20051021Decision memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
CO MMISSI 0 NER SMITH
COMMISSIONER HANSEN
COMMISSION SECRETARY
COMMISSION STAFF
FROM:DON HOWELL
DATE:OCTOBER 19, 2005
SUBJECT:PROPOSED STRAY VOLTAGE RULES,
DOCKET NO. 31-6101-0501
In March 2005 , the Idaho Legislature passed and the Governor signed the Stray
Current and Voltage Remediation Act codified at Idaho Code 99 61-801 et seq. Section 61-803
requires that the Commission promulgate temporary and proposed rules establishing uniform
procedures for the measurement of stray current or voltage. Following negotiated rulemaking,
the Commission issued a Notice of Temporary and Proposed Rulemaking which was published
in the Administrative Bulletin on September 7, 2005. The temporary rules became effective on
September 14, 2005.The Commission s Notice required that interested persons submit
comments regarding the proposed rules no later than September 27 2005.
THE COMMENTS
The Commission received three comments. In a letter dated August 23 , 2005 , the
Legislative Services Office indicated that the Senate and House Subcommittees for review of
administrative rules have examined the proposed rules. The letter stated that no "meeting will be
held, and we are pleased to report that no objections will be filed (to the proposed rules).
Idaho Power also submitted comments recommending that the Commission make
four changes to the Temporary and Proposed Rules. Idaho Power s comments are attached. The
four changes proposed by Idaho Power affect Rules 71 , 74 and 75. First, Subsection 71.01 of the
Temporary and Proposed Rules requires that the six stray voltage tests be performed in sequence.
Idaho Power is recommending that 71.01 be modified to allow the utility to conduct the tests in
any order. Staff and the Dairymen/Milk Producers concur with this proposed change. Ken
McClure s letter from the Dairymen/Milk Producers is also attached.
DECISION MEMORANDUM
The second change would allow a utility to reduce the duration of the 48-hour test
(Test 2) in instances where it is clearly determined that the utility must conduct remediation for
stray voltage or current. In such instances, the Company is recommending that the 48-hour test
be abbreviated to a minimum of at least 24 hours. Staff and the Dairymen/Milk Producers agree
with this proposed change.
Third, the Company is proposing an addition to Rule 71 to allow the stray voltage
investigation to be suspended or limited in instances where the utility and the dairy producer
agree in writing. As Idaho Power explains in its comments
, "
a dairy customer may ask the utility
to check contact voltages in a specific area following nearby electrical changes. Similarly, the
utility may want to make measurements on its own initiative as part of its normal system
maintenance.The Commission Staff does not object to this change. The Dairymen/Milk
Producers also agree but proposed an additional sentence for clarification. Staff agrees with the
clarifying sentence.
Finally, the Company recommends changes to the primary profile test (Test 3).
Currently, Temporary and Proposed Rule 75 requires that the utility conduct stray voltage
measurements within 3/4 of mile on either side of all primary service points and "all branch lines
encountered within this specified distance.Rule 75.02.While the Staff and the
Dairymen/Milk Producers do not object to the deletion of checking branch lines, Staff and the
Dairymen/Milk Producers recommend that the Commission reject the distance reduction from
3/4 of a mile to a half-mile. Staff believes that the greater distance is the appropriate testing
distance. The Dairymen/Milk Producers also object to adding the phrase "to the extent practical
. . . to Rule 75.02.a. Staff agrees.
COMMISSION DECISION
Does the Commission wish to adopt any of Idaho Power s suggested changes to the
Temporary or Proposed Rules? Does the Commission wish to add the Dairymen/Milk Producers
clarifying sentence? With the changes (if any), does the Commission wish to adopt the proposed
Stray Voltage Rules as pending rules? I have attached a draft of the agreed upon changes. Does
the Commission wish to issue a Notice of Pending Rule and a change to the Temporary Rules to
be published in the Administrative Bulletin on December 7, 2005?
blslN:31-6101-0501 OecMemo dh2
DECISION MEMORANDUM
An IDACORP Company
Paul E. Ortmann,
Senior Electrical Engineer - Power Quality
273 Blue Lakes Blvd. South , Twin Falls, 10 83301
Phone: [phone] Fax: [phone]
e-mail: portmann~idahopower.com
EWIO
Comments and Recommendations on the IPUC Temporary Stray Voltage Rules
Overview:
Idaho Power Company recommends changes to the Stray Voltage Rules based on field
experience applying the temporary rules. The intent of these recommended changes is to:
1. Provide increased flexibility in scheduling the individual tests
2. Reduce the overall time necessary to complete the required tests, and
3. In cases where the Preventive Action Level (PAL) is exceeded, reduce the time required
to determine the off- fann contribution to the cow-contact voltage and identify likely
sources so that appropriate mitigation can begin sooner.
