A201903 NOPV Response

1411 E. Mission,PO Box 3727
Spokane, WA 99220-3727
Submitted to Darrin Ulmer via electronic mail at [e-mail]
July 3, 2019
Mr. Darrin Ulmer
Program Manager
Idaho Public Utilities Commission
PO Box 83720
Boise,ID 83720-0074
Re: Response to IPUC letter dated June 7,2019
Dear Mr. Ulmer:
In your letter of June 7,2019,you documented two areas of probable violation discovered during the
IPUC Pipeline Safety Records Audit on February 26—28,2019. The probable violations pertain to a
blowing gas incident that occurred on March 14,2018 in Lewiston, Idaho and the subsequent Avista
Incident Assessment that is dated April 2,2018. Please find herein a restatement of the probable
violations/findings and Avista's responses.
Probable Violation#1:
Avista was found out of compliance with 49 CFR §192.605(a)and(b)(9)as discussed herein:
49 C.F.R.§192.605 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.
b) (9) Taking adequate precautions in excavated trenches to protect personnel from the
hazards of unsafe accumulations of vapor or ggs
and making available when needed at the
excavation, emergency rescue equipment, including a breathing apparatus and, a rescue
harness and line.
Avista Utilities 2018 Gas Emergency and Service Handbook
Emergency Procedures 4.0 Emergency Procedures-Blowing or Uncontrolled Escaping Natural Gas

General
Employees responding to natural gas emergencies shall be trained and qualified under current
Company standards, and per any applicable State or Federal regulations.Such employees shall
adhere to the following procedures in controlling emergency situations:
• Evaluate any emergency scene to assess the extent of any leakage or damage, and to
determine what action is necessary to safeguard life first and then property(such as other
utilities that can cause an immediate hazard). Evaluation actions shall Include the use of a
combustible gas indicator that is capable of indicating percentage gas In air readings.
Avista Response to Probable Violation#1:
1. Avista concurs that company personnel did not meet the requirements of§192.605(a)and(b)(9)
specifically the company did not follow its own procedures found in Gas Emergency Service
Handbook, Section 4,Sheet 1 as noted above.
2. Upon completion of a formal Incident Assessment,the following corrective actions and
additional trainings were accomplished:
• In May 2018,the Director of Gas Operations personally met with each of the Idaho gas
operations districts to emphasize company expectations regarding emergency response
and safe practices
• The Avista Incident Prevention Manual(IPM)Section 7.7 Gas Worker Protection was
reviewed and updated as of February 2019 to provide enhanced guidance for personnel
responding in the Immediately Dangerous to Life or Health(IDLH)environment
• The aforementioned updates to iPM Section 7.7 were presented by the Director of Gas
Operations and the Manager of Gas Compliance during 2019 OQ Refresher to emphasize
Avista's commitment to worker safety
• Incident Command Training was added to OQ Refresher in 2019 and will be trained
annually moving forward
• Enhanced training on recognizing the need for and proper use of the Self Contained
Breathing Apparatus(SCBA)was provided during the 2019 OQ Refresher sessions
Probable Violation#2:
Avista was found out of compliance with 49 CFR§192.615(c)as discussed herein:
(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.

Avista Response to Probable Violation#2:
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.
2. Moving forward,Avista will require each construction manager to annually complete a
Capabilities Survey with their applicable first responders. Additionally,each manager will be
required to keep documentation of Public Safety Liaison Meetings up to date and accurate.
Respectfully Submitted,
x�o(
6
Michael Jlfaulkenberry
Director,Natural Gas
MJF/rkb
Enclosure—Avista Incident Prevention Manual
Cc: Paul Good,Compliance Manager
IPUC Correspondence File