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Home My WebLink AboutDP202101 NOPV Response D O U GLAS PIPELINE COMPANY October 6, 2021 Mr. Bruce Perkins Interim Pipeline Safety Program Manager Idaho Public Utility Commission P.O. Box 83720-0074 Boise, Idaho 83720-0074 Dear Mr. Perkins: Thank you for your audit of Douglas Pipeline Company's procedures_ This letter is in response to the Notice of Probable Violation dated October 4, 2021: PROBABLE VIOLATIONS 49 CFR §192.605; Procedural manual for operations, maintenance; andemergencies. General Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. Douglas Gas Pipeline Idaho Power Langley Gulch and Idaho Power Bennett Mountain Operations & Maintenance Manual Section 14 Transmission Lines: Leak Surveys, Leak Classification States: Note: a visual vegetation leakage survey is done in conjunction with each pipeline patrol. This visual vegetation survey is not to be considered a substitute for the annual Leakage Survey with an instrument. The leakage survey instrument used is indicated on each Leak Survey Report. The instrument used for leakdetection is calibrated prior to each survey with canned methane and calibrated annually by a manufacturer-authorized technician. Findin Douglas Pipeline Companies Heath DP-IR Methane Leak Detector has a calibration sticker with a 2017 date indicating that it has not been calibrated annually by a manufacturer-authorized technician as required by the operations& maintenance procedures. 901 Castle Shannon Blvd. o Pittsburgh, Pennsylvania • 15234 Telephone: 412,531,2440 9 www.douglaspipeline.com DOUGLAS PIPELINE COMPANY Douglas Pipeline Company acknowledges that the Leak Surveys section of the Operations and Maintenance Manual for the Idaho Power Langley Gulch facility, and the Idaho Power Bennett Mountain facility did not include the complete procedure for leak detection instrument calibration. As the Director of Regulatory Compliance, it is my responsibility to ensure that these written procedures are accurate, and that they are implemented by our technician team. Statement#1 below describes the proposed revision to the O&M Manual that accurately describes the leak detection instrument procedure, and statement#2 describes the calibration verification of the instrument used at the Idaho Power locations on September 20, 2021. 1) Douglas Pipeline Company will revise Section 14- Transmission Lines: Leak Surveys, Leak Classification of the Idaho Power Operations and Maintenance Manual for the Idaho Power Langley Gulch facility, and the Idaho Power Bennett Mountain facility so that it is inclusive for all brands of leak detection instruments that Douglas Pipeline Company technicians may use to complete a leak survey: "A gas leak survey with a leak detection instrument will be performed on the entire route of the pipeline in Class 1 and Class 2 Locations at least once each calendar year at intervals not exceeding 15 months. Due to the gas not being odorized, Douglas Pipeline shall also perform a gas leak survey in each Class 3 Location area at least twice per calendar year not exceeding 7 '/z months. As of the date of this manual there are no Class 4 Location segments on the Idaho Power pipeline system. The leakage survey instrument used for each inspection is documented on each Leak Survey Report. The instrument used for leak detection shall be calibrated per the manufacturer's requirements and documented per Douglas Pipeline Company Procedure SOP-05-Leak Survey and SOP-23-Instrument Calibration. DPC shall document these surveys and retain records of each leak survey as required by 49 CFR 192.723 for at least five years. Whenever an indication of leakage is detected, DPC will further evaluate the area with a gas detector. Leak locations will require bar holes to be made and tested with a combustible gas indicator (CGI), the extent of gas migration determined, and the leak pinpointed and classified. Each detected leak will be documented on the Leak Investigation Report showing a sketch of the leak location, any nearby buildings, leak classification, date, and signature. The adequacy of all the repairs of leaks will be checked by appropriate methods immediately after repairs are completed. Where there is residual gas in the ground, a follow up inspection using a gas detector instrument must be made as soon as the gas has had an opportunity to dissipate, but no later than one month for Grade 1 leaks and six months for Grade 2 leaks. The date and status of recheck will be recorded on the leak repair record. 