20150813Reply Comments.pdf

(208) 343-7sfi)
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, - ,.,r::-
McDevitt & Miller r,r,p
Lawyer in,*U* f : PH 2: t0
420 Weet Bannock Ste*-r', ; ;,-:,',, r.,,, ;.1:. i i i.'
P.O. Box 256,t-m?0lt-\ t : ':
Boise,Idaho 83702
August 13,2015
Chas. F. McDevitt
DeanJ. $oe) Millet
Celeste trL Miller
Yia llaadDeliuery
JeanJewell, Secetary
Idaho Rrblic Utilities Commission
472W. Washington St
Boise,Irlaho 83720
Re: Case No LM-W-15-02
Deat Ms.Jewell:
Enclosed fs1 filing please fiad an odginal and seveo (/) copies of the Reply Comments of United
rUTater Idaho Inc.
If you have any questioas, please do not hesitate to cootact me.
Kindty retum a stamped copy.
DJM/hh
Very Truly Yours,
ORIGINAL
Dean J. Miller (ISB No. 1968)
Chas. F. McDevitt (ISB No. 835)
Celeste K. Miller (ISB No. 2590)
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564-83701
Boise, D 83702
Tel: [phone]
Fax: [phone]
j [e-mail]
chas@mcdevitt-miller. com
[e-mail]
Attorneyfor United Water ldaho Inc.
IN THE MATTER OF THE JOINT
APPLICATION OF UNITED WATER
IDAHO fNC., AND THE CITY OF BOISE,
IDAHO FOR APPROVAL OF AN
AGREEMENT FOR REPLACEMENT AND
OPERATION OF FIRE HYDRANTS AND
RELATED RATE MAKING TREATMENT
rd! -^,.t, !i'l, , ' , !,l-t
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. UWI-W-15-02
REPLY COMMENTS OF UNITED
WATER IDAHO INC.
COMES NOW United Water Idaho Inc., ("United Water"), pursuant to Order No. 33300,
and submits the following Reply Comments in response to Comments of the Commission Staff
dated July23,2015.
Introduction and Summary of Areument
For over one hundred years United Water and its predecessors have provided domestic
water service to the citizens of the City of Boise ("Boise", or "Citt''). About eighty five percent
(85%) of United Water customers are residents of Boise. As part of its obligation of service,
United Water has designed and constructed its systern so as to provide adequate fire protection to
its customers and the City of Boise.
ii
REPLY COMMENTS OF I'NITED WATER IDAHO INC-I
But, for reasons that are lost in history, United Water does not own or maintain the 6,700
fire hydrants-an obviously critical component of a fire protection system-located within the
City. (Staff Comment, pg. 6). They are owned and maintained by the City. This arrangement is
an anomaly. In almost every other circumstance of which United Water is aware, the entity that
provides fire protection also owns and operates the hydrants, for obvious reasons. (Direct
Testimony, Gregory P. Wyatt, pg.4; Direct Testimony of Neal Oldemeyer, pgs. 3-5).
In2012 the Mayor and Council of the City, the elected representatives of most of the
same people who are United Water customers, determined it would be in the best interests of
their constituents to transfer ownership and operation of hydrants to the entity better suited to
operate and maintain them-United Water. (Direct Testimony, Gregory P. Wyatt, pg.2).
United Water, as is its practice, began exploring ways to accommodate the preferences of
elected public officials to the extent it could do so consistent with its other public utility
obligations. (Direct Testimony, Gregory P. Wyatt, pg.2).
The parties eventually reached an agreement which is the subject of this Application. In
essence, United Water will fund the replacement of existing City fire hydrants within United
Water's certificated area over an approximate forty-year (40) time frame resulting in United
Water assuming ownership and responsibility for the hydrants on a newly installed basis.
(Agreementfor Replacement and Operation of Fire Hydrants, Exhibit l, Application).
Mr. Wyatt more fully explained the rational for the forty-year (40) transition in response
to Staff Production Request No. 6:
"'When the City of Boise first approached United Water they proposed the concept of
immediately transferring all City-owned hydrants to United Water. United Water
determined that the immediate transfer of all hydrants was not in the best interest of the
Company or its customers. This determination was based on the unknown amount of
potential risk and liability associated with a set of assets (hydrants) of undetermined
condition, quality, or age. A contributing consideration was the associated operations
REPLY COMMENTS OF UNITED WATER IDAHO INC-2
and maintenance (O&M) costs. The Company determined that it was in the best interest
of customers to not take on the full O&M costs immediately, but to grow into those costs
over time.
Based on that recognition, the City of Boise and United Water continued to negotiate and
finally agreed to the transfer on a newly installed basis. This insures that United Water
takes responsibility only for new facilities that have been installed and inspected in
accordance with the Company's requirements. This significantly reduces the risk and
liability to United Water and its customers related to these assets. It also enables the full
O&M costs to be incurred more slowly and over a longer period of time, which is
beneficial to customers."
The rate impact to United Water customers is small. In the first year it will be
approximately $ I .45 per customer per year, or about 50.24 per bi-monthly bill. Over the entire
life of the replacement program the net present value of the cumulative revenue requirement per
customer is approximately $118. (Staff Comments, pg. l1). Fire hydrants are non-revenue
producing assets and United Water will not realize new revenue from the replacement program.
The only financial benefit to United Water is the opportunity to earn a return on the investment
in fire hydrants as it grows over time. As shown below the hydrant investment and associated
return is small compared to United Water's total utility plant investment.
