N202001 LOC

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Idaho Public Utilities Commission BragL ,Governor
Po Box 83720.Boise,ID 83720 0074 - Pant Kjllai�ier;"Commissioner,
Kristine Raper,Commissioner
Eric Anderson,Commissioner
Letter of Concern
March 23, 2020 Report# N202001
Nathan Caldwell
Northwest Gas Processing
Weiser Brown Operating
117 E. Calhoun St. (box 500)
Magnolia, AR 71753
Dear Mr. Caldwell:
On February 14 and 28, 2020, representatives of the Idaho Public Utilities Commission, Pipeline
Safety, pursuant to Chapter 601 of Title 49, United States Code, conducted an onsite
construction inspection of the Harmon Pipeline project#1 located in Payette, Idaho.
As a result of the inspection, it appears there are area(s) of concern that do not fully meet the
intent of the pipeline safety regulations Title 49, Code of Federal Regulations, Part 192 for
calendar year 2020.
The item(s) listed below are of concern:
1. § 192.605(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.manua! ,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.
During the inspection it was noted that Performance Energy, a welding crew employed by
Northwest Gas Processing using Procedure PES-API-PQR-001 were not checking the preheat
temperature at the weld groove and weld area as required by Northwest Gas Processing
Operations and Maintenance Manual procedure 16.8 Preheat and Post Heat.
11331 W.Chinden Blvd.,Building 8,Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

The above mentioned items were brought to the attention of your representatives during the
onsite inspections. We would request that you review these matters and respond in writing
within 30 days regarding the above issue including any planned corrective actions.
If you have any questions concerning this notice, please contact me at [phone]. All
written responses should be addressed to me at: 11311 W Chinden Blvd, Ste 201-A, Boise,
Idaho 83714 or you can fax your response to [phone].
Because of the good faith that you have exhibited up to this time, we expect that you will take
action to bring your program into compliance with pipeline safety regulations.
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sinc ely,
Darrin M. r
Pipeline Safety, Program Manager
Idaho Public Utility Commission
NWGP SOP 'LETTER OF CONCERN — PAGE 2