2 DOUGLAS PIPELINE COMPANY Reference: Douglas Pipeline Procedure SOP-05-Leak Survey Douglas Pipeline Procedure SOP-05B-Leak Investigation Report Douglas Pipeline Procedure SOP-23-Instrument Calibration" 2) The DP-IR used for the leak survey at the Idaho Power Bennett Mountain and Langley Gulch facilities on September 20, 2021, was calibrated by a Heath authorized technician on 05/17/2017 and subsequently self-tested per the manufacturer's instructions. • Douglas Pipeline Procedure SOP-05-Leak Survey is attached as Exhibit 1. • Douglas Pipeline Procedure SOP-23-Instrument Calibration is attached as Exhibit 2. • The calibration/self-test portion of the Heath DP-IR operation manual is attached as Exhibit 3. • Records of these self-tests are attached as Exhibit 4. Thank you for your attention to this matter. We appreciate and respect the auditing process that The Commission provides and your support in promoting effective pipeline safety practices. Please contact me by phone or email if you have any questions. Sincerely, Andrea Shacklett Director of Regulatory Compliance Douglas Pipeline Company 412-531-2440 Ext. 29 ashacklett{cDdouglaspipeline.com 3 Exhibit 1 Douglas Pipeline Procedure SOP-05-Leak Survey DOUGEAS PIPELINE COMPANY DPC SOP 05: Leak Survey Douglas Pipeline Company Standard Operating Procedure. Leak Survey This procedure is used to inspect the pipeline for natural/landfill gas leaks using approved, authorized, and properly calibrated leak detection equipment. Description The leak survey shall be performed as part of a patrol to observe surface conditions for evidence of excavation damage or construction activities along the pipeline right-of-way. 49 CFR Part 192.706 Leakage surveys of a transmission line must be conducted at intervals not exceeding 15 months, but at least once each calendar year. However, in the case of a transmission line which transports gas in conformity with §192.625 without an odor or odorant, leakage surveys using leak detector equipment must be conducted— (a) In Class 3 locations, at intervals not exceeding 71/2 months, but at least Code Reference - twice each calendar year; and Frequency (b) In Class 4 locations, at intervals not exceeding 41/2 months, but at least four times each calendar year. 49 CFR Part 192.936 (d) An operator of a transmission pipeline operating below 30%SMYS located in a Class 3 or Class 4 area but not in a high consequence area must perform semi-annual leak surveys (quarterly for unprotected pipelines or cathodically protected pipe where electrical surveys are impractical). Revision Date/Number 02/01/2017—Revision 1 06/01/2019—Revision Z 1. Class Location survey, and odorant confirmation Prerequisite 2. Ensure the exact location of the pipeline 3. Current Instrument Calibration Documentation Responsibilities: Operator personnel are responsible for completion of leak surveys on every transmission facility no less than the minimum frequency specified in State and Federal Pipeline Safety Regulations, or as specified in each pipeline owners Operations and Maintenance Manual. Operator personnel must initiate follow-up checks, inspections, repair work, remedial actions, and protective measures resulting from leaks discovered by survey or reported by the public. It is also the responsibility of operations to ensure proper, correct, and complete documentation showing that Douglas Pipeline has complied with State and Federal Regulations, as well as pipeline owner requirements. 1 DOUGrLAS PIPELINE COMP N V DPC SOP 05: Leak Survey Facilities that Require Leak Survey: Leak surveys may be conducted from ground patrols along the pipeline route. Ground surveys are to include: • Tap site • Station yard piping up to building walls • Station piping inside buildings • Meter and regulator buildings • Road and highway crossings • Railroad crossings • Casing vents • Paved areas • Valve sites including valves and piping • Regulated Gathering and Storage field lines • Transmission lines • Compressor station piping not equipped with fixed gas detection Surveying for odor, noise, or other indications of blowing gas or gas leaks should also be used to check for gas leaks during routine facility visits—normal quarterly patrols. Leak Detection Equipment: Leak detection equipment is required that has been calibrated and maintained per manufacturer recommendations. Each calibration procedure must be documented, and the