In short, the Agreement achieves a sensible balance between transferring hydrant
ownership to the more appropriate entity while minimizing rate impacts over a long period of
time.
Notwithstanding this, Staff Comments recommend that the Commission not approve the
Agreement. After consideration of Stafls arguments, United Water still believes the Agreement
is consistent with the public interest and should be approved, for the reasons discussed below.l
I United Water will acquiesce in one Staff recommendation regarding rate making treatment if the Agreement is
approved, as discussed below.
REPLY COMMENTS OF UNITED WATER IDAHO INC-3
Standard for Evaluation of Application
The Staff Comments do not attempt to articulate the legal standard by which the
Application should be evaluated and focus almost exclusively on ratepayer cost (in an
incomplete way, as discussed below).
The Commission, however, has broader mandate to take into account all relevant factors,
of which cost is one, to determine if the Application is consistent with the public interest.
"In general, where the Commission is required to consider the'public interest", it must
look to "the interest of the public, their needs and necessities and location and, in fact, all
the surrounding facts and circumstances to the end that the people be adequately served".
Browning v. Wood,99 Idaho 174, 579 P.2d 120 (1978) (motor carrier case); See also,
IPUC Order No. 28213, Case No. PAC-E-99-1.
This public interest standard is consistent with the statutory duty of a utility to maintain
adequate service:
"Every public utility shall fumish, provide and maintain such service, instrumentalities,
equipment and facilities as shall promote the safety, health, comfort and convenience of
its patrons, ernployees and the public, and as shall be in all respects adequate, efficient,
just and reasonable" Idaho Code $61-302.
The statute does not require service be provided at lowest possible cost but takes into
account broader concepts of o'safety, health, comfort, convenience of patrons employees and
public".
Staff Comments Present an Incomplete Cost Picture
Staff Comments, at pages 10-12, contain a discussion of costs to United Water
ratepayers. On May 22,2015 United Water, in response to Staff Production Request No. 2
provided to Staff an Excel based model that computed annual revenue requirements over the life
of the replacement cycle. Staff has used those values, without change, shown in that model in its
discussion of costs, so United Water does not dispute the numbers in the Staff Comments.
REPLY COMMENTS OF UNITED WATER IDAHO INC-4
However, Staff Comments make no effort to place those numbers in an overall
perspective. For example:
. Staff correctly notes that the first year revenue requirement per customer is $ 1.45, but
fails to note that average revenue per customer is $515.16, so the percent increase per
customsr is only a mere .18%.
r Even assuming that revenue per customer of $516.16 remains constant over the 80-
year life, that annual percent increase never exceeds 5Yo, and that does not occur until
year 40.
The average annual revenue requirement impact per customer would average $13.12
annually or only 2.54% (over the 80 years).
Along similar lines, Staff argues that United Water will benefit from the Agreement from
the opportunity to earn upon a larger rate base. (Staff Comments, pg. l3). However, Staff fails to
put the incremental earning potential in context. In United Water's general rate case now
pending (Case No. UWI-W-15-1), Exhibit 11, Schedule l, shows a current rate base of
5173,322,068. The expected annual fire hydrant investment of $765,000 is 0.44% of rate base.
A .44% increase in earning potential is not something that shocks the conscience, to put it
mildly.
As shown above, the incremental increased earnings potential resulting from hydrant
acquisition is quite small compared to total rate base and total eamings. Further, hydrants are
not-as Staff admits-revenue producing assets. United Water will not realize additional
revenue from the replacement program. The modest additional eaming potential was not the
motivating factor behind United Water's participation in the hydrant transfer Agreement.
REPLY COMMENTS OF I]NITED WATER IDAHO INC-s
Staff Understates the Complexity of Fire Hydrants
At page 6, Staff Comments state, "fire hydrants are very simple devices that require very
little expertise to operate". This statement is offered-without any evidence to support it-to
bolster Staff s view that it does not make much difference whether Boise or United Water owns
and operates the hydrants. (Staff Comments, pg.7).
This statement may be semi-accurate, compared, say, to a nuclear reactor. But a fire
hydrant-despite its outward appearance-is a more complicated device than Staff understands.
Attached as Exhibit A are schematic diagrams of four different hydrant tlpes that are currently in
service on United Water's system. As can be seen from these diagrams, the maintenance and
repair of these devices is not something you would entrust to someone with very little expertise
and hydrants are not simple devices.
In fact, The American Water Works Association (AWWA), the standards setting body
for the water utility industry, has published an entire manual, Installation, Field Testing and
Maintenance of Fire Hydrants Ml7 relating to the operation of hydrants, a portion of which is
attached as Exhibit B.
The Agreernent incorporates many of the AWWA maintenance and operation standards
to ensure adherence to them over time. (Agreement, Paragraph 1(0). United Water personnel are
trained in the AWWA procedures and United Water maintains and operates hydrants in
accordance with these industry best practices. This is in contrast to the curent practice of Boise,
which assigns on-duty firemen to maintenance duties.
