A202502 LOC Response

2406 N. Dollar Road
Spokane Valley, WA 99212
Submitted to Jeff Brooks via electronic mail at [e-mail].
August 19, 2025
Mr. Jeff Brooks
Pipeline Safety Program Manager
Idaho Public Utilities Commission
11331 Chinden Blvd., Building 8, Suite 201-A
Boise, ID 83714
Re: IPUC Sandpoint District Field Audit Letter of Concern—Avista Response
Dear Mr. Brooks:
In a recently received letter(Report#A202502), you listed an area of concern(AOC)discovered
during the 2025 Sandpoint Field Audit that was conducted July 29, 2025. In this letter we have
provided a restatement of the AOC as noted in your letter, and Avista's response.
Area of Concern (AOQ References:
§192.605,Avista Gas Standards Manual Spec. 2.32, Cathodic Protection, §192, Appendix D, and
§192.465
Description of AOCs
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)
Controlling corrosion in accordance with the operations and maintenance
requirements of Subpart I of this part.

2025 Gas Standards Manual
(2.32)Cathodic Protection(Cathodic Protection Design)
Cathodic Protection-It is not economically feasible to design, apply, install and
maintain a coating that will completely insulate metal pipe from the soil
electrolyte. Instead,the protection provided by an economical pipe coating is
supplemented with the application of cathodic protection, an electromechanical
method that forces the metal to become cathodic to its environment.
Impressed Current System-In areas where current requirements are higher,
impressed current protection systems be used. These systems normally utilize
a rectifier which changes alternating current (AC) to direct current (DC) which
then is caused to flow into the soil through an anode and ultimately to flow onto
the pipeline thereby cancelling all undesired corrosion current.
2. Annendix D to Part 192- riteria for Cathodic Protection and Determination
Q Measurements
I.Criteria for cathodic protection-
A. Steel, cast iron, and ductile iron structures.
(1) A negative (cathodic) voltage of at least 0.85 volt, with reference to a
saturated copper-copper sulfate half cell. Determination of this voltage must
be made with the protective current applied, and in accordance with sections II
and IV of this appendix.
3. 49 CFR§192.465 External corrosion control: Monitoring and re—Mediation
(a) Each pipeline that is under cathodic protection must be tested at least once
each calendar year, but with intervals not exceeding 15 months, to
determine whether the cathodic protection meets the requirements of§
192.463_However, if tests at those intervals are impractical for separately
protected short sections of mains or transmission lines, not in excess of
100 feet(30 meters), or separately protected service lines,these pipelines
may be surveyed on a sampling basis. At least 10 percent of these
protected structures, distributed over the entire system must be surveyed
each calendar year, with a different 10 percent checked each subsequent
year, so that the entire system is tested in each 10-year period. Otherwise
protected against such damage.
(b) Cathodic protection rectifiers and impressed current power sources must
be periodically inspected as follows:
(1) Each cathodic protection rectifier or impressed current power source must
be inspected six times each calendar year, but with intervals not exceeding
2'/2 months between inspections, to ensure adequate amperage and voltage
levels needed to provide cathodic protection are maintained. This may be
done either through remote measurement or through an onsite inspection
of the rectifier.

Findinj4(s):
During the 2025 Sandpoint, Idaho Field Inspection, Commission Staff witnessed a low Cathodic
Protection reading of-0.764mV on Reg Station 206. The associated rectifier was later found in
the off position.
The above-mentioned items were brought to the attention of Avista representatives during the
inspection. We request that you review these matter(s)and respond in writing within 30 days
regarding the above issue(s)including any planned corrective actions.
Avista Response to AOCs:
As the IPUC is aware, Avista's previous 5G, Remote Monitoring Unit(RMU)technology was
recently rendered obsolete. We are in the process of moving to a new RMU provider whose
technology will expeditiously provide cellular text notification when a rectifier is non-
operational. This will resolve any future similar situations from occurring where a Cathodic
Technician performs a site visit to a rectifier and neglects to reenergize the unit prior to
departure. It is anticipated that this technology update will be completed by September 30, 2025.
Respectfully Submitted,
Alicia Gibbs
Director,Natural Gas
AG/rkb
Cc: Carie Mourin, Manager, Gas Compliance, and Integrity
Jeff Webb, Manager, Gas Design, Measurement and Planning
Seth Samsell, Manager, Coeur d'Alene/Sandpoint Gas Operations
Gary Douglas, Cathodic Foreman