N202002 NOPV Response

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Northwest Gas Processing (NWGP
117 E. Calhoun St. (box 500)
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Magnolia, AR 71753 µ "
870.234.3080
Attention Mr. Darrin Ulmer and Bruce Perkins
Idaho Public Utilities Commission
11331 W. Chinden Blvd, Bldg 8, Suite 201-A
Boise, ID 83714-1021
Subject: Response to Probable Violations July 14, 2020
Hello Bruce and Darrin,
Enclosed/Attached please find response to your recently delivered Probable Violations. As we've
discussed, due to the recent Bankruptcy filing of the previous operator of the subject line, we've had
encountered issues in attempting to retrieve some of the requested data.
However, we have, and or are in the process of testing to ensure the subject issues have been addressed
to ensure safety, and furthermore have every intention of maintaining compliance moving forward as
the managing member of NWGP, it's facilities and gathering lines.
We appreciate your time working with us through this transition, and please do not hesitate to contact
myself or Mr. Stephen Hernandez with The Compliance Group whom is helping us resolve and bring to
date these issues.
Truly yours
Nate Caldwell

July 13, 2020
Mr. Darrin M. Ulmer
Pipeline Safety, Program Manager
Idaho Public Utility Commission
Subject: Plan of Correction
Report# N202002
Dear Mr. Ulmer—
Northwest Gas Processing (NWGP) is submitting this letter to your office to update the
Idaho Public Utility Commission's Pipeline Safety Division on NWGP's progress for
resolution of the alleged violations from report number N202002.
Item No 1
Description: §195.605(a) Procedural manual for operations, maintenance,
and emergencies.
Finding: NWGP has no evidence of readings at test points or casings
occurred in 2019, other than rectifiers.
NWGP cannot locate the cathodic protection test point readings
NWGP in 2019. Test point readings were taken in March of 2020. There
Response: were no indications of inadequate cathodic protection during this
inspection.
Item No 2
Description: §195.743(a) Pressure limiting and regulating stations: Capacity
of relief devices.
Finding: NWGP has no records that the testing of relief devices in place
or by review and calculations.
NWGP does not have any relief devices on this pipeline. The
pipeline is protected by pressure switches and shut down valves.
NWGP Reviewing the capacity of the safety devices is not relevant for
Response: this system.
Item No 3
Description: §195.615(b)(2) Emergency Plans
Finding: NWGP has no records that this training has taken place
NWGP NWGP will conduct an emergency training and table top or drill
Response: in 2020.

Item No 4
Description: §195.709(c) Transmission Lines: Record Keeping
NWGP has no records / evidence of Cathodic Protection
Finding: readings at test points or casings occurred in 2019, other than
rectifiers.
NWGP cannot locate the cathodic protection test point readings
NWGP in 2019. Test point readings were taken in March of 2020. There
Response: were no indications of inadequate cathodic protection during this
inspection.
NWGP is committed to full compliance with the Administrations rules and appreciates
your consideration in this matter.
Sincerely,
Nathan Caldwell
Operations Manager
Northwest Gas Processing