Discussion of recommended changes:
The existing rules require two initial tests, the cow-contact test and the forty-eight hour test, to
detennine if the PAL is being exceeded. Depending on the results of the first two tests, four
additional tests may be required. These additional tests are used to help detennine the sources of
the cow-contact voltage. Rule 071.01 requires that the tests be conducted in a specific order
which may be interpreted to require that the 48-hour test must be completed before tests three
through six can begin. In a typical investigation, the 48-hour test will not begin until near the
end of the first day of the investigation. Rule 071.01 would require that no further testing be
conducted for two days, until the 48-hour test is complete.
In detennining the off-farm contribution to cow contact voltage, the data used from the 48-hour
test is the highest recorded steady-state cow-contact voltage, (V cc) and the primary neutral-to-
earth voltage (Vp) recorded at the same time. This data is combined with data from the load box
test to calculate the off-farm contribution to that maximum-recorded steady-state cow-contact
voltage.
In some cases, the investigator may know that the PAL is being exceeded before beginning the
48-hour test based on the results of the cow-contact test. In other cases, cow-contact voltages in
excess of the PAL may be recorded early in the 48-hour test. In either case, the question of
whether or not the PAL is being exceeded will have been answered well before the 48-hour
recording has been completed. Also, the primary profile test, and often the secondary neutral
voltage drop test, load box test, and signature test may be conducted at times when they will
have little or no impact on the dairy operation and without affecting the results of the 48-hour
test.
Recommendation
Idaho Power recommends changing Rule 071 to give investigators the flexibility to conduct tests
, 4, 5 , and 6 in any order, and to allow these tests to be conducted immediately prior to, during,
or following the 48-hour test. To facilitate this, Idaho power recommends allowing the 48-hour
recording to be interrupted so that data may be downloaded periodically for review and analysis
and so that sampling rates can be adjusted if desired. For example, sampling rates of 1 second
rather than 10-seconds are sometimes used to provide better resolution of the signature test data.
An IDACORP Company
Paul E. Ortmann, P.
Senior Electrical Engineer - Power Quality
273 Blue Lakes Blvd. South, Twin Falls, 10 83301
Phone: [phone] Fax: [phone]
e-mail: portmann~idahopower.com
IDf.\HO
.:!!
POWER
This change to rule 071 would facilitate faster completion of the on- fann tests and could
contribute to faster resolution of a stray voltage problem if one exists. If this change were
adopted, it may be possible to detennine that a utility is required to conduct remediation under
rule 71.02.d during the first day of an investigation rather than after the third or fourth day of an
investigation.
Recommendation 2:
Idaho Power recommends that if a utility, using the results of the cow-contact test, any portion of
a 48-hour test, and a load box test, detennines that it is required to conduct remediation under
rule 71.02., the utility may reduce the duration of the 48-hour test to a minimum of 24-hours.
Idaho Power is only proposing a shorter recording if enough data has already been collected to
detennine that utility mitigation is required, and under these circumstances Idaho Power
recommends a minimum recording of 24 hours.
Recommendation 3:
Idaho Power recommends adding a provision to the rules that would allow for a limited stray
voltage investigation, or for the suspension of a stray voltage investigation prior to the
completion of all required tests, if both the utility and the dairy agree to limit or suspend the
investigation. This recommendation has two purposes. First, it allows the investigation to be
intentionally limited. For example, a dairy customer may ask the utility to check contact
voltages in a specific area following nearby electrical changes. Similarly, the utility may want
to make measurements on its own initiative as part of its nonnal system maintenance. Second
this change would allow a nonnal stray voltage investigation to be suspended before completion.
For example, it may be immediately apparent to both the investigator and the diary customer that
the cow-contact voltage at a particular location is largely the result of some specific on- fann
electrical condition. In such a case, it is nonnally more productive to correct this on- fann
electrical condition before proceeding with the rest of the investigation.
Recommendation 4:
For the Primary Profile test, Idaho Power recommends that rule 075.02 be changed to require the
primary profile to extend along the primary distribution line to which the dairy is connected for a
distance of at least 1/2 mile in each direction from the dairy s connection point, or to the end of
the primary distribution line if that is less than 1/2 mile from the dairy s connection to the
primary distribution line. Idaho Power also recommends that the requirement in rule 075.02., to
check all branch lines encountered within the specified distance, be removed. This change
reduces the number of individual locations where measurements are required for the primary
profile test, but does not preclude the investigator from extending the primary profile further
along the main distribution line, or along any branch lines encountered, if the investigator
believes this will aid in the identification of an off- fann issue that is contributing to the stray
voltage on the dairy being investigated. Reducing the extent of the primary profile reduces the
investigation time in cases where it may be immediately clear from the data collected on or near
the dairy that a more extensive primary profile is not required.
Paul E. Ortmann, P .
Senior Electrical Engineer - Power Quality
273 Blue lakes Blvd. South, Twin Falls, 1083301
Phone: [phone] Fax: [phone]
e-mail: portmann~idahopower.comAn IDACORP company
To aid in the incorporation of these recommendations if they are adopted, specific changes to the
pertinent sections of the rules are included as a markup below.