document shall be stored in DPC's"Instrument Inventory" file. Leak detection equipment includes: • Approved catalytic/thermal conductivity-type combustible gas indicator • Flame Ionizations unit • Optical remote methane detector Additional equipment or methods which may be used to pinpoint leaks include Gas-Trak devices, personal monitors, bar hole probes for leak survey, and soapsuds Leak Survey Form; 1. Complete the Leak Survey form notating location of any leaks found 2. Grade leaks using the GTPC Classification chart a. If Grade 1 or 2 leaks are found an AOC form should be completed 3. Leaks requiring immediate repair 4. Inform pipeline owner of action plan regarding any leaks found 5. Complete a Pre-construction form and schedule repair upon approval 2 DOUGLAS PIPELINE COMPANY Y DPC SOP 05: Leak Survey Leak Survey Pipeline Name Location Inspected By Inspection Date Required Frequency Annual? Survey Method Instrument Used Serial Number Calibration Date Areas Surveyed Valves and above ground piping? Leak Survey Results *If leaks are found, complete Location and Grade Section Leak Location and Grade Leak Location Grade Action Plan 3 DOUGLAS PIPELINE COMPAN s' DPC SOP 05: Leak Survey GPTC Leak Classification Grade 1 Definition Action Criteria j Examples A leak that represents Requires prompt action*to 1.Any leak which, in the judgment of an existing or probable protect life and property, operating personnel at the scene, is hazard to persons or and continuous action until regarded as an immediate hazard. property, and requires the conditions are no longer 2. Escaping gas that has ignited. immediate repair or hazardous. 3. Any indication of gas which has continuous action until migrated into or under a building, or the conditions are no *The prompt action in some into a tunnel. longer hazardous. instances may require one 4.Any reading at the outside wall of a or more of the following: building, or where gas would likely a. Implementation of migrate to an outside wall of a company emergency plan building. (§192.615). 5.Any reading of 80% LEL, or greater, b. Evacuating premises. in a confined space. c. Blocking off an area. 6.Any reading of 80% LEL, or greater d. Rerouting traffic. in small substructures(other than gas e. Eliminating sources of associated substructures)from which ignition, gas would likely migrate to the outside f.Venting the area. wall of a building. g. Stopping the flow of gas 7. Any leak that can be seen, heard, or by closing valves or other felt, and which is in a location that means. may endanger the general public or I h. Notifying police and fire property. departments. Grade 2 Definition Action Criteria Examples A leak that is Leaks should be repaired or cleared A. Leaks Requiring Action Ahead recognized as being within one calendar year, but no later of Ground Freezing or Other non-hazardous at the than 15 months from the date the Adverse Changes in Venting time of detection, but leak was reported. In determining the Conditions. justifies scheduled repair priority,criteria such as the repair based on following should be considered: Any leak which, under frozen or probable future a. Amount and migration of gas. other adverse soil conditions, would hazard. b. Proximity of gas to buildings and likely migrate to the outside wall of subsurface structures. a building. c. Extent of pavement. d. Soil type and soil conditions (such B. Leaks Requiring Action Within as frost cap, moisture and natural Six Months venting). 1. Any reading of 40% LEL,, or Grade 2 leaks should be reevaluated greater, under a sidewalk in a wall- at least once every six months until to-wall paved area that does not cleared. The frequency of qualify as a Grade 1 leak. 4 DOUGL.AS PIPELINE COMP.ANY DPC SOP 05: Leak Survey reevaluation should be determined 2.Any reading of 100% LEL, or by the location and magnitude of the greater, under a street in a wall-to- leakage condition. wall paved area that has significant gas migration and does not qualify Grade 2 leaks may vary greatly in as a Grade 1 leak. degree of potential hazard. 3. Any reading less than 80% LEL in small substructures Some Grade 2 leaks, when evaluated (other than gas associated by the above criteria, may justify substructures)from which gas scheduled repair within the next 5 would likely migrate creating a working days. probable future hazard. 4.Any reading between 20% Others will justify repair within LEL and 80% LEL in a confined space. 