N202101 NOPV

Idaho Public Utilities Commission Brad Little,Governor
PO Box 83720,Boise,ID 83720-0074 Paul Kiellander,Commissioner
Kristine Raper,Commissioner
Eric Anderson,Commissioner
August 30, 2021 #N202101
Nathan Caldwell
Northwest Gas Processing
Weiser Brown Operating
117 E. Calhoun St. (Box 500)
Magnolia, AR 71753
Dear Mr. Caldwell:
On August 23-25, 2021, the Idaho Public Utilities Commission, Pipeline Safety Division, pursuant
to Chapter 601 of Title 49, United States Code, conducted a records inspection and field review
on the natural gas pipeline facilities (System) of Northwest Gas Processing, LLC's (NWGP) in the
state of Idaho.
The inspection found that NWGP's System in Idaho was out of compliance on certain items,
resulting in probable violation of the pipeline safety regulations at Title 49, Code of Federal
Regulations, Parts 192. See 49 CFR §190.207. The probable violations are as follows:
PROBABLE VIOLATIONS
1. 49 CFR §192.605; Procedural manual for operations, maintenance, and
emergencies.
(b)Maintenance and normal operations. The manual required by paragraph(a)of this section
must include procedures for the following, if applicable, to provide safety during maintenance
and operations.
(8) Periodically reviewing the work done by operator personnel to determine the effectiveness,
and adequacy of the procedures used in normal operation and maintenance and modifying the
procedures when deficiencies are found.
NWGP Gas Operations& Maintenance Plan, Section 1.9 Review of Personnel
Performance 192.605 (b) (8)(c)(4)
Northwest will periodically review the performance of normal operations& maintenance procedures
conducted by Northwest personnel and/or contractors to determine the effectiveness of the procedures. If
applicable, their response to abnormal operations,safety related conditions, and emergencies will also be
reviewed. If any deficiencies are identified corrective action will be taken immediately
11331 W. Chinden Blvd., Building 8, Suite 201-A, Boise ID 83714
Telephone: [phone], Facsimile: [phone]

Periodically:Recommended in combination with Operator Qualification evaluations, after the occurrence
of any AOC,SRC, or emergency, and anytime significant procedures within this manual are changed. The
reviewer shall utilize a minimum of one(1)site specific procedure and utilize any of the methods listed
below to conduct the review: •Observing performance of the procedure •Conducting a mock drill•
Individual or group "classroom"training • Tabletop discussion •Regulatory pre-audits • During regulatory
agency audits •Review of operations& maintenance documentation •In combination with OQ
evaluations • Other methods that prove to be effective
Form-26 can be used to document this review. However, depending on which method from above is
utilized,an alternate documentation method may be more logical(e.g., OQ records, audit checklist,
training log, etc.)Modifications to procedures shall be made as appropriate and a Management of Change
(MOC)shall be documented and distributed to all applicable personnel in accordance with the internal
Northwest MOC process.
Finding:
NWGP has no record of periodic reviews done by operator personnel of normal
operations & maintenance procedures to determine the effectiveness of the
procedures or that they are being documented on a Form 26 or alternate
method as required by their O&M procedures.
2. 49 CFR§192.605; Procedural manual for operations, maintenance, and
emergencies.
(a)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.
NWGP Gas Operations& Maintenance Plan, Section 9.5 Pressure Relief&
Limiting Device Design 192.199, .201
General Procedures
Each pressure relief or regulating device will be designed and sized to ensure that it has sufficient
capacity to relieve the system from overpressuring.
Special attention will be given to compressor stations and other stations where the failure of any
equipment could cause abnormal flows resulting in pressure build up. The design of these devices
will be made for each system based on individual operating conditions.
A part of daily maintenance shall include insuring that all pressure relief devices are protected
from accumulation of dirt, moisture, etc. that may hinder operation.
All pressure relief valves shall be checked for pressure setting and operability in accordance with
49 CFR 192.Any malfunction detected shall be cause for immediate replacement or repairs. If it is
not practical to test a relief valve in place, it shall be replaced with one that has been set and
tested at off-site facilities.
Reports of above inspections and tests shall be documented on Form—4 and retained in the
operations file
NWGP RECORD AND FIELD PROBABLE VIOLATIONS LETTER—PAGE 2

