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DECISION MEMORANDUM TO:COMMISSIONER KJELLANDER COMMISSIONER RAPER COMMISSIONER ANDERSON COMMISSION SECRETARY LEGAL WORKING FILE FROM:JOHNATHAN FARLEY BATE:JANUARY 22,2016 RE:FORMAL COMPLAINT OF ERIC CONRAD On December 27,2015,Eric Conrad filed a “formal”complaint (Attachment A)with the Commission against Intermountain Gas Company (IGC).Mr.Conrad is unsatisfied with the outcome of the Stalls efforts to informally resolve his complaint (Rules 2 1-24)and filed this “formal”complaint.While building a home near Idaho Falls,IGC required Mr.Conrad to purchase and install a meter protection structure at his own expense before the utility would provide gas service at his residence.He was frustrated by his inability to obtain information about the specific requirements for meter protection including technical design specifications for meter protection structures. In his letter to the Commission,Mr.Conrad requests: a.Compensation of $220 for Gas Cover and $150 in Labor for installation + $1,010.82 in construction loan interest because work had to be pushed off inside the home because of no heat. b.Review by PUC into Intermountain Gas Practices of requiring roofs over gas meters in an inconsistent manner and with no public facing information for owners or builders to know what is acceptable. BACKGROUND During the month of November 2015,Mr.Conrad was in the process of building a new home.1-le had been in contact with IGC in order to establish service at the residence.Prior to his initial interaction with IGC,Mr.Conrad’s contracted builder (J.B.Kay Construction)had installed gas lines in the home and predetermined a location for the gas meter to be installed. When Intermountain Gas came to Mr.Conrad’s residence to install a gas meter and connect service,the Company allegedly determined that the eaves on the residence were too DECISION MEMORANDUM 1 JANUARY 22,2016 narrow to protect the gas meter and that additional protection would be required prior to the installation of the meter.Mr.Conrad then built a freestanding wooden structure that would cover the meter when installed.Intermountain Gas allegedly determined that the wooden structure was inadequate because it was not permanently affixed to the residence and was not approved to meet snow load for the area by an engineer. When Mr.Conrad contacted Intermountain Gas for technical specifications for building snow covers,the Company provided the customer with photographs of protective measures (Attachment B)and a copy of a form letter dated April 19,2012,that apparently had been sent to builders,dealers and architects.The letter addressed the importance of safe meter locations and the need for an engineered structure if a safe meter location could not be identified.None of the materials provided by IGC had any technical specifications pertaining to what constitutes an adequate structure for protecting a gas meter. On November 13,2015,Mr.Conrad contacted the Staff and made an informal complaint. When contacted by Staff.Intermountain Gas maintained that Mr.Conrad’s residence needed additional protection for the meter due to the location of the meter and the narrow eaves on the home.Mr.Conrad indicated to Staff that he had driven around Rexburg and noted that a number of homes that had been built in 2015 did not have meter protection structures in place. Intermountain Gas was unable to provide Staff with the specific criteria or standards used to determine if additional meter protection is needed or any technical specifications for meter protection structures.Intermountain Gas did provide the following:(1)excerpts from Title 49, Part 192,Subpart H of the United States Code of Federal Regulations,(2)an excerpt from Sections 409 &410 of the 2012 International Fuel Gas Code;(3)an excerpt from Intermountain Gas’procedures for Siting Service Lines and A’feter Sets:and (4)photographic examples of constructed and prefabricated meter protection structures1.Staff forwarded documents 1,2,&3 above (Attachment C)to Mr.Conrad. Mr.Conrad subsequently installed a meter protection structure that satisfied the Company’s expectations. Staff notes that the CFR excerpt provided to staff is dated December 2008.The Commissions Safety and Accidental Reporting Rules adopt by reference the 2011 edition of49 CFR Part 192.See Safety Rule 201,IDAPA 3 1 .11.01 .201. DECISION MEMORANDUM 2 JANUARY 22,2016 STAFF QUESTIONS &CONCERNS 1.It appears the Company does not have any publications or other readily-available written materiai or detailed specifications regarding what constitutes an acceptable meter protection structure in areas where heavy or deep snow conditions exist.If such materials do exist,please provide copies. 2.It does not appear that builders,contractors or others engaged in construction activities are knowledgeable about Intermountain Gas Company’s meter protection requirements. If such information is provided,please provide copies,identifying when,how and to whom the information is provided. 3.What training is provided to Company employees to assure uniform and consistent application of the Company’s meter protection requirements? 4.Staff notes that IGC Procedures,Section C.6.f,states that “IGC will provide protection for meter sets when required.”See Attachment C3,p.4.To whom and in what circumstances does this provision apply? 5.The Commission’s Safety and Accident Reporting Rules (IDAPA 31.11.01)adopt by reference several national safety codes applicable to natural gas utilities and federal safety regulations applicable to natural gas and pipeline utilities.Staff is concerned that the adopted current editions of these codes and regulations are not made available to the Company’s employees,customers and other interested parties. STAFF RECOMMENDATION Staff recommends the Commission issue a summons to Intermountain Gas Company and direct the Company to file a response to the Complaint and address Staffs questions below. COMMISSION DECISION Does the Commission wish to accept Mr.Conrad’s formal complaint?Does the Commission wish to issue a summons? - .)Johnathan Farley “ / Udmemos/Conrad Complaint dec memo DECISION MEMORANDUM 3 JANUARY 22,2016 rfCCLI::DDecember2l5,2015 20150EC2$MI 9:LEricW.Conrad 2277 Hendricks Circle IDAHO ruTLC Rexburg,ID 83440 UTILITIES COMMISSION 208-201-6692 -- e ricwcon ra d m a iI.com Public Utility Commission Secretary Jean Jewell 472 West Washington Street P.O.Box83720 Boise,ID 83720-0074 Dear PUC: Having held senior management positions at AT&T,US WEST,AIMCO and CB Richard Ellis I know that working through the PUC is sometimes the only way to get the attention of large monopolistic companies. Per Rule 54 I am making a complaint on behalf of myself (Owner of new property at 2277 Hendricks Circle)and all other new home owners in the counties of Freemont,Madison,Bonneville,Bingham and Caribou counties who have been required to install snow covers for gas meters. 01)Respondent a.Intermountain Gas Company 02)State the Facts a.Intermountain Gas Company is requiring covers for gas meters inconsistently across their coverage area. b.No public facing information for owners or builders is available to understand what is required to meet their requirements and to estimate the costs of such a requirement. 03)Applicable Provisions a.After multiple inquiries to Intermountain Gas for clarification on what would be an acceptable roof over the gas meter I contacted the PUC for help.An informal request was made to Intermountain Gas by iohnathan Farley for clarification.Johnathan was able to obtain IGC Procedures #4017 (Attached)and Part 192 Transportation of Natural and other gas by Pipeline (Attached).Both of these documents are internal documents to Intermountain Gas and are nowhere to be found in the public domain. b.Procedures #4017 states the following: i.“Protected by gutter or eave line if possible.” N.“On the gable end if possible” iii.“IGC will provide protection for meter sets when required.” iv.“When heavy or deep snow conditions exist,a higher aspect meter set that exceeds the height of a standard installation should be a consideration” c.Part 192 states the following: i.“Be rain and insect resistant” ii.“Be protected from damage caused by submergence in areas where flooding may occur” Attachment A Decision Memorandum Page I of33 iii.“Each meter and each regulator must be installed so as to minimize anticipated stresses upon the connecting piping and the meter.” 04)State the Relief Desired: a.Compensation of $220 for Gas Cover and $150 in Labor for installation +$1,010.82 in construction loan interest because work had to be pushed off inside the home because of no heat.- b.Review by PUC into Intermountain Gas Practices of requiring roofs over gas meters in an inconsistent manner and with no public facing information for owners or builders to know what is acceptable. 