DP202601 NOPV Response

D O U GLAS
PIPELINE COMPANY
August 3, 2026
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
Langley Gulch facility. This letter is in response to your Notice of Probable Violation dated June
24, 2026:
Findings from June 23, 2026 Field Audit
,k negative voltage of at least -0.85mV was not adequately achieved at the following
.ocations:
• 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 technician Cash McGinnis completed an "Abnormal Operating Condition
(AOC)" report on June 23, 2026, documenting deficient pipe-to-soil readings identified at four
cathodic protection (CP) test stations. Idaho Power's pipeline at the Langley Gulch Power Plant
receives cathodic protection from buried magnesium anodes. Upon discovery of the condition,
Mr. McGinnis and Douglas Pipeline Company's integrity specialist, Shawn Mason, consulted
with our cathodic protection contractor, Steele Cathodic, to evaluate the condition and develop
an appropriate remediation plan.
On July 2, 2026, Douglas Pipeline Company provided Idaho Power with a proposal for Steele
Cathodic to install and connect two (2) 20-pound magnesium anodes to the pipeline's test
stations and pipeline leads. This work is intended to restore adequate cathodic protection in
accordance with 49 CFR 192.463, External Corrosion Control: Cathodic Protection, which
requires that each cathodic protection system provide a level of protection meeting one or more
of the applicable criteria contained in Appendix D to Part 192.
Idaho Power representative Mike Williams approved the proposal immediately upon receipt, and
installation is scheduled for September 15, 2026.
929 Park Ave. Floor 2 • Pittsburgh, Pennsylvania • 15234
Telephone: [phone] • www.douglaspipeline.com

D O U GLAS
PIPELINE COMPANY
The planned remediation schedule is fully compliant with Douglas Pipeline Company's
procedures, and the corrective action requirements of 49 CFR 192.465(d). The deficiency was
identified on June 23, 2026, a remedial action plan was developed well within the required six-
month timeframe, and corrective action is scheduled to be completed on September 15, 2026—
well in advance of the regulatory deadline of September 23, 2027.
In accordance with 49 CFR 192.465(f), Douglas Pipeline Company also evaluated the extent of
the area with inadequate cathodic protection following the deficient annual pipe-to-soil readings
to ensure the condition was appropriately assessed.
Thank you again for your attention to this matter. We appreciate and respect the Commission's
audit process and its role in promoting safe and effective pipeline operations. Should you have
any questions or require additional information, please feel free to contact me by phone or
email.
Sincerely,
C�c
Andrea Shacklett
Director of Regulatory Compliance
Douglas Pipeline Company
412-531-2440 Ext. 29
ashacklett(a�douglaspipeline.com
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