N201901 NOPV

Idaho Public Utilities Commission Brad Little,Govemor
PO Box 83720,Boise,ID 83720-0074 Paul Kjellander,Commissioner
Kristine Raper,Commissioner
Eric Anderson,Commissioner
November 5, 2019 #N201901
Hal Chapelle
Northwest Gas Processing
15021 Katy Frwy, Suite 400
Houston, TX 77094
Dear Mr. Chapelle:
On September 30 and October 3, 2019, the Idaho Public Utilities Commission, Pipeline Safety
Division, pursuant to Chapter 601 of Title 49, United States Code, conducted a records
inspection and field review on the natural gas pipeline facilities (System) of Northwest Gas
Processing, LLC's (NWGP) in the state of Idaho.
The inspection showed that NWGP's System in Idaho was out of compliance on certain items,
resulting in probable violation of the pipeline safety regulations at Title 49, Code of Federal
Regulations, Parts 192 and 199. See 49 CFR §190.207. The probable violations are as follows:
PROBABLE VIOLATIONS
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.
NWGP Gas Operations & Maintenance Plan, Section 7.4 Leak Detection
Surface Leakage Survey Procedure-electronic leak detection equipment may be of either the portable
(hand-carry)or mobile(mounted on vehicle)type, capable of detecting a concentration of gas in air of SO
ppm. In either case,sampling above buried facilities should be as close to the ground surface as possible
not to exceed 2 inches)[sic].
Finding:
NWGP has no records that leakage surveys with leak detector equipment have ever taken place.
11331 W. Chinden Blvd., Building 8, Suite 201-A, Boise ID 83714
Telephone: [phone], Facsimile: [phone]

2. 49 CFR §192.615(c)(1),(2),(3), and (4); Emergency Plans.
(c)Each operator shall establish and maintain liaison with appropriate fire,police, and other
public officials to:
(1)Learn the responsibility and resources of each government organization that may respond to
a gas pipeline emergency,•
(2)Acquaint the officials with the operator's ability in responding to a gas pipeline emergency,
(3)Identify the types of gas pipeline emergencies of which the operator notifies the officials,and
(4)Plan how the operator and officials can engage in mutual assistance to minimize hazards to
life or property.
49 CFR §192.616(c) Public Awareness.
The operator must follow the general program recommendations, including baseline and
supplemental requirements of API RP 116Z unless the operator provides justification in its
program or procedural manual as to why compliance with all or certain provisions of the
recommended practice is not practicable and not necessary for safety.
ADB-05-03 (05/23/2005) Planning for Coordination of Emergency Response to Pipeline
Emergencies.
See https://www.federalregister.gov/documents/2005/05/`23/05-10202/pipeline-safety-
planning-for-coordination-of-emergency-response-to-pipeline-emergencies
NWGP Gas Operations& Maintenance Plan, Section 18.6 Liaison with Public
Officials 192.615(c).
Northwest personnel(or designee) will meet(in person)at intervals not exceeding 15 months, but
at least once each calendar year with local fire,police, and other appropriate public emergency
response officials to learn the responsibility and resources of each government organization that
may respond to a hazardous liquid pipeline emergency and acquaint the officials with
Northwest's ability in responding to an emergency and means of communication. Local officials
with be provided with a copy of the Safety Data Sheets(SDS),pipeline map, emergency
notification list for Northwest and any other additional information as necessary. Liaison with
public officials can be documented on ;o,
Finding:
Although NWGP attended a Local Emergency Planning Committee meeting in Payette County on
February 22, 2018,there is no documented proof that they learned the responsibility and
resources of each government organization that may respond to a hazardous pipeline emergency
and acquaint the officials with NWGP's ability in responding to an emergency and means of
communication.
3. 49 CFR §192.706 Transmission lines: Leakage surveys.
Leakage surveys of a transmission line must be conducted at intervals not exceeding 15 months, but at
least once each calendar year. However, in the case of a transmission line which transports gas in
conformity with§192.625 without an odor or odorant, leakage surveys using leak detector equipment
must be conducted(.)
NWGP Gas Operations & Maintenance Plan, Section 7.4 Leak Detection
Surface Leakage Survey Procedure-electronic leak detection equipment may be of either the portable
(hand-carry)or mobile(mounted on vehicle)type, capable of detecting a concentration of gas in air of 50
ppm. In either case,sampling above buried facilities should be as close to the ground surface as possible
not to exceed 2 inches)[sic].
NWGP PROBABLE VIOLATIONS LETTER—PAGE 2