05)Process:I am willing to travel to Boise at my expense to testify or work through the PUC in anyway the PUC deems necessary to fix this problem. As Ever, Eric W.Conrad Attachment A Decision Memorandum Page 2 of33 PART 192 -TRANSPORTATION OF NATURAL AND OTHER GAS BY PIPELINE:MINIMUM FEDERAL SAFETY STANDARDS Subpart H—Customer Meters,Service Regulators,and Service Lines §192.351 Scope. This subpart prescribes minimum re quirements for installing customer meters, service regulators,service lines,service line valves,and service line connections to maths. [Pan 192-Org.,Aug.19,1970] §192.353 Customer meters and regula ton:Location. (a)Each meter and service regulator, whether inside or outside a building,must be installed in a readily accessible location an4 be protected from corrosion and other damage,including,if installed outside a buildinj vehicular damage that may be an ticipated.However,the upstream regulator in a series may.be buried. (b)Each act-vice regulator installed within a building must be located as near as practical to the point of service line en- france. (c)Each meter installed within a build ing must be located in a ventilated place and not less than 3 feet (914 millimeters)from any source of ignition or any source of heat which might damage the meter. (d)Where feasible,the upstream regula tor in a series must be located outside the building,unless it is located in a separate metering or regulating building. [Part 192 -Org.,Aug.19,1970,as amended by Amdt.192-85,63 FR 37500,July 13, 1998;Amdt.192-93,68 FR 53895,Sept. 15,2003) §192.355 Customer meters and regula tors:Protection from damage. (a)Protection from vacuum or back pressure.If the customer’s equipment might create either a vacuum or a back pressure,a device must be installed to protect the sys tem. (b)Service regulator vents and relief vents,Service regulator vents and relief vents must terminate outdoors,and the out door terminal must: (1)Be rain and insect resistant; (2)Be located at a place where gas from the vent can escape freely into the almos- phere and away from any opening into the building;and, (3)Be protected from damage caused by submergence in areas where flooding may occur. (c)Pits and vaults.Each pit or vault that houses a customer meter or regulator at a place where vehicular traffic is anticipated, must be able to support that traffic. [Part 192-Org.,Aug.19,1970,as amended byArndt.192-58,53 FR 1633,Jan.21, 1988] §192.357 Customer meters and regula tors;Installation. (a)Each meter and each regulator must be installed so as to minimize anticipated stresses upon the connecting piping and the meter. (b)When close all-thread nipples are used,the wall thickness remaining after the threads are cut must meet the minimum wall thickness requirements of this part. (c)Connections made of lead or other easily damaged material may not be used in the installation of meters or regulators. Revision 12/08 —Current thni 192-108 Attachment A 58/146 Decision Memorandum Page 3 of 33 GAS PIPING INSTALLATIONS 409.2 Meter valve.Every meter shall be equipped with a shutoff valve located on the supply side of the meter. 409,3 Shutoff valves for multiple-house line systems. Where a single meter is used to supply gas to more than one building or tenant,a separate shutoff valve shall be provided for each building or tenant. 409.3.1 Multiple tenant buildings.In multiple tenant buildings,where a common piping system is installed to supply other than one-and two-family dwellings,shutoff valves shall be provided for each tenant.Each tenant shall have access to the shutoff valve serving that tenants space. 4093.2 Individual buildings.In a common syslem serv ing mnre than one building,shutoff valves shall be installed outdoors nt each building. 409.33 Identification of shutoff valves.Each house line shutoff valve shall be plainly marked with an identifica tion tag attached by the instnller so that the piping systems supplied by such valves are readily identified. 409.4 IMP regulator valves.A listed shutoff valve shall be installed immediately ahead of each NIP regulator. 409.5 Appliance shutoff valve.Each appliance shall be pro vided with a shutoff valve in accordance with Section 409.5.1,409.5.2 or 409.5.3. 409.5.1 Located within same room.The shutoff valve shall be located in the same room as the appliance.The shutoff valve shall be within 6 feet (1829 mm)of the appliance,and shall be installed upstream of the union, connector or quick disconnect device it serves.Such shut off valves shall be provided with access.Appliance shut off valves located in the firebox of a fireplace shall be installed in accordance with the appliance manufacturer’s instructions. 409.5.2 Vented decorative appliances and room heat ers.Shutoff valves for vented decorative appliances,room heaters and decorative appliances for installation in vented fireplaces shall be permitted to be installed in an area remote from the appliances where such valves are pro vided with ready access.Such valves shall be permanently identified and shall serve no other appliance.The piping from the shutoff valve to within 6 feet (1829 mm)of the appliance shall be designed,sized and installed in accor dance with Sections 401 through 408. 409.5.3 Located at manifold.Where the appliance shut off valve is installed at a manifold,such shutoff valve shall be located within 50 feet (15 240 mm)of the appliance served and shall be readily accessible and permanently identified.The piping from the manifold to within 6 feet (1829 mm)of the appliance shall be designed,sized and installed in accordance with Sections 401 through 408. 409.6 Shutoff valve for laboratories.Where provided with two or more fuel gas outlets,including table-,bench-and hood-mounted outlets,each laboratory space in educational, )research,commercial and industrial occupancies shall be pro vided with a single dedicated shutoff valve through which all such gas outlets shall be supplied.The dedicated shutoff valve shall be readily accessible,located within the labora 2012 INTERNATIONAL FUEL GAS CODE’ tory space served,located adjacent to the egress door from the space and shall be identified hy approved signnge stating “Gas Shutoff.” SECTION 410 (IFGC) FLOW CONTROLS 410.1 Pressure regulators:A lin4ressure regulator shall be installed where the opplia:ce is designed to operate at a lower pressure than the supply pressure.Line gas pressure regulators shall be listed as complying with ANSI Z2l.80. Access shall be provided to pressure regulaturs.Pressure reg ulators shall be procctccl from physical damage.Regulators installed on the exterior of the building shall be upproi’ed for outdoor installation. 410.2 NP regulators.MP pressure regulators shall comply with the following: 1.The MP regulator shall be approved and shall be suit able for the inlet and outlet gas pressures for the appli cation. 2.The MP regulator shall maintain a reduced outlet pres sure under lockup (no-flow)conditions, 3.The capacity of the MP regulator,determined by pub lished ratings of its manufacturer,shall be adequate to supply the appliances served. 4.The MP pressure regulator shall be provided with access.\Vhcre located indoors,the regulator shall be vented to the outdoors or shall be equipped with a leak- Limiting device,in either case complying with Section 410.3. 5.A tee fitting with one opening capped or plugged shall be installed between the MP regulator and its upstream shutoff valve.Such tee fitting shall be positioned to allow connection of a pressure-measuring instrument and to serve as a sediment trap. 6.A tee fitting with one opening capped or pitigged shall be installed not less than 10 pipe diameters downstream of the ML’regulator outlet.Such tee fitting shall be positioned to allow connection of a pressure-measuring instrument. 410.3 Venting of regulators.Pressure regulators that require a vent shall be vented directly to the outdoors.The vent shall be designed to prevent the entry of insects,water and foreign objects. Exception:A vent to the outdoors is not required for regu lators equipped with and labeled for utilization with an approved vent-limiting device installed in accordance with the manufacturer’s instructions. 410.3.1 Vent piping.Vent piping for relief vents and breather vents shall be constructed of materials allowed for gas piping in accordance with Section 403.Vent piping shall be not smaller than the vent connection on the pres sure regulating device.Vent piping serving relief vents and combination relief and breather vents shall be run independently to the outdoors and shall serve only a single device vent.Vent piping serving only breather vents is permitted to be connected in a manifold nrrangcment Attachment A Decision Memorandum 75 Page 4 of33 Home >Operations Procedures 3O00!4000]>DOT Required >Customer Meters, Service Regulators and Service Lines >Siting Service Lines and Meter Sets 14017] IGC PROCEDURES DATE:01/31/05 TITLE:Siting Service Lines and Meter Sets NUMBER:4017 REFERENCES I PURPOSE I SCOPE GENERAL I RESPONSIBILITY I STANDARDS I SERVICE LOCATIONS I METER LOCATIONS I EXAMPLES REFERENCES Regulations ICC General Service Provisions 49 CFR 192,351,353,355,357 Policy 501 Gas Delivery Pressure Procedures 4019 Curb and Other Property Line Valves 4015 Upstream Regulation of High Pressure Service Lines (Farm Taps) RoofTop Distribution System 9375 Service Line Installations 4026 P.E.Plastic Pipe System Design and Installation PURPOSE Attachment A Decision Memorandum -- -Pagesof3j Provide proper guidelines for determining service line,meter set,and riser locations and routes for the service line that are acceptable and safe under the General Service Provisions and applicable safety,building codes and operating policies. SCOPE Applies to all Company personnel assigned the responsibility of selecting service line routes and meter locations. GENERAL Service lines will be installed at the minimum total length necessary to conform with Company requirements regarding meter set locations. The criteria for service lines to be installed in conjunction with new mains is contained in Procedure 9371 Plant Additions-Revenue. When a service line cannot be located according to the requirements of this Procedure,contact the Operations/Division/District Manager for instructions. As described in Section A,Paragraph 12.9 of the General Service Provisions,a second service line will be installed for a customer only when the second location is justified and more than fifty (50)feet from the existing service line.See also Rooftop Distribution Systems,and 9375,Service Line