A202001 LOC Response

1411 E. Mission, PO Box 3727
Spokane,WA 99220-3727
Submitted to Darrin Ulmer via electronic mail at [e-mail]
April 26,2019
Mr. Darrin Ulmer
Program Manager
Idaho Public Utilities Commission
PO Box 83720
Boise,ID 83720-0074
Re: Response to IPUC letter dated April 3, 2019
Dear Mr. Ulmer:
In your letter of April 3,2019,you documented two areas of concern discovered during the IPUC
Pipeline Safety Records Audit on February 26—28, 2019. Please find herein an overview of the areas of
concern/findings and Avista's responses.
Area of Concern#1:
Avista could not demonstrate compliance with 49 CFR§I92.615(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.
Summarization/Description of Findings for Area of Concern#1:
1. Avista did not meet the requirements of§192.615(c)which says: "Each operator shall 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 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 and property."
2. Avista did not meet the requirements of§192.605(a)which says: "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 did not follow its procedures found
in Gas Emergency and Service Handbook, Section 13, Emergency Planning, specifically the
sections named"Communication with Public Officials"and"Mock Emergency Drills".

Avista Response to Area of Concern#1:
1. Avista concurs that the company did not meet the requirements of§192.615(c)and specifically
the company could not show each Idaho construction office had maintained the appropriate
liaisons and documented the meetings. Moving forward,Avista will require each construction
manager to complete a Capabilities Survey annually with their applicable first responders.
Additionally,each manager will be required to keep their documentation of all Public Safety
Liaison Meetings(ex: PUBLIC SAFETY FORM 2019.xism)up to date and accurate to include
attendee lists and training covered as applicable.
2. Avista concurs that the company did not meet the requirements of§192.605(a)when company
managers did not follow written procedures found in Gas Emergency and Service Handbook,
Section 13, "Communication with Public Officials". This portion of the company's standards
will be followed as described in#1 above.
Avista does not concur that the company did not meet the requirements of§192.605(a)when
company managers supposedly did not follow written procedures found in Gas Emergency and
Service Handbook, Section 13, "Mock Emergencies". Avista managers in all five construction
offices did actually perform/participate in mock drills in 2018. Avista may not have shown
documentation of the drills during the audit or in follow-up correspondence but has attached
documentation herein of the mock drill completions for 2018.
Area of Concern#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)
Summarization/Description of Findinys for Area of Concern#2:
The IPUC recommends that Spec.4.13 be changed to read: When a contract locator notifies Avista's
local office of an un-locatable facility,they shall sheald 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:
Avista Response to Area of Concern#2:
Avista will make the recommended change to the 2020 edition of the Gas Standards Manual.
k
Su i ed,
ulkenberry
Director,Natural Gas
MJF/rkb
Enclosure
Cc: Paul Good,Compliance Manager
IPUC Correspondence File

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TTX Name: Ross Ranch Pipeline Rupture D.te: April 19, 2018
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