December 30,2025
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 18,2025(Report#I202517)
Dear Mr.Brooks,
This letter is intended to address five(5)notices of probable violations stemming from a Procedural,Records,and
Observation Audit conducted by the Idaho Public Utilities Commission(IPUC) on November 17,2025,of
Intermountain Gas Company(IGC) liquified natural gas(LNG)facility located in Nampa,Idaho,pursuant of
Chapter 601 Title,49,United States Code.
PROBABLE VIOLATION
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§193,2513 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
SF422 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
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 recommended the requirement be added to the transfer procedures
and checklist to align with the scope of SF422.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. An MOC has been initiated to align OPS 650—
Nampa LNG Plant Operating Manual and the LNG Transfer Operations Checklist. The revised procedure and
checklist will be implemented on or before February 27,2026.
Additionally,to further enhance safety precautions at IGC's LNG facilities,an MOC has been initiated to create
a new JSA specific to LNG operations. The new form will be implemented on or before February 27,2026.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608- BOISE,IDAHO 83707•[phone]•FAX:[phone]
3. 49 CFR 6193,2521 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
(incorporate by reference, see 193.2013) requires. Such records, whether required by this part of
NFPA-59A-2001,must be kept for a period or not less than five years.
OPS 650 Nampa LNG Plant O en rating 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.
Finding(s)•
No requirement in OPS 650 to retain records of inspections,tests and investigations for 5 years.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. An MOC has been initiated to revise OPS 650—
Nampa LNG Plant Operating Manual to include the requirement to obtain records of inspections, tests, and
investigations for five years. The revised procedure will be implemented on or before February 27,2026.
4. 49 CFR§193.2635 Monitoring Corrosion Control
193.2635(d) Each component that is protected from atmospheric corrosions 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 corrosions at intervals not
exceeding three(3)years.
Finding(sl•
OPS 650 Section 17 was limited to carbon steel pipe.
Intermountain Gas Response
IGC acknowledges the findings brought forth by the IPUC. An MOC has been initiated to revise OPS 650—
Nampa LNG Plant Operating Manual to clarify requirements and ensure alignment with 49 CFR§193.2635.
The revised procedure will be implemented on or before February 27,2026.
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 recommended integrating descriptions and schedules in OPS 650 and the Security Training Manual
as per 193.2903(a)
Intermountain Gas Response
The Policy and Procedure department has initiated a review to evaluate OPS 650—Nampa LNG Plant Operating
Manual and the Nampa LNG Plant Security Training Manual.An update will be provided by July 1,2026.

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD-P.O.BOX 7608- BOISE,IDAHO 83707•[phone]•FAX:[phone]
6. 49 CFR 6193,2503 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.
Intermountain Gas Response
The Engineering Services department has initiated a review to locate additional supporting documentation for the
vaporizer design specifications.An update will be provided by July 1,2026.
Please contact Josh Sanders at(701)222-7773 with questions or comments.
Respectfully Submitted,
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Pat Darras
Vice President,Engineering&Operations Services
Intermountain Gas Company