30 days_ During the working day on S. Any reading on a pipeline which the leak is discovered, these operating at 30 percent SMYS, or situations should be brought to the greater, in a class 3 or 4 location, attention of the individual which does not qualify as a Grade 1 responsible for scheduling leak leak. repair. 6.Any reading of 80% LEL, or greater, in gas associated On the other hand, many Grade 2 substructures. leaks, because of their location and 7. Any leak which, in the judgment magnitude, can be scheduled for of operating personnel at the scene, repair on a normal routine basis with is of sufficient magnitude to justify periodic reinspection as necessary scheduled repair. Grade 3 Definition Action Criteria Examples A leak that is non-hazardous at These leaks should be Leaks Requiring the time of detection and can reevaluated during the next Reevaluation at Periodic be reasonably expected to scheduled survey, or within 15 Intervols remain non-hazardous. months of the date reported, 1.Any reading of less than whichever occurs first, until the 80% LEL in small gas associated leak is regraded or no longer substructures. results in a reading. 2.Any reading under a street in areas without wall-to-wall paving where it is unlikely the gas could migrate to the outside wall of a building. 3.Any reading of less than 20% LEL in a confined space. 5 Exhibit 2 Douglas Pipeline Procedure SOP-23-instrument Calibration DOUGL..AS PZP1:LINE Ct7A1i'ANY DPC SOP#23: Instrument Calibration Douglas Pipeline Company Standard Operating Procedure: Instrument Calibration This procedure is used to ensure that instruments used to perform Operations and Maintenance, and Emergency procedures are calibrated per manufacturers Description recommendations and State and Federal Pipeline Safety Regulations. All records of calibration activity need to be readily available both in the field and in Egnyte. All instruments being used to perform • DP-IRrator Operations and Maintenance and • Odo Odo Applicability Emergency procedures on regulated natural/landfill gas pipelines that • MX6 require regular calibration activity • Crystal Gauge • Torque Wrench Frequency Varies per manufacturer requirement and State and Federal Pipeline Safety Regulations. Recision Date/Number • Revision 1:06/01/2019 • Version 1:02/01/2017 1) Read the owner's manual for each instrument 2) Technicians must have preapproval before sending any instrument in for Prerequisite calibration or repairs 3) Ensure that you have a back-up instrument to use if needed while yours is at the manufacturer for service Procedure—Use the following calibration record to determine which instruments need to be calibrated and how often calibration is to occur. 1) You must always keep a current copy of the manufacturer's calibration report or their recommended documentation form with each instrument. 2) You must submit evidence of the manufacturer's calibration to the Director of Regulatory Compliance within 5 days of receipt: -This can be a picture that clearly shows all data on the calibration report, or a scan of the report, or mail a COPY of the report to the Pittsburgh office 3) DP-IR's require self-testing to be documented monthly or before each use instead of factory calibration.Take a legible picture of your self-test records and send to Director of Regulatory Compliance at least once a month and a copy will be kept with each instrument 4) The Heath Odorator2 requires documentation of self-tests monthly or before each use—take a legible picture of your self-test records and send to Director of Regulatory Compliance at least once a month 5)Torque Wrenches- Per manufacturers specification or annual calibration 6)Crystals- Per manufacturers specification or annual calibration 1 DOUGLA.S PIPELINE COMPANY DPC SOP#23: Instrument Calibration 7) Industrial Scientific MX4&MX6-require documentation of monthly calibrations and bump testing before each use.Take a legible picture of your monthly calibration record and bump-test records and send to the Director of Regulatory Compliance at least once a month. 8) Instruments and Tools requiring annual calibration/certification will be completed by a 3r, party vendor at the annual DPC safety training days. 2 Exhibit 3 Calibration/self-test portion of the Heath DP-IR Operation Manual TM 11) P R User 's Manual Heath Consultants Incorporated Houston,TX Phone: 713-844-1300EATH Fax: 713-844-1309tC\O , 1-800-HEATH-US www.heathus.com Your Safety...Our Commitment 102105A DP-iR MANUAL REV M Page 1 of 35 Table of Contents Notice............ .........................................................................................................2 Warnings ..................................................................................................................3 Overview ...................................................... ............................6 Chapter I DP-IR System Specifications ...................................................................................7 DP-IR System Components .....................................................................................8 Optional Accessories ..............................................................................................10 Chapter II Operatingthe DP-IR..............................................................................................11 Keypad ...............................................................................................................11 UserInterface .....................................................................................................12 ExternalFeatures ................................................................................................13 Turningthe DP-IR On/Off.................................................................................13 Usingthe Menu ..................................................................................................14 Zero ....................................................................................................................14 Auto/Manual Ranging .......................................................................................14 AlarmLevel ........................................................................................................15 DetectionModes ................................................................................................15 Usingthe Tick Mode ..........................................................................................15 Self-Test.................................................................................................................16 Chapter III Battery/External Power Operation RechargeableBattery .........................................................................................18 BatteryCharging ................................................................................................19 BatteryReplacement..........................................................................................19 ExternalPower...................................................................................................19 102105-0 DP-IR MANUAL REV M Page 4 of 35 Chapter IV Serial Data Communication ....................................................................................20 Chapter V Surveyingwith the DP-IR.......................................................................................21 Usingthe Bar Hole Probe ........................................................................................22 Chapter VI Maintenance and Troubleshooting Information Troubleshooting the Instrument...........................................................................23 Maintenance .........................................................................................................24 Chapter VII Service Information Warranties and Warranty Repair..........................................................................25 ObtainingService ................................................................................................25 DP-IR Parts List ......................................................................................................26 DP-IR Daily Self-Test and Calibration Log............................................................33 Declarationof Conformity......................................................................................34 ContactInformation ................................................................................................35 102105-0 DP-IR MANUAL REV M Page 5 of 35 Overview The HEATH Detecto Pak-Infrared (DP-IRT") uses highly advanced optical technology capable of detecting methane gas utilizing the Infrared Controlled Interference Polarization Spectrometry method. The DP-IR is the latest leak survey instrument from HEATH that greatly improves productivity, cost and safety of walking and mobile surveys. The DP-IR functions by using an infrared optical gas detection system. This instrument