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Home My WebLink AboutN202101 NOPV Response NORTHWEST GAS PROCESSING,LLC September 23,2021 Idaho Public Utilities Commission `; s ys9: 43 Pipeline Safety Division PO Box 83720-0074 _ Boise,Idaho 83720-0074 Re: Pipeline Safety Evaluation Reference Number: #N202101 Dear Mr. Bruce Perkins: This letter is in response to the letter dated August 30,2021,alleging four probable violations on the Northwest Gas Processing,LLC's pipeline facilities,herein called NWGP. Each is discussed below. Item #1- 192.605 Periodic Review of Operator Personnel 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. NWGP agrees there is no record of a periodic review,but NWGP disagrees that it has violated 192.605. 192.605 allows the Operator to determine the appropriate time frame for a"periodic" review.Assessing relevant factors,an Operator may choose longer or shorter time frames as appropriate. In this case,the individuals operating the pipeline were qualified and trained through the Operator Qualification program in April and May of 2020. Because the initial OQ training occurred last year,NWGP believes a longer,time period is justified. During the pre-audit and audit,all three operator employees were assessed by Randy Shelton,a contractor with extensive OQ and operations knowledge. See the Form 26 attached. Because the term"periodically" does not specify a time period,NWGP believes a review performed within 15- 16 months of an initial training is appropriate.Additional reviews of operator personnel will occur periodically in the future. Item #2— 192.605—O&M Designated Form Finding: NWGP has not documented the above inspections on Form-4 as required by their O&M procedures. NWGP agrees that the O&M 9.5 states that"reports of above inspections and tests [pressure relief valves] shall be documented on Form—4 and retained..." and that the relief valve inspection was performed and documented on a form that was not the specified Form—4. A contract company performed the valve inspection as required but documented the inspection on the contract company's form,not NWGP Form—4. NWGP's O&M manual is updated to ensure there is no requirement to use a specific form and instead it references forms that may be utilized. Item#3— 192.706 Corrosion Control Records—Rectifier Readings Finding: NWGP personnel were not recording the voltmeter readings correctly as required by their O&M procedures. NWGP agrees that the records demonstrating adequate rectifier readings and corrosion protection were unclear and indicated a lack of understanding on behalf of the person taking the readings. Subsequent hands-on training for the remaining employees who will be responsible for reading rectifiers has occurred,and follow-up field verification has occurred ensuring employees can both read rectifiers and record those readings properly. Current rectifier and cathodic protection readings indicate adequate corrosion protection on NWGP facilities. Item#4— 192.63 Marking of Materials Finding: NWGP personnel could not show where this requirement is in their O&M procedures. NWGP agrees that the O&M manual did not include requirements for marking of materials in 192.63. Due to the nature of the O&M manual being tied to a contract agreement,a company memorandum is being added to the physical O&M in order to satisfy this requirement. See attached Memorandum. Thank you for your time and consideration. Sincerely, Nathan Caldwell /s/ Enclosures: (2) Form 26 Memorandum MEMORANDUM September 1, 2021 RE: Addition to NWGP O&M Manual The following is incorporated in Northwest Gas Processing, LLC's Operation& Maintenance Manual. SCOPE [§192.605(b)(1)] This addition to the Operation and Maintenance Manual is to ensure pipeline construction complies with the requirements of part 192 Subpart, B Materials. All construction must comply with provisions outlined in DOT Part 192 and API-1104, as applicable. References to API-1104 apply to the Latest Approved Edition of the document. MARKING MATERIALS [§192.63] Pipe and pipeline components, including but not limited to flanges, flange