DP202301 NOPV Response

DOUCLAS
PIPELINE COMPANY
November 3, 2023
Mr. Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utility Commission
P.O. Box 83720-0074
Boise, Idaho 83720-0074
Dear Mr. Brooks:
Thank you for your audit of Douglas Pipeline Company's field procedures at the Idaho Power
Bennett Mountain facility. This letter is in response to the Notice of Probable Violation dated
October 2, 2023:
PROBABLE VIOLATIONS
During an annual field equipment inspection on the Bennett Mountain Power Plant
transmission pipeline in Mountain Home, Idaho, staff identified there were insufficient
voltage readings at locations 2 and 3. A negative voltage of at least -0.85 volts was not
achieved with the results at Station 2: (Route 20 at Veterinarian Way; Station 9+38)
being-0.782 and at Station 3: (Veterinarian Way and Route 20; Station 11+08)the reading
was -0.63 7.
Cash McGinnis completed an "Abnormal Operating Condition" report for the deficient pipe-to-
soil readings found at two of the CP test stations on September 26, 2023. Idaho Power's
pipeline at the Bennett Mountain Power Plant receives current for its cathodic protection from
the Williams Northwest Pipeline via a bond at their interconnect. Cash and I consulted with the
Steele Cathodic representatives who were already on site for an integrity direct assessment.
They advised that we increase the Williams bond output, add water to the soil near the test
station, and repeat the pipe-to-soil potential measurements. After a week of wagging the bond
output and measuring pipe-to-soil, the readings got closer to -0.85V for a day and then started
to increase again (becoming less negative).
Steele Cathodic suggested that we contact Williams Northwest's local technician to see if they
were having CP deficiencies and/or doing work on their CP system. Williams confirmed that
they are in the middle of updating their system to correct similar issues, thus causing irregular
current flow to the Idaho Power Pipeline. Upon learning this, Steele Cathodic recommended
remedial procedures as presented in the remainder of this letter.
901 Castle Shannon Blvd. • Pittsburgh, Pennsylvania • 15234
Telephone: [phone] www.douglaspipeline.com

D O U GLAS
PIPELINE COMPANY
Douglas Pipeline provided a quote to Idaho Power for Steele Cathodic to install a sacrificial
magnesium anode at each of the test stations along the pipeline to restore adequate cathodic
protection to the pipeline in accordance with 49 CFR 192.463: "External Corrosion Control: Cathodic
Protection,"
(a) Each cathodic protection system required by this subpart must provide a level of cathodic
protection that complies with one or more of the applicable criteria contained in appendix D of
this part. If none of these criteria is applicable, the cathodic protection system must provide a
level of cathodic protection at least equal to that provided by compliance with one or more of
these criteria.
After the anodes are installed, Douglas Pipeline will disconnect the bond from Williams in order
to preserve the life of the anodes and protect only the Bennett Mountain Pipeline. Whenever the
time arrives that Williams has resolved their CP issues (they did not give a timeframe for
completion), we will reconnect our bond and disconnect the magnesium anodes from the test
stations. The anodes will remain buried and ready to reconnect in the event that Williams has
another issue in the future.
On September 28, 2023, 1 notified Russ Stamps, the regional operations manager of Idaho
Power, of the condition that was found. He asked me to keep him posted with our progress and
plan. The Steele Cathodic proposal was issued to Douglas Pipeline Company on October 10,
2023, and Russ Stamps approved the proposal and procedure on November 2, 2023. The
installation will occur as soon as possible in spring of 2024, and must be completed by July 15'
in order to meet the remediation time-frame criteria in 49 CFR 192.465(d):
49 CFR 192.465: External Corrosion Control: Monitoring and Remediation
(a) Each pipeline that is under cathodic protection must be tested at least once each
calendar year, but with intervals not exceeding 15 months, to determine whether the
cathodic protection meets the requirements of 192.463. However, if tests at those
intervals are impractical for separately protected short sections of mains or transmission
lines, not in excess of 100 feet (30 meters), or separately protected service lines, these
pipelines may be surveyed on a sampling basis. At least 10 percent of these protected
structures, distributed over the entire system must be surveyed each calendar year, with
a different 10 percent checked each subsequent year, so that the entire system is tested
in each 10—year period.
(b) Cathodic protection rectifiers and impressed current power sources must be
periodically inspected as follows:
(2) After January 1, 2022, each remotely inspected rectifier must be physically inspected
for continued safe and reliable operation at least once each calendar year, but with
intervals not exceeding 15 months.
