D202202 LOC Response.pdf

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11/18/2022

Mr. Jeff Brooks
Pipeline Safety, Program Manager
Idaho Division of Public Utilities
11331 W Chinden Blvd
Boise, ID 83714

Dear Mr. Brooks,

Dominion Energy Idaho (DEI) has received your Letter of Concern dated October 26, 2022, regarding the
joint procedures audit and appreciates the opportunity to respond. Your letter stated that the following
items of concern were found and noted along with DEI’s response:
1. 49 CFR § 192.619 Maximum allowable operating pressure: Steel or plastic pipelines.
(a) No person may operate a segment of steel or plastic pipeline at a pressure that exceeds a
maximum allowable operating pressure (MAOP) determined under paragraph (c), (d), or (e) of
this section, or the lowest of the following:
Finding(s): Unable to locate this code requirement in DEUWI procedures where it covers plastic
pipelines.
DEI Response:
DEI has incorporated the following language in DEUWI Standard Practice 1-97-04; “Determining
Maximum Allowable Operating Pressure (MAOP) for Plastic or Steel Pipelines”, section 4.1. Please find
attached an updated copy for your records.
4.1. No person may operate a segment of steel or plastic pipeline at a pressure that exceeds an
established maximum allowable operating pressure (MAOP) or the lowest of the following
contained in 6.5.2. (a) and (b).

 2. 49 CFR § 192.747 Valve maintenance: Distribution systems.

(b) Each operator must take prompt remedial action to correct any valve found inoperable,
unless the operator designates an alternative valve.

Finding(s): DEUWI Standard Operating Procedure (SOP) 8.5 states. "Should any emergency
valve be found inoperable document on DOT Valve Inspection Report that remedial action
(RA) is required and return DOT Valve Inspection Report to Central DOT File where a RA
report shall be generated and assigned to the appropriate individual". This procedure does
not require that the operator must take prompt remedial action.

DEI Response:

In DEUWI Standard Practice 3-25-01; “Valve Inspection and Maintenance”, subsequent to section 8.5.,
entitled Note, it states:
“High Pressure Engineering or Operations Engineering shall identify a temporary isolation valve if
valve cannot be repaired in a timely manner.”
Mr. Jeff Brooks P a g e | 2 November 18, 2022

The word “timely” as defined in the Free Dictionary depicts “done or occurring sufficiently early; prompt”.
DEI believes the language currently depicted, captures the intent of the code requirement as stated.

3. 49 CFR § 192.605 Procedural manual for operations, maintenance, and emergencies.
(b) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following, if applicable, to provide safety during
maintenance and operations. (3) Making construction records, maps, and operating history
available to appropriate operating personnel.

Finding(s): 49 CFR § 192.605 (c) states "Making construction records, maps, and operating
history available to appropriate operating personnel". Unable to locate this code requirement in
DEUWI procedures.

DEI Response:

Please reference the following language located in Appendix G section 1.1. of DEUWI’s Emergency Plan:

“1.1. Make construction records, maps and operating history available to appropriate operating
personnel….”

4. 49 CFR § 192.16 Customer notification.
(c) Each operator shall notify each customer not later than August 14, 1996, or 90 days after the
customer first receives gas at a particular location, whichever is later. However, operators of
master meter systems may continuously post a general notice in a prominent location frequented
by customers.

Finding(s): Unable to locate this code requirement in DEUWI procedures.

DEI Response:

Although DEI has a process that ensures new customers receive the required notification within 90 days,
generally during the first billing cycle, DEI agrees it is not readily identifiable in DEUWI procedures. DEI
will draft a new, dedicated standard practice that will include the overall process regarding customer
notification, encompassing the language noted above. DEI will provide the standard in Q1 of 2023 for
your records.

Should you have any additional questions regarding our response and corrective actions, please contact
Steve Bursett, Supervisor, Pipeline Compliance, 801-324-3697.

Respectfully,

Steven Ridge
VP & General Manager, Western Distribution
Dominion Energy Idaho

Attachment: Standard Practice 1-97-04 (updated)

Mr. Jeff Brooks P a g e | 3 November 18, 2022

cc:
State of Idaho (OPS):
Matt Galli
Bruce Perkins

DEUWI:
Matt Bartol
Steve Bursett
Jeff Hansen
Reid Hess