DP202301 NOPV

Idaho Public Utilities Commission Brad Little,Governor
P.O. Box 83720, Boise,ID 83720.0074 Eric Anderson,President
John R.Hammond,Jr.,Commissioner
Edward Lodge,Commissioner
October 2, 2023 Report# DP202301
Andi Shacklett
Douglas Pipeline Company
901 Castle Shannon Blvd
Pittsburgh, PA 15234
Dear Ms. Shacklett:
On September 26, 2023, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a Field Inspection on the natural gas system of Douglas Pipeline
Company (DPC) in Mountain Home, ID pursuant to Chapter 601 of Title 49, United States Code.
Staff observed that some of the Idaho natural gas system(s) owned and operated by DPC
("Company") was out of compliance on item(s). This results in probable violations of the pipeline
safety regulations Title 49, Code of Federal Regulations, Part 192. The probable violations are as
follows:
PROBABLE VIOLATION(S)
1. 49 CFR 092.605 Procedural manual for operations, maintenance, and emergencies
(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.
2. Appendix D to Part 192—Criteria for Cathodic Protection and Determination of
Measurements
i. Criteria for cathodic protection—A. Steel
1. A negative (cathodic) voltage of at least 0.85 volt, with reference to a saturated
copper-copper sulfate half-cell. Determination of this voltage must be made with the
protective current applied, and in accordance with sections II and IV of this appendix.
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
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3. Douglas - Gas Pipeline Operations and Maintenance Manual
19.6 Part 192 Appendix D: Criteria for Cathodic Protection/Determination of
Measurements
I. Criteria for cathodic protection—A. Steel, cast iron, and ductile iron structures.
(1) A negative (cathodic) voltage of at least 0.85 volt, with reference to a saturated
copper-copper sulfate half-cell. Determination of this voltage must be made with the
protective current applied, and in accordance with sections II and IV of this appendix.
(2) A negative (cathodic) voltage shift of at least 300 millivolts. Determination of this
voltage shift must be made with the protective current applied, and in accordance with
sections II and IV of this appendix. This criterion of voltage shift applies to structures not
in contact with metals of different anodic potentials.
(3) A minimum negative (cathodic)polarization voltage shift of 100 millivolts. This
polarization voltage shift must be determined in accordance with sections III and IV of
this appendix.
(4) A voltage at least as negative (cathodic) as that originally established at the beginning
of the Tafel segment of the E-log-I curve. This voltage must be measured in accordance
with section IV of this appendix.
(5) A net protective current from the electrolyte into the structure surface as measured by
an earth current technique applied at predetermined current discharge (anodic) points of
the structure.
19.7 External Corrosion Control: Monitoring§192.465
Performance of CP systems will be monitored by DPC regularly with tests performed at
least once per calendar year 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. Remedial action will be taken if the voltage reads below
the required -0.85 volts. Corrective actions will be recommended within 30 days of the
detection of any materially significant deficiencies.
Finding(s)
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 -0.637.
REQUESTED ACTIONS
A reply to this correspondence is required no later than 45 days from the date of this letter. Please
submit a written reply providing a statement of all relevant facts including a complete description
of the corrective action(s) taken with respect to the above referenced probable violations, and all
actions to be taken to prevent future failures in these areas of concern. This written reply must be
signed by a Company official with authority to bind the Company.
Please send all documents to our office at 11331 W. Chinden Blvd, Boise, Idaho 83714-1021. Be
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]

advised that all material you submit in response to this enforcement action may be a public record
and subject to disclosure under Idaho's Public Records Law. See Idaho Code §§74-101 et seq.
If you wish to dispute any of the above referenced potential violations,you have the right to appear
before the Pipeline Safety Division in an informal conference before November 16, 2023, at the
above address. You have the right to present relevant documents and evidence to the Pipeline
Safety Division at that conference. The Pipeline Safety Division will make available to you any
evidence which indicates that you may have violated the law, and you will have the opportunity to
rebut this evidence. See Commission Orders 35095 and 35334, which can be found at
https://puc.idaho.gov/. If you intend to request an informal conference,please contact the Pipeline
Safety Division no later than November 1, 2023.
If you wish to dispute any of the allegations in this Notice,but do not want an informal conference,
you may send the Pipeline Safety Division a written reply to this Notice. This written reply must
be filed with the Commission on or before November 16,2023, and must be signed by a Company
official with authority to bind the Company. The reply must include a complete statement of all
relevant facts, and all documentation, evidence, and argument the Company submits to refute any
of the above referenced probable violations.
If you do not respond to this notice by November 16,2023,you may be subject to any Commission
enforcement action as allowed under Idaho law including, but not limited to, potential civil
penalties of up to two hundred thousand dollars ($200,000). See Idaho Code §61-712A.
If you have any questions concerning this Notice,please contact me at(208)334-0333. All written
responses should be addressed to me at the above address, or you may fax your response to (208)
334-3762.
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sincerely,
Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]