REPLY COMMENTS OF I.]NITED WATERIDAHO INC-6
Along these lines, in response to Staff Production Request No. 3, Mr. Wyatt further
explained the benefit of hydrant ownership by United Water:
"As reflected in Mr. Oldemeyer's filed testimony (page 7, lines 17-21), if the proposal is
approved, United Water customers will benefit from having the oversight and
maintenance of the hydrants managed by United Water which has demonstrated water
distribution system (including hydrants) operating and maintenance experience and
expertise. For many years United Water has owned and operated a fleet of over 1,000 fire
hydrants in its service area outside the City of Boise. Integrating the hydrants into United
Water's system will allow the Company to integrate the operation and maintenance of
those hydrants into its tracking systerns (GIS & work management), contract preparation
and bid processes, and current industry practices and standards to ensure operational
efficiency.
United Water has the financial, technical, and operational resources to ensure that fire
hydrants are maintained, repaired, and/or replaced more quickly without the delay of
coordinating those efforts with City of Boise personnel . As reflected in Boise City's
response to Staffs First Production Request No. 5, The City of Boise uses on-duty
firemen to perform inspection and maintenance, while United Water uses trained and
certified water distribution system operators to perform hydrant maintenance".
United Water Customers Have Not Expressed Opposition
In its Notice of Application, issued on May 12,2015 the Commission established a long
public comment period ending July 23,2015, a comment period of about ten weeks. The
Commission also issued a press release advising customers of the Application on June 6,2015.
During that time, the Commission received one written comment, and that commenter
supported the Application.
(See, http://www.puc.idaho. gov/fi leroom/cases/summaryfu WIW I 502.html)
As the Commission knows from other proceedings, members of the public know how to
express their opposition to utility proposals if they desire to do so. (See e.9., Case No. IPC-E-15-
01).
REPLY COMMENTS OF I.]NITED WATER IDAHO INC-7
Disparate Rate Impacts
Staff Comments observe that future recovery of hydrant related costs could impact
different customers in different ways. (Staff Comments pgs. 3-4). This is true, but it is not a
reason to reject the Agreement.
Under traditional principles, fire protection and hydrant costs are considered fixed and
recovered through customer charges, which vary by meter size. However, in United Water's
current tariff, consistent with Commission policy, a significant portion of fixed costs related to
fire protection are not included in the tariff customer charge, but allocated to the volumetric rate.
Every change in utility investment has the potential to create different rate effects for
different customers. In future proceedings the Commission, as it has done in the past, has
adequate discretion to allocate recovery of hydrant costs in ways it thinks best to ensure fair and
reasonable rates for all customers.
Franchise Fees
From its review of Staff Comments, United Water infers that Staff s opposition to the
Agreement is propelled at least in part by Staff s dislike of municipal franchise fees that are
collected from customers on utility bills: "Staff does not believe it should be the responsibility
of United Water customers to fund the City's services for fire, police, library and parks (pg. 5);
"Staff believes that a reduction in franchise fees would provide equity for the increase in cost
that will be bome by ratepayers", (pg. 9).
United Water understands some of these concerns. From a utility perspective franchise
fees create an administrative burden of billing, collection and remittance. And they increase the
perceived cost of water sold to customers.
REPLY COMMENTS OF I]NITED WATER IDAHO INC-8
But, as Boise points out in its Reply Comments, the franchise fee system in place in
Idaho is authorized by both the Idaho State Constitution (Art. XV Sec. 2) and Idaho State Statute
(Idaho Code $50-3 29 et. seq). The Commission, as a body of limited jurisdiction, lacks authority
to regulate or direct the affairs of a municipal corporation. (See, Idaho Code $61-104-municipal
corporation is not a "corporation" within the meaning of the Public Utility Law; Ada County
HighwayDistrictv. IdahoPublicUtilitiesCommission,l5l Idaho, I,253P.3d675 (20llF
Commission may not regulate activities of entities not subject to its jurisdiction.
Staffls dislike of a system that neither it nor the Commission can either change or
regulate is not a solid reason for rejecting an otherwise sensible agreement.
Accountine/Ratemakin g Treatment
In its Application (paragraph 10) United Water requested two ratemaking treatments:
"United Water requests a determination by the Commission that the investments incurred
in conformity with the Agreement are prudently incurred and that the Commission provide
an assurance that they will be fully included in rate base (not l3-month averaged) and in
rates in United Water's subsequent general rate proceedings over the life of the
Agreonent. United Water proposes the Commission allow the Company to continue the
calculation and accrual of post-closing AFUDC on the investments anticipated by the
Agreement until such time as those investments are fully accounted for and included in
rates in subsequent general rate case determinations over the life of the Agreement".
Staff Comments (pgs. 12-13) support the first request-year end rate base-noting that
hydrants are neither revenue producing nor expense reducing.
Staff Comments oppose accrual of AFUDC. Without conceding the logic of StafPs
position, United Water hereby withdraws its request for post-closing AFUDC accrual.
Conclusion
Taking into account all relevant factors the Commission should find that the Agreement
is consistent with the public interest and should approve it, along with United Water's requested
raternaking treatment, as modifi ed.
REPLY COMMENTS OF I.'NITED WATER IDAHO INC-9
DATED tfris \\lAayofAugust, 2015.
By
UNTTED IWATER IDAHO INC.
Attorneyfor United Water ldaho Inc.