Installation. Meter sets will be located along the wall of the structure least susceptible to future building,fencing or other additions.Residential meter sets will not be located in the rear of the dwelling, unless circumstances are such that the rear of the dwelling is the most feasible and desirable location available (townhouses,alley distribution system,etc.).When a Service Line application shows a rear meter location,an explanation of the conditions requiring such a location must be included on the 512-A.This explanation will be reviewed and accepted by the Marketing Manager and submitted to the Regional/Division/District Manager for approval prior to installation of the service line. RESPONSIBILITY The Operations Managers are responsible for the administration of this Procedure. Attachment A Decision Memorandum Page 6 of33 STANDARDS A.Selecting Service Locations 1.Precautions to take regarding service locations a.When possible,select a termination location for the service line that is at least twelve inches (12”)from other underground facilities,If it is a joint trench service line,ensure that the service is installed according to joint trench specifications. b.Do not wn plastic systems within the influencing area of any system that radiates temperatures above 1000 F.If there is a concern that this may occur,contact General Office Engineering for necessary calculations, 2,When paralleling a foundation for more than five (5)feet,select a location for the service line at least three (3)feet from the foundation, whenever possible.If a basement has been excavated,and there could be excessive soil settling,the service should be run outside of the disturbed soil area. 3.Whenever paralleling a sidewalk or retaining wall and if possible, select a location at least one (1)foot from the sidewalk and three (3) feet from the retaining wall,when possible. 4.Select service line locations so that adjacent private property is not crossed unless a properly executed right-of-way agreement is obtained, 5.Whenever possible,avoid selecting line locations where the service will pass under concrete slabs,carports or through retaining walls. Avoid periodic maintenance areas over septic tanks,oil and gasoline tanks etc. 6.Whenever possible install service line locations so that the service line will run in a straight line from the stub or tee to the service line riser location. 7.Consider possible future additions to the property and locate the service so that it will not be built over or have the meter location fenced in at a later date. 8.Any service lines running under a building will be encased.The casing will be sealed and vented to the outside at the point where it enters the building.Service lines will not be installed under a building without Operations Manager approval. C.Riser and Meter Set Locations Position the riser and meter set in a readily accessible location.The meter and meter stop must be easily accessed in case of emergencies and for routine maintenance and meter reading. When possible select a location outside an area that is,or may be fenced. Attachment A Decision Memorandum Page 7 of33 1.The meter shall be located at the point on the structure: a.As close to stub or main as possible. fr trotected bjgufter or eave line if posthble d.If main line is in the front of the structure;place riser as close as possible to the front of the structure;however,the service riser and meter shall be located at least 18”horizontally from an electrical meter.(See Example 1)(Most common distance is four (4)feet.) e.If main line is behind the house;place the riser at the closest point in the back of the structure maintaining the 1 8”horizontal distance from the electrical meter or service panel. 1.Manifolds shall be located in the same manner as single meters and allow for the required width for the number and size of the meters.If a stack manifold is required,the upper portion shall be secured to the structure during installation. 1.When the meter and service regulator will be installed outside the building, select location of service line riser to meet the following: a ervice line nserwjhEe lo6átd a m’n,niiim octiv!inch 12roQthe building-and protcteg from arfttcipated Where a main customer valve is used,an additional 3”to 4” shall be needed for house line installation.Large meter sets shall be sited as needed for clearance. b.Do not locate under or in front of windows or other building openings which may be used as emergency fire exits or under interior or exterior stairways. c.When the service line riser is on the driveway side of a dwelling,at least three (3)feet of spacing between the driveway and the building is necessary.Additional protection will be provided,such as a meter guard.(See Example 5) d.Where a service line riser is likely to be set in paving of any kind,a short piece of two inch (2”)or larger P.E.pipe will be used to sleeve the pipe at ground level. e.When a meter is set outside a school,a permanently locked fence or enclosure may be provided by the Company. f;ICC iIl provideprotection for meter sets when required. g.When locating a riser for a large meter set,adequate space and access shall be provided to allow for normal maintenance and testing. 1.Select location for service line and service line riser and meter set for large commercial and industrial services to meet the following additional requirements: Attachment A Decision Memorandum Page 8 of33 a.When the service line will parallel the foundation,a minimum of five (5)feet clearance from the building will be maintained. b.The meter will not be located directly underneath and will have at least three (3)feet minimum horizontal clearance from an electric panel,air intake or any equipment that could possibly be a source of ignition. c.Space requirements for large meter sets will be determined from the meter set design.See specified or standard meter set drawings. d.When meters are set outside a school,a permanent locked fence or enclosure may be provided by the Company. e.When meters are set outside a church and extra security is necessary,a permanent locked fence or enclosure,with SC access,is to be provided by the customer. When the meter and service regulator will be set inside the building,the location for the service line riser will meet the following requirements: NOTE:Written approval must be obtained from the Operations Manager for any inside meter set.That approval must be attached to the asbuilt drawing on Form 512-A or 319. a.The service line riser,meter stop and service line entrance into the building will be as near as practicable to the meter and regulator location. b.When possible,the service line riser and meter stop will be above ground outside the building and the entrance of the service line into the building will be above ground with a readily accessible outside shut-off valve. c.Any service entrance into the building below ground will incorporate an outside curbvalve and will be cased and the casing sealed at the points the service line enters and exits the casing.The casing must be vented to the outside atmosphere. d.All regulators located inside a building must be located in a ventilated area and not less than three feet from any source of ignition or heat which could damage the meter.All inside regulators will be vented separately to the outside of the structure and installed to prevent water buildup and entry of insects and debris. e.A meter and regulator installed in a recessed opening is considered an outside meter set if the following conditions are met: i.The recess has an exterior wall N.The service line enters the recess above ground (over the sill) Ni.The recess is lined with fireproof and vapor-proof material 1.Any service line riser cannot be located to meet the requirements of this Procedure shall be referred to the OperationslDistrict Manager. Attachment A Decision Memorandum Page 9 of33 NOTE:ICC will provide protective steel posts for the meter set,when required,where no protection is provided by the customer.Adequate meter protection consists of either the company approved meter guard,(Example 5)a two inch (2”)or four inch (4”)diameter post,or a permanent protective wall. 1.No meter or service regulator will be located in a pit or vault.Contact the Operations Manager for alternative locations. 1.When services and meters are on a rooftop system,see Procedure 4016 Rooftop Distribution Systems,for requirements. 1.Meters installed on manufactured housing where flex connectors are utilized shall have the meter bar assembly stabilized by use of a meter bar support. C.Riser and Meter Set Height 1.Standard installation height shall be achieved when the bottom of the stop equals the height of foundation.(Caution should be taken to ensure the bury line on the riser is not below future grade).(See Example 6) 2.Installation height of larger meters and meters installed on multilevel foundations shall be accomplished by determining future grade according to building specification.This may be determined by: a.Contacting builder b.Reviewing plans a.Future grade indicators that exist or are apparent. C.Riser and Meter Height -Heavy or Deep Snow Area’s -Wheq heavy or de r o nditions exist”igher aspecmeter set that eêêd1the height of stan_çJ 1lain should coñsidefalidh (See ,E*ánjp!&4) 2 •In deep snow areaso ing off the ro puldalsqbe considered a damaging force.ShoW shields ha ethatailedif naç’. If a safe rneterJocaiontan not b identified on a hor!ieocb,uitdiênpng!nQr?d4ructureIhaIllows:sJequateventilatiqn.snd !designe,to aet tl)e potential snow lopd can be used to protect the meter and must be in plac,pnor to eüichéihfràëtiVatêd. 