20160219Respondent Answer.pdf

Williams Bradbory
ATTORNEYSAT LAW
February 19,2016
fiECTIVED
i[:6 r:-* t 9 fit{ il: 27
r', 'li. ,. ri";iiJ,i8r,r*
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,lD 83702
Re: NT-G-16-01
Dear Ms. Jewell:
Please find enclosed an original and seven copies of the Answer of Respondent
Intermountain Gas Company for filing in the above referenced case.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
RLWjr
Enclosures
l/hJ,A
Ronald L. Williams
1015 W. Hays Street - Boise; ID 83702
Phone: [phone] - www.williamsbradbury.com
Ronald L. Williams,ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise,ID 83702
Telephone: [phone]
Email: [e-mail]
Attorneys for Respondent Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
ERIC CONRAD,) Case No. INT-G-16-01
)Complainant, ) AIISWER OF RESPONDENT
) INTERMOUNTAIN GASvs. ) COMPANY
)
INTERMOUNTAIN GAS COMPANY, )
)Respondent. )
COMES NOW Intermountain Gas Company (.'IGC", "Intermountain" or the
"Company"), in response to the Complaint filed by Mr. Eric Conrad at the Idaho Public Utilities
Commission ("Commission" or'oldaho PUC") and the Summons issued by the Commission on
February 1,2016, states as follows:
INTRODUCTION
Mr. Conrad's Complaint and the Commission's four areas of inquiry focus on the IGC
processes for informing customers about meter protection requirements, and whether those
processes are fair, adequate and reasonable to IGC customers. Before addressing these four
questions however, IGC believes it is also important to understand "why" meter protection is
important. In a nutshell, the answer to this question is "safety".
Intermountain is committed to safety, beginning with the Company's Corporate Mission
Statement and continuing with the "safety mindedness" ingrained within the everyday attitudes
ANSWER OF RESPONDENT INTERMOUNTAIN GAS COMPANY, Page I
of IGC employees. This commitment to safety is unwavering and extends to all aspects of IGC's
business operations, including public safety, employee safety, emergency services safety and
pipeline safety. As it relates to meter protection, Intermountain takes very seriously the need to
keep its natural gas meters, and the customer piping connected to its meters, protected from
environmental hazards. This necessary focus is embodied within the Company's procedures
which address the need to keep snow and ice from compromising gas meters. Snow or ice
falling from a roof can strike an unprotected gas meter with an impact sufficient to crack or
break the gas piping or fittings at or around the meter, either on the outside or as they enter a
structure. Consequently, the Company is always concemed and vigilant that gas meters be and
remain protected from weather related environmental hazards.
As more fully delineated below, IGC expects a builder to be knowledgeable of codes and
standards regarding the protection of meters, and IGC relies on builders to be its partner in meter
safety. Intermountain also believes it has a duty to raise the awareness of meter safety issues by
communicating with its customers and with builders the importance of meter protection from
weather and environmental hazards.
COMMISSION AREAS OF INQUIRY
Inquiry No. I - What written material is available and distributed to customers
regarding meter protection structures in areas of heavy or deep snow? Please provide
copies of such materials.
Response to Inquiry No. I - Attached as Exhibit No's. I and2 are the information
given to IGC customers and builders, regarding meter protection in areas of heavy or deep snow.
The mailer shown in Exhibit No. I is given to new customers at the time the customer
relationship is established with the Company. This same mailer is also distributed once per year
during Intermountain's January billing cycle. Exhibit No. 2 includes two versions of a letter
ANSWEROF RESPONDENT INTERMOUNTAIN GAS COMPANY, Page2
provided to builders when they select gas service from lntermountain for a home or structure
they are about to construct. The builder's letter from IGC addresses the importance and the
necessity to comply with the requisite protections to the customer's natural gas meter. Given the
many factors involved with each customer's building conditions (snow fall levels for the region,
the location of the home in relation to predominant weather patterns, the height, pitch and size of
the roof, the roof type and the surrounding landscape, etc.), it should be noted that this
communication is not specific as to the exact meter protection design specifications. Together,
Exhibit No's. I and2 inform and remind IGC customers and builders of the need for meter
protection when environmentalhazards, in conjunction with an improperly protected meter, can
put their safety at risk.
In addition to these distributed materials, IGC's Procedure 4017 (Exhibit No. 3), which is
on file with the Commission and which was provided to Mr. Conrad, states under sub-paragraph
D:
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 cannot 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 signafure will
be needed approving the structure's design and ability to protect the meter from
snow and ice.
Inquiry No.2 - Describe in detail how Intermountain Gas disseminates information
to customers, builders, contractors and others about meter protection requirements.
Response to Inquiry No. 2 - In addition to the disseminated written materials
highlighted in the Company's Response to Inquiry No. l, Intermountain employs additional
ANSWER OF RESPONDENT INTERMOUNTAIN GAS COMPANY, PAgC 3
communication avenues to inform our customers, builders and contractors regarding meter
protection requirements.
The Company utilizes personal face-to-face communications to address, with its
customer and/or builder, the safest location for the customer's meter. Because each situation is
unique in terms of the architectural design of the building and the potential for that design to
impact the safe functioning of the natural gas meter, there is not a "one size fits all" safety
solution. In the case of meter protection from snow and ice, [GC's Consumer Sales
Representatives provide personalized communication to the customer pointing out potential
environmentalhazards. The customer is advised to locate the meter where it will be protected
from falling snow, ice and dripping water. If, for instance, the meter is in the drip-line of a non-
gabled end of the roof, then the meter is considered unprotected. These meter safety related
issues are communicated to the owner/builder at the time a new service is initiated.