RBPLY COMMENTS OT IINTED WATER II'AEO INC.IO
CERTIFICATE OF SERYICE
I hereby certii/ that on tn" -fttay of Augus t,2Ol5,I caused to be served, via the
method(s) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
47 2 W est Washington Sfreet
P.O. Box 83720
Boise,lD 83720-0074
ijewell@puc. state.id.us
Brandon Karpen
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idalro 83720-0074
Brandon. [e-mail]. eov
Douglas K. Strickling
Boise City Attorney's Office
P.O. Box 500-83701
150 North Capitol Boulevard
Boise,Idaho 83702
dsfrickline@cityofboise. ore
Hand Delivered
U.S. Mail
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REPLY COMMENTS OF UNITED WATERIDAHO INC.ll
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Page2 of 4
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EXHIBIT A
Page3 of4
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5OO PSI HYDROSTATIC TEST PRISSURE
MAIN VALVE SIZES AVAII.AB|uE: 5 1/4"
MEETS OR EXCEEDS AWWA C5O2
HYDRANT SHOE STYLES AVAII-ABLET
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EXHIBIT A
Page 4 of 4
M&H VALVE COMPANY
ANNISTON,ALABAMA
A OIVISION OF MCWANE INC.
DATE; 7 /1 /05
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AWWA MANUAL M17
Third Edition
American Woter Works Associotion
EXHIBIT B
Page I of14
.&
Copyright O 1970, 1980, 1989
Arnerican Water Works Association
6666 West Quincy Ave.
Denver, CO 80235
Printed in USA
ISBN 0-89867-460-3
Contents
Foreword, v
Chapter 1 A Brief History of Fire Hydrants . I
L.1 Origins, 1
1.2 hon Pipe and Permanent Access Points, 2
1.3 Development of Dry-Barrel Hydrants, 3
1.4 Recent Developments, 3
Chapter 2 Dry-Barrel Hydrants: Definitions and
Preferred Nomenclature
2.1 Types of Dry-Ban'el Hydrants, S
2.2 Construction Terms for Dry-Ban'el Hydrants, 9
2.3 Installation Terms for Dry-Bartel Hydlants, 10
2.4 Preferred Nomenclature for: Dry-Barrel Hydrant Components, 1,0
2.5 Auxiliary Components for Dry-Barrel Hydtants, 15
2.6 Miscellaneous and Obsolete Hydrant Terms, 15
Chapter 3 lVet-Barrel Hydrants: Definitions aud
Preferred Nomenclature 16
3.1 Wet-Barrel Hydrants, 16
3.2 Construction Terms for Wet-Barrel Hydlants, 17
3.3 Installation Terms for Wet-Barrel Hydrants, 17
3.4 Prefer:red Nomenclature for Wet-Barrel Hydrant Components, 17
3.5 l\{iscellaneous and Obsolete Hydrant Terms, 19
Chapter 4 Inspection
Hydrant in Service
, Installation, Testing, and Placing the
4.1 Inspection Prior to Installation, 20
4.2 Installation, 21
4.3 Testing, 26
4.4 Placing the Hydrant in Ser:vice, 27
Chapter 5 Maintenance
5.1 Uses of Hydrants, 28-
5.2 Special-Use Concerns, 28
5.3 Inspection,29
5.4 Lubrication, 31
5.5 Repairs, 31
5.6 Record Keeping, 33
Chapter 6 Flow Tests
6.I Terms Used in Flow Testing, 39
6.2 Personnel and Equipment for Flow Tests,40
6.3 Offrce Planning Prior to Field Testing, 41
20
28
EXHIBIT B
Page 3 of 14
llt
Fielil Procedure for Flow Tests, 41
Cautions to Be Observed When Fielit Testing, 4t!
\l[arning About Rigid Diverters, 43
Detemrinine Available Flow, 43
Appendix A Illustrated Gulde to Dry-Banel Fire
Hydrant Nomenclature
Appendix B Illustrated Guide to Wet'Barrel Fire
Eydrant Nomenclature
Bibliography,116
Indexrll7
6.4
6.6
6.6
6.7
96
EXHIBIT B
Page 4 of 14
lv
Foreword
This manual was prepared by the AWWA Standards Committee on Fire Hydrants.
It is intended for use by persons responsible for the installation, operation, and
maintenance of dry-barrel and wet-barrel fire hydrants. It is the second revision of
the original manual, which was published in 1970.
The diversity of hydrants and the detailed maintenance prucedures recom-
mended by specific manufacturers make it difficult to develop a text that is both
comprehensive and concise. Therefore, this manual is intended to be used as a sup-
plement to detailed information available from specific hydrant manufacturers.
It is the judgment of the committee that the major purpose and function of a
fire hydrant is public fire protection. Usually, the hydrant is the property or respon-
sibility of the water utility. However, during fire emergencies the hydrant is
operated by members of a fire department rather than by water utility personnel.
The use of a fire hydrant as a soulce of water for street cleaning, eonstrrrction
projects, or for any purpose other than frre frghting is outside the primary purpose
for which a hydrant is installed. Such uses should he rigidly restricted and
controlled in the interest of keeping the fire hydrant in good working order for'fire
frghting.
The water utility, unless expressly relieved of its responsibility by the fire
department in accordance with a written agreement, public ordinance, or other
ownership, should schedule regular and sufficiently frequent inspections of hydrants
to ensure they are in good working condition.
Additional AWWA publications on hydrants include AWWA C502, Standard for
Dry-Barrel Fire Hydrants, and AWWA C503, Standard for Wet-Barrel Fire
Hydrants. The bulk of the material in this manual refers to hydrants claimed by the
respective manufacturers to be manufactured in accordance with AWWA C502 and
AWWA C503; however, information is also included on hydrants that are not
intended to comply with these standards, such as high-pressure and flush-type
hydrants. Installation practices described are consistent with AWWA C600, Installa-
tion of Ductile-Iron Water Mains and Their Appurtenances.
