Letter Of Concern Avista 2012.doc

LETTER OF CONCERN

February 23, 2012

Mike Faulkenberry
Avista Utilities Company
1411 Mission Avenue
Spokane, WA. 99202

Dear Mike;

On February 7 and 8, 2012 The Idaho Public Utility Commission, Pipeline Safety Division, conducted an onsite compliance inspection of Avista’s pipeline safety records for the Idaho natural gas distribution system owned and operated by Avista Utilities for calendar year 2011.

As a result of the inspection, it appears there are three areas of concern that does not fully meet the intent of the pipeline safety regulations Title 49, Code of Federal Regulations, Part 192 for calendar year 2011.

The items listed below are of concern:

1. § 192.481 The atmospheric corrosion monitoring met the requirements for the system to be inspected at the required time intervals. However, several addresses revealed the corrosion inspector commented in the records that the meter and associated piping inspected was overbuilt, overgrown and other customer items were covering the meter and pipeline assemblies. Avista was unable to definitively show documentation that these meters and piping labeled as “overbuilt”, “overgrown” and “other customer items” were indeed inspected for corrosion.

2. § 192.723 All leak survey’s met the requirements to be performed with the required time intervals. However, upon review of the leak survey maps used, Avista was unable to definitively document that services and meters labeled as "cannot find" were indeed leak surveyed. A review of the gas maps in Avista's Electronic Mapping System seemed to suggest several possible reasons the contractor could not find the meter/service including mapping errors and in some cases lack of a diligent effort on the part of the contractor to walk around the entire structure to find the meter.

3. § 192.721 Review of pipeline patrol records for the Spokane Street Bridge in Post Falls indicated the inspector had documented the pipeline on December 12, 2011 having active corrosion where the pipeline entered a concrete abutment. Review of work order records revealed a work order had not been entered into the system for corrective action or follow-up. The company immediately sent a corrosion technician out to verify the condition and imputed a work order into the system for corrective action.

More detailed documentation and follow-up is required to ensure full compliance with Federal Regulations.

Please respond in writing within thirty days regarding the above concerns, and any planned corrective actions that will be implemented to prevent further deficiencies.

Because of the good faith that you have exhibited up to this time, we expect that you will act to bring your program into compliance with pipeline safety regulations.

Sincerely,

V. Joe Leckie
Executive Director
Idaho Public Utility Commission