N202003 NOPV

Idaho Public Utilities Commission Brad Utde,Govemor
PO Box 83720,Boise,ID 83720-0074 Paul KJeltander,Commissioner
Kristine Raper,Commissioner
Eric Anderson,Commissioner
Letter of Concern
15 Oct, 2020 Report# N202003
Nathan Caldwell
Northwest Gas Processing
Weiser Brown Operating
117 E. Calhoun St. (box 500)
Magnolia, AR 71753
Dear Mr. Caldwell:
On 1 Oct 2020, representatives of the Idaho Public Utilities Commission, Pipeline Safety,
pursuant to Chapter 601 of Title 49, United States Code, conducted an onsite specialized field
inspection in your Payette Idaho District.
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. 49 CFR§192.605 (a) Procedural manual for operations, maintenance, and
emergencies.
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.
2. Northwest Gas Processing, LLC Gas Operations & Maintenance Plan (Sec 11.1).
11.1 Valve Security-reads: To prevent unauthorized operation, lock all emergency
valves that control gas flow, excluding valves protected by some other positive
type of security, such as those located within: 1. A 24-hour manned plant or
facility, 2. A manned or fenced (locked) plant or facility. 3. A manned or locked
buiding or house.) Refer to section 6.
Valve sites 1, 2, 3, 4 and Fallon well-head are not locked to prevent unauthorized operation.
11331 W.Chinden Blvd.,Building 8,Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

3. Northwest Gas Processing, LLC Gas Operations & Maintenance Plan (Sec 8.3).
8.3 Continuing Surveillance-reads: The periodic inspections, patrols, surveys, etc.
prescribed in this manual will be supplemented by routine surveillance and awareness
by Northwest field personnel and/or contractors. Particular attention will be focused on
physical conditions on or near a pipeline, including the following: (3) Condition of right
of way and surface installations-indications of leaks; excessive vegetation;
encroachment by others; cave-ins or ditch settling; warning signs; vent pipes;fences
and gates; paint deterioration.
Valve sites 1, 2, 3, 4, 155, 285, 261 and Fallon well-head all had excess vegetation that needs to
be removed and continually monitored. Additionally valve sites 65 and 326 need to have
carsonite markers replaced/repaired and new identification stickers installed.
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,
arrin M.*Ue
Pipeline Safety, Program Manager
Idaho Public Utility Commission
IGC IDAHO FALLS FIELD AUDIT LETTER OF CONCERN-PAGE 2