4.If an engineered structure for meter protection is used,an engineer’s signature will be needed approving the structure’s design and ability to protect the meter from snow and ice.(See Example #7 Approval of Engineered Design for Meter Protection.)This approval shall be signed and added to the asbuilt and added to Scanned Images with the asbuilt D.Regulator Venting Requirements 1.Regulators shall be installed vertically with the vent pointed downward 2.Regulators that cannot be installed with vent pointed downward shall have additional vent piping installed to ensure downward venting 3.Vents will be screened or have caps installed to prevent entry of water, insects,debris,or foreign objects Attachment A Decision Memorandum Page 10o133 4.In high snow aspect areas vents will be extended to above the anticipated snow level 5.Extended vent piping will be placed in such a position to prevent entry of water,insects,debris,or foreign objects and protected from heavy snow or water run off 6.Vent piping will be sized according to the size of the vent opening on the regulator 7.Vent piping will be secured as necessary 8.If a meter set is located within three (3)feet of any air intake which is permanently opened into a structure,the regulator will be vented remotely from the area.Note:Windows,whether operable or non-operable,are not considered an air intake. 9.Meter locations protected under roof valleys and eaves where run off due to rain and snow may affect the regulator vent shall have the regulator vent piping extended to a protected location 10.All inside regulators shall be vented separately to the outside of the structure and installed to prevent water buildup and entry of insects and debHs E.Meter Stop Valve Installation and Replacements 1.Service riser applications sized 3/4”through 2”(single meter and manifolds) operating at 60 psig or less shall use a valve stop with an insulating union incorporated in the body of the stop 2.Greater than 60 psig operating pressure -High pressure installations shall require a.Non insulated stop. b.Insulation shall be obtained by one of the following: i.Insulating union downstream of the secondary pressure regulator fl.Flange gasket insulators at the flanges (2)of a flanged by-pass riser 2.Maintenance -In the course of performing maintenance to resolve leaking spuds or to remediate cathodic protection issues at the meter set assembly,the following actions should be performed where applicable: a.Replace a non-insulated valve stop with an insulated valve stop, b.Replace meter loop assembly with a pre fabricated meter loop incorporating a customer valve in the meter loop and non-insulated spuds. c.Replace a non-insulated valve stop with an insulated valve stop without a pre fabricated meter loop when alignment with existing house piping is not feasible. EXAMPLES Attachment A Decision Memorandum Page II of33 EXAMPLE 1 Distance from Electrical Meter EXAMPLE 2 Flex Riser EXAMPLE 3 Support Assembly EXAMPLE 4 High Aspect Riser EXAMPLE 5 Meter Guard EXAMPLE 6 Standard Meter Installation EXAMPLE 7 Approval of Engineered Design for Meter Protection 4017-Siting Service Lines and Meter Sets Attachment A Decision Memorandum Page 12of33 Qmail -Meter Protection Page 1 of 18 c:;riai Eric Conrad <ericwconrad@gmail.com> Meter Protection 27 messages Robinson,Sarah <SARAH.ROBINSDN©intgas.com>Thu,Nov 12,2015 at 4:47 PM To:‘ericwconrad@gmail.com”<ericwconrad@gmait.com> Per our telephone conversation,please see the attachments regarding meter protection.I have also attached some examples of meter protection that has been approved in our area. If you have further questions,please let tile know. Thank You, Sarah Robinson Intermountain Gas Company Operations Aide,Teton District 208-542-6616 (Phone) 208-542-6639 (Fax) C n’ Sarah.Robinsonintgas.com (Email) A JNTERMOUNTMN LI GAS COMPANY C’n.‘-0 4:- 5 attachments IMG_201 30925_I 55735_I 10.jpg 667K Attachment A Decision Memorandum Page 13 o133 hups://mail.google.comJmajl/ulOfluj=2&ilc=dde5549800&vjew=pt&search=inbox&th=1 11/30/2015 Gmail -Meter Protection Page 2 of 18 ij Untitled (12).pdf 465K photo.JPG 3922K photo (3).JPG 2708K Erie Conrad <ericwconrad@gmail.com> To:Kami Conrad <kamiconrad@outlook.com> [Quoted text hidden] Thu,Nov 12,2015 at 4:53 PM 5 attachments IMG_201 30925_I 55735_I 1O.jpg 667K Attachment A Decision Memorandum Page 14 of 33 luntitiedl.Pdf 870K https://mail.google.com/mail/uJO/?ui2&i1edde5549800&viewpt&searchinbox&tIvl 11/30/2015 Omail -Meter Protection Page 3 of 18 photo.JPG 3922K photo (3).JPG 2708K Untitled (12).pdf 465K Eric Conrad <ericwconradgmail.com>Thu,Nov 12,2015 at 9:58 PM To:bhill@ruddco.com,bhill@senate.idaho.gov Brent:I think!have uncovered something at Intermountain Gas that may not be illegal,but I definitely can not find any information about the requirements of dog house roofs being OK’d by the PUC,I have been on the Idaho Public Utilities Web site and can not find any information on this requirement,nor can I find anywhere to lodge a complaint Can you direct me to someone at the PUC that I can speak with? Long story short.lntermountain Gas is holding me hostage and not hooking my Gas meter up because they require some type of cover over the gas meter.When I asked for clarification,I was sent the following POF and pictures.No height or width requirements,etc.You will see in the letter that it is vague at best on rules to follow. ‘3 I called lntermountain Gas out to install the meter over three weeks ago.They came out,left a voice mail on my contractors phone (J.B.Kay and said they couldn’t install until the meter was covered.)We had hoped the overhang was out far enough and when the gutter was on we would get approval.So,i called g Intermountain Gas again to get clarification and ask them to come out and install the meter.They would :; not install a Gas Meter until a shed was installed.So my contractor built a temporary shed to cover the (Untitledj.pdf 870K httns://mail.google.comlmail/u/0/?ui2&ikdde5549800&viewpt&searchinbox&th 1...11/30/2015 Gmail -Meter Protection Page 4 of 1$ area of the gas meter until we can get the rain gutters up.They came out today and did not install the gas meter again,saying that I needed a “Permanent Covering”. I called the Idaho Falls office of Intermountain Gas this afternoon to find out what exactly I needed.They sent me the attached information.I read through it and found it very unprofessional in how they could hold anyone to a standard with the required documents.I would expect if it was law,that they would reference the law.If it was an internal requirement that they would have a spec sheet outlining how big the roof should be over the gas meter,how high above the ground,etc. I have to get gas,I have $30,000 in wood flooring that is going to fail because they will not provide gas until I meet their demands.I finally relented and said I would have the contractor buy a prefabbed roof and get it installed tomorrow.I asked to schedule another time to get the gas meter installed and they refused to discuss even scheduling a time for an install until I could prove I had the roof installed.I assured them I would have something installed,but at this point I worried if it would be everything they expected when I could not find anything in writing that outlined all expectations. Anyway,can you forward me to someone at the PUC that can help?Also a media person at the PUC, because I think the public should be aware.I should have an interview tomorrow with Local News 8 lined up by mid morning,they said they are very interested in doing investigative reporting like this. Thanks,Eric Forwarded message From:Robinson,Sarah <SARAH.ROBINSONintgas.com> Date:Thu,Nov 12,2015 at 4:47 PM Subject:Meter Protection To:“ericwconrad@gmail.com”<ericwconradgmail.com> [Quoted text hiddeni IMG_201 30925_155735_1 1O.jpg 667K photo.JPG 3922K Attachment A Decision Memorandum Page 16of33 5 attachments https://mail.google.corn/mail/u/0/?ui=2&ikdde5549800&viewpt&search=inbox&thl ...11/30/2015 Gmail -Meter Protection Page 5 of 18 Untitled (12).pdf 465K photo (3).JPG 2708K Eric Conrad <ericwconradgmail.com> To:“Robinson,Sarah”<SARAH.RO8lNSONintgas.com> Cc:Jared Kay <jared@jbkayconstruction.com> Sarah: Thu,Nov 12,2015 at 10:38 PM Thanksfor sending this information and speaking with me this afternoon.I just wanted to insure I heard you correctly this afternoon.I completely understand the gas company wanting to protect the meter from ice build up.I have an overhang on my new residences.and will have gutters installed,but this is not adequate per the attached document and your comments.You rnention overhangs that have been approved,how were they approved and what was the criteria to approve them? 1)If an overhang s not adequate,the picture of the extended overhang you sent seems to meet the requirement but no specifications are mentioned of what that overhang should be. 2)when I asked for clarification on the pictures you sent you said there are no specifications on height (rpm ground,how large thp structure should be or any specifications other Than the required signature from n engineer?What specifications is an engineer supposed to validate his design calculations against? 