A202501 NOPV Response

2106 N. Dollar Road
Spokane Valley, WA 99212
Submitted via electronic mail to [e-mail]
July 16,2025
Mr. Jeff Brooks
Pipeline Safety Program Manager
Idaho Public Utility Commission
11331 W.Chinden Blvd.
Boise,ID 83714-1021
Re: Idaho PUC Report dated June 17,2025
Dear Mr. Brooks:
In your letter of June 1,2025,you documented one probable violation(two parts)that was discovered
during the Idaho PUC Procedural Audit. The purpose of this letter is to respond to you as requested.
Notice of Probable Violation Detail:
1. 49 CFR§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. 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.
(3)The pipe adequately resists exposure to ultraviolet light and high and low temperatures.

Findings:
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).
Avista Response to Notice of Probable Violation:
Avista concurs that the company Gas Standards Manual(GSM) is deficient on the topic of aboveground
temporary installation of plastic pipe. The upcoming 2026 edition of the GSM is being worked on and
will address this shortfall. Here is a screenshot of the proposed(still needs to be final vetted by the Gas
Standards Committee)new verbiage in GSM Spec.2.13, in the section titled"Aboveground Plastic Pipe".
Aboveground Plesfic Pipe
Plastic pipe is typically installed below ground level,with the exception of when encased in a steel riser as
part of a meter set,for a temporary bypass condition.for temporary aboveground installations/
emergency repairs,and when encased on bridge crossings For temporary aboveground
installations,the plastic pipe must be protected from potential damage
The appropriate method of protection will depend on the project site and associated risk of leaving the
aboveground plastic pipe unattended.Possible methods of protection include
• Install barricades and/or fencing around the aboveground plastic pipe
• Wrap the plastic pipe in yellow caution tape
• Build an aboveground conduit casing for the aboveground plastic pipe
• SmoOng of the pipe from duoct sunlight
If the temporary aboveground plastic pipe will be in place for one week or longer,Gas Engineering should
be contacted to discuss an appropriate protection plan.
/Respec fly Subm
itted,
licia bbi Director.Natural Gas
AG/rkb
Cc: Carie Mourin,Gas Compliance Manager