is intended to replace the current surveying equipn-tent using the traditional Flame Ionization method with next-generation technology utilizing an infrared light beam, eliminating the need for expensive gas cylinders and refill systems. It is designed to be highly selective to detecting methane gas and will not false alarm on other hydrocarbon gases which may be encountered during a normal natural gas leak survey, s z. Figure 1: The DP-IR uses advanced infrared optical technology to achieve high sensitivity to methane gas. The DP-IR operates under a variety of field conditions, including cold and hot temperatures. Its rugged design will stand up to normal field use and operating conditions. The DP-IR has a built-in self-test function that will verity that the instrument is operating properly. Using the internal calibration cell, the operator performs the self-test as part of a daily start-up routine. while in operation, the DP-IR continuously monitors several internal parameters to ensure that it is functioning properly. Should any of these parameters go outside of operational limits, a constant audible alarm will sound and an ERROR icon will be displayed. 102105-0 DP-rR MANUAL REV M Page 6 of 35 CHAPTER I DP-IR System Specifications Detection Method: Infrared Controlled Interface Polarization Spectrometer Measurement Range: 0-100,000 PPM 1-100% Gas Display Range: Auto Ranging: Manual Ranging: PPM: 0-10,000 PPNI scale: 0-10,000 % Gas- 1-100% % Gas: 0-1009% Sensitivity: 0-1000 PPM: 1 PPNI 1000-10,000 PPM: 5 PPM 1-100% Gas: 0.5% Accuracy: Greater of+/- .5%or+/- 10% of reading (typical, std conditions) (% Gas on manual mode) Detection Alarms Modes: Digital Methane Detection (DMD): Audible tone when detection threshold is exceeded Adjustable Alarm Level from 1 to 9000 PPM Tick: Continuous audio tone relative to concentration System Fault Warning: Audible tone and indication on the display Self-Test & Calibration: Built in Self-Test and Calibration function verifies operation and adjusts calibration for maximum sensitivity. Test gas cell integrated within the instrument. Compliance: EN 61326-1 Conducted Emissions Class B EN 61326-1 Radiated Emissions Class B EN 61000-4-2 4kV/8kV ANSI C63.4 Class B EN 61000-4-3 3 VIM FCC 47 CFR Part 15 Class B Dust Filter: Replaceable filter provides dust protection. Easy change out quick disconnect filter cap. Dis la : Large easy to read backlit LCD (.75" Numeric) Operating Temperature: 0 to + 122' F (-17 to 50' C) (nominal battery voltage) Humidity: 5 to 95% RH, non-condensing Enclosure: IP54 (Water splash and Dust resistant) Instrument Weight: 5.6 tbs. Carrying Case: 13 lbs. empty, 21 lbs. filled 24.5" x 21" x 9" Power Supply: Internal rechargeable Li-ion battery or External 12 VDC car battery with optional power conditioner Battery Operating Life: 8 hours at 32' F with out backlight on Battery Charger: External, in-line, 110 - 240 VAC, 50/60 hertz. 10 hours to 90% charge Shoulder Strap: Single over the shoulder padded strap Speaker Volume: 108 dBs @ Alarm port (A-fast) Survey Probe: Quick connect fitting with locking clasp.Adjustable length from 25" to 41" Bar hole Probe: Std: 20": Optional 36" Intrinsic Safety: Class 1 Division 1 Group D T3 UL 913 and CSA 22.2 No. 157 MET Lab #El12840 10210540 aim-rR MANUAL REV nr Page 7 of 35 3. If the location with the fastest tick rate is consistent, then the leak is at that spot. 4. If the tick rates are not consistent, keep working the area. The gas plume may be drifting around causing inconsistent readings. In some cases, the gas plume may be large enough that localization is not very accurate. Self-Test The DP-IR has a built-in function to perform a self-test and calibration of the instrument. The self-test feature should be used on a daily basis to ensure that the instrument is in proper working order. HEATH recommends that the self-test function be performed prior to beginning your survey day. Each self-test should be recorded into a daily log.An example daily log has been included at the end of this manual for your convenience. To perform the self-test, the following procedure should be followed: 1. Remove the instrument form the carrying case. 2. Turn on the instrument and allow it to warm up. 3. Verify that the battery has four or more bars. 4. Press the MENU button until the SELF-TEST icon is shown on the display (Note: the Retry and OK icon are also displayed). 