This manual was reviewed and approved by the AWWA Standards Committee
on Fire Hydrants. Members of that committee, at the time of approval, v/ere as
follows:
S.F. Gorden (Chairman), Portland Water District, Portland, Maine
G.C. Anderson, ISO Commerical Risk Services, Inc., Parsippany, N.J.
E.E. Alasmith, Halsey, Ore.
E.E. Baruth, Standards Engineer Liaison, AWWA, Denver', Colo.
K.M. Bell, Underwriters Laboratories, Inc., Northbrook, Ill.
Jeny Bottenfield, Clow Corporation, Oslcaloosa, Iowa
J. Bouchard, Fred F. James of New England, Boston, Mass.
EXHIBIT B
Page 5 of 14
T.J. Brown Jr., Factory Mutual Research Corporation, Norwood,
Mass.
K.J. Carl, Baldwin, N.Y.
E.J. Carville, East Bay Municipal Utility District, Oakland, Calif.
Joe Daghe, Mueller Company, Decatur, Ill.
J.B. Donohoe, Birmingham, Ala.
L.J. Dosedlo, Underwriters Laboratories, Inc., Northbrook, Il1.
S. Gudavicius, Edmonton Water and Sanitation, Edmonton, Alta.
T.C. Jester, Birmingham, Ala.
T.W. Knowlton, Salem-Beverly Water Supply Board, Beverly, Mass.
R.J. Kocol, Milwaukee, Wis.
R.L. Larkin, American-Darling Valve, Birmingham, Ala.
J.L. Lynn, James Jones Company, El Monte, Calif.
P.I. McGrath Jr., US Pipe & Foundry Company, Birmingham, Ala.
K.C. Mueller, Council Liaison, St. Louis County Water Company,
St. Louis, Mo.
H.E. Otte, Waterous Company, South St. Paul, Minn.
A. Parker, Los Angeles Fire Department, Los Angeles, Calif.
B.M. Platusich, Kennedy Valve, Division of ITT Grinnell Valve Co.,
Inc., Elmira, N.Y.
W.E. Powers, Department of Public Works, Milwaukee, Wis.
C.E. Reuben, Department of Water and Power, Los Angeles, Calif.
D.L. Tippin, City of Tampa Water Department, Tampa, Fla.
J.F. Wandyez,Eie County Water Authority, Buffalo, N.Y.
William Whitman, Springfreld Water Department, Springfield, Mass.
M.P. Yoke, M&H Valve Company, Anniston, Ala.
The AWWA Standards Committee on Fire Hydrants gratefully acknowledges
the contributions made by members of the M17 Subcommittee in preparing this
manual. The committee's efforts in developing this manual answer the need for
expanded information on fire hydrants for the industry.
Appreciation is expressed. to Ray Jackson, a past chairman of the AWWA
Standards Committee on Fire Hydrants, whose personal dedication and leadership
as chairman of the committee made various AWWA publications a reality. Apprecia-
tion is also extended to E.E. 'Skeet" Arasmith, chairman of the M17 Subcommittee,
who served to make this greatly expanded edition of M17 as comprehensive and up-
to-date as possible.
EXHIBIT B
Page 6 of 14
vl
Chapter
5.I USES
AWWAMANUALWT
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To ensure that a hydrant will work correctly when it is needed, a periodic testing and
maintenance progt'am must be followed. Aithough hydrants arc operated by members
of the fire department, it is generally the water utility's responsibility to maintain
them in wor'king order'.
In many small communities, especially where the water purveyor is not the
same political entity as the fire department, agreements have been made with the
individual fire departments to maintain and test fire hydrants. While this practice is
worthwl'rile, it should be remembered that unless there is a verifrable agt'eement, the
owner of the hydrant retains the responsibility for maintenance and inspection of the
hydrant.
OF HYDRANTS
The primary purpose of a fir'e hydrant is fire suppression. However, hydrants also
serve other usefirl functions. For exarrrple, hydrants provide a method. of testing the
distribution system's florv capabilities. They also provide a means for' flushing the
system mains, for street cleaning and sewer cleaning, for street and building con-
struction, and for recreation.
While each of these functions might be of great importance to certain individuals
or gt'oups, the primary purpose-fire suppression-is paramount. Hydrant owners
have a moral obligation to see that adequale fir'e flow can be delivered from every
hydranf under their jurisdietion. If adequate flow cannot be delivered by a particular'
hydrant, then that hydrant is not fulfilling the primary purpose. If that is the case,
the hydrant should be removed. A hydrant signifies to the public that water for fight-
ing fires is available.
5.2 SPECIAL-USE CONCERNS
When the main valve of a dry-ban'el hydrant is left partially open, substantial
amounts of water may leak through the drain valves. Depending on the volume of
leakage and the soil in which the hydrant is located, the results can be relatively
minor or catastrophic. For example, a hydrant rviih the main valve left partially open
EXHIBIT B
PageT of14
28
INSPECTION,INSTAU"ATION,TESTING 27
hydrant. Repair will require tliggrng down around the outsiile of the hydrant and
clearing tJ:e drain outlet.
4.4 PLACINC THE I.IYDRANT IN SERVICE
The follovring steps are recommended for placing a hydrant in service.
