HomeMy WebLinkAboutN201901 NOPV Response NORTHWEST GAS PROCESSING, LLC RECEIVED
CORPORTATE OFFICE 0 19 D C i 7 PM 2: 06
16600 Park Row
Houston,TX 77084
"T IL_I E :3 iC,01,11YIISSION
December 13, 2019
Mr. Darrin M. Ulmer
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Northwest Gas Processing, LLC (NWGP)
Pipeline Safety Division Inspection — September 30 and October 3, 2019
Dear Mr. Ulmer:
We are in receipt of your November 5, 2019 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: The inspection found that NWGP has no records that leakage surveys with
leak detector equipment have ever taken place.
NWGP Response: TEAM, Inc conducts quarterly leakage surveys with FLIR equipment
throughout our Hwy 30 facility to comply with the IDEQ air permit, but not along the
pipeline. NWGP agrees with this finding and, beginning in the first quarter of 2020, will
have The Compliance Group conduct leakage surveys in accordance with 49 CFR
192.706.
Item No 2
Requirement: 49 CFR § 192.615(c)(1),(2),(3), and (4); Emergency Plans, public liaison
49 CFR § 192.616(c); Public Awareness
Finding: Although NWGP attended a Payette County LEPC meeting on
February 22, 2018, there is no documented proof that NWGP learned the
responsibility and resources of each government organization that may
respond to a hazardous emergency, and acquaint officials with NWGP's
ability to respond.
Idaho Public Utilities Commission
December 13, 2019
Page Two
NWGP Response: Documentation was presented during the records inspection
confirming Stephen Hernandez's meeting with local officials on September 16, 2019. We
are attaching NWGP's 2019 liaison packet presented to these officials at that time.
NWGP will meet with appropriate fire, police and other emergency officials during or
before the last quarter of 2020. As discussed with Mr. Bruce Perkins on November 20,
2019, NWGP extends an invitation to IPUC to join them during these visits.
Item No 3
Requirement: 49 CFR § 192.706 Transmission Lines: Leakage Surveys
Finding: NWGP stated that no leakage surveys with leak detector equipment have
taken place.
NWGP Response: NWGP agrees with this finding and, as stated in response to Item
No. 1 above, will initiate a leakage survey program.
Item No 4
Requirement: 49 CFR § 192.491(c) Corrosion Control Records
Finding: NWGP stated it was unable to locate records prior to 2018.
NWGP Response: NWGP maintains records from April 2018 and forward.
Item No 5
Requirement: 49 CFR § 192.463(b)(2) External corrosion control: Cathodic protection
Finding: During the field inspection on September 30, 2019 it was discovered that the
Rectifier at Little Willow was shut off. The CP tech had turned it off while
taking an instant off reading and forgot to turn it back on.
NWGP Response: NWGP agrees with this finding and has re-trained personnel and has
included signage at rectifier so that it is turned back on following all readings.
Idaho Public Utilities Commission
December 13, 2019
Page Three
Item No 6
Requirement: 49 CFR § 192.743(a) Pressure limiting and regulating sessions: Capacity
of relief devices
Finding: NWGP has no records that the testing of relief devices in place or by review
and calculations.
NWGP Response: NWGP agrees with this finding.
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 281-994-5429 or dkassab@high-mesa.com if I can provide additional information.
Sincerely,
Diane M. Kassab
Regulatory Compliance Manager
Attachments