5. Press the UP button to initiate the self-test. 6. If the OK icon is displayed, the instrument passed the self-test. a. If the RETRY icon is displayed then the instrument failed the self-test, press the UP button to retry the self-test. 7. Press the MENU button to return to the survey run display. If the self test fails multiple times make sure the battery is fully charged and the instrument is properly warmed up. **Note** The instrument may continue to stabilize for up to 10 to 15 minutes. Re-zero as need or re-run self test. "Caution" Should the instrument not pass after several attempts, do not use the instrument for survey work until the problem is corrected. Contact HEATH for further assistance. Self-test may fail if performed shortly after reading high gas concentrations, (e.g. after bar holing measurement) do to gas still present in the sample cell. Allow the unit to fully purge before running a self-test. Self-test may fail if the battery voltage is too Iow (below four bars). 102105-0 nr-rx MANUAL REV M Page 16 of 35 U Q O s�( T� i.+ U 1■1 I .r. � S?. r� J c� Q G� a U :� a Q 102105-1311P-FR MANUAL REV M Page 33 of35 Exhibit 4 Records of DP-IR Self-tests DPIR SELF TEST AND CALIBRATION REPORT-SN 9101521003 DATE TECHNICIAN SELF-TEST READING READING LEVEL NOTES 5/17/2017 Heath x x x Certified by Heath 6/14/2017 Urbanski Yes 77 97 1 KC Beech Island 7/6/2017 Weidenhamei Yes 75 96 1 Rockingham 8/11/2017 1 Urbanski Yes 77 96 1 Greenwood 1/31/2018 Urbanski Yes 75 97 1 Acme Brick 2/6/2018 Urbanski Yes 76 96 1 First Quality 2/13/2018 Urbanski Yes 77 96 1 Tropicana 3/29/2018 Urbanski Yes 78 95 1 Cherokee 4/10/2018 Urbanski Yes 77 96 1 Idaho power 5/14/2018 Urbanski Yes 77 96 1 KC Beech Island 6/28/2018 Urbanski YEs 76 96 1 Easley 7/12/2018 Urbanski yes 78 94 1 Big Ox 8/6/2018 Urbanski Yes 76 94 1 Greenwood 9/25/2018 Urbanski Yes 78 93 1 U N CCH 10/16/2018 Urbanski YES 79 94 1 12/4/2018 Urbanski Yes 78 94 1 Ironwood 1/16/2019 Urbanski Yes 78 93 1 Acme(2) Calhoun j� DPIR SELF TEST AND CALIBRATION REPORT DATE TECHNICIAN SELF-TEST READING READING LEVEL NOTES 1/16/2019 Urbanski Yes 78 93 1 Acme(2) Calhoun 1/21/2019 Urbanski Yes 75 97 1 Cherokee 1/27/2019 Urbanski Yes 76 93 1 UPS and Big Ox 2/5/2019 Urbanski Yes 77 94 1 FQT and Arriza 3/10/2019 Urbanski Yes 76 96 1 Beech Island 3/25/2019 Urbanski Yes 74 96 1 Idaho Power 4/14/2019 Urbanski Yes 78 94 1 UPS and Big Ox 5/21/2019 Urbanski Yes 74 96 1 Beech Island 6/24/2019 Urbanski Yes 77 95 1 Aiken and Easley Housing 6/25/2019 Urbanski yes 91 113 1 Greenwood 7/24/2019 Urbanski Yes 89 109 1 Ironwood 7/28/2019 Urbanski yes 78 108 1 Big ox compressor station 8/7/2019 urbanski Yes 79 96 1 Sent to Jamestown 8/20/2019 Urbanski Yes 91 114 i Return from Jamestown 9/24/2019 Urbanski Yes 82 97 1 Boise 10/21/2019 Urbanski Yes 83 94 1 UPS 10/30/2019 Urbanski Yes 86 93 1 Aiken and Easley Housing 11/19/2019 Urbanski Yes 88 93 1 Big Ox compressor station 12/26/2019 Urbanski Yes 83 108 1 Alanta UPS 12/27/2019 Urbanski Yes 89 106 1 Aiken and Easley Housing 12/30/2019 Urbanski Yes 91 99 1 Easley 1/9/2020 Urbanski Yes 103 97 1 Acme 1/10/2020 Urbanski Yes 97 94 1 Calhoun 1/20/2020 Urbanski Yes 101 92 1 Cherokee 1/31/2020 Urbanski Yes 96 93 1 Blossman 2/10/2020 Urbanski Yes 99 93 1 First Quality 2/26/2020 Urbanski Yes 103 91 1 Mt Home 2/26/2020 Urbanski Yes 103 91 1 Langley Gultch 3/18/2020 Urbanski Yes 98 91 1 Tropicana 4/19/2020 Urbanski Yes 97 94 1 Aiken 5/15/2020 Urbanski Yes 89 94 1 UPS Louisville 6/3/2020 Urbanski Yes 91 92 1 Greenwood 6/4/2020 Urbanski Yes 97 104 1 Beech Island 6/5/2020 Urbanski Yes 94 89 1 Beech Island 6/16/2020 Urbanski Yes 89 101 1 KC Jenks 9/10/2020 Urbanski Yes 95 89 1 Aiken 9/16/2020 Urbanski Yes 98 91 1 bennett mt. 11/18/2020 Urbanski Yes 83 102 1 Atlanta UPS 12/23/2020 Urbanski Yes 104 94 1 Easley Housing 1/11/2021 Urbanski Yes 93 101 1 Amce Brick NG 1/17/2021 Urbanski Yes 104 94 1 Calhoun 1/19/2021 Urbanski Yes 92 94 1 UPS Atlanta 2/11/2021 Urbanski Yes 92 88 1 KCC Beech Island 2/12/2021 Urbanski Yes 94 88 1 First Quality 2/16/7021 Urbanski Yes 98 91 1 Tropicana 2/25/2021 Urbanski Yes 91 94 1 Greenwood 2/26/2021 Urbanski Yes 100 95 1 Greenwood 3/4/2021 Urbanski Yes 89 101 1 Ironwood 3/23/2021 Urbanski Yes 94 98 1 Idaho Power- Bennett Mtn 3/23/2021 Urbanski Yes 87 93 1 Idaho Power- Langley Gulch 3/25/2021 Urbanski Yes 88 94 1 Smithfield Hog 4/5/2021 Cash McGinnis started tracking on the Heath form - kept with the instrument i ' t h v ! C f it •wr i, , - rew r.y T � .s .� � �� _fhS � Y �•, i� yam. �.y. `� � `t � C•_ 1t kt v It Page 33 of 3r