A201904 NOPV Response

1411 E. Mission, PO Box 3727
Spokane, WA 99220-3727
Submitted to Darrin Ulmer via electronic mail at [e-mail]
August 8,2019
Mr. Darrin Ulmer
Program Manager
Idaho Public Utilities Commission
PO Box 83720
Boise,ID 83720-0074
Re: Response to IPUC letter dated July 2,2019
Dear Mr. Ulmer:
In your letter of July 2,2019,you documented one area of probable violation discovered during the IPUC
Pipeline Safety Drug and Alcohol Program Audit on May 7,2019. Please find herein a restatement of the
probable violation/findings and Avista's response.
Probable Violation:
Avista was found out of compliance with 49 CFR §199.105 as discussed herein:
PROBABLE VIOLATION
1. 49 C.F.R.§199.105 Drug tests required(c)Random testing.
• (1)Except as provided in...the minimum annual percentage rote for random drug
testing shall be 50 percent of covered employees.
• (6)The operator shall randomly select a....if the operator conducts random drug testing
through a consortium,the number of employees to be tested may be calculated for each
individual operator or may be based on the total number of covered employees covered
by the consortium who are subject to random drug testing at the some minimum annual
percentage rate under this subpart or any DOT drug testing rule.
Findin s:
Avista used Cascade Cable Constructors Inc.in 2018 as a part of the consortium contractor pool
that is administered by a third party. A review of the DOT Drug and Alcohol Testing
Management Information System(MIS)Data Collection Form revealed that the pool may not
have met the required 50 percent testing rate. Avista has confirmed that the pool in fact did not
meet that rate for 2018.

Avista Response to Probable Violation:
Cascade Cable Constructors,Inc.has opted to become a stand-alone pool in 2019,which ensures that
Avista will be able to properly monitor all required testing moving forward. In addition,Avista will be
doing a quarterly reconciliation of our third party administrator's(National Compliance Management
Systems-NCMS)records beginning in Q3 of 2019,to ensure that testing thresholds are being met.Avista
will record any discrepancies found in the data and work with contract companies to correct any issues
discovered. Avista is also reviewing its contract language to ensure that contracting companies are aware
of their obligations as they relate to DOT Drug and Alcohol testing.
Respectfully Submitted,
Michael aul enbe
Director,Natural Gas l
MJF/rkb
Cc: Karen Cash,Gas Compliance Manager
Patrick Everitt, Manager HR Analytics and Consulting Services
Hallie Rowland, Fitness for Duty and HR Compliance Administration
IPUC Correspondence File