A201901 LOC

Idaho Public Utilities Commission Brad Little,Govemor
PO Box 83720,Boise,ID 83720-0074 Paul Kjellander,Commissioner
Kristine Raper,Commissioner
Erie Anderson,Commissioner
April 3,2019 Report#A201901
LETTER OF CONCERN
Mike Faulkenberry
Avista Corporation
1411 Mission Ave, MSC-6
P.O. Box 3727
Spokane,WA.99220-3727
Dear Mr. Faulkenberry:
On February 26-28, 2019 representatives of the Idaho Public Utility Commission, Pipeline Safety
Division, conducted a records compliance inspection of Avista's pipeline safety records for the Idaho
natural gas distribution system.
As a result of the inspection, it appears there are areas of concern that do not fully meet the intent of
the pipeline safety regulations Title 49,Code of Federal Regulations, Part 192 for calendar year 2018.
The items listed below are of concern:
1. Avista could not demonstrate compliance with 49 CFR§192.615(c)Emergency Plans, 49 CFR§
192.605(a)Procedural manual for operations,maintenance, and emergencies and Avista Gas
Emergency and Service Handbook section 13 Emergency Planning.At our request the Public Safety
Specialist provided documentation of all events that took place in 2018. IPUC noted inconsistencies
in the required training/mock drills,documentation, personnel/entities attendance and after action
plans across all construction areas including those required items underlined below
§192.615(c) Each operator shall establish and maintain liaison with appropriated fire,police and other
public officials: (1)Learn the responsibility and resources of each government organization that may
respond to a gas pipeline emergency, (2)Acquaint the officials with the operator's ability in responding
to a gas pipeline emergency; (3)Identify the types of gas pipeline emergencies of which the operator
notifies the officials,and(4)Plan how the operator and officials can engage in mutual assistance to
minimize hazards to life or property.
472 West Washington Street,Boise ID 83702
Telephone:[phone] Facsimile:[phone]

§192.605(a)Each operator shall prepare and follow for each pipeline, a manual of written procedures
for conducting operations and maintenance activities and for emergency response.
Avista Utilities 2018 Gas Emergency and Service Handbook
Emergency Planning 13.0 Emergency Planning, Training, and Incident Notification.
Communication with Public Officials:
Effective control of emergency situations is performed through partnering with appropriate
fire, police,and other public officials.
A liaison program with fire and police shall be documented and maintained by each local
construction office that addresses how these agencies and Avista respond and take action to
protect life first and then property. This is often accomplished by offering training classes and
other materials to the various fire and police departments within each construction area.
In addition, each construction area is responsible to establish and maintain liaison with
appropriate fire,police, and other public officials to:
1. Learn the responsibility and resources of each government organization that may respond to
a gas pipeline emergency.
2. Acquaint the officials with Avista's ability in responding to a gas pipeline emergency.
3. Identify the types of gas pipeline emergencies of which Avista notifies the officials.
4. Plan how Avisto and the officials can engage in mutual assistance to minimize hazards to
life or property.
Mock Emergency Drills:
In addition to employee training, the Emergency Operations Plan (EOP)should be exercised to
ensure the plan adequately supports operations and ensures applicable personnel are
adequately trained in EDP response.
These mock emergency drills should include external stakeholders when applicable. (Fire,
police, emergency management(EMS), co-located utility companies, etc.). The Company has
commitments to complete mock emergencies as detailed below.(Table on page 3 of 9)(Idaho
Annually)
Mock emergency drills should be completed via a table top or field mock emergency and should
be evaluated for enhancement opportunities to the Gas EOP.At a minimum, documentation of
the following information should be completed for each mock drill conducted with a copy
forwarded to the Pipeline Safety Engineer:
-Mock drill scenario
-Date and time(Include start time, end time, and other significant times)
-Personnel and entities that participated
- Things that went well
- Things that need improvement
-Follow-up action items with due dates
AviSTA RECORDS LETTER OF CONCERN—PAGE 2

2. It is the recommendation of the IPUC that the wording contained in Avista Operations Damage
Prevention Program Spec 4.13 Pg. 6 Paragraph 8 be changed (See Below)
When a contract locator notifies Avista's local office of an un-locatable facility,they shall should
take additional actions to identify the location of the facilities within the prescribed timeline of
the locate ticket unless documented arrangements with the excavator have been made.
Additional actions may include but are not limited to:
The above mentioned items were brought to the attention of your representatives during the records
compliance inspection.We would request that you review this matter and respond in writing within 30
days regarding the above issue including any planned corrective action.
If you have any questions concerning this notice, please contact me at(208) 334-0331. Also all written
responses should be addressed to me at: P.O. Box 83720-0074, Boise, Idaho 83720-0074 or you may fax
your response to(208)334-3762.
Because of the good faith that you have exhibited up to this time,we expect that you will act to bring
your program into compliance with pipeline safety regulations. We appreciate your attention to this
matter and your effort to promote pipeline safety.
Icly,
Darrin Ulmer
Pipeline Program Manager
Idaho Public Utility Commission
AVISTA RECORDS LETTER OF CONCERN—PAGE 3