A202301 NOPV

Idaho Public Utilities Commission Brad Little,Governor
P.O.Box 83720, Boise, ID 83720-0074 Eric Anderson,President
John R.Hammond,Jr,Commissioner
Edward Lodge,Commissioner
June 14, 2023 Report #A202301
Alicia Gibbs—Director of Natural Gas
Avista Corporation
1411 Mission Ave, MSC-6
P.O. Box 3727
Spokane, WA 99220-3727
Dear Mrs. Alicia Gibbs:
On June 6,2023,the Idaho Public Utilities Commission("Commission"),Pipeline Safety Division
("Staff"), conducted a Field Inspection in the Avista Coeur d'Alene District pursuant to Chapter
601 of Title 49, United States Code.
Staff observed that some of the Idaho natural gas distribution system owned and operated by Avista
was out of compliance on item(s). This results in probable violations of the pipeline safety
regulations Title 49,Code of Federal Regulations,Part 192.The probable violations are as follows:
PROBABLE VIOLATIONS)
1. 49 CFR §192.739 (a) (4) Pressure limiting and regulating stations: Inspection and
testing.
Pressure limiting and regulating stations: Inspection and testing—reads: Properly
installed and protected.from dirt, liquids, or other conditions that might prevent proper
operation.
2. 192.605 Procedural manual for operations, maintenance, and emergencies.
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.
a. Avista Standard 5.12 Maintenance Regulator & Relief Inspection
Overpressure protection devices (including relief valves, monitor regulators, and
safety shutoff valves) shall be inspected and tested once each calendar year.
Overpressure protection devices shall be inspected to ensure the following:
• They are in good mechanical condition.
• They are as specified by Gas Engineering. In some cases, the relief set point
may be less than the MAOP due to operating restrictions.

• They are properly installed and protected from dirt, liquids, and other
conditions that might affect proper operation.
• Sensing lines, control lines, filters, restrictors, etc. on relief valves have been
inspected and repaired as necessary.
Findings)
Regulator Station 2029 failed to lock-up on the worker regulator due to fouling on the
pilot stem.
Regulator Station 4246 failed to lock-up on the worker and the monitor due to fouling on
the pilot stem and diaphragm. This regulator station additionally failed during the 2022
Coeur d'Alene field audit.
Regulator Station 604 failed to lock up on the worker and monitor. Avista personnel
observed a small indentation on the rubber portion of the pilot stem.
The above station failures were corrected on-site during the audit.
REQUESTED ACTIONS
A reply to this correspondence is required no later than 45 days from the date of this letter. Please
submit a written reply providing a statement of all relevant facts including a complete description
of the corrective action(s) taken with respect to the above referenced probable violations, and all
actions to be taken to prevent future failures in these areas of concern. This written reply must be
signed by an IGC official with authority to bind the company.
Please send all documents to our office at 11331 W. Chinden Blvd, Boise, Idaho 83714-1021. Be
advised that all material you submit in response to this enforcement action may be a public record
and subject to disclosure under Idaho's Public Records Law. See Idaho Code §§74-101 et seq.
If you wish to dispute any of the above referenced potential violations,you have the right to appear
before the Pipeline Safety Division in an informal conference before July 29, 2023, at the above
address. You have the right to present relevant documents and evidence to the Pipeline Safety
Division at that conference. The Pipeline Safety Division will make available to you any evidence
which indicates that you may have violated the law, and you will have the opportunity to rebut this
evidence.See Commission Orders 35095 and 35334,which can be found at https://puc.idaho.gov/.
If you intend to request an informal conference, please contact the Pipeline Safety Division no
later than July 14, 2023.
If you wish to dispute any of the allegations in this Notice,but do not want an informal conference,
you may send the Pipeline Safety Division a written reply to this Notice. This written reply must
be filed with the Commission on or before July 29, 2023, and must be signed by an IGC official
with authority to bind the company. The reply must include a complete statement of all relevant
facts, and all documentation, evidence, and argument IGC submits to refute any of the above
referenced probable violations.
If you do not respond to this notice by July 29, 2023, you may be subject to any Commission

enforcement action as allowed under Idaho law, including but not limited to, potential civil
penalties of up to two hundred thousand ($200,000). See Idaho Code §61-712A.
If you have any questions concerning this Notice,please contact me at(208) 334-0333. All written
responses should be addressed to me at the above address, or you may fax your response to (208)
334-3762.
We appreciate your attention to this matter and your effort to promote pipeline safety.
Sincerely,
Jeff Brooks
Pipeline Safety, Program Manager
Idaho Public Utility Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]