As part of this face-to-face communication, if the customer or builder insists on locating
the meter in an unprotected location, IGC then advises the customer or builder to provide an
engineered snow shield over the meter location as noted on IGC Procedure 4017, subparagraph
D, item 2 ("an engineered structure that allows adequate ventilation and is designed to meet the
potential snow load can be used to protect the meter"). As also noted in this subparagraph, the
engineered protection structure "must be in place prior to service being activated".
IGC also relies on the builder's requisite knowledge of the Codes and Standards that
pertain to meters and regulators needing protection from environmental forces, such as snow and
ice (see Exhibit No. 4). Builders, engineers, and architects who operate consistently in IGC's
high snow areas are aware of the requirements to site the meter in a protected location or provide
an engineered designed meter protection solution. Builders and owners who don't often build in
ANSWER OF RESPONDENT INTERMOUNTAIN GAS COMPANY, Page 4
areas of snow should take the necessary steps to identi$ the unique building standards for these
areas.
To reinforce the builder's requirements pertaining to protected meters, IGC sent a letter
to builders at the time the Company's meter protection program was initiated (see Exhibit No. 2).
This initial written communication was followed-up with personal communication as each
builder requested a new natural gas service line. Following this initial roll-out communication,
the Company's Idaho Falls District sends a letter to the builders at the beginning of the building
season each year (end of March beginning of April time period). This has been the Idaho Falls
District's practice since 2010. The Idaho Falls mailing list consists of builders who have built
homes the previous year. For example, every builder that built a new house in 2015 will get the
aforementioned letter in March/April of 2016.
J.B. Kay Construction ("JBK") was the builder for Mr. Conrad and was not a builder of
record for IGC since. According to IGC's records, JBK had not built a structure using gas since
2006. Consequently, JBK was not a recipient of this IGC letter to builders. However, when JBK
called to request gas service for Mr. Conrad's home on October 7,2015, JBK was informed of
the possible snow shield requirement as JBK had already installed pipe to the outside at a
potentially unsafe location (" [CustomerJ Advised may need meter protection. Already piped
out." See Service Line Work Order, Exhibit No. 5).
In addition to the Company's direct mailing efforts, IGC employs advertising to
communicate the importance of protecting the natural gas meter when heavy snow or ice is an
issue. During years with normal to heavy snow, for instance, IGC advertised in the most likely
affected regions. The most recent advertising was done during the winter of 2011 (see Exhibit
No. 6). IGC is also planning similar advertising during 2016.
ANSWER OF RESPONDENT INTERMOLTNTAIN GAS COMPANY, Page 5
Inquiry No.3 - Describe the training of Company employees and the frequency of
such training about meter protection requirements.
Response to Inquiry No.3 - The Company's Consumer Sales Representatives,
Operations Assistants and Engineering Associates are all trained regarding meter protection
requirements during their initial employment with the Company. These employees are trained to
recognize that when the natural gas meter is located in the drip-line of a non-gabled end of a
roof, the meter is unprotected and unsafe. When a customer or builder insists on an unprotected
location, or if the roof line is unknown, these same employees are trained to provide direction to
the builder/owner that engineer designed meter protection is required. These same employees are
trained to note this event on the Company's Service Line Work Order. Once the proper meter
protection is in place and documented, these Company employees are then allowed to set the
meter and they note this information on their order completion (see Exhibit No. 7).
Inquiry No. 4 - Explain when the IGC Procedure Section C (Riser and Meter Set
Locations) 6 (f) "IGC will provide protection for meter sets when required" is applicable
and to what type of customer.
Response to Inquiry No. 4 - IGC's Procedure 4017 (Exhibit No. 3) for siting service
lines and meter sets is used by the Company as a guideline when determining the safe location of
a service line, meter set, riser and routes for service lines. This same procedure attempts to
embody applicable safety codes and procedures. This procedure should be viewed as a whole
and with sections of it not selectively quoted and taken out of context. This is important because
sections of the procedure address meter locations, while other sections address meter protections.
For example, the procedure states "The meter shall be located at the point on the
structure...protected by gutter or eave line if possible, on the gabled end if possible". In another
ANSWEROF RESPONDENT INTERMOUNTAIN GAS COMPANY, PAge 6
section the procedure outlines when and what kind of meter protection is needed. In other words,
proper meter location obviates the need for additional meter protection.
With regard to the section in question, "IGC will provide protection for meter sets when
required", Intermountain's intended use of the word "required" is contextual, not literal. IGC
will provide, on its own behalf and at its own cost, meter protection to older existing services
when the risk for damage to the meter by non-weather related actions becomes a concem, or if
such non-weather related damage has already taken place. By way of example, IGC can provide
protection from vehicle intrusions or provide fencing when a meter needs isolation from
pedestrian traffrc.
Conversely, Intermountain does not and has never considered snow shields at a new
service installation to be required - at IGC's expense - when other construction options for
meter protection are readily apparent, available and should have been planned for in construction
design. For example, in Mr. Conrad's instance, an alternative piping layout to a protected
exterior location would have eliminated the need for an engineered snow shield over his meter.