3)When I questioned why my dog roof that I put in place was not good enough for the gas meter,you said itfleded tO be “permanent”and also stated that this is what it said in the technician notes.I can not find anything in the information you sent me that uses the word permanent Although it does state it needs to meet engineers snow load. 4)I have driven around Rexburg and have noted a number of homes that have been started and completed construction this year that do not have dog house roofs.I am confused.Would you like the addresses to verify my observations? As you have required,I will call back once the prefab roof is in place,but can you clarify for my contractor and myself how far above ground it is to be located? Thanks,Eric Conrad 208.201.6692 [Quoted text hlddenj Senator Brent Hill <bhillsenate.ldaho.gov> To:Eric Conrad <ericwconradgmaiI.com> Senator Brent Hill FrI,Nov13,2015 at 8:54 AM Attachment A Decision Memorandum Page 17 of33 [Untitledj.pdf 870K hflnv//ninfl annole.r.nm/mnflhi/0/7iii=7&rik=dde5S4QRflfl&wjew=nt&senrch=jnhny&th=1...11/10/2015 borwarcea message From:Robinson,Sarah <SARAH.ROBINSONintgas.com> Date:Thu,Nov 12,2015 at 4:47 PM -- Subject:Meter Protection To:“ericwconradgmail.com’<ericwconradgmail.com> <imageOOl.jpg> Per our telephone conversation,please see the attachments regarding meter protection.I have also attached some examples ofmeter protection that has been approved in our area. if you have further questions,please let me know. Thank You, Sarah Robinson Tutermountain Gas Company Operations Aide,Teton District 208-542-6616 (Phone) 208-542-6639 (Fax) Sarah.Robinsonintgascom (Email) <JmqgeOO2.png> <IMG_201 30925_i 5573511 0.jpg><photo.JPG’<photo (3).JPG><[Unthled].pdPcUnUhled’ (1 2).pdf https:I/maiLgoog1e.comImai1/&O/?uj=2&j1dde55498O0&vie=pt&searehnbox&th=1 ..11/30/2015 Attachment A Decision Memorandum Page l8of33 Gmail -Meter Protection Page 8 of 18 Eric Conrad <ericwconrad@gmail.com> To:“Robinson,Sarah”<SARAH.ROBINSON@intgaS.com> Thanks,will do. [Quoted text hidden] Fri1 Nov 13,2015 at 8:58 AM Eric Conrad <ericwconradgmail.com> To:johnathan.farlypuc,idaho.gov Here you go,thanks for your call. Forwarded message From:Robinson,Sarah <SARAH.RO8lNSONintgas.com> Date:Thu,Nov 12,2015 at 4:47 PM Subject:Meter Protection To:“ericwconradgmail.com”<ericwconradgmail.com> [Quoted text hidden) Fri1 Nov 13,2015 at 10:35 AM 5 attachments IMG_201 30925_I 55735_Il 0.jpg 667K photo.JPG 3922K photo (3).JPG 2708K Attachment A Decision Memorandum Page 19of33 ...-.c..IL./nIo..:_-,ii nnnni c Ornail -Meter Protection Page 9 of 18 [Untitled].pdf 870K Untitled (12).pdf 465K postmastercio.idaho.gov <postmastercio.idaho.gov>Fri1 Nov 13,2015 at 10:36 AM To:ericwconrad@grnail.com -—The following addresses had delivery problems — <johnathan.farly©pucidaho.gov>(5.3.4 Message size exceeds fixed maximum message size) Forwarded message——— From:Eric Conrad <ericwconrad@gmail.com> To:johnathan.farly©pucidaho.gov Cc: Date:Fri1 13 Nov2015 10:35:33 -0700 Subject:Fwd:Meter Protection Here you go,thanks for your call. Forwarded message From:Robins O noname.eml 3K Eric Conrad <ericwconrad@gmail.com>Fri1 Nov 13,2015 at 10:36 AM To:johnathan.farley@puc.idaho.gov Here is the e-mail I sent last night with my concerns.No response yet. I also asked for her supervisor to call me,no response yet. Thanks,Eric fOucted text hiddenj Johnathan Farley <Johnathan.Farleypuc.idaho.gov>Fri1 Nov 13,2015 at 10:44 AM To:Eric Conrad <ericwconrad©gmail.com> Hi Eric, I have your received your email and will get on this issue. All the best, John Attachment A Decision Memorandum Page 20 of3J Giai1 -Meter Protection Page 10 of 18 From:Eric Conrad [mailto:ericwconrad@gmail.com] Sent:Friday,November 13,2015 10:37 AM To:Johnathan Fancy <JohnathanFanleypuc.idaho.gov> Subject:Fwd:Meter Protection IQuoted Iext hidden] Eric Conrad <ericwconradgmail.com> To:tkunz@kidk.com Fri1 Nov 13,2015 at 10:54 AM Todd:Let me know if you are interested in doing any investigative reporting on this,I can be reached at 208,201.6692. Long story short,I have spoken with Brent Hill Senate Pro Temp President,PUC commissioner and Johnathan Farley of the Consumer Protection Division about the requirement of these roofs over gas meters that are now being required.Doesn’t look like anyone in Boise knows about this.Some homeowners required and others not?No specifications on how to build them or where,sounds like SE Idaho Management an lntermountain gas have gone rogue. Thanks,Eric Forwarded message From:Robinson,Sarah <SARAH.ROBINSON@intgas.com> Date:Thu,Nov 12,2015 at 4:47 PM Subject:Meter Protection To:“enicwconradgmail.com”<enicwconradgmail.com> [Quoled text hidden] IMG_20130925_155735_1 IO.jpg 667K photo.JPG 3922K Attachment A Decision Memorandum Page 21 of33 0 I ._I_0.4,1._I 5 attachments photo (3).JPG 2708K II ——lnnnnn I 1/In/nAiC Omail -Meter Protection Page 11 of 18 .;J.J - Untitled (12).pdf 465K Eric Conrad <ericwconrad@gmail.com> To:johnathan.fadeypuc.idaho.gov Fri1 Nov 13,2015 at 10:55 AM Looks like you have a size limit.Ill do individually. Forwarded message From:Robinson,Sarah <SARAH.RQBINSONintgas.com> Date:Thu,Nov 12,2015 at 4:47 PM Subject:Meter Protection To:“ericwconradgmail.com”<ericwconrad@gmail.com> [Quoted text hidden] [Untitledj.pdf 870K Eric Conrad <ericwconrad@gmail.com> To:johnathan.farleypuc.idaho.gov A few pictures with no specs... Forwarded message From:Robinson,Sarah <SARAH.ROBINSON@intgas.com> Date:Thu,Nov 12,2015 at 4:47 PM Subject:Meter Protection To:“ericwconrad©gmail.com”cehcwconrad©grnaiLcom> [Quoted text hidden] Fri1 Nov 13,2015 at 10:57 AM 2 attachments IMG_201 30925_155736_1 I O.jpg 667K Attachment A Decision Memorandum Page 22 of 33 [Untitled].pdf 870K Ghai1 -Meter Protection Page 12 of 18 photo (3).JPG 2708K Thanks,Eric.I received the pdf and the photos. Best, John Fri,Nov 13,2015 at 11:00AM From:Eric Conrad [mailto:ericwconradgmaN.comJ Sent:Friday,November 13,2015 10:58 AM To:Johnathan Farley <Johnathan.FarIeypuc.idaho.gov> Subject:Fwd:Meter Protection A few pictures with no specs... [Quoted text hidden Eric Conrad <ericwconrad@gmail.com> To:Johnathan Farley <Johnathan.Farleypuc.idaho.gov> Fri1 Nov 13,2015 at 6:24 PM Any progress today?I have not had any response from my e-mail or phone call yesterday with Intermountain Gas.I assume they are on lockdown in communicating with me?That doesn’t really help my problem and even shows they are holding me hostage and stonewalling me even more.Great ethics case. Anyway,let me know.Thanks for your work.Eric Attachment A Decision Memorandum Page 23 of33 Johnathan Farley <Johnathan.Farleypuc.idaho.gov> To:Eric Conrad <ericwconrad@gmail.com> I -‘I----”—I—-1!.In!o..:_’Ii /‘fl/’7fl1 S Grnail -Meter Protection Page 13 of 18 [Quoted text hiddeni Johnathan Farley <Johnathan.Fadeypuc.idaho.gov>Mon,Nov 16,2015 at 8:03 AM To:Eric Conrad <ericwconrad@gmail.com> Good Morning Eric, When you open a complaint with the PUC,it is our protocol to have to company cease communication with the customer.I should hear back from them today. All the best, Jo Fin From:Eric Conrad [mailto:ericwconrad@gmail.com] Sent:Friday,November 13,2015 6:25 PM To:iohnathan Farley <Johnathan.FarTeypuc.idaho.gov> Subject:Re:Meter Protection JQuoed texi hiddenj Eric Conrad <ericwconradgmail.com>Mon1 Nov 16,2015 at 8:07 AM To:Johnathan Farley <Johnathan.Farleypuc.idaho.gov> Cc:Jared Kay <jared@jbkayconstruction.com> Good to know.Thanks.Just need to figure out what needs to be done before my house freezes up. Jared:FYI (Jared is my builder) [Quoted text hddenJ Johnathan Farley <Johnathan.Farley@puc.idaho.gov>Mon1 Nov 16,2015 at 3:11 PM To:Eric Conrad <ericwconrad@gmail.com> Hi Eric, Can you send me a picture of your meter placement and the overhang? Thank you, John Attachment A Decision Memorandum Page 24 of 33 •Gffiail -Meter Protection Page 14 of 18 From:Eric Conrad [mailto:ericwconradgmail.com] Sent:Monday,November 16,2015 8:08 AM To:Johnathan Farley <Johnathan.Farley@puc.idaho.gov> Cc:Jared Kay <jared@jbkaycanstruction.com> Subject:Re:Meter Protection IQuoted Iext hidden] Eric Conrad <ericwconrad@gmail.com>Mon,Nov 16,2015 at 5:14 PM To:Johnathan Farley <Johnathan.Farleypuc.idaho.gov> OK.Here are three examples that are in my subdivision that do not have dog house roofs,you can see why I am confused. [Quoted text hidden] Examples of Gas Meters.docx 360K Eric Conrad <ericwconradgmail.com>Mon,Nov 16,2015 at 5:21 PM To:Johnathan Farley <JohnathanFarleypuc.idaho.gov’ Thanks for your help on this.Attached are two pictures of where my gas lines are run and awaiting meter. Can you please send me the documentation that intermountain gas sent you and the location it can be found in local domain for either consumer or builder? Thanks,Eric On Mon,Nov 16,2015 at 3:11 PM,Johnathan Farley <Johnathan.Farleypuc.idaho.gov>wrote: [Quoted text hidden] Conrad Residence.docx - 237K Johnathan Farley <Johnathan.Farleypuc.idaho.gov>The,Nov 17,2015 at 10:40 AM To:Eric Conrad <ericwconradgmail.com> Hi Erk, Attached you find the procedural documentation that was provided to me by lntermountain Gas. Additionally,I have attached a letter that outlines the formal complaint procedure.Please do not hesitate to email pr call me with any question5. All the best, Attachment A John Decision Memorandum Page 25 of33 GmaiI -Meter Protection Page 15 of 18 From:Eric Conrad [mailto:ericwconrad@gmail.com] Sent:Monday,November 16,2015 5:21 PM jQuoted text hidden] [Quoted text hidden] 4 attachments Procedure 4017.docx 26K IFGC 410.1.pdf 1309K 192 Pipeline Safety Regulations.pdf 978K Formal Complaint Procedure CONRAD E.doc 27K Eric Conrad <ericwconrad@gmail.com>Tue Nov 17,2015 at 11:00 AM To:Johnathan Farley <Johnathan.Farleypuc.idaho.gov> Awesome,thanks for your help.I will definitely do the formal complaint,but will do so after Thanksgiving and my gas is for sure on.Where is this information in the Public Domain?If Intermountain Gas is going to hold consumers and contractors to rules and specifications that are not publicized,I believe that to be an issue. Thanks,Eric [Quoted iext hidden) Johnathan Farley <Johnathan.Farleypuc.idaho.gov>Tue,Nov 17,2015 at 11:27 AM To:Eric Conrad <ericwconradgmail.com> No problem.I completely understand your frustrations.Best of luck with the rest of your build! Best, John From:Eric Conrad [mailto:ericwconrad@gmail.com] Sent:Tuesday,November 17,2015 