Findin :
NWGP has not documented the above inspections on Form-4 as required by their 0&M
procedures.
3. 49 CFR§192.706 Corrosion Control Records.
(a)Each operator shall maintain records or maps to show the location of cathodically protected
piping, cathodic protection facilities, galvanic anodes, and neighboring structures bonded to the
cathodic protection system. Records or maps showing a stated number of anodes, installed in a
stated manner or spacing, need not show specific distances to each buried anode.
(b)Each record or map required by paragraph(a)of this section must be retained for as long as
the pipeline remains in service.
(c)Each operator shall maintain a record of each test,survey, or inspection required by this
subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or that a
corrosive condition does not exist. These records must be retained for at least 5 years, except that
records related to§§192.465(a)and(e)and 192.475(b)must be retained for as long as the
pipeline remains in service.
NWGP Gas Operations& Maintenance Plan, Section 10.7 Rectifier Inspections
192.45 b
Meter reading procedures-After the rectifier unit has been visually inspected, the rectifier's output(volts
and amperes)must then be measured and recorded on the Rectifier Inspection Form.All rectifier readings
must be taken using an approved multimeter to verify the rectifier's meter readings and/or to adjust the
output
Findinpu
NWGP personnel were not recording the voltmeter readings correctly as required by
their O&M procedures.
4. 49 CFR§192.63 Marking of materials.
(a)Except as provided in paragraph(d)and(e)of this section, each valve,fitting, length of pipe, and other
component must be marked as prescribed in the specification or standard to which it was manufactured.
(b)Surfaces of pipe and components that are subject to stress from internal pressure may not be field die
stamped.
(c)If any item is marked by die stamping, the die must have blunt or rounded edges that will minimize
stress concentrations.
(d)Paragraph(a)of this section does not apply to items manufactured before November 12, 1970, that
meet all of the following:
(1)The item is identifiable as to type, manufacturer, and model.
(2)Specifications or standards giving pressure, temperature, and other appropriate criteria for the use of
items are readily available.
Finding:
NWGP personnel could not show where this requirement is in their 0&M procedures.
NWGP RECORD AND FIELD PROBABLE VIOLATIONS LETTER—PAGE 3

REQUESTED ACTIONS
A reply to this correspondence, as outlined below, is required no later than 45 days from the date of this
letter. Please send all documents to our office at P.O. Box 83720-0074, Boise, Idaho 83720-0074. Be
advised that all material you submit in response to this enforcement action may be a public record,
subject to disclosure under Idaho's Public Records Law. See Idaho Code §§74-101 et seq.
You have a right to appear before the Pipeline Safety Division in an informal conference before October
14, 2021, at the Commission's offices at 11331 W. Chinden Blvd, Boise. You have the right to present
relevant documents 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's order#35095, available on the PUC
website: www.puc.id.us. If you intend to request an informal conference, please contact the Pipeline
Safety Division no later than October 1, 2021.
If you wish to dispute 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 October 14, 2021 and must be signed by a NWGP official with authority to
bind the company. The reply must include a complete statement of all relevant facts including a
complete description of the corrective action(s)taken and any and all actions to be taken to prevent
future failures in these areas of concern.
If you do not respond to this notice by October 14, 2021,you may be subject to statutory civil penalties
and further enforcement, as allowed under Idaho law. Idaho Code §61-712A states that"[a]ny person
who violates or fails to comply with, or who procures, aids or abets any violation of title 61, Idaho Code,
governing safety of pipeline facilities and the transportation of gas, or of any order, decision, rule or
regulation duly issued by the Idaho public utilities commission governing the safety of pipeline facilities
and the transportation of gas, shall be subject to a civil penalty of not to exceed two thousand dollars
($2,000)for each violation for each day that the violation persists. However,the maximum civil penalty
shall not exceed two hundred thousand dollars ($200,000)for any related series of violation."
If you have any questions concerning this notice, please contact me at(208) 334-0321. Also, all written
responses should be addressed to me at the above address,or you may fax your response to (208) 334-
4045.
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sinc ly,
A
Darrin M. Ulmer
Pipeline Safety, Program Manager
Idaho Public Utility Commission
NWGP RECORD AND FIELD PROBABLE VIOLATIONS LETTER—PAGE 4