Letter Of Concern.doc

Letter of Concern

October 2, 2008

Mr. Eldon Book
Vice President, Operations
Intermountain Gas Company
555 S Cole Road
Boise, Idaho 83707

Dear Mr. Book

On August 11, 13 and September 8, 9, 2008, representatives of the Idaho Public Utilities Commission, Pipeline Safety, pursuant to Chapter 601 of Title 49, United States Code, conducted an onsite specialized inspection of your Idaho Falls, Boise, and Twin falls inspection units.

During the inspections of regulators stations, it was noted that four separate regulator stations had excessive vegetation growing around and under the regulators, piping, and relief stacks. Due to the unusual number of vegetation defects found during these inspections, the commissions concern is, if the grass/weeds were to catch fire, would the internal components fail due to high temperatures and prevent the proper operation of regulators and relief devices.

Although no direct 49 CFR cite addressing excessive vegetation is available, 192.739(a) (4) reads: ….inspections and tests to determine that it is properly installed and protected from, liquids, or other conditions that might prevent proper operation. As pipeline safety representatives, we feel this condition does not represent best maintenance and operating practices, and more attention to this issue is needed.

The above mentioned items were brought to the attention of your representatives during the onsite inspections. We would request that you review this matter and respond in writing within 30 days regarding the above issues including any planned corrective action.

We appreciate your attention to this matter and your efforts to promote pipeline safety.

Sincerely,

Ron Law
Executive Administrator
Idaho Public Utilities Commission