11:00 AM To:Johnathan Farley <Johnathan.Farley@puc.idaho.gov>Attachment A Subject:Re:Meter Protection Decision Memorandum Page 26 of33 [Quoted text hidden] Eric Conrad <encwconrad@gmail,com>Tue Nov 17,2015 at 7:02 PM To:“Robinson,Sarah”<SARAH.ROBINSON@Intgas.com> Giñail -Meter Protection Page 16 of 18 Cc:Johnathan Farley <johnathan.farleypuc.idaho.gov>,Jared Kay <jaredjbkayconstmction.com> Sarah:As you requested,my contractor has purchased and installed the pre-fabed meter protection.Can you confirm if this will work before we attach it to the home?Can I get a meter set appointment scheduled? We are anxious to get gas on. Thanks,Eric On Thu,Nov 12,2015 at4:47 PM,Robinson,Sarah <SARAH.ROBINSONintgas.com>wrote: [Ouated text Ndden] 2277 Hendricks Meter Cover.jpg 3547K Hi Eric, Wed,Nov 18,2015 at 9:14 AM I am just waiting for my Supervisor to get out of a meeting so that I can have her take a look at this.I will let you know ASAP. Thank You, Sarah Robinson Intermountain Gas Company Operations Aide,Teton District 208-542-6616 (Phone) 208-542-6639 (Fax)Attachment A Decision Memorandum Robinson,Sarah <SARAH.RQBINSONIntgas.com> To:Eric Conrad <ericwconrad@gmail.com> Sarah.Robinsonintgas.com (Email)Page 27 of 33 Gmail -Meter Protection Page 27 of 18 A INTERMOUNTMN fl GAS COMPANY A $a.iwanan anit From:Eric Conrad [mailto:ericwconrad@gmaiLcom] Sent:Tuesday,November 17,2015 7:02 PM To:Robinson,Sarah Cc:ichnathan Farley;Jared Kay Subject:Re:Meter Protection This is an EXTERNAL email.Exercise caution. [Quoted text hidden] Robinson,Sarah <SARAH.ROBINSON@intgas.com>Wed!Nov 18.2015 at 10:39 AM To:Eric Conrad <ericwconrad@gmail.com> 1 just spoke to my Supervisor and it is hard to tefl from the picLure if the meter protection covers the regulator.We are sending a Service Tech out to look at it and will let you know ASAP. Thanks, Sarah Robinson Intermountain Gas Company Operations Aide,Teton District 208-542-6616 (Phone) 208-542-6639 (Fax) Sarah.Robinsonintgas.com (Email) Attachment A Decision Memorandum Page 28 ofJ3 •Gthail -Meter Protection Page 18 of 18 A INThRMOIMIMNrGASCOMPANY AStVIOF%iqr Dc From:Eric Conrad [mailto:ericwconradgmail.com] Sent:Tuesday,November 17,2015 7:02 PM To:Robinson,Sarah Cc:Johnathan Farley;Jared Kay Subject:Re:Meter Protection ***This is an EXTERNAL email.Exercise caution. Sarah:As you requested,my contractor has purchased and installed the pre4abed meter protection.Can you confirm if this wiJI wDrk before we attach it to the home?Can I get a meter set appointment scheduled? [Quoted text hiddenj jQuoted texi hidden] Eric Conrad <edcwconradgmaiI.com>Wed,Nov 18,2015 at 10:56 AM To:“Robinson Sarah”<SARAH.ROBINSCN©intgas.com’ Thanks. lQuoted text hidden] Attachment A Decision Memorandum Page 29 of33 n ‘nfl r A INTERMOUNTAIN flGAS COMPANY ASusidia0/ofMDL)Resc’ns &v,Uc 1527 HOLLIPARK DR.•P.O.BOX 51220 •IDAHO FALLS,ID 83405-1 220 (208)542-6600 •FPX(208)542-6639 www.intgas.com April 19,2012 XYZ Builder or Dealer or Architect Builder or Dealer Business Name Address Town,Idaho ZIP Dear XYZ, Thank you for your support and selection in using Natural Gas for your buildings energy needs. We enjoy ourJoint partnership in providing safe,efficient and the best energy value,Natural Gas, to our mutual customers. It has always been a priority for Intermountain Gas Company to comply with federal,state and local jurisdictional codes,as well as [he manufacturers recommendations concerning the safety of the Natural Gas metering system.Intermountain Gas Company will ensure the ongoing safe operation to you and our mutual customers through enforcement of meter sel locations in such a manner and location to comply with appropriate codes. For example,meter locaUons can not be located under roof valleys and eaves where run off due to rain and snow may affect the meter set.Meter locations on any TMgable”end of the homes roof line that provides protection from any rain and snow run off or other possible hazards will be allowed. If a safe meter location can not be identified on a home or building,an engineered structure that allows adequate ventilation and is designed to meet the potential snow load can be used to - protect the meter and must be in place prior to service being activated. If an engineered structure is used,an engineers signature will be needed approving the structure’s design and ability to protect the meter from snow and ice, Please contact the Customer Sales Representative in your area for further details or if you have any questions. Again,thank you for your support! Sincerely, Ten TeNgaio Teton District Manager cc:file Attachment A Decision Memorandum Page 30 of33 Intermountain Gas Company Approval of Engineered Design for Meter Protection. I hereby certify that the structure being installed over and around the meter set at ____________________________________ (Address), _______________________ (Town),Idaho: for ________________________________________________ (Customer)will ventilate any gas from the regulator and will withstand the anticipated snow and ice loads that may occur at this address. Signed: Customer/or BuiLder Date Engineer Date Attachment A Decision Memorandum Page 31 of33 Gas Meter on South side of home, gutters in place. Attachment A Decision Memorandum Page 32 of 33 Gas Meter on East side of new home built this summer,no gutters,you can see splash near meter.Approved. Gas Meter on South East side of new home built this summer. Attachment A Decision Memorandum Page 33 of33 2277 Hendrick5 Circle,Gas Placement on North Side of home,away from wind and drifts.Gutters to be installed in two weeks 2277 Hendricks Circle,Gas Placement on North Side of home,away from wind and drifts that come from SE. Gutters to be installed in two weeks Attachment B Decision Memorandum Page I of2 Attachment B Decision Memorandum Page 2 of 2 PART 192 -TRANSPORTATION OF NATURAL AND OTHER GAS BY PIPELINE:MINIMUM FEDERAL SAFETY STANDARDS Subpart H—Customer Meters,Service Regulators,and Service Lines §192.351 Scope. This subpart prescribes minimum re quirements for installing customer meters, service regulators,service lines,service line valves,and service line connections to maths. [Part 192-Org.,Aug.19,1970] §192.353 Customer meters and regula tors:Location. (a)Each meter and service regulator, whether inside or outside a building,must be installed in a readily accessible location and be protected from corrosion and other damage,including,if installed outside a building,vehicular damage that may be an ticipated.However,the upstream regulator in a series may be buried. (b)Each service regulator installed within a building must be located as near as practical to the point of service line en trance. (c)Each meter installed within a build ing must be located in a ventilated place and not less than 3 feet (914 millimeters)from any source of ignition or any source of heat which might damage the meter. (d)Where feasible,the upstream regula tor in a series must be located outside the building,unless it is located in a separate metering or regulating building. [Part 192-Org.,Aug.19,1970,as amended by Amdt.192-85,63 FR 37500,July 13, 1998;Amdt.192-93,68 FR 53895,Sept 15,2003] §192.355 Customer meters and regula tors:Protection from damage. (a)Protection from vacuum or back pressure.If the customer’s equipment might create either a vacuum or a back pressure,a device must be installed to protect the sys tem. (b)Service regulator vents and relief vents.Service regulator vents and relief vents must terminate outdoors,and the out door terminal must: (1)Be rain and insect resistant; (2)Be located at a place where gas from the vent can escape freely into the afrnos phere and away from any opening into the building;and, (3)Be protected from damage caused by submergence in areas where flooding may occur. (c)Pits and vaults.Each pit or vault that houses a customer meter or regulator at a place where vehicular traffic is anticipated, must be able to support that traffic. [Part 192-Org.,Aug.19,1970,as amended byAmdt,192-58,53 FR 1633,Jan.21, 1988] §192.357 Customer meters and regula tors:Installation. (a)Each meter and each regulator must be installed so as to minimize anticipated stresses upon the connecting piping and the meter. (b)When close all-thread nipples are used,the wall thickness remaining after the threads are cut must meet the minimum wall thickness requirements of this part. (c)Connections made of lead or other easily damaged material may not be used in the installation of meters or regulators. Attachment CI 58/146 Decision MemorandumRevision12J08—Cuuent thm 192-108 GAS PIPING INSTALLATIONS 409.2 Meter valve.Every meter shall be equipped with a shutoff valve located on the supply side of the meter. 409.3 Shutoff valves for multiple-house line systems. Where a single meter is used to supply gas to more than one building or tenant,a separate shutoff valve shall be provided for each building or tenant. 409.11 Multiple tenant buildings.In multiple tenant buildings,where a common piping system is installed to supply other than one-and two-family dwellings,shutoff valves shall be provided for each tenant.Each tenant shall have access to the shutoff valve serving that tenant’s space. 409.3.2 Individual buildings.In a common system serv ing more than one building,shutoff valves shall be installed outdoons at each building. 409.3.3 Identification of shutoff valves.Each house line shutoff valve shall he plainly marked with an identifica tion tag attached by the installer so that the piping systems supplied by such valves are readily identified. 409.4 MP regulator valves.A listed shutoff valve shall be installed immediately ahead of each MP regulator. 