In such a case, IGC does not consider a snow shield as being oorequired". When, as in Mr.
Conrad's case, the customer insists on an unprotected meter location, it is the customer's
responsibility to provide an appropriately engineered meter protection structure.
ADDITIONAL AREAS OF ANSWER
Safety as a Number One Concem: The root cause of Mr. Conrad's complaint with IGC
is that Mr. Conrad, or his builder, selected a natural gas meter location that required additional,
and necessary, protective measures, when other options were available. When Mr. Conrad and
his builder were alerted to this problem, Mr. Conrad went in search of precise meter protection
specifications that, for the reasons explained in the Response to Inquiry No. 2 above, do not and
cannot exist, at the level of detail he expected to find. In an attempt to further assist Mr. Conrad,
ANSWEROF RESPONDENT INTERMOUNTAIN GAS COMPANY, PageT
IGC provided pictures/examples of previously approved meter shield designs and referred Mr.
Conrad to a local fabrication shop that manufactures approved designs.
To make matters worse, Mr. Conrad and his builder initially installed a temporary meter
protection shield that did not comply with the engineering requirements of Procedure 4017. As a
result, IGC refused to install its meter. Mr. Conrad then purchased and installed an approved
meter protection shield from the local fabrication company and IGC installed Mr. Conrad's
natural gas meter on November 19, 2015. The attached Exhibit No. 8 depicts the non-approved
meter protection shield originally built and located by Mr. Conrad and the currently installed
approved shield purchased by Mr. Conrad which provides his natural gas meter with the
necessary safeguards against environmental hazards.
Intermountain understands Mr. Conrad's frustration with the process. However, as
exemplified throughout this response, Intermountain's commitment to safety is unwavering and
extends to all aspects of its business. While promoting safety, Intermountain concurrently strives
to build positive relationships with its customers. Unfortunately, in Mr. Conrad's instance, these
twin goals of safety and customer service came into conflict. In such a situation, IGC was forced
to choose safety as its number one priority.
Mr. Conrad's Requested Relief: Mr. Conrad requests two areas of relief: (i)
compensation, and (ii) review and revision of IGC's rules or procedures as it relates to meter
protection.
With respect to the second area, Intermountain agrees with Mr. Conrad that procedure
4017 can be revised to more clearly direct the reader to the applicable citations within the
Procedure. Intermountain will begin the process of making these enhancements to Procedure
4017, in collaboration with Commission Staff.
ANSWER OF RESPONDENT INTERMOUNTAIN GAS COMPANY, Page 8
Regarding the second area of requested relief - compensation - Intermountain hopes to
begin the process of building goodwill back with Mr. Conrad and agrees to reimburse Mr.
Conrad, in the form of billing credits, for his cost of a Gas Cover ($220) and the labor to install
the cover ($150), provided Mr. Conrad provides IGC with invoices of these two amounts.
Intermountain also recognizes the unique factors involved in this case, and that such an
accommodation to Mr. Conrad does not constitute a precedent that builders are now free to
design and set meters in environmentally unprotected areas and that IGC will pay for additional
meter protections.
Intermountain declines to also reimburse Mr. Conrad $1,010.82 in "construction loan
interest" because of the tenuous relationship between the construction interest and: (i)
Intermountain's legitimate safety concerns, (ii) the yet quantified "delay period", (iii) other
construction activities that may have taken place during this delay period, and (iv) Mr. Conrad's
actions that may have contributed to the delay.
Dated this 19tr day of February, 2016.
Respectfully submitted, '.
RrA L (,r/rtlrt -Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays St.
Boise LD,83702
Telephone : [phone]
ron@williamsbradbury. com
Attorneys for Intermountain Gas Company
ANSWER OF RESPONDENT INTERMOUNTAIN GAS COMPANY, PAge 9
CERTIFICATE OF DELIVERY
I hereby certifu that on this 19th day of February, 2016,I caused to be served a true and
correct copy of the Answer of Intermountain Gas Company upon the following individuals in the
manner indicated below:
Hand Deliverv: (original & 7 copies)
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W . Washington Street
Boise,lD 83720
Mail and Electronic Deliverv:
Eric W. Conrad
Complainant
ericwconrad@ gmail. com
2277 Hendicks Circle
Rexburg,ID 83440
(Alternative mailing address)
1030 s. 2ndE.
Rexburg,ID 83440
flu /u/,*
Ronald L. Williams
ANSWER OF RESPONDENT INTERMOUNTAIN GAS COMPANY, Page l0
Exhibit No. 1
Case No.lNT-G-15-01
Intermountain Gas company
Page I of 2
EesP3s a --
s:EEg':PE900
gE H FEE O bE Xx!9odJG.=-.r(D -gEE=EE
:3H€eS96e q; B
ieHgcE
EiSEEE
E E E a *E
EEE$;t
EEE u: g
;Ei aEE
:EEH3f
Eg€ Egf;E:rO t o:vE
E=E : E*
igE;EE;
E EE ^^
=.9E iE=ss$E o oeA.6>
is#EBEgs6
E= H€ EEiE Hraa?btsP:c
3-E a:EgEEE,
EEggEEE6E
gi EafiEEHC
EE o EUJ (E oG;-IA ^r
AA
CE3AJEG
OE(lo
a1 tPG6('As.tEi3=otoE.,
o6CG
io,gEol,lrt EriL6$rGE 9
'=EEESo! Etoc
E:3E irgs*E
B:E
eEiE.E ao (,-E EE..9c
=o.!E$Eol6
'Eeelt=<fO(o
FRONT ]MAGE
Exhibit No. 1
Case No. INT-G-16-01
lntermountain Gas Company
Page 2 of 2
i= s i i
iEEEBEEg,
.sbo
fo
c)ooaHt{00
o-ctE5c
o)-c
(Eo
E
8.o
CL
fo
coaoo.E
(uo!