1. After testing and backfiIling, the hydrant shouid be flushed and tested to be
sure that it is bacteriologcally safe before it is put into service.
2. Tighten the outlet-nozale caps. Back them off slightly so they will not be
exeessively tight, but tight enough to prevent *rcir removal by hand.
3. Clean the hydrant exterior to remove dirt accumulated during installation. If
necessary for protection or appearance, the exposed portion ofthe hydrant shoulil be
painted with one or more coats of the utility's standard paint.
EXHIBIT B
Page I of 14
IIIAINTENANCE 29
located in easily saturated soil lv'ill fail to drain properly after main valve closure.
Excessive leakage can undermine a hydrant located in soil that is easily washed
away.
When in use, the main valve of a dry-bau'el hydlant should always be eomplete-
ly opened to ensure that the drain valve is closed. Instructions to this effect should be
given to all persons authorized to use the hydrants, including fire figlrters, contrac-
tors, street cleanets, and surnmer playground superwisors. (An isolation valve should
be connected to the hose nozzle each time the hydrant is used for pulposes other than
frre fighting, This allows the user: to control the flow without moving the main valve.)
When hydrants are repeatedly used as a water source during new construction,
the owner must consider ways to protect the hydrant, protect the water from con-
taminaiion through backllow, and also control consumption. Adequate protection and
control can be achieved through installation of a hose gate on the outlet nozzle, a
hydrant meter, and an acceptable backflow-prevention device. When the hydrant is in
use, the main valve must be left in the fully open position. Users should be instructed
to control flow through the hose gate on the outlet nozzle instead of operating the
main valve.
The use of hydrants to flrll street sweepels, sewer-flushing trucks, and sewer
high-velocity clearlers requiles special attention. Ttre connection of a hose from the
hydrant to the truck, even through a check valve, is considered a cross connection and
therefore hazardous. Hydrant owners may reqtrire each truck to have an acceptable
in-line hackflow-prevention-device connection. Another solution is to identify water.
ing poin[s that can be protected by backflow-prevention devices, such as reduced-
p1'essure devices (RPD) and/or air gaps.
In all communities, hydrants are occasionally used by unauthorized individuals.
When unauiltor{zed use of hydrants becomes a problem, special cr:ntrol techniques
may be required. Common control techniques involve legal action and penalties
against the offenders and the installation of special operating nuts and nozzle caps
that can be operated only with special wrenches. The special operating nut and
wrench designs make it difficult to lemove outlet-nozzle caps or to operate the
hydrant with standard tools.
Occasionally, a hydrant is installed where vehicular traffic inflicts repeated
damage to the hydrant, Under such a condition, it is best to move the hydrant.
However, if that is not possible the hydrant may be protected by installing a barrier
of vertical pipes or steel rods approximately 3 ft (1 m) from the hydrant.
5.3 INSPECilON
All h.ydrants should be inspected regularly, at least once a year', to ensule their satis-
factory operation. In fi'eezing climates, dry-barrel hydrants may require two inspec-
tions per year'. A common technique is to per{orm one inspection in the fall and
another in the spring. In severe freezing conditions, periodic wintel inspections may
also be rcquired. Winter inspections are especially important for dly-barrel hydrants
that are installed in areas with high groundwater levels (whether or not the drain
outlet is plugged).
It is advisable to inspect all types of hydrants afler each use. Dry-barrel
hydrants with pelmanently plugged drains must be pumped out alter eash use and
then inspected. During f'reezing conditions, after-use inspections are especially
important for dry-barrel hydrants.
To reduce manpower, inspection crews should be equipped to repair all hydrants
at the time of inspection. However, some jurisdictions prefer to have hydrants
inspected by one person and repaired by a follow-up crew.
EXHIBIT B
Page 9 of 14
30 FIRE HYDRANTS
Dqr-Barrel Hyclrant Inspection Procedure
1. Check the hydrant's appearance. Remove obstructions around it. If paint is
needed, either paint the hydrant or schedule it for painting. Check to see whether the
hytlrant needs to be raised because ofa change in the ground-surface grade. Ifadjust-
ments are needed, schedule the work.
2. Remove one outlet-nozzle cap and use a listening device to check for main-
valve leakage.
3. Using a plumb bob, check for the presence of water or ice in the hydrant
barrel.
4. Repiace the outlet-nozzle cap. Leave it loose enough to allow air to escape.
5. Open the hydrant only a few turns. All'ow air to vent from the outlet-nozzle
cap.
6. Tighten the outlet-nozzle cap.
7. Open the hydrant fully. Check for ease of operation. Certain water conditions
may cause hard-water buildup on the stem threads of toggle and slide-gate hydrants
and on the threads ofwet-top hydrants. Opening and closing the hydrant repeatedly
usually removes this buildup. If the hydrant has no threads in the water, but operates
with diffrculty, check the lubrication before proceeding with the inspection. Other
problems that may make operation diffrcult are stuck packing and bent stems.
8. With the hydrant fully open, check for leakage at flanges, around outlet noz-
zles, at packing or seals, and around the operating stem. Repair as needed.
9. Partially close the hyilrant so the drains open and water flows througb- under
pressure for about 10 s, flushing the drain outlets.
10. Close the hydrant completely. Back off the operating nut enough to take
pressure off of the thrust bearing or packing.