409.5 Appliance shutoff valve.Each appliance shall be pro vided with a shutoff valve in accordance with Section 409,5.1,409.5.2 or 409,5,3. 409.5.1 Located within same room.The shutoff valve shall be located in the same room as the appliance.The shutoff valve shall be within 6 feet (1829 mm)of the appliance,and shall be installed upstream of the union, connector or quick disconnect device it serves.Such shut off valves shall be provided with access.Appliance shut off valves lacated in the firebox of a fireplace shall be installed in accordance with the appliance manufacturer’s in stttctons. 409.5.2 Vented decorative appliances and room heat ers.Shutoff valves for vented decorative appliances,room heaters and decorative appliances for installation in vented fireplaces shall be permitted to be installed in an area remote from the appliances where such valves are pro vided with ready access.Such valves shall he permanently identified and shall serve no other appliance.The piping from the shutoff valve to within 6 feet (1829 aim)of the appliance shall be designed,sized and installed in accor dance with Sections 401 through 408. 409.5.3 Located at manifold.‘here the appliance shut off valve is installed at a manifold,such shutoff valve shall be located within 50 feet (15 240 mm)of the appliance served and shall be readily accessible and permanently identified.The piping from the manifold to within 6 feet (1829 mm)of the appliance shall be designed,sized and installed in accordance with Sections 401 through 408. 409.6 Shutoff valve for laboratories.Where provided with two or more fuel gas outlets,including table-,bench-and hood-mounted outlets,each laboratory space in educational. research,commercial and indnstrial occupancies shall be pro vided with a single dedicated shutoff valve through which all such gas outlets shall he supplied.The dedicated shutoff valve shall be readily accessible,located within the labora tory space served,located adjacent to the egress door from the space and shall be identified by approved signage stating “Gas Shutoff.” SECTION 410 (IFGC) FLOW CONTROLS 110.1 Presstire regttlators.A line pressure regulator shall he installed where the ipplhn c is designed to operate at a lower pressure than the stppl’pressure.Line gas pressure regttlators shall he !isrcd as conml’inc with ANSI Z2 ISO. At’ccs.’shall he pnivitied to pressure regulators.Pressure reg ulators shall he protected front physical damage.Regtilators in%talled on the exterior of the htiildInc shall be approved for outdoor installation. 410.2 MP regalators.Ml’pressure regulators shall comply with the following: I.The MP regulator shall be approved and shall be suit able for the inlet and outlet gas pressures for the appli cation. 2.The MP regulator shall maintain a reduced outlet pres sure under lockup (no-flow)conditions. 3.The capacity of the MP regulator,determined by pub lished ratings of its manufacturer,shall be adequate to supply the appliances served. 4.The MP pressure regulator shall be pravided with access.Where located indoors,the regulator shall be vented to the outdoors or shall be eqttipped with a leak- limiting device,in either case complying with Section 410.3. 5.A tee fitting with one opening capped or plugged shall be installed between the NIP regulator and its upstream shutoff valve.Such tee fitting shall be positioned to allow connection of a pressure-measuring instrument and to serve as a sediment trap. 6.A tee fitting with one opening capped or plugged shall be installed not less than 10 pipe diameters downstream of the NIP regulator outlet.Such tee fitting shall be positioned to allow connection of a pressure-measuring instrument. 410.3 Venting of regulators.Presstire regulators that require a vent shall be vented directly to the outdoors.The vent shall be designed to prevent the entry of insects,water and foreign objects. Exception:A vent to the outdoors is not requited for regu lators equipped with and labeled for utilization with an approved vent-limiting device installed in accordance with the manufacturer’s instructions. 4103J Vent piping.Vent piping for relief vents and breather vents shall be constructed of materials allowed for gas piping in accordance with Section 403.Veat piping shall be not smaller than the vent cnnnection on the pres sure regulating device.Vent piping serving relief vents and combination relief and breather vents shall be run independently to the outdoors and shall serve only a single device vent.Vent piping serving only breather vents is pernutted to he connected in a manifold arrangement Attachment C2 Decision Memorandum 72012INTERNATIONALFUELGASCODE’ Home>Operations Procedures 13000/4000]>DOT Reguired>Customer Meters. Service Regulators and Service Lines>Siting Service Lines and Meter Sets [4017] ICC PROCEDURES DATE:01/31/05 TITLE:Siting Service Lines and Meter Sets NUMBER:4017 REFERENCES I PURPOSE SCOPE I GENERAL I RESPONSIBILITY I STANDARDS I SERVICE LOCATIONS I METER LOCATIONS I EXAMPLES REFERENCES Regulations IGC General Service Provisions 49 CFR 192,351,353,355,357 Policy 501 Gas Delivery Pressure Procedures 4019 Curb and Other Property Line Valves 4015 Upstream Regulation of High Pressure Service Lines (Farm Taps) 4016 RoofTop Distribution System 9375 Service Line Installations 4026 P.E.Plastic Pipe System Design and Installation PURPOSE Attachment C3 Decision Memorandum Page 1 of S Provide proper guidelines for determining service line,meter set,and riser locations and routes for the service line that are acceptable and safe under the General Service Provisions and applicable safety,building codes and operating policies. SCOPE Applies to all Company personnel assigned the responsibility of selecting service line routes and meter locations. GENERAL Service lines will be installed at the minimum total length necessary to conform with Company requirements regarding meter set locations. The criteria for service lines to be installed in conjunction with new mains is contained in Procedure 9371 Plant Additions-Revenue. When a service line cannot be located according to the requirements of this Procedure,contact the Operations/Division/District Manager for instructions. As described in Section A,Paragraph 12,9 of the General Service Provisions,a second service line will be installed for a customer only when the second location is justified and more than fifty (50)feet from the existing service line.See also 4016! Rooftop Distribution Systems,and 9375,Service Line Installation. Meter sets will be located along the waN of the structure least susceptible to future building,fencing or other additions.Residential meter sets will not be located in the rear of the dwelling, unless circumstances are such that the rear of the dwelling is the most feasible and desirable location available (townhouses,alley distribution system,etc.).When a Service Line application shows a rear meter location,an explanation of the conditions requiring such a location must be included on the 512-A.This explanation will be reviewed and accepted by the Marketing Manager and submitted to the Regional/Division/District Manager for approval prior to installation of the service line, RESPONSIBILITY The Operations Managers are responsible for the administration of this Procedure. Attachment C3 Decision Memorandum Page 2 of 8 STANDARDS A.Selecting Service Locations 1.Precautions to take regarding service locations a.When possible,select a termination location for the service line that is at least twelve inches (12”)from other underground facilities.If it is a joint trench service line,ensure that the service is installed according to joint trench specifications. b.Do not run plastic systems within the influencing area of any system that radiates temperatures above 1000 F.If there is a concern that this may occur,contact General Office Engineering for necessary calculations. 2.When paralleling a foundation for more than five (5)feet,select a location for the service line at least three (3)feet from the foundation, whenever possible.If a basement has been excavated,and there could be excessive soil settling,the service should be run outside of the disturbed soil area. 3.Whenever paralleling a sidewalk or retaining wall and if possible, select a location at least one (1)foot from the sidewalk and three (3) feet from the retaining wall,when possible. 4.Select service line locations so that adjacent private property is not crossed unless a properly executed right-of-way agreement is obtained. 5.Whenever possible,avoid selecting line locations where the service will pass under concrete slabs,carports or through retaining walls.Avoid periodic maintenance areas over septic tanks,oil and gasoline tanks etc. 6.Whenever possible install service line locations so that the service line will run in a straight line from the stub or tee to the service line riser location. 7.Consider possible future additions to the property and locate the service so that it will not be built over or have the meter location fenced in at a later date. 8.Any service lines running under a building will be encased.The casing will be sealed and vented to the outside at the point where it enters the building.Service lines will not be installed under a building without Operations Manager approval. C.Riser and Meter Set Locations 2.Position the riser and meter set in a readily accessible location.The meter and meter stop must be easily accessed in case of emergencies and for routine maintenance and meter reading. 3.When possible,select a location outside an area that is,or may be fenced. Attachment C3 Decision Memorandum Page 3 of 8 4.The meter shall be located at the point on the structure: a.As close to stub or main as possible. b.Protected by gutter or eave line if possible. c.On the gable end if possible. d.If main line is in the front of the structure;place riser as close as possible to the front of the structure;however,the service riser and meter shall be located at least 18”horizontally from an electrical meter.