A202602 NOPV Response

2406 N. Dollar Road
Spokane Valley, WA 99212
Submitted to Jeff Brooks via electronic mail at [e-mail].
July 7, 2026
Mr. Jeff Brooks
Pipeline Safety Program Manager
Idaho Public Utilities Commission
11331 Chinden Blvd., Building 8, Suite 201-A
Boise, ID 83714
Re: IPUC Moscow District Field Audit Probable Violation Letter—Avista Response
Dear Mr. Brooks:
In your letter of May 28, 2026, you listed a Probable Violation discovered during the 2026
Moscow Field Audit that was conducted May 19-20, 2026. In this letter we have provided a
restatement of the probable violations as noted in your letter, and Avista's response.
Notice of Probable Violation (NOPV) References:
49 CFR §192.605
49 CFR §192.703
49 CFR 192.747
Avista Gas Standards Manual Section 5.13
Description of NOPVs
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.

49 CFR & 192,703 General
No person may operate a segment of pipeline,unless it is maintained in accordance with this
subpart.
49 CFR 6192,747 Valve Maintenance: Distribution System.
(a) Each valve, the use of which may be necessary for the safe operation of a distribution
system, must be checked and serviced at intervals not exceeding 15 months, but a least
once each calendar year.
Avista Gas Standards Manual-Section 5.13 Valve
GENERAL VALVE MAINTENANCE AND INSTALLATION NOTES:
Maintenance
Avista gas distribution and transmission valves, based on the criteria established in
Specification 2.14, Valve Design, shall be maintained to ensure they are operable and
serviced according to the following schedule:
FrequencyValve Category
Emergency omit lion b Trarin�ssion
VaWS(VaMes as spwftd in§192.1T9 and Once each cmkmdw Vow.tat
§192.181)that are necessary for Emen+W to etooeed 15 I'Mma a
Operabom
Emergency Curb Valves (Inaccessible meter Once each calendar year, not
sets, churches, schools, hospitals,jails, to exceed 15 months
convalescent homes. etc.
Regulator Stabon Isdadon VaWs)(isobbon Once each calendar year, not
valves as spedhd by 1192.181 to exceed 15 nvnihs
Every five years not to exceed
Secondary Valves 63 months (This is a Best
Practice but not a requirement)
Finding(s)-
The inlet valve associated with Regulator Station 3760 in Deary, Idaho was not identified as an
emergency valve. Additionally, no annual inspection records for this valve were provided when
requested and have not been made available to operating personnel as required.

Avista Response to NOPVs:
Avista concurs that the inlet valve to Regulator Station 3760 was neither properly mapped in
Avista's GIS Mapping system nor receiving the appropriate annual maintenance as required by
Federal Code and Avista Standards. Even with this being the case, when the valve was exercised
during the audit, it performed properly.
Back in 2020, Station 3760 was upgraded to a District Regulator Station (DR)from a Farm Tap
(SSFT)as part of Avista's Annual review of DR/SSFTs. At that time,the inlet valve should
have been verified to physically exist and be appropriately mapped in the GIS. Neither of these
activities occurred as that step has, erroneously, not been a documented/formal part of the annual
DR/SSFT review process.
Moving forward,the process is being enhanced to ensure all stations that are changed to a DR,
have an inlet valve that is designated an emergency valve and is set up appropriately for annual
maintenance. Additionally, the Avista Idaho Compliance Specialist researched back five years
looking for similar errors where SSFTs were converted to a DR and the inlet valve was
potentially overlooked for emergency valve classification and found no such problems.
Since the Moscow Audit, the valve in question has been formally maintained (Done on 6/11/26)
and mapped (Identified as PUM 1206). Annual Maintenance has been set up and will occur as
required moving forward.
Respectfully Submitted,
Ryan Bean, PE �KF2
Director,Natural Gas
RB/rkb
Cc: Carie Mourin, Manager, Gas Compliance, and Integrity
Ted Boyle, Manager, Lewiston Gas Operations