11. Remove an outlet-nozzle cap.
12. Attach a seetion offire hose or other deflector to protect the street, traffrc,
and private property from water expelled at high velocity. (See warning aboui rigid
diverters in Sec. 6.6.)
13. Open the hydrant and flush to remove foreign material from the interior
and lead.
14. Close the hydrant. Remove the deflector and check the operation of the
drain valve by placing the palm ofone hand over the outlet nozzle, Drainage should
be suffrciently rapid to create noticeable suction. For no-drain hydrants, pump the
water from the barrel.
15. Using a listening device, check the main valve for leakage.
16. Remove all outlet-nozzle caps, clean the threads, check the condition of the
gaskets, and lubricate the threads. (Graphite powder in oil works well, as do several
ofthe never-seize compounds.) Check the ease ofbperation ofeach cap.
17. Check outlet-nozzle-cap chains or.cables for free action on each cap. If the
chains or cables bind, open the loop around the cap until they move freely. This will
keep the chains or cables from kinking when the cap is removed during an emergency.
18. Replace the caps. Tighten them, and then back off slightly so they will not
be excessively tight. Leave them tight enough to prevent their removal by hand.
19. Check the lubrication of operating-nut threads. Lubricate per the
manufacturer's recommendations.
20. Locate and exercise the auxiliary valve. Leave it in the open position.
21. On traffic-model hydrants, check the breakaway device for damage.
22. lf t}ne hydrant is inoperable, tag it with a clearly visible mark and notify the
fire deparbment. This may save fire fighters valuable time in an emergency. Schedule
the hydrant for repair.
EXHIBIT B
Page 10 of14
MAINTENANCE 31
Wet-Barel Hyclrant Inspection Procedure
1. Check the hydrant's appearance. Remove obstructions alound it. If paint is
needed, either paint the hydrant or sehedule it for painting. Check to see whether the
hydrant needs to be raised because ofa change in the g::ound-surface grade. Ifadjust-
ments are needed, schedule the work.
2. Remove outlet-nozzle caps and check for valve-washer leakage.
3. Install a test outlet-nazzle cap.
4. Open each valve and test for ease ofoperation. If stem action is tight, open
and close several times until opening and closing actions are smooth and free.
5. Clean the cap andnozzle threads. Inspect and replace damaged cap gaskets.
Lubricate the nozzle threads. (Graphite powder in oil works well, as do several of the
neverseize compounds.)
6. Check the outlet-nozzle-cap chains and cables for free action on each cap. If
the chains or cables bind, open the loop around the cap until they move freely. This
will keep the chains or eables from kinking when the cap is removed during an emer-
gency.
7. Replace the caps. Tighten them, and then back off slightly so they will not be
excessively tight. Leave them tight enough to prevent their rerroyal by hand.
8. Loeate and exercise the auxiliary valve. Leave it in the open position.
9. If the hydrant is inoperable, tag it with a clearly visible mark and notify the
fire department. This may saye fire fighters valuable time in an emergenry. Schedule
the hydrant for repair.
5.4 LUBRICATION
For detailed information on how to lubricate a particular hydrant, contact the
hydrant's manufacturer'. The following general guidelines should be used in conjunc-
tion with the manufacturer:'s recom mendations.
l. Determine if the hydrant uses oil or grease on the operating threads. If the
threads are exposed to water, the grease should not be water soluble.
2. In order to lubricate the ttu'eads on toggle-type hydrants, the entire operating
meehanism must be removed.
3. In arctic climates, moisture in the air often will freeze the outlet-nozzle caps
and operating nut. A common solution to this problem is to coat the threads and nut
with antifreeze. The antifreeze should be made of a nontoxic, noncorrosive eompound
that is approved by the drinking water authority that has jurisdiction over potable
water.
Noru: Placing antifreeze into the barel section of the hyd.rant is not recom-
mended.
5.5 RI,PAIRS
Any condition that cannot be repaired easily during routine inspection should be
recorded in the inspection report. The problem should also be reported for action by
repair crews. Leakage, broken parts, bad operation, corrosion, and other major
defeets should be repaired as soon as possible after the defect is reported. If repairs
are to be performed in the field, the repair crew should take a full complement of
repair parts to the job site.
Nmr: Before any repair takes place, the fire department must be notified.
To obtain the exaet procedure for disassembly and repair of a specific hydrant,
refer to the manufaeturer's miintenance manual. The following information is to be
EXHIBIT B
Page 11 of 14
32 FM,E }IYDRANTS
used as a general guideline. If it appears to conflict with the manufacturer's recom-
mendations, then the manufacturer's recommendations should be followed.
1. Close the auxiliary valve ahead of the hydrant or use another means to cut
off flow and pressure to the hydrant. CeutIoN: Before proceeding, open the main
valve a few turns to make certain pressure to the hydrant has been cut off.
2. Disassemble the hydrant in accordance with the manufacturer's recommen-
dations.
3. Replace damaged parts and parts that show wear, corrosion, or signs of
incipient failure. Always replace all gaskets, packing, and seals.
4. Reassemble the hydrant and open the.auxiliary valve (or otherwise pres-
surize the hydrant). Test the main valve for leakage.
5. Vent the air from the hydrant and put the entire hydrant under pressure.
Check for leakage, ease ofoperation, and drainage.
6. Always record the repair and operating condition of the hydrant after comple-
tion of the repairs. Notify the fire department after completion of the repair.
