DP202601 NOPV

Z
Idaho Public Utilities Commission Brad Little,Governor
P.O.Box 83720,Boise,ID 83720-0074 Edward Lodge,President
John R.Hammond,Jr.,Commissioner
Dayn Hardie,Commissioner
June 24, 2026, Report#DP202601
Andi Shacklett
Douglas Pipeline Company
901 Castle Shannon Blvd
Pittsburgh, PA 15234
Dear Ms. Shacklett,
On June 23, 2026, the Idaho Public Utilities Commission ("Commission"), Pipeline Safety
Division ("Staff'), conducted a Langley Gulch Field Equipment Inspection on the natural gas
system of Douglas Pipeline Company (DPC) in New Plymouth, 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 VIOLATIONS)
1. 49 CFR 092.605 Procedural manual for operations, maintenance, and emergencies.
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.
DOUGLAS PIPELINE NEW PLYMOUTH FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 1 of 3

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 11 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)•
A negative voltage of at least -0.85mV was not adequately achieved at the following
locations:
• Station 2: TS 43.920445, -116.813418 TS across from tap; Station 1+49, the
reading was -0.370mV
• Station 3: TS 43.918117,-116.813430 TS at gas processing plant; Station 9+30,the
reading was -0.234mV
• Station 4: TS 43.913131, -116.813621 Hay Sale; Station 28+43, the reading was
-0.320mV
• Station 5: TS Route 84; Station 48+02, the reading was -0.340mV
DOUGLAS PIPELINE NEW PLYMOUTH FIELD AUDIT PROBABLE VIOLATIONS LETTER— Page 2 of 3

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
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 August 8,2026,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 July 24, 2026.
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 August 8, 2026, 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.
These violations may be subject to any Commission enforcement action as allowed under Idaho
law including, but not limited to, potential civil penalties in accordance with 49 CFR 190.223(a).
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.
Since ly,
7
Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
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