A201701 NOPV Response

1411 E. Mission,PO Box 3727
Spokane, WA 99220-3727
Submitted to Joe Leckie via electronic mail [e-mail]
July 17,2017
Mr.Joe Leckie
Executive Director/Program Manager
Idaho Public Utilities Commission LL
PO Box 83720
Boise, ID 83720-0074
Re: Response to IPUC letter dated May 15, 2017 '
Dear Mr. Leckie:
In your letter of May 15,2017,you documented two probable violations discovered through Avista's self-
reporting of the shortcomings in a teleconference with the IPUC on December 12,2016. Please find
herein a restatement of the probable violations/findings and Avista's response.
Probable Violations:
1. 49 CFR 192.723(b)(1)Distribution Systems: Leakage Surveys
A leakage survey with leak detector equipment must be conducted in business districts,
including...at intervals not exceeding 15 months, but at least once each calendar year.
2. 49 CFR 192.723(b)(2)Distribution Systems: Leakage Surveys
A leakage survey with leak detector equipment must be conducted outside business districts as
frequently as necessary, but at least once every 5 calendar years at intervals not exceeding 63
months.
Findines•
It was revealed during the teleconference that the leak surveys in the Silver Valley on Northern Idaho
were only one-third complete and it was believed that they were not going to be completed by years end.
The previous leak survey for this portion of the distribution system was completed in September 2011.
To be in compliance,the leak survey must have been completed by December of 2016. The survey was
ultimately suspended(due to low survey quality and safety issues) in December with the onset of winter.
The subsequently caused some of the annual leak surveys to exceed 15 months. At the time of the
teleconference it was relayed that 58 leaks had been discovered during the survey(by survey's end a total
of 89 leaks were discovered).
The leak survey manager informed us that come spring of 2017 the entire Silver Valley would be
completely re-surveyed.

Avista Response to the above NOPVs:
Avista concurs that the company did not complete the distribution leakage surveys in their entirety within
the time periods required by federal code in both business and non-business districts in its Kellogg
District. Avista regrets, however,that IPUC Safety Staff s findings did not acknowledge,the reasons
Avista represented to Staff for missing the required dates. The following detail describes company
planning,unprecedented weather conditions,and efforts to complete leak survey associated with the
aforementioned leakage surveys.
The 5-year leak survey for Avista's Kellogg District was scheduled to begin on October 19,2016 and be
completed by November 4, 2016. The leak surveys in several districts including the Kellogg District
were delayed in starting because of record-setting precipitation(see enclosed article by Mike Prager,
Spokesman Review,dated October 31, 2016).
As early as October 2016,Avista realized that missing compliance was a possibility without initiating
changes to surveyor staffing and work schedules. Avista took steps to reinforce survey efforts including
shifting leak survey technicians from Oregon to Washington/Idaho and began working Saturdays. With
the quick onset of winter weather,Avista consulted with the leak survey contractor, Southern Cross, and
implemented a cold weather leak survey process. This included concentrating survey efforts in business
districts and Aldyl-A piping areas where snow was cleared, slowing the survey speed, and expanding the
typical 10-foot buffer for surveying venting locations to a 25-foot buffer on all visible venting locations
(i.e.pavement joints,cracks,valve boxes etc.) However,these efforts were not able to make up for the
lost survey days due to the slowing of the survey from snow/ice on the ground and associated access
limitations. Ultimately, Avista elected to suspend further survey after December 19,2016.
The decision to suspend further leak survey until appropriate weather was made for the following reasons:
1. Leak Survey Protocols Regarding Inclement Weather—
a. During times of inclement weather it is the responsibility of the leak survey technician, in
consultation with contractor management and Avista,to evaluate if continued survey is
appropriate. Under marginal weather conditions(i.e.precipitation, ground saturation and
or wind)the leak survey technician is required to detect two known leaks using standard
survey protocols.
b. If the known leaks cannot be detected then low survey quality is expected(as described
below)and survey is not appropriate until conditions improve. To check ground
saturation a leak survey technician may also commonly perform a bar hole evaluation. In
several cases in late 2016 and early 2017 after extraction of the bar,the hole would fill up
with groundwater indicating saturated ground conditions.
2. Low Survey Quality—
a. During wet weather, ground conditions become saturated(i.e. interstitial spaces between
the soil particles become occupied by groundwater). This creates a relatively low-
permeability condition reducing potential for natural gas to migrate upward where it may
be detected with leak survey equipment. A similar condition is created when ice and
snow cover the ground surface causing a"capping"situation. During these times leak
survey effectiveness is significantly reduced.
b. Wet weather also reduces the effectiveness of the Flame Ionization(FI)unit. FI units
operate by burning a mixture of nitrogen and hydrogen gases. Moisture in the air, on the
ground and cold temperatures can cause the unit to fault and not function pr