(c) Each reverse current switch, each diode, and each interference bond whose failure
would jeopardize structure protection must be electrically checked for proper
performance six times each calendar year, but with intervals not exceeding 2-W
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D O U GLAS
PIPELINE COMPANY
months. Each other interference bond must be checked at least once each calendar
year, but with intervals not exceeding 15 months.
(d) Each operator must promptly correct any deficiencies indicated by the inspection and
testing required by paragraphs (a) through (c) of this section. For onshore gas
transmission pipelines, each operator must develop a remedial action plan and apply for
any necessary permits within 6 months of completing the inspection or testing that
identified the deficiency. Remedial action must be completed promptly, but no later than
the earliest of the following: prior to the next inspection or test interval required by this
section; within 1 year, not to exceed 15 months, of the inspection or test that identified
the deficiency; or as soon as practicable, not to exceed 6 months, after obtaining any
necessary permits.
(f)An operator must determine the extent of the area with inadequate cathodic
protection for onshore gas transmission pipelines where any annual test station reading
(pipe-to-soil potential measurement) indicates cathodic protection levels below the
required levels in appendix D to this part.
As a result of the AOC review and the plan that has been put into place by Douglas Pipeline
Company, Idaho Power, and Steele Cathodic, Douglas Pipeline Company will update the
cathodic protection monitoring procedures in Idaho Power Bennett Mountain Operations and
Maintenance Manual prior to the 41" quarter 2023 right-of-way patrol to include quarterly
documentation of pipe-to-soil readings at all stations. This update will occur on Friday
November 3, 2023:
Douglas Pipeline Company Operations and Maintenance Manual for Idaho Power
Bennett Mountain- Revision 14-1, Section 8.7: External Corrosion Control:
Monitoring and Remediation
Performance of the CP system will be monitored by DPC regularly with pipe-to-soil
readings recorded quarterly, and an on-off survey to be performed at least once per
calendar year at intervals not to exceed 15 months. The criteria used for the pipeline will
be a negative voltage reading of at least -0.85 volts, with reference to a saturated
copper-copper sulfate half-cell.
New procedure effective November 3, 2023:
In September of 2023, there were deficient pipe-to-soil readings at two of the test
stations. An investigation resulted in the discovery that Williams Northwest's cathodic
protection system is being remediated which causes the shared current thought the
bond with Williams to be weak. This Abnormal Operating Condition was documented,
and a plan was put into place to remediate this deficiency.
Prior to July 15, 2024, a sacrificial magnesium anode will be installed at each of the test
stations along the pipeline to restore adequate cathodic protection to the pipeline in
accordance with 49 CFR Part 192.465 (below). After the anodes are installed, Douglas
Pipeline will disconnect the bond from Williams in order to preserve the life of the anodes
and protect only the Bennett Mountain Pipeline. Whenever the time arrives that Williams
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D O U GLAS
PIPELINE COMPANY
has resolved their CP issues, DPC will reconnect our bond and disconnect the
magnesium anodes from the test stations. The anodes will remain buried and ready to
reconnect in the event that Williams has another issue in the future.
Once the anode installation project is completed an updated "anode option" procedure
for monitoring the CP system performance, determining when to switch between the
Idaho Power anodes and the Williams bond, and how to make the switch, will be added
to this O&M Manual.
After the new anode option procedure is implemented in 2024, remedial action will be
taken if the voltage reads below the required -0.85 volts. Corrective action will be
recommended within 30 days of the detection of any materially significant deficiencies.
Though deficient pipe-to-soil readings may continue between now and the completion of the
anode installation project, the corrosion risk remains low. The pipe is still receiving current for its
cathodic protection system, and as Idaho PUC staff, Douglas Pipeline Company staff, and
Steele Cathodic staff witnessed on September 26, 2023, and as is documented in the attached
"Idaho Power Bennett Mtn 2023 Assessment Report," the coating is in excellent condition. The
soil resistivity testing that was documented on September 26 (page 15 of the .pdf) indicates that
the soil is "Essentially non-corrosive."
All of the attachments have also been added to the online shared folder that was assembled for
the 2023 records audit that Matt Galli has initiated.
Thank you again for your attention to this matter. We appreciate and respect the auditing
process that The Commission provides and your support in promoting effective pipeline safety
practices. Please contact me by phone or email if you have any questions.
Sincerely,
Andrea Shacklett
Director of Regulatory Compliance
Douglas Pipeline Company
412-531-2440 Ext. 29
ashacklett(a.douglaspipeline.com
Attachments:
- Idaho Power Bennett Mountain Operations and Maintenance Manual Rev 14-1
- Idaho Power Bennett Mtn 2023 Assessment Report
- Idaho Power Bennett Mountain AOC and Project Plan
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