(E
o6)C669o. .='d uo !Po.= =O6sbo:) or6-lo\5FEEEE
O-6oa=xEaSp E
S€i sE; BEE; E AE'= 1r poaatao=cSEEEgUHE
UIF.9 I
J(E.:J.c-e9P :5 =6
i* HE sEsUi t!= =tso I uY o -
t$a*tIg
€E H;g!E
E=;EE;Et; E ptE aeE=ESEEEEEf :IEEE3
=-E HIbEEE
EI E;EE g *5.g ;5:.3:. P
-Eg $Et$ii E
sElcEo-'oo
BACK IMAGE
Exhibit No. 2
Case No. INT-G-16-01
lntermountain Gas Company
Page 1 of2
EXHIBIT 2 _ BUILDER LETTERS FOR SNOW PROTECTION_ 2 VERSION HISTORY
Exhibit 24
October t8,2OL3
Builder or Dealer Name
Business Name
Address
Town, ldaho ZIP
RE: Meter Protection
Dear Builder or Dealer.
It has always been a priority for lntermountain Gas Company to comply with federal, state, and local
jurisdiction codes, as well as the manufacture/s recommendations concerning the safety of the Natural
Gas metering system. lntermountain Gas Company will ensure the ongoing safe operation to you and our
mutual customers through enforcement of meter set locations.
Meter locations on a "gable" end of the building or home is preferred because it provides protection
from any rain or snow run off or other possible hazards. Meters cannot be located under roof valleys or
eaves where run off due to rain or snow may affect the meter.
lf a safe meter location cannot be identified on a building or home, 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. Our sales staff will be documenting the need for
meter protection on the service line work order at the time the meter location is determined and the
service is ordered. Our service technicians have been instructed to deny the request for a meter if that
protection is not in place when they go to set the meter. Once the meter protection is in place and the
meter is set, the service technician will document their order.
Thank you for your cooperation and support in providing our mutual customers with safe and efficient
service as well as the best value, Natural Gas.
lfyou have any questions, please contact the Consumer Sales Representative in your area.
Respectfully,
TeriTeNgaio
Teton District Manager
Exhibit No. 2
Case No. INT-G-16-01
lntermountain Gas Company
Page2 of 2
Exhibit 28
(Date)
XYZ Builder or Dealer or Architect
Builder or Dealer Business Name
Address
Town, ldaho ZIP
Dear XYZ,
Thank you for your support and selection in using Natural Gas for your building's energy needs.
We enjoy our joint partnership in providing safe, efficient and the best energy value, Natural Gas,
to our mutual customers.
It has always been a priority for lntermountain Gas Company to comply with federal, state and
localjurisdictional codes, as well as the manufacturer's recommendations concerning the safety
of the Natural Gas metering system. lntermountain Gas Company will ensure the ongoing safe
operation to you and our mutual customers through enforcement of meter set locations in such a
manner and location to comply with appropriate codes.
For example, meter locations 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 "gable' end of the home's roof
line that provides protection from any rain and snow run off or other possible hazards will be
allowed.
lf 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.
lf an engineered structure is used, an engineer's 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,
TeriTeNgaio
Teton District Manager
cc:file
Exhibit No. 3
Case No. INT-G-16-01
lntermountain Gas Company
Page 1 of4
IGC PROCEDURES
DATE: 01/31/05
TITLE: Siting Service Lines and Meter Sets
NUMBER:4017
PURPOSE I SCOPE I GENERAL I RESPONSIBILITY I STANDARDS I SERVICE LOCATIONS I METER LOCATIONS I
REFERENCES
Regulations
IGC General Service Provisions
49 CFR 192, 351, 353, 355, 357
Policg
501 Gas Delivery Pressure
Ptocedures
4019 Curb and Other Property Line Valves
40'15 Upstream Regulation of High Pressure Service Lines (Farm Taps)
4016 RoofTop Distribution System
9375 Service Line lnstallations
4026 P.E. Plastic Pipe System Design and lnstallataon
PURPOSE
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 OperationyDivision/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 lnstallation.
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.). \Men a Service Line application shows a rear meter location, an explanation of the conditions requiring
such a location must be included on the qlA\. 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.
Exhibit No. 3
Case No. INT-G-16-01
lntermountain Gas Company
Page2 ol 4
RESPONSIBILITY
The Operations Managers are responsible for the administration of this Procedure
STANDARDS
Selecting Service Locations
L Precautions to take regarding service locations
a. \Mren possible, select a termination location for the service line that is at least twelve inches (12") from other underground facilities.
lf 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 100o F. lf there is a concern
that this may occur, contact General Office Engineering for necessary calculations.
2. Vvhen 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. lf a basement has been excavated, and there could be excessive soil settling, the service should be run outside of
the disturbed soil area.
