A202501 NOPV

'�" ' Idaho Public Utilities Commission Brad Little,Governor
` � P.O.Box 83720, Boise, ID 83720.0074 Edward Lodge,President
�� John R.Hammond,Jr.,Commissioner
Dayn Hardie,Commissioner
June 17, 2025 Report# A202501
Alicia Gibbs
Avista Corporation
1411 Mission Ave, MSC-6
P.O. Box 3727
Spokane, WA 99220-3727
Dear Mrs. Alicia Gibbs:
On May 29, June 2 and June 3, 2025, the Idaho Public Utilities Commission ("Commission"),
Pipeline Safety Division ("Staff'), conducted a Procedural Audit of Avista Corporation pursuant
to Chapter 601 of Title 49, United States Code.
Staff observed that some of the Idaho natural gas system(s) owned and operated by Avista
Corporation("Company")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 VIOLATION(S)
1. 49 CFR 4192.605 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. For transmission lines, the manual must also include procedures for handling
abnormal operations. This manual must be reviewed and updated by the operator at
intervals not exceeding 15 months, but at least once each calendar year. This manual must
be prepared before operations of a pipeline system commence. Appropriate parts of the
manual must be kept at locations where operations and maintenance activities are
conducted.
2. 49 CFR §192.321 Installation of plastic pipe.
(g) Uncased plastic pipe may be temporarily installed above ground level under the
following conditions:
(1) The operator must be able to demonstrate that the cumulative aboveground
exposure of the pipe does not exceed the manufacturer's recommended maximum
period of exposure or 2 years, whichever is less.
(2) The pipe either is located where damage by external forces is unlikely or is
otherwise protected against such damage.
AVISTA PROCEDURAL AUDIT PROBABLE VIOLATIONS LETTER— Page 1 of 3

(3) The pipe adequately resists exposure to ultraviolet light and high and low temperatures.
Findin$(s)•
During the 2025 Avista Procedural Audit, inspectors from the Idaho Public Utilities Commission
(IPUC)identified a gap in Avista's Gas Standards Manual(GSM). Specifically,the manual lacked
a defined written procedure for the installation of temporary aboveground plastic piping, as
required under 49 CFR 192.321(g).
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 a Company 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 August 1,2025, 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://pue.idaho.gov/.
If you intend to request an informal conference, please contact the Pipeline Safety Division no
later than July 17, 2025.
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 August 1, 2025, and must be signed by a Company
official with authority to bind the Company. The reply must include a complete statement of all
relevant facts, and all documentation, evidence, and argument the Company submits to refute any
of the above referenced probable violations.
These violations may be subject to any Commission enforcement action as allowed under Idaho
law including, but not limited to, potential civil penalties in accordance with 49 CFR 190.223(a).
AVISTA PROCEDURAL AUDIT PROBABLE VIOLATIONS LETTER— Page 2 of 3

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 Utilities Commission
11331 W.Chinden Blvd.Ste 201-A Boise ID 83714
Telephone:[phone] Facsimile:[phone]
AVISTA PROCEDURAL AUDIT PROBABLE VIOLATIONS LETTER— Page 3 of 3