DE2021 LOC Response.pdf

7/29/2021

Mr. Darrin M. Ulmer
Pipeline Safety Program Manager
Idaho Public Utility Commission
11331 W. Chinden Blvd, Building 8, Ste 201-A
Boise, Idaho, 83714

Dear Mr. Ulmer,

Dominion Energy Utah Wyoming Idaho (DEUWI) has received your letter of concern dated July 6, 2021
regarding the onsite inspection of the Integrity Management verification dig and appreciates the
opportunity to respond. Your letter stated that a non-compliance item was found and noted:

The item(s) listed below are of concern:
1. § 192.605(a) 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. For transmission lines,
the manual must also include procedures for handling abnormal operations.
This manual must be reviewed and updated by the operator at intervals not
exceeding 15 months, but at least once each calendar year. This manual must
be prepared before operations of a pipeline system commence. Appropriate
parts of the manual must be kept at locations where operations and
maintenance activities are conducted.
During the inspection it was noted that the Whitaker Construction crew employed
by DEUWI, did not have a calibrated holiday detection device (jeep) to check for
coating defects as required by DEUWI Specification 9-11-0112.5.1 Coating
Inspection "... Contractor shall ensure holiday detector is properly calibrated. "
There was no reference to calibration in SP 4-13-01 Portable Electrical Holiday
Detector Operating Procedures.
DEUWI took prompt action on the day of discovery and stopped the contractor from using the piece of
equipment in question and required them to obtain a properly calibrated unit. Additionally, DEUWI has
also taken action to reduce the likelihood of this issue reoccurring. This issue was reviewed with Whitaker
Construction and it was identified that there was a gap in their process for tracking equipment calibration.
To fill this gap, Whitaker Construction is implementing a software, B2W, to track equipment maintenance
and calibration dates. DEUWI has supplied a list of equipment requiring calibration to inspectors
observing this work and instructed them to check the calibration dates. Finally, DEUWI is implementing a
step to verify equipment calibration in the procedure.

Should you have any additional questions regarding our response and corrective actions, please contact
me directly.

Respectfully,

Steve Bursett
Supervisor Gas Operations
Dominion Energy Utah

cc:
Matt Bartol
Jeff Hansen
Reid Hess
Richard Kiser
Chris Noble
Craig Wagstaff