Finding:
NWGP stated that no leakage surveys with leak detector equipment have taken place. See also"Finding"
in Section 1 above.
4. 49 CFR §192.491(c) Corrosion control records.
Each operator shall maintain a record of each test survey, or inspection required by this subpart in
sufficient detail to demonstrate the adequacy of corrosion control measures or that a corrosive condition
does not exist. These records must be retained for at least 5 years, except that records related to§§
192.465(a)and(e)and 192.475(b)must be retained for as long as the pipeline remains in service.
Finding:
NWGP stated it was unable to locate records prior to 2018.
S. 49 CFR §192.463(b)(2) External corrosion control: Cathodic protection.
The entire buried or submerged pipeline must be cathodically protected at a cathodic potential that meets
the requirements of appendix D of this part for amphoteric metals
Finding:
On 30 September 2019 during the field portion of the inspection it was discovered that the Rectifier at
Little Willow was shut off.After inquiring why, it was determined that their CP tech had turned it off while
taking an instant off reading in August and he forgot to turn it back on.
6. 49 CFR §192.743(a) Pressure limiting and regulating stations: Capacity of relief devices.
(a) Pressure relief devices at pressure limiting stations and pressure regulating stations must have
sufficient capacity to protect the facilities to which they are connected. Except as provided
in§192.739(b), the capacity must be consistent with the pressure limits of§192.201(a). This capacity
must be determined at intervals not exceeding 15 months, but at least once each calendar year, by
testing the devices in place or by review and calculations.
Finding:
NWGP has no records that the testing of relief devices in place or by review and calculations.
REQUESTED ACTIONS
A reply to this correspondence, as outlined below, is required no later than 45 days from the date of this
letter. Please send all documents to our office at P.O. Box 83720-0074, Boise, Idaho 83720-0074. Be
advised that all material you submit in response to this enforcement action may be a public record,
subject to disclosure under Idaho's Public Records Law. See Idaho Code §§74-101 et seq.
You have a right to appear before the Pipeline Safety Division in an informal conference before
December 23, 2019, at the Commission's offices at 11331 W. Chinden Blvd, Boise. You have the right to
present relevant documents to the Pipeline Safety Division at that conference. The Pipeline Safety
Division will make available to you any evidence which indicates that you may have violated the law, and
you will have the opportunity to rebut this evidence. See IDAPA 31.01.01.21-26. If you intend to
request an informal conference, please contact the Pipeline Safety Division no later than December 9,
2019.
If you wish to dispute the allegations in this Notice, but do not want an informal conference, you may
send the Pipeline Safety Division a written reply to this notice. This written reply must be filed with the
NWGP PROBABLE VIOLATIONS LETTER—PAGE 3

Commission on or before December 23, 2019, and must be signed by a NWGP official with authority to
bind the company. The reply must include a complete statement of all relevant facts including a
complete description of the corrective action(s)taken and any and all actions to be taken to prevent
future failures in these areas of concern.
If you do not respond to this notice by December 23, 2019, you may be subject to statutory civil
penalties and further enforcement, as allowed under Idaho law. Idaho Code §61-712A states that "(ajny
person who violates or fails to comply with, or who procures, aids or abets any violation of title 61,
Idaho Code, governing safety of pipeline facilities and the transportation of gas, or of any order,
decision, rule or regulation duly issued by the Idaho public utilities commission governing the safety of
pipeline facilities and the transportation of gas, shall be subject to a civil penalty of not to exceed two
thousand dollars ($2,000) for each violation for each day that the violation persists. However, the
maximum civil penalty shall not exceed two hundred thousand dollars ($200,000) for any related series
of violation."
If you have any questions concerning this notice, please contact me at [phone]. Also all written
responses should be addressed to me at the above address or you may fax your response to (208) 334-
4045.
We appreciate your attention to this matter and your effort to promote pipeline safety.
c
Sincerely,
i /
Darren M. mer
Pipeline Safety, Program Manager
Idaho Public Utility Commission
NWGP PROBABLE VIOLATIONS LETTER—PAGE 4