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. s
3. Safety of Leak Survey Technicians—As noted above, efforts were implemented for cold
weather survey. However, leak survey technicians were being exposed to potentially hazardous
winter conditions including slips,trips, falls and surveying close to vehicles that were driving on
icy roads.
4. Access Limitations—Due to ice and snow accumulations, leak survey technicians were not able
to access some service pipelines and meters behind gated fences. In addition,many rural areas
that were not plowed, such as long driveways and/or on steeper streets, could not be accessed
even by vehicle.
Completion of the 2016 5-year Leak Survey
In its decision to suspend the remaining Kellogg District survey in 2016,Avista made known that the
entire 5-year survey(including annual survey areas)for the district would be completed off-cycle in early
2017, as soon as weather permitted. In addition the scheduled annual survey would be recompleted in
2017 to maintain the compliance schedule into the future.
Avista scheduled the resurvey of the Kellogg District 5-year to begin in spring 2017 and it was completed
in mid-June 2017. The following leaks were discovered from this survey:
Leak Type Number of Leaks
Grade 1 Aboveground 0
Grade 2 Aboveground 11
--- _
Grade 3 Aboveground 78
Total Aboveground Leaks 89
Grade 1 Belowground 1
Grade 2 Belowground 5
Grade 3 Belowground 3
Total Belowground Leaks 9
Avista Responses to IPUC Staff Questions from June 29,2017 Meeting in Spokane,WA.
On Thursday, June 29,2017,Mike Faulkenberry and Karen Cash of Avista met with Joe Leckie and
Darrin Ulmer to discuss this issue. Following are Avista's responses to the two questions raised by Joe.
Why not add more leak survey technicians to complete the survey sooner?
Leak Survey is conducted on regular schedule to complete annual surveys in 12 months not to exceed 15
months and 5-year survey in 60 months not to exceed 63 months. Schedules are developed at the
beginning of each season to allow necessary time,with a contingency,to complete the surveys in the
required timeframes. In the case of Kellogg District in 2016,the contingencies were depleted prior to
arrival in Kellogg due to record-setting precipitation.
The challenges in adding a large number of leak survey technicians to an operational area are as follows:
• Overwhelms operational resources needed to repair leaks.
• Requires several weeks to train additional leak survey technicians to increase crew sizes to cover
more territory.

Why not complete the survey earlier in the year?
Avista schedules the required Leak Survey at the beginning of each season. Several parameters must be
considered when developing and executing the schedule including:
1. The overall footage of pipeline and its geographic location
To maintain our annual and 5-year compliance requirements,Avista must schedule to complete
approximately 26 million feet of pipeline and associated meter sets every year distributed across
Washington, Idaho,and Oregon. It requires the entire season(early March through late October)
to complete this effort.
2. Previous Compliance Dates
The schedule is configured to meet existing compliance(based on previous years)and also to the
extent possible to start in lower elevation(warmer)areas and working through the larger
operations areas and ending in the smaller areas.
3. Sensitivity regarding 15-month and 63-month requirements from the prior leak survey
The subject year's leak survey is directed by the previous survey to meet the 12 to 15 and 60 to
63 month requirements. Leak surveys that start too early or too late and/or surveys conducted too
slow or too quickly can create unrealistic timeline requirements for future surveys.
In conclusion,Avista acknowledges the violation of 49 CFR 192.623(a)and(b)in calendar year 2016 in
the Kellogg District. The violations were not due to negligence but a result of our decision to maintain
the quality of our leak survey process and for public and employee safety.
Respectfully Su miffed,
Michael . F ulkenberry
Director,Natural Gas
MJF/rkb
Enclosure
Cc: Karen Cash, Compliance Manager
Jodie Lamb,Leak Survey Program Manager
IPUC Correspondence File