N202003 NOPV Response

December 22, 2020
Mr. Darrin M. Ulmer
Idaho Public Utilities Commission
11331 W Chinden Blvd., Building 8 Suite 201-A
Boise I D 83714
Re: Northwest Gas Processing, LLC (NWGP)
Pipeline Safety Division Inspection —October 1, 2020
Dear Mr. Ulmer:
We are in receipt of your October 15, 2020 letter and respectfully submit the following response to the
Probable Violations:
Item No 1
Requirement: 49 CFR § 192.605(a) Procedural manual for operations, maintenance and emergencies
Finding: General. Each operator shall prepare and follow for the pipeline, a manual of written
procedures for conducting operations and maintenance activities and for emergency
response.
NWGP Response: The findings and corrective actions for Item Number 1 are detailed in Item Number
2 and Item Number 3 below.
Item No 2
Requirement: 49 CFR § 192.605(a) Procedural manual for operations, maintenance and emergencies
Finding: 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 building or house.) Refer to
section 6.
Valve sites 1, 2, 3, 4 and Fallon well-head are not locked to prevent unauthorized
operation.
NWGP Response: All valve sites mentioned above have been locked to prevent unauthorized
operation. This was done by either placing a pad lock or combination lock on the valve itself or on the
fencing that secures the valve site.'
20201222 NWGP Idaho PUC LOC Response 1 of 2

Item No 3
Requirement: 49 CFR § 192.605(a) Procedural manual for operations, maintenance and emergencies
Finding: Northwest Gas Processing, LLC 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.
Valves 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.
NWGP Response: The vegetation at the valve sites mentioned above has been removed. In the
spring of 2021, Northwest Gas Processing will spray the weeds with an herbicide and monitor to ensure
the vegetation stays at an acceptable height.
Northwest Gas Processing is committed to full compliance with the Idaho Public Utilities Commission's
rules and appreciates your consideration in this matter. Please contact me at 870-234-3080 or
[e-mail] if I can provide additional information.
Sincerely,
��Q�
Nathan Caldwell
Operations Manager
NWGP