3. Vvhenever 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.
Riser and Meter Set Locations
l. 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.
2. l /hen possible, select a location outside an area that is, or may be fenced.
3. The meter shall be located at the point on the structure:
a. As close to stub or main as possible.
b. Protected by gutteroreave line ifpossible.
c. On the gable end if possible.
d. lf 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. lf main line is behind the house; place the riser at the closest point in the back of the structure maintaining the 1 8" horizontal
dastance ftom the electrical meter or service panel.
4. 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. lf
a stack manifold is required, the upper portion shall be secured to the structure during installation.
5. Vvhen 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. \/wren 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. Vvhere 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. \Mren 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. \Mren locating a riser for a large meter set, adequate space and access shall be provided to allow for normal maintenance and
testing.
6. Select location for service line and service line riser and meter set for large commercial and industrial services to meet the following
additional requirements:
a. \Men 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.
Exhibit No. 3
Case No. INT-G-16-01
lntermountain Gas Company
c. Space requirements for large meter sets will be determined from the meter set design. See specified or standard meter set Page 3 of 4
drawings.
d. When meters are set outside a school, a permanent locked fence or enclosure may be provided by the Company.
e. \Mren meters are set outside a church and extra security is necessary, a permanent locked fence or endosure, with IGC access, is
to be provided by the customer.
7. Vvhen 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 fmm the Operations Manager for any anside meter set. That approval must be attached to the asbuilt drawing
on Form 51 2-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. \Men 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
ii. The service line enters the recess above ground (over the sill)
iii. 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.
NOTE: IGG 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.
9. No meter or service regulator will be located in a pit or vault. Contact the Operations Manager for alternative locations.
10. Vvhen services and meters are on a rooftop system, see Procedure 4016 Rooftop Distribution Systems, for requirements.
I l. 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
l. 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. lnstallation 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.
D. Riser and Meter Height - Heavy or Deep Snow Area's
I . Vvhen heavy or deep snoiv conditions exist, a higher aspect meter set that exceeds the height of a standard installation should be a
consideration. (See Example 4)
2. ln deep snow areas, snow sliding off the roof should also be considered a damaging force. Snow shields shall be installed if necessary.
3. lf 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 snor load can be used to protect the meter and must be in place prior to service being activated.
4. lfan engineered structure for meter protection ls used, an engineer's signature will be needed approving the structure's design and ability
to protect the meter from sno/v 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 lmages with the asbuilt
E. Regulator Venting Requirements
l. 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
4. ln 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 protecled 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. lf 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. Nole: VMndows, whether operable or non-operable, are not considered an air intake.
9. Meter locations protected under roof valleys and eaves where run ofi due to rain and snow may affect the regulator vent shall have the
regulator vent piping extended to a protected location
10. Allinsideregulatorsshallbeventedseparatelytotheoutsideofthestructureandinstalledtopreventwaterbuildupandentryofinsects
and debris
F. Meter Stop Valve lnstallation and Replacements
l. Service riser applications sized %" through 2" (single meter and manifolds) operating at 60 psig or less shall use a valve stop with an
Exhibit No. 3
Case No. INT-G-16-01
insulating union incorporated in the body of the stop lntermountain Gas company
Page 4 of 42. Greater than 60 psig op€rating pressure - High pressure installations shall require
a. Non insulated stop.
b. lnsulauon shall be obtained by one of the bllowing:
i. lnsulating union do/vnstream of ihe secondary pressure regulator
ii. Flange gasket insulators at the flanges (2) of a flanged by-pass riser
3. Maintenance - ln the course of performing maintenance to resolve leaking spuds or to remediate cathodic protection issu$ at the meter
set assembly, the folloring ac,tions 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
EXAMPLE 1
Distance from Electrical Meter
DqMPLE 2
Flex Riser
EXAMPLE 3
SupportAssembly
EMMPLE4
High Aspect Riser
EXAMPLE 5
Meter Guard
EXAMPLE 6
Standard Meter lnstallation
EXAMPLE 7
Approval of Engineered Design for Meter Protection
4017 - Siting Service Lines and Meter Sets
http:l I igc-apps.mdu.com/IgcBusinessProcedures/40 I 7.htm 2/1012016
Exhibit No. 4
Case No. INT-G-16-01
lntermountain Gas Company
Page 1 of 1
.tOgJ Mcter velvc Every nptcr shall be equip@ with a
shuroff valvc locatcd on the supply sidc of the metcr.
4119.3 Shutoff yrlvcs for multlple.lmrm lhc system6.
Where a single metcr is uscd to supply gas lo ,norE lhan ooe
building or tcnant, I separate shutoff valve *hall bc provided
for each building or tenanl.
4093.1 Multlple tonont bulldlngs. ln multiplc tenant
buildings, whcrc a common piprirg system ir installcd to
supply other thar mc- and two-family dwellings, shutoff
valves shall be provided for each tcnant. Each rcnant shall
have access to the shutoff valve serving that tcnant's
space.
tllll3.2 Indlvidual bulldlqs. In a common sysacm s€rv-
ing morc than one building, shutoff valves shall bc
installcd flrtdocs at each building.
{D.33 ldentlllcatlott of shutolf vrlves. Each house line
shutoff valvc shall bc plainly marted with an identifica-
tion tag attached by the installer so that thc 2rping systcms
supplied by such valves are rcdily idcntified.