Specific Repairs
Packing replacement. Braided or woven packing around the stem will wear
out in time. Old, worn-out packjng can be the source of leakage and can make it dif-
frcult to open and close the hydrant. The following guidelines may be helpful for
replacing packing material.
1. Select the proper packing. In the past, the most common packing material
used was asbestos graphite. Today, it is recommended that asbestos-based packing
not be installed. Instead, use some form of synthetic packing material. Manufacturers
of packing material and the manufacturer of the hydrant can provide guidelines on
packing-material selection.
2. Locate and remove the packing gland.
3, Using a packing hook, remove all of the old packing. Never place new pack-
ing over the old.
4. Remove old material and dried-on grease from the packing gland and stuffing
box.
5. Determine the size of the packing. Packing is square and is manufaetured in
Vre-in. (1.6-mm) increments. For control of leakage, the packing must be the correct
size.
6. Wrap the packing around the operating nut and mark the exact length.
7. Remove the packing and cut to length along the mark.
8. Place the packing into the stuffrng box, one ring at a time, seating each ring
with a wooden block. The joints of the packing must be staggered at 90o intervals.
9. Replace the packing gland and tighten until it is finger tight.
10. Place the hydrant under pressure.
11. Adjust the packing gland until there is only a small amount of leakage
(a tricHe of water, not a stream) around the shaft.
Traffic-Moc{el Damage
When traffic-model hydrants become damaged, follow the repair procedure listed
below. In order to execute timely repair, an inventory of parts for tra{Iic-model
hydrants should be kept on hand. Extra gaskets, Iubricant, O rings, and bolts should
be kept on hand.
1. Notify the frre department of the outage. Ttris should be done as soon as the
damage is discovered
EXHIBIT B
Page 12 of 14
MAINTENANCE 33
2. Protect the area with proper traffic and pedestrian control. If the hydrant
cannot be immediately repaired, the broken and loose components should be removed
from the site and the hole covered to keep pedestrians from stepping in it.
3. Repair following the manufacturer's recommended procedure.
Adjusting hydrant height. When the height of a hydrant must be changed
due to a change in street grade, it is important to first notiff the fire department.
Proper care must be taken to control baffic and pedestrians. Each hydrant manufac-
turer has a specific procedure that should be followed in changing the height.
5.6 RECORD IGEPINC
In order to earry out a meaningful inspection and maintenance program, it is essen-
tial to record the location, make, f4pe, size, and date ofinstallation for each hydrant.
Other information also may be recorded, depending on the nature of the record-
keeping system used.
When a hydrant is inspected, the lecord should indicate the inspection date and
the condition of the hydrant. If repair work is necessary, the nature of the work
should be indicated. When repair work is completed, the nature of the repairs, date,
and other relevant information should be r"ecorded. Other information, such as test-
ing, pumping, ease of operation, direction of open, and number of turns to open, is
also important and should be carefully recorded. This data may be hept in hard copy
or transferred to a data base on a microcomputer. It is suggested that these records
be altered to meet individual needs.
Samples of record and survey sheets are shown in Figures 5-1 through 5-5. Some
type of basic "masterp record is necessary to give backg:'ound informabion on hydrant
type and installation (see Figure 5-1). This infor:nation will make it much easier to
determine parts inventory and training requirements. This record is also useful in
comparing hydrants. This is useful to determine which styles, nozzle thread sizes,
and operating uuts are the most common in the system.
The center section of the master-r'ecord form allows for the accumulation of
information concerning the frequency of inspections and repair.s. This data is impor-
tant to the Insurance Services Office and can help in determining the fi'equency of
maintenance on a particular hydrznt. A padiculal hydrant or type of hydrant that
continues to develop the same repair problem can be systematically removed from the
system. Without this type of information, it would be difficult to determine that a par-
ticular type of problem is recurring.
The diagram at the bottom of the form should give as much detail as possible
about fitting types, branch line lengths, and valve locations. This information is help-
ful for repair and maintenance.
The hydrant-maintenance and hydrant-inspection repolt forms (Figures 5-2 and
5-3) are used during routine hydrant inspections in conjunction with the procedures
described in Sec. 5.3, Sec. 5.4, and Sec. 5.5-. The hydtant-maintenance-report form is
used when hydrants are repailed during routine inspections. The hydrant-inspection-
report for:rn is used when the inspeetion crew makes only minor repairs. All major
]'epairs are written on a worh-order forrn and are performed by a repair crew.
The flow-test-report form and the hydrant-test form (Figures 5-4 and 5-5) are
used in conjunction rvith the flow test procedure described in chapter 6. The flow-test-
report form is used to record the results of a single flow test; the h.ydrant-test form is
a historical record of one hydranl. The historical record is extremely useful in deter-
mining distlibution-system changes that affect fire flows.
EXHIBIT B
Page 13 of 14
84 TIBE ITYDRANTII
FIRE HYDRANT MASTER RECORD
Manufacturer Dale- Hydrant No.
Type lnlet
Bury Hose Outlet-Nozzle Size _ Thread Type
Pumper Outlet-Nozzle Size
-
Thread Type
-
lnstalled by Date
-
wo No.- Cost
-
Operating Nul Turns to Open
Line Static Pressure
Property Line
(!3
o
c.9ar
Date lnspected Tested Repaired Painted Opened by Cost Bemarks
Water Main-Size/Tyge
EXHIBIT B
Page 14 of 14
Flgure 5-1 Master recotd.