L202502 NOPV Response

LOWER YAIIFY_®
- E N E R G Y 136 N.Washington •P.O.Box 188 •Afton,WV 83110•307-885-3175•fax.[phone]
Jeff Brooks October 23, 2025
State Of Idaho —Public Utilities Commission
11331 W. Chinden Blvd. Ste 201 A
Boise Id. 83714
Subject: Crow Creek Pipeline Construction Inspection—Lower Valley Energy
Report # L202501 & L202502
Dear Mr. Brooks:
Here are the responses to the items of concern discovered during inspection of Lower Valley
Energy's Crow Creek Pipeline project, conducted Aug 25-26 & September 15 -16.
Items of Concern:
1. Both company and contractor personnel had been actively involved in Butt fusion operations
and pipeline installation. No documented procedures specific to the construction of
transmission lines were made available.
2. During pipeline staging activities, multiple lengths of fused pipe were positioned above the
Spider Plow equipment. The pipe traversed the terrain; where it encountered obstructions
including rocks and debris. One segment made direct contact with the Spider plow blade
during its decent.
3. Individuals assigned to inspect or evaluate joints in plastic piping systems must possess
documented qualifications — obtained through formal training or demonstrable experience —
specific to the joining procedure being performed. The individual who conducted
destructive testing on butt fusion joints prior to August 28 did not possess the requisite
qualifications for that procedure. The induvial was limited exclusively to socket fusion and
did not extend to butt fusions.
4. Certain individuals who had performed Butt fusions were not qualified in accordance with
the Record of Pipe Joining Qualification Test form. The premature certification of
destructive testing activities without access to the necessary equipment undermines the
credibility and regulatory validity of the qualification records in question.

5. A material discrepancy was identified within the record of pipe joining qualification test
documentation. The records indicate that destructive testing was conducted in June 2025,
however it was confirmed that the testing equipment was not available until August 2025.
6. LVE's Welding-Fusing-Manual referenced WL Plastics procedures but that has not been
included among the procedures referenced within the manual.
7. During fusion operations, pyrometers were used to verify the surface temperatures of
heating tools. These instruments lacked valid and current calibration documentation.
8. Staff found both heating plates in use during fusion operations had substantial accumulation
of plastic residue. Also, on Report#L202502
9. Section H in heat fusion procedures revealed that the manual did not include mandatory
inspection of melt surfaces for defects such as concave profiles, bubbling, or pocket-
marking prior to the joining process. Joining procedures must incorporate quality control
measures that adequately address pre join surface conditions.
Response:
LVE recognizes each item of concern. Each concern will be addressed below.
1. Procedures were updated when the Teton Village line was installed which included 4710
Section H. (Welding fusing procedures heat fusing Procedures W/F &M -H.)
The incorporation of 4710 updated in 2017 recognized the construction of transmission lines
because LVE used 4710 only as transmission. All distribution lines are yellow 2406 pipe.
Transmission was implied in our procedure when 4710 is used, however, to clarify that I
have updated the Welding and Fusing procedures and Construction Manual procedures to
clarify that 4710 is Transmission, and 2406 is Distribution. This was referenced in our
Construction manual CM-C 1 which has also been updated.
2. During the start of construction, we noticed an area of concern of pipe damage during
unloading, stringing and installing which we corrected. Due to this we trained and had an
inspector walk the line measuring all damage to the pipe. The inspector marked all areas of
concern and then Todd as a qualified inspector verified all areas of concern and cut out
anything that warranted removal. We also had our Inspector, fusers and spider plow
operators checking for any gouges or issues with the pipe prior to installation. We did cut
out over 15 areas of concern. We also contacted Pipeline Plastics who gave us guidance on
pipe damage evaluation. "In accordance with industry practice PLP recommends the
maximum allowable damage to a pipe is no more than 10%of the thickness of the wall. Due
to cuts scraps gouges or abrasions. This 10% is considered the industry's best practice as
recommended after thorough research and investigation. This number represents a
conservative recommendation based on that research." We replaced all abrasions scraps and
gouges that were 5% or more leading to a higher standard than the best practice considered
by Pipeline Plastics.
POWERFUL1 r a•.

3. The absence of any socket fusion on this project would indicate that the paperwork was
filled out incorrectly. The paperwork should have indicated Butt fusion instead of Socket
fusion. That paperwork has been filled out correctly. The individual that the paperwork was
wrong with does have 25 years of experience and was quilifed but the error in paperwork
was wrong and corrected.
4. We did use Accel fusion for fusing who had all qualification needed to perform the task.
Westwood's crews had training from ISCO prior to any fusing. The individual who had
performed Butt fusion was qualified but incorrect paperwork was filled out.
5. LVE did not have the stress test machine and had filled out the paperwork which was wrong
and will not happen again. Since we got the machine, we did catch up on all testing and
have tested as needed, on time, and filled out the paperwork correctly. Proper record keeping
is essential to showing that things are done correctly.
6. LVE's Fusing Procedure Manual and Construction Manual has been updated to reference
WL Plastics joining and field procedures and McElroy's app for fusing. It is noted at the end
of section H in the Welding and Fusing Manual Plexco's practices which include
Performance Pipe for fusing.
7. During fusing, pyrometers were being used but there were no calibration records for those
pyrometers. To correct that LVE ordered new pyrometer with the proper calibration
paperwork and used those going forward.
8. Our procedures require heating plates to be clean before fusing. This area of concern was
addressed, and all machines put on new plates which were cleaned daily and inspected by
LVE's inspector. All fuses from the Acccel fusion machines were data logged and had to
pass the test for proper documentation of a good fuse.
9. The manual did include mandatory inspection of melt surfaces for defects such as concave,
profiles, bubbling or pock marking referenced in section H under Driscoplex which is also
part of Performance Pipe. We did add clarity the end of Section H where it references
Performance Pipe with Driscoplex reference which does address surface defects.

LVE has never had a fusion failure with over 250 miles of fused pipe. However, due to some of
these concerns LVE �vjll leak survey the Crow Creek Transmission line 2 times in 2026 at our
MAOP of 125 psi to insure the safe operation of our new natural gas pipeline. Thanks for working
with Lower Valley to help us be compliant with the federal code and more effective in our
responsibilities of working safely and according to best practices. LVE is confident that we will
continue to create a safe working environment and to comply with all regulations at our facilities.
Give me a call if you have questions at 307-885-6151 or my cell at 307-248-2885. Hope you have a
nice day.
Sincerely,
C_ IZ,,
Craig Coles
Director—Gas Operations
cc: Jim Webb