N201801 NOPV Response

(4pALTA MESA SERVICES, LP
15021 Katy Freeway,Suite 400
Houston,Texas 77094
[phone]
[phone] FAX
January 25, 2019
Mr. Darrin M. Ulmer
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Pipeline Safety Evaluation — Idaho Public Utilities Inspection — October 23-24, 2018
Dear Mr. Ulmer:
In response to your letter dated December 5, 2018, Northwest Gas Processing (NWGP) is respectfully
submitting this letter in response to the following alleged violations:
Item No 1
Description: The inspection showed that no records were produced when requested. NWGP stated it
was unable to locate training records maintained by a former employee.
Requirement: 49 CFR § 199.241 Training for Supervisors
49 CFR § 199.117(a)(4) Recordkeeping
NWGP Response: Records were located following the inspectioo and are included as Attachment A.
Item No 2
Description: The inspection showed that no records were produ,,,ed when requested. NWGP stated it
was unable to locate records maintained by a former employee.
Requirement: 49 CFR § 192.745(a) Valve maintenance: Transmission lines
NWGP Response: Documentation .has been located and is included as Attachment B.
Item No 3
Description: The inspection showed that no records were prudu+;_�d when requested. NWGP stated it
was unable to Iccate records i�aintained by a fo'r`'`:.` employee.
Requirement: 49 CFR § 192.465 External cu rosim ccritrols. n .;..:ring
NWGP Response: Documentation has been located and is Attachment C"

Idaho Public Utilities Commission
January 25, 2019
Page Two
Item No 4
Description: The inspection showed that no records were produced when requested. NWGP stated it
was unable to locate records maintained by a former employee.
Requirement: 49 CFR § 192.481(a) Atmospheric corrosion control: Monitoring
NWGP Response: Documentation from the Atmospheric Corrosion Survey is Attachment D.
Item No 5
Description: The inspection showed that no records were produced when requested. NWGP stated it
was unable to locate records maintained by a for.-no,employee.
Requirement: 49 CFR § 192.605(a) Procedural manual f; operations, maintenance, and
emergencies.
NWGP Gas Operations & Maintenance Plan, Sec::,' -,, 4.1 Location of Records.
NWGP Response: Operations and Maintenance Manual Review Revision Log included as Attachment
E.
Item No 6
Description: In the NWGP, LLC. Public Awareness Program PAP) dated 1 May, 2018 (hereinafter
the NWGP PAP) Section 5.2 Third-Party Venders Used to Identify Stakeholders was
missing information. The contact/address lists for the Northwest Stakeholder Audiences
was not included in the PAP. See Question 4 on PHMSA Form 21).
Requirement: 49 CFR § 192.616(d),(e), and (f) Public Awareness.
NWGP Response:Audience Identification Records included as Attachment F with this letter.
Item No 7
Description: In the NWGP PAP dated 1 May, 2018, Section 5.4 Affected Public, and Section 5.7
Excavators, no Public Awareness & Damage Prevention Record keeping Reports were
included. Therefore, the inspection could not validate that Audience Identification
Records exist. See Question 5 on PHMSA Form 21.
Requirement:49 CFR § 192.616(d),(e), and(f) Public Awareness (as referenced above in Probable Violation 6)
NWGP Response:Audience Identification Records included as Attachment F with this letter.

Idaho Public Utilities Commission
January 25, 2019
Page Three
Item No 8
Description: 8.1. Documentation of direct mailings that should include maps showing the "could
affect" zone as well as a listing of each person's name and address that was targeted.
No evidence of this documentation was provided during the inspection.
8.2. Face to face meetings should include name, address and signature for each person
met with, the topics of discussion and any material they have requested. No evidence of
this documentation was provided during the inspection.
8.3. Documentation should include copies of all business reply cards received as well as
contact address & personnel changes on the Stakeholder listing. No evidence of this
documentation was provided during the inspection.
8.4. No evidence of the address/contact list fer mail distribution, and proof of mail
distribution to the Stakeholders was provided during the inspection. Additionally, the
invitation list, attendance list and proof of invitation mailings to the Emergency Officials
and Public Officials were not included in the PAP. See Question 10 on PHMSA Form 21.
Requirement:49 CFR § 192.616(c) Public Awareness.
API RP 1162 Table 2-1.
API RP 1162 Table 2-3.
NWGP Response: The project was completed by an employee who is no longer with NWGP and
most of the records from this project were misplaced in the transition. A record from a community
meeting with officials is included as Attachment G. NWGP was represented by Ronda Louderman. The
discussion is summarized in the attachment. Face to Face Liaison will be completed by NWGP by
March 30, 2019.
Item No 9
Description: Section 6.4, Liaison with Emergency Officials, of the NWGP PAP requires information
describing the ongoing relationship between the operator and local emergency response
officials in order to help prevent incidents and assure preparedness in emergencies. This
information was not included in the NWGP PAP. See Question 11 on PHMSA Form 21.
Further the NWGP PAP does not show the establishment or maintaining of a liaison with
appropriate fire, police and other public officials. See Question 11 on PHMSA Form 21.
Requirement:49 CFR § 192 Procedural manual for operations, maintenance, and emergencies.
49 CFR § 192(c)(1),(2),(3), and (4); Emergency Plans
49 CFR § 192(c) Public Awareness.
NWGP Response: In February 2018 a meeting was held with appropriate fire, police and other public
officials as required by 49 CFR 192. The project was completed by an employee who is no longer with
NWGP and most of the records from this project were misplaced in the transition. A record from a
community meeting with officials is included as Attachment G. NWGP was represented by Ronda