{09.4 MP rc8ulrtor volyes. A /r',rrcr, shutoff valve shall be
installcd immcdiatcly ahcad of each MP regulator.
illD.S Appllancc chutoff vdve. Fach appliuttcc shall be pro-
vidcd with a shutoff valve in accordance with Section
4,09.5. l. ,m9.5.2 or 409.5.3.
{19.5.t l,ocrtd rvlthln ramc mouu Thc shutoff valvs
shall be locsted in lhc samc room as ihc uppliancc.Tlrc
shutoff valve shall bc within 6 fcet (1829 mm) of rhc
applioncc, and shall bc installed upstrEam of thc union.
connector or quick disconnect device il tcrvqs. Strch shut-
off valves shall be providcd wilh accas.r. Appliance shut-
off valvcs locatcd in thc firebox of a firoplace r,hdl bc
installed in accordance with thr- applianca manufacturcr's
instruclions.
tllD.S.2 Vcnted dccoraalvc appllancer end r,oom hcrt.
ers. Shutoff valves for vcnted decoralivc applianccs. room
hcatcn and dccorativc appliance.i for installation in ventcd
tirepluces shall be pemilted to bc installcd in an arca
remolr fmm hc applilnocs where such valvcs arc pro'
vidcd with rcady ac'r'css. Such valves shall bc pcrmancntly
identilied and shall serve no other appliance.The piping
from the shutoff v'alve to within 6 fcet ( lE29 mm) of thc
appliance shall bc designcd, sized and installcd in accor-
dance with Scctions t[()l through 4O8.
409.53 Locatcd st manlfoH. Where the appliancr shut-
off valve is installed at r manifold, such shuroff valve shall
bc locrtcd within 50 fcct (15 240 mm) of thc appliance
servcd and shall bc rcadily accessiblc and pcrmancntly
identified, Tlrc piping fuom the manifold to within 6 fcct
( I E29 mm) of the appliarce shall bc designcd. sizcd ard
installcd in accordrnce with Scctions 401 through t108.
41D.6 Shutoff vrlvc for lrbontorles. Whcrc providod with
two or nxnE fucl gas outlets. includinS, mbh-, bench- and
hood-mountcd outleis, each laboralory spacc in educational,
rcsearch. commercial and indusrrial occupancics shall bc pro-
vifu with a single dedicated shutoff valve throuSh u,hich oll
such gas ourle$ $hall be supplicd. Thc dcdicated shutoff
valve shall be rcadily uccessible, ltuatcd within the labora-
2012 IITEAilATIONAL FUEL GAS CODET
GAS PIPIXO III9TALLATIOI{s
tory rpscc scrvcd. bcatcd adjaccnt to thc egrcss door from
the space lnd shall bc idcntified by appmvcd signoge suting
'Gas Shutoff."
sEcnoN 410 0FGc)
FLOW CONTROLS
410.1 Prtsurc rogu.lrlorr. A line presture rcgulttor sholl hc
iarullcd whert the qplimnr is designcd lo opcrflte al ir
lower prcssun lhon thc supply pressure. Linc gari presrurc
rcgulators shrll bc /r:rlrd ur conrplying wi$ ANSI Z2l.t(t).
At'r'rss shlll bc pmvidctl to prus$urc rcgulatrrn. Pressurc rcg-
ulaton shall he pr<rtected tnrrn physicll dlntagc. Rcguluron
instslled on the exrcrio,r of thc building shtll be aplrttt'ed for
outrltxrr insullation.
{10.2 MP ngulrtors. MP prcssurc rrgulators shall comply
with the following:
l. Thc MP rcgulator shall lx approved and shall be suit-
uble for the inlet and outlct gas pressures for thc appli-
colion.
2. The MP regulator shall rnaintain a rcduccd oullct prcs-
sure undcr lockup (no-flow) corxlitions,
3. Ttrc capocity of thc MP rcguluor, determincd by puF
lishod ratings of its manufacturcr. shall be adcqurtc to
.supply rhc appriances scrved.
4. The MP prcssur€ regulilor shall bc provided with
acccss. Whcrc locatcd indoors, ihc rcgulstor shall be
vcntcd to thc outdoors or *rall be equipped with r hak-
limiling device. in cither care omplying with Scoion
410.3.
5. A te€ fiuing with one opening cappcd or plugged shall
bc installed betwccn thc MP rcgulntor and its upstrcam
shutoll valve. Such tec frtting shall bc poritioncd to
allow conncclion of a prassurc-rneasuring instrumcnt
and to scrvc as a scdimcnt trap.
6. A tee filing wilh one opning capped or pluggcd shall
bc installcd not lcss thm l0 pipe diameBrs do*nttrctm
of the MP rcguhtor outlct. Such rc€ firting shall bc
positioncd lo allow conncclion of a pressurc-measuring
insrumcnt.
4103 Vcnting of tlguhfors. hessure rcgulalors thar rcquirr
a vent shall be venlcd dirrctly to the outdoors. Thc vent shall
be designed lo pnrvcnl ftc entry of inscctc, water and forcign
objects.
Exceptlon: A vcnt to the ouldoors is not rcquircd for regu-
lators equipped wilh and labeled tor utilizorion with sn
approvcd vcnt-limiting dcvicc instrllcd in accordance with
the manuficturcr's inslrucaions.