(See Example 1)(Most common distance is four (4)feet.) e.If main line is behind the house;place the riser at the closest point in the back of the structure maintaining the 18”horizontal distance from the electrical meter or service panel. 5.Manifolds shall be located in the same manner as single meters and allow for the required width for the number and size of the meters.If a stack manifold is required,the upper portion shall be secured to the structure during installation. 6.When the meter and service regulator will be installed outside the building, select location of service line riser to meet the following: a.Service line riser will be located a minimum of twelve inches (12”)from the building and protected from anticipated traffic, possible flooding and other sources of damage. Where a main customer valve is used,an additional 3”to 4” shall be needed for house line installation.Large meter sets shall be sited as needed for clearance. b.Do not locate under or in front of windows or other building openings which may be used as emergency fire exits or under interior or exterior stairways. c.When the service line riser is on the driveway side of a dwelling,at least three (3)feet of spacing between the driveway and the building is necessary.Additional protection will be provided,such as a meter guard.(See Example 5) d.Where a service line riser is likely to be set in paving of any kind,a short piece of two inch (2”)or larger P.E.pipe will be used to sleeve the pipe at ground level. e.When a meter is set outside a school,a permanently locked fence or enclosure may be provided by the Company. f.IGC will provide protection for meter sets when required. g.When locating a riser for a large meter set,adequate space and access shall be provided to allow for normal maintenance and testing. 7.Select location for service line and service line riser and meter set for large commercial and industrial services to meet the following additional requirements: Attachment C3 Decision Memorandum Page 4 of 8 a.When the service line will parallel the foundation,a minimum of five (5)feet clearance from the building will be maintained. b.The meter will not be located directly underneath and will have at least three (3)feet minimum horizontal clearance from an electric panel,air intake or any equipment that could possibly be a source of ignition. c.Space requirements for large meter sets will be determined from the meter set design.See specified or standard meter set drawings. d.When meters are set outside a school,a permanent locked fence or enclosure may be provided by the Company. e.When meters are set outside a church and extra security is necessary,a permanent locked fence or enclosure,with IGC access,is to be provided by the customer. 8.When the meter and service regulator will be set inside the building,the location for the service line riser will meet the following requirements: 6.NOTE:Written approval must be obtained from the Operations Manager for any inside meter set.That approval must be attached to the asbuilt drawing on Form 512-A or 319. •The service line riser,meter stop and service line entrance into the building will be as near as practicable to the meter and regulator location. a.When possible,the service line riser and meter stop will be above ground outside the building and the entrance of the service line into the building will be above ground with a readily accessible outside shut-off valve. b.Any service entrance into the building below ground will incorporate an outside curbvalve and will be cased and the casing sealed at the points the service line enters and exits the casing.The casing must be vented to the outside atmosphere. c.All regulators located inside a building must be located in a ventilated area and not less than three feet from any source of ignition or heat which could damage the meter.All inside regulators will be vented separately to the outside of the structure and installed to prevent water buildup and entry of insects and debris. d.A meter and regulator installed in a recessed opening is considered an outside meter set if the following conditions are met: v.The recess has an exterior wall vi.The service line enters the recess above ground (over the sill) vii.The recess is lined with fireproof and vapor-proof material 8.Any service line riser cannot be located to meet the requirements of this Procedure shall be referred to the Operations/District Manager. Attachment C3 Decision Memorandum Page 5 of8 NOTE:IGC will provide protective steel posts for the meter set,when required,where no protection is provided by the customer.Adequate meter protection consists of either the company approved meter guard,(Example 5)a two inch (2’)or four inch (4’)diameter post,or a permanent protective wail. 9.No meter or service regulator will be located in a pit or vault.Contact the Operations Manager for alternative locations. 10.When services and meters are on a rooftop system,see Procedure 4016 Rooftop Distribution Systems,for requirements. 11.Meters installed on manufactured housing where flex connectors are utilized shall have the meter bar assembly stabilized by use of a meter bar support. C.Riser and Meter Set Height 0.Standard installation height shall be achieved when the bottom of the stop equals the height of foundation.(Caution should be taken to ensure the bury line on the riser is not below future grade).(See Example 6) 1.Installation height of larger meters and meters installed on multilevel foundations shall be accomplished by determining future grade according to building specification.This may be determined by: a.Contacting builder b.Reviewing plans c.Future grade indicators that exist or are apparent. C.Riser and Meter Height -Heavy or Deep Snow Area’s 0.When heavy or deep snow conditions exist,a higher aspect meter set that exceeds the height of a standard installation should be a consideration.(See Example 4) 1.In deep snow areas,snow sliding off the roof should also be considered a damaging force,Snow shields shall be installed if necessary. 2.If a safe meter location can not be identified on a home or building,an engineered structure that allows adequate ventilation and is designed to meet the potential snow load can be used to protect the meter and must be in place prior to service being activated. 3.If an engineered structure for meter protection is used,an engineer’s signature will be needed approving the structure’s design and ability to protect the meter from snow and ice.(See Example #7 Approval of Engineered Design for Meter Protection.)This approval shall be signed and added to the asbuilt and added to Scanned images with the asbuilt D.Regulator Venting Requirements 0.Regulators shall be installed vertically with the vent pointed downward 1.Regulators that cannot be installed with vent pointed downward shall have additional vent piping installed to ensure downward venting 2.Vents will be screened or have caps installed to prevent entry of water, insects,debris,or foreign objects Attachment C3 Decision Memorandum Page 6 of 8 3.In high snow aspect areas vents will be extended to above the anticipated snow level 4.Extended vent piping will be placed in such a position to prevent entry of water,insects,debris,or foreign objects and protected from heavy snow or water run off 5.Vent piping will be sized according to the size of the vent opening on the regulator 6.Vent piping will be secured as necessary 7.If a meter set is located within three (3)feet of any air intake which is permanently opened into a structure,the regulator will be vented remotely from the area.Note:Windows,whether operable or non-operable,are not considered an air intake. 8.Meter locations protected under roof valleys and eaves where run off due to rain and snow may affect the regulator vent shall have the regulator vent piping extended to a protected location 9.All inside regulators shall be vented separately to the outside of the structure and installed to prevent water buildup and entry of insects and debris E.Meter Stop Valve Installation and Replacements 0.Service riser applications sized 3h”through 2”(single meter and manifolds) operating at 60 psig or less shall use a valve stop with an insulating union incorporated in the body of the stop 1.Greater than 60 psig operating pressure -High pressure installations shall require a.Non insulated stop. b.Insulation shall be obtained by one of the following: I.Insulating union downstream of the secondary pressure regulator ii.Flange gasket insulators at the flanges (2)of a flanged by-pass riser 2.Maintenance -In the course of performing maintenance to resolve leaking spuds or to remediate cathodic protection issues at the meter set assembly,the following actions should be performed where applicable: Replace a non-insulated valve stop with an insulated valve stop, a.Replace meter loop assembly with a pre fabricated meter loop incorporating a customer valve in the meter loop and non-insulated spuds. b.Replace a non-insulated valve stop with an insulated valve stop without a pre fabricated meter loop when alignment with existing house piping is not feasible. EXAMPLES Attachment C] Decision Memorandum Page 7 of 8 EXAMPLE 1 Distance from Electrical Meter EXAMPLE 2 Flex Riser EXAMPLE 3 Support Assembly EXAMPLE 4 High Aspect Riser EXAMPLE 5 Meter Guard EXAMPLE 6 Standard Meter Installation EXAMPLE 7 Approval of Engineered Design for Meter Protection 4017 -Siting Service Lines and Meter Sets Attachment C3 Decision Memorandum Page 8 of 8