accessories, standard fittings, and tapping fittings, will be selected that will maintain the structural integrity of the pipeline under the pressure, temperature, chemical, and environmental conditions that are anticipated. The pipe and pipeline components will meet the requirements of 192 Subpart B, and must be marked to indicate size, material, manufacturer, pressure rating, and temperature rating as appropriate. For sour gas service, the material will meet NACE Standard MR-01-75 guidelines. MARKING LIMITATIONS [§192.63] Surfaces of pipe and components that are subject to stress from internal pressure may not be field die stamped, and if any item is marked by die stamping, the die must have blunt or rounded edges that will minimize stress concentrations. i FORK! 26 Periodic Review of O&M Procedures Pipeline System N W G P Requirement: 192.605(b)(8) - Periodically reviewing the work done by operator personnel to determine the effectiveness of the procedures used in normal operation and maintenance and taking corrective action where deficiencies are found. 192.605(c)(4) - Periodically reviewing the response of operator personnel to determine the effectiveness of the procedures controlling abnormal operation and taking corrective action where deficiencies are found. Ri Procedure(s) Deficiency Periodic Review Satisfa tory Found O&M Procedure Reviewed j Normal Operations ❑ yc S Abnormal El ❑ Operations Safety Related El ❑ Condition Emergency ❑ ❑ Response Method Utilized indicate the method used for the review of workperformed.) Performance in Field ❑ Mock Drill ❑ Classroom Setting [Regulatory Pre-Audit ❑ Regulatory Audit ❑ Hands On Training Zcombined with OQ Eval. ❑Other(Please Indicate) Recommended Action (Attach Addition Supporting Documentation,As Applicable) Ad1 r l/-4 4-L e-S /J Employee: Date: 7 �O�+vIS �-aa- al �-ac-ai Operations Manager: Date: 61116's FORM 26 Periodic Review of O&M Procedures Pipeline System AlyjG P Requirement: 192.605(b)(8) - Periodically reviewing the work done by operator personnel to determine the effectiveness of the procedures used in normal operation and maintenance and taking corrective action where deficiencies are found. 192.605(c)(4) - Periodically reviewing the response of operator personnel to determine the effectiveness of the procedures controlling abnormal operation and taking corrective action where deficiencies are found. " Periodic Review Procedure(s) Deficiency O&M Procedure Reviewed i Satisfactory Found Normal Operations ❑ eS Abnormal ❑ ❑ Operations Safety Related ❑ ❑ Condition Emergency ❑ ❑ Response Method Utilized Indicate the method used for the review of workperformed.) Performance in Field ❑ Mock Drill ❑ Classroom setting Regulatory Pre-Audit VdRegulatory Audit ❑ Hands On Training WCombined with OQ Eval. ❑ Other(Please Indicate) Recommended Action (Attach Addition Supporting Documentation,As Applicable) nni� ecl:t'a2 Ak o a,' oar ;� ViatL"'-S t�A4L�a hR Employee: Date: - "T NARTU N� Operations Date: Manager: Co FORM 26 Periodic Review of O&M Procedures Pipeline System lV W GP Requirement: 192.605(b)(8) - Periodically reviewing the work done by operator personnel to determine the effectiveness of the procedures used in normal operation and maintenance and taking corrective action where deficiencies are found. 192.605(c)(4) - Periodically reviewing the response of operator personnel to determine the effectiveness of the procedures controlling abnormal operation and taking corrective action where deficiencies are found. Periodic Ri Procedure(s) Deficiency Review Satisfactory Found O&M Procedure Reviewed I Normal Operations ❑ YeS Abnormal: ❑ ❑ Operations Safety Related ❑ ❑ Condition Emergency ❑ ❑ Res onse Method Utilized Indicate the method used for the review of workperformed.) Performance in Field ❑ Mock Drill ❑ Classroom Setting Regulatory Pre-Audit VRegulatory Audit ❑ Hands On Training Combined with OQ Eval. ❑ Other(Please Indicate) Recommended Action /n(Attach Addition Supporting Documentation,As Applicable) ee/�1'- �Le- ;e.2 LA L1A1e J-Ns to /Y)a A L9-A t Employee: Date: Operations Date: Manager: Cc i1,$LA L n -J 4