4103.1 Vcot plplng Vent pipirtg for reliof vent$ end
breather vens shall bc consructed of materials allowcd
for gas pryia3 in accodance s,ith Secrion 403. Yeat piping
shall be no smollcr than the venr connection on lhe pres-
sure reguladng dcvice. Vent pr'ping scrving rclicf vcnls
and combinution rclief and brcather vcnts shall bc run
intlepcndcntly to thc outdoors and shall serve only a singlc
dcvicc vcnt. Vent piping serving only brcather vens is
permitted to be connccled in a manifold arrsngcnlcnt
Exhibit No. 5
Case No. INT-G-16-01
lntermountain Gas Company
Page 1 of 10094i.775 7tast12 i;r; t *llffibtot Ir\01
2277 Hendrlekr Clr Llttletown Dr. tYE'
IA 6 I Brddlo croek Erb.ffi,r,.{*-oo 0.26
Ra-2 ""frt*r lt;+, " l';aW I tdlron lYor r--'ur
2"Y 85 60 06 I 60 I ll[,l TAmrn
lT7tn /E hu rna l-l19'lt rq-qq rc lil){tt'llffi'l*
J
_1ru
flercanJwmlmer
r
t
l*l*t-k
eD. lllt 2
anE RaaklartLl
lru 1,7t8
BtE BhoL
ErDrnoY .!!.!!!E[o[. ln
Rffi ll.tnrllL.L
oflflm itf
traw rXoK
mrrn
lm 1 dtr lo,lr.f ll.a,to I BEO ilo
lEtL-.
2 to
,|rln ao
;ol.srn& RrrburgPlbo f,.old l0o{rto !tC{710
ktuh.lnqm.dnfirpr!0.ouca. Allr$lb||lost (Om.d !?kco.lr.d
cotlr crtux* JE|(Contruodon Jrrd Tla.Ztta
11 ,/21 / '$l
6r rrtrctri rtrLl rtolJ !ron: yeaLJ_tt
I zzsoom
oKl
arY 3r4"lr.r
rTYT,rrflN
.uir P':t lrr54,
Y gl1", n*'4'84
10'x'0-
tlrUl
E E G ru
E.-
Im
tr0rta ,n
I'
t,ltte x V lln,tal
m a a ru LOrm.m ttl rnauStltFolunc
RU Effi
umti u.Y ,u-lL nc,lItFt',il-'rl^- l,ADMuti
E
E.g
I
auu ,t^a u'NNm.m
3.ra.tn tes r,'trulllllt tntl
il;o[T'-" lrroFd({todloboLls Ep...d, Ootlbiirhi, hp, uctoolallct, Pqtl[dCm.r, Opi-.r, Oorftotld.[ohl
7) fd.(trrb Ytfrl'ttv uilr urr a cFv (l /.,tr
flll wro{vn. Ato.I nrl.Atlt)tt bu. J tllesl,rl
a,
Art<+nn Thrtll.t
^S
t fto,ro.tlO..lbAt
rrrEiroutrrrnoABoof,pAilysERyrEuilEAoRErrElrr *tu,htmiflpfu
JBX.y eoil0ucdolt rml hrrur!h(,.t co.qatlc{. S rt rE .tt' bctd d
&f7l{ordrlct3of m,}u
t' mmfbt,rilrl:Eiailtlor.ldfr mdd.md.qnomi
IAGREETO:l.Rrlltr.rtrmnbho..f __---lgl!99_E0rxrlo.frrlrqFillcld.db.hrrocor.nltrfrrrdt'r
?'PrtDry$ablr|qaot t p.,bclfo. _!A_ ilorah.to,..rtb.hGbrhe I ifA ,drdt
no.hrea t' hlrtrrouf*r O...
!. f Oar!/tatr tr luttc.rtdmmgocnfudr tr nf *ilr Hoyamorhah{tfhfih, ha$}rtinarbltlnutrr hbrmnlL o co.ierry. I ]!EJL h Ell rDrirmilt cn ryb lr,
Eouffirrn ffirlco*r.m [rvr,n: I c-
l_ aoF !q07n0 0&7ro237{
--
case No. =riilBiil,:;?
lntermountain Gas Company
Page 1 of3
EXHBIT 6 _ ADVERTISING EXAMPLES FOR KEEPING METER
CLEAR OF SNOW
12-359-4
30 sec Radio Spot
Title: Winter Snow
SFX: Blowing wind, car tires spinning. Scrapping windsheilds, etc.
Winter's upon us and here's a tip from your friends at Intermountain Gas.
Don't let Old Man Winter hide your gas meter. If you can keep your gas
meter clear of snow and ice, our automated meter-reading trucks can get an
actual reading of your natural gas usage, otherwise we can only do our best
in sending you an estimated bill.
For valuable energy saving tips visit our web site at INTGAS.com.
Natural Gas. It's worth asking for.