Idaho Public Utilities Commission
January 25, 2019
Page Four
Louderman. The discussion is summarized in the attachment. Face to Face Liaison is scheduled to be
completed by NWGP by March 30, 2019.
Item No 10
Description: Section 9.13, of the NWGP PAP, Measuring Program Implementation & Effectiveness,
should show the annual audit/review and which of the three alternative methodologies
was used in completing the audit/review. See Question 16 on PHMSA Form 21.
Requirement: 49 CFR § 192.GIG(c) Public Awareness, as stated above in Probable Violation 10. 49
CFR § 192.616(i) Public Awareness.
API RP 1162 8.3 Measuring Program Implementation.
NWGP Response: The 2015-2018 Annual Evaluation has been completed by using number 2 from
Section 9.13 Alternative Methodologies. Third-Party audits where the evaluation is undertaken by a
third-party engaged to conduct an assessment and provide recommendations for improving the
program design or implementation. Attachment H
Item No 11
Description: Section 9.13 of the NWGP PAP, Measuring Program Implementation & Effectiveness,
requires Forms 10.8-10.11- effectiveness questionnaires from all stakeholders used to
measure program effectiveness. NWGP did not provide evidence of these records
during the inspection. See Question 18 on PHMSA Form 21.
Requirement:49 CFR § 192.616(c) Public Awareness. (as referenced above in Probable Violation 10.
API RP 1162 8.4 Measuring Program Effectiveness.
NWGP Response: The 2015-2018 Effectiveness Evaluation has been completed by using number 2
from Section 9.13 Alternative Methodologies. Third-Party audits where the evaluation is undertaken by
a third-party engaged to conduct an assessment and provide recommendations for improving the
program design or implementation. Attachment l I
Item No 12
Description: Examples and evidence of all the measures taken under Section 9 of the NWGP PAP,
Implementation of Program Measure 1, were not provided during the inspection. See
Question 19 on PHMSA Form 21.
Requirement: 49 CFR § 192.616(c) Public Awareness, as referenced above Probable Violation 10.
API RP 1162 8.4.1 Measure 1-Outreach: Percentage of Each Intended Audience
Reached with Desired Messages
NWGP Response: Feedback information from the Response Cards can be located in the 2015-2018
Effectiveness Evaluation attached. Attachment 11

Idaho Public Utilities Commission
January 25, 2019
Page Five
Item No 13
Description: No evidence was provided that NWGP PAP Forms 10.8-10.11 were sent out and
returned in reference to Pre-test materials/Survey target stakeholder audiences.
Additionally, examples of items mentioned in API RP 1162 dated December 2003
Appendix E: Additional Guidelines for Undertaking Evaluations that have been used to
measure the understandability of
message content were not provided. See Question 20 on PHMSA Form 21.
Requirement: 49 CFR § 192.616(c) Public Awareness as referenced above. API RP 1162 8.4.2
Measure 2-Understandability of the Content of the Message.
NWGP Response: Pre-test materials/Survey documentation is included as Attachment 1.
Item No 14
Description: No proof or evidence of changes or modifications to the program based on results and
findings of the program effectiveness evaluations were provided as a result of the
inspection. See Questions 23 on PHMSA Form 21.
Requirement: 49 CFR § 192.GIG(c) Public Awareness as referenced above in Probable Violation 10.
API RP 1162 8.5 Summary of Baseline Evaluation Program.
NWGP Response: Supplemental Enhancements are outlined in the 4 year Effectiveness Evaluation
Attachment H. To our knowledge there have been zero near hits or misses. In the event of a near hit
or miss it would be tracked electronically for future retention and evaluation.
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 281-943-5581 or
[e-mail] if you have any questions or require additional information.
Sincerely,
Diane M. Kassab
Regulatory Compliance Manager
Attachments