Exhibit No. 6
Case No. INT-G-16-01
lntermountain Gas Company
Page 2 of 3
Sno* rcason ir fually D:re and you nay h.w E Ehmrcl Eore fian yw friw. If yilr t.s rEr is hrld in mo,s
fr ice ym @uld hirt . FoblEo. T[.t's wly yil ttocd to be ilrE ],our Gtf,r and/or ngulxc iar't i.e mtrccd or
U[i!d. T]c itrprcr of h.asy roor rnd XE cilt jrr tte Etr st. If tG gil rctulitG bccoDrs fiour rhtr. ia mry
intdrE ei0tic supply dt.stoyol[appliener, f puEmiscolErrd ri& mif,, righnm, plcese pliynraft
ild C,AREFULLY dig it out. &rd if )iou hivE no bErr c relI gar, crll ur insediaely-
IUETm' REAI'ING & SAFETI' REQUIRES CI.EAN ACCESS AT ALLTI}IES
trce aul mow mry ilio block tie dr(tilic RadfuB of ]rottr Eter. Pterse bep $e xee in frurt of ad rromd you
t s rErcbar.Thrtinctodcs sr+cof borBaMtziEs.orr&rirEistoDe.Db@ rcurdclylradlry[ffi.
SAIETI'COUNTS
If you dit ont yotlr gr3 Ers.plat? vv/cn lw tfierc vuniag fig*t:
A d.{se fog, ai!r, c rhilc claurl Adistir*tivs garmr o&.tlis*l8. $trisdfint c tqrirlB twir..
CaU &B ImErDounEin Gar emrgeocy nurDer al-tl7-T|7:74{2 iffidirtcllt if po erperimce my of th rbo$e.
Boisc/Ihtanm !'elhy Ar.lnl JT7 &Ml)
A ffiffifly" N f*Tffi,';iffi'i**,ffig_
INTGAS PRINT AD: JO3 375 Snow removal
OLD MAN WINTER AND YOUR GAS METER
case No =-Xiltsllll;?
lntermountain Gas Company
Page 3 of 3
Snow season is finally here and you may have to shovel more than your driveway. If your gas meter is
buried in snow or ice you could have a problem. The impact of heavy snow and ice can jar the meter set. If
the gas regulator becomes frozen shut, ice may interfere with the supply of gas to your appliances. If your
meter is covered with snow right now, please play it safe and CAREFULLY dig it out. If you have no heat
or smell gas, call us immediately.
METER READING & SAFETY REQUIRES CLEAR ACCESS AT ALL TIMES
Please keep the area in front of and around your gas meter clear. Our desire is to be able to accurately read
you meter. This includes the storage ofboats, trailers, as well as snow and ice.
SAFTEY COUNTS
When you dig out your gas meter, please watch for these warning signs.
SIGHT - A dense fog, mist, or white cloud.
SMELL - A distinctive gaseous odor.
SOLIND - Hissing, whistling, or roaring noise.
Call the Intermountain Gas emergency telephone number: l-877-777-7442 immediately if you experience
any ofthe above conditions
NEW rGC LOGO- 8ll LOGO-ENERGY STARLOGO (SMALL)
Boise/Treasure Valley Area 37 7 -6840
All Other Areas l-800-548-3679
Call:7 AM to 7 PM - Monday - Friday
www.intgas.com
Exhibit No.7
Case No. INT-G-16-01
lntermountain Gas Company
Page 1 of 1
Exhibit 7 -Meter Set Order Documenting Meter Protection
lkfa.tlr/EEIHomr.tbn
Uits llumb.r NEU, ERT Nuobcr I'lr*
'nn lffiizs-l Srwicccs<* lclrEtYtfrn I
CGt R:em
t{i KCxl \qmb.tr o{ &.E !}illsng p6clru NFtrl Rtg fnia
rt8.{xr}r
r{.i.l.i{0cr. SUG R CITY
A.t*rtLt [t
rr,CoaplGa{r.Lts A€toa
F{STALL IETER
Ll."ts !firBdl
RSv
L,4n, luur LlEW
lffi--ltrufstt
AL.l2a
,g
00
rar! )rl Si:a
loct Up
o.fr
tifi 16{ (rfrn} (Fl{ Lrrrer
Ai,(trthnJ (hcrtrlilam.U(lt
Ufirr iltoson fa{t
lgg fut{orrnrdr ilryo.t fJo{ gttloffiid
MSiERSE?.
fttt l{3r€r Tsp
ttrr FqJnd :.eft
Ratuttt
Rcd Try Co.nmailt
I
Rf.rf$.l,
Y
Rmetmm
Rrgrvltor rlor
l*-ll,*--_IFqJrlal
AfEl.rff.t Cn.*.o
v
'll:r.dour Cftidoor
llKtr
4*o Trg hru+d,
v
Odo.r\t Pcrcacdro{a
Yv
,hJ. ?ar!r
Comnx{ra
Sllt'Er DIEG!!il q rl,Erpsw. EtrtrtD latt aa !E cEf il.[cro trlrl ar!c. s&msls ilorrtlltttD Afr&E wffi&
I43ar,Bsr -ll6*rre|---llffiF--l S' v 025 v rocrsr3c yl----- il-'-' --' I r--- |taf/ MCta, ,\umorr Vanry it? r&Jnba. :ndfi q.$ vfi.t frp. itEw 3arorf} ot6sr1 1Ew lqv hlotEffi;--_-l
)rtia CffiE.B.ted
0v
Exhibit 8 - Conrad Snow Protection - Before and After
Conrad Proposed Meter Protection - Denied by IGC
Conrad Final Meter Protection - Approved by IGC
Exhibit No. 8
Case No. INT-G-16-01
lntermountain Gas Company
Page 1 of 1