Rule 071
071. STRAY CURRENT OR VOLTAGE TESTS (Rule 71).
Subject to Subsection 071.02 of this rule, there are six (6) tests used to detect and measure stray current or voltage.
01. Scheduline Order of Stray Voltage Tests. 6Sts shan be performed in the order listed below-. I
Efforts shall be made to perform the tests under conditions substantially similar to those conditions existing at the
time(s) the dairy producer believes stray voltage to be a problem.(List omitted) 02. Testing Sequence. Tests I ~shall be performed first Tests I and 2 are used to determine th.
presence and level of stray voltage and must be perfOImed in all investigations. subject to the provisions of
subsection 071.02.e. Tests 3, 4, 5. and 6 may be perfonned in any order and may be performed without first
detennining that these tests are required under subsection 071.02.b. Tests 3. 4, 5, and 6 may be performed prior to
starting the recording for test 2 or while test 2 is in progress. to determine the presence aI1d level of stmy':oltage.
Test 2 may be illtcITUpJed as necessary to conduct tests 4.5, and 6, or for review and analysis or the data recorded up
to that point.
a. If the results from Tests 1 and 2 indicate that stray voltage does not exceed the preventive action
level (PAL), the utility has no further testing or remediation obligations under these rules during this test cycle.
b. If the PAL is exceeded, the utility shall perform the remaining four (4) tests subject to the
provisions of subsection 071.02.. The utility shall also perfonn analysis to determine whether the portion of the
stray current or voltage attributable to an off.farm source exceeds fifty percent (50%) of the PAL.
C. If the PAL is exceeded, and the portion of the stray current or voltage attributable to an off-farm
source does not exceed fifty percent (50%) of the PAL, the utility has no further testing or remediation obligations.
d. If the PAL is exceeded, and the portion of the stray current or voltage attributable to an off-farm
. source exceeds fifty percent (50%) of the PAL, the utility shall conduct remediation pursuant to Section 091. Under
this condition, the 48-hour recording or test 2 may be reduced to no fewer than 24 hours.
e. With the agreement of both the utility and the dairy customer. a stray voltage investigation may be
suspended at any point in the investigation. Also with the agreement of both the utility and the dairy customer. the
utility may employ a limited set oftests or measurements on a dairy as part of an intentionally limited evaluation.
&:f:. For all testing conducted under these rules, the utility shall have a qualified analyst prepare a report
pursuant to Section 082.
Rule 074
074.TEST 2 - FORTY-EIGHT (48) HOUR TEST (Rule 74).
01. Purpose. The purpose of this test is to detennine whether stray current or voltage exceeds the
preventive action level (PAL) at selected location(s) over a forty-eight (48) hour period. subject to rule 071.02.d and
subsection 074.06.The test also demonstrates whether the primary or secondary sides of the system have a specific
impact on the recorded current or voltage at specific times of day.
Paul E. Ortmann, P.
Senior Electrical Engineer - Power Quality
273 Blue Lakes Blvd. South, Twin Falls, 1083301
Phone: [phone] Fax: [phone]
e-mail: portmann~idahopower.comAn IDACORP Company
-eN ew subsection 074. 06~06. Reduced Recordine Period. If a Qualified analyst concludes that mitigation by the utility is
required under rule 071.02.d prior to the completion of a 48-hour recording period. th.e recording period may be
reduced to no fewer than 24 hours.
Rule 015.
02. Conducting the Test. The primary profile test requires concurrent measurement of the ground electrode
resistance and current at all primary system ground points within at least one hal f (1/2) three quarters (3.'4).of a mile
on either side of all primary service points serving the dairy, or to the end of the line if less than one hIDf (1.12) three
quarters (3/4)of a mile. Alternatively, the voltage between a remote grounding rod and the primary ground point
being tested may be measured.
a. To IDe extent practical.+this test shall be conducted starting at one end of the distribution system
and working toward the other end along the main primary distribution system .end '."hile checking all branch lines
encountered within the specified distance.Figure 4 below illustrates the procedure.
-(Subsections 075.02.(a)(i) and 075.02(a)(ii) would be deleted.
Idaho Power believes that these recommended changes, if incorporated in the Stray Voltage
rules, would benefit both dairy customers and utilities. These changes could significantly reduce
the time required to determine that utility mitigation is required if that is the case, and could
reduce the overall time required to complete a stray voltage investigation that meets the
requirements of the rules.
Please feel free to contact Idaho Power if there are questions regarding any of these comments
and recommendations.
Paul Ortmann, P.
Senior Electrical Engineer - Power Quality
Idaho Power Company
GIVE SLEY
I.LP
LAW OFFICES
601 W. Bannock Street
PO Box 2720, Boise. Idaho 83101
TELEPHONE: [phone]
FACSIMILE: 208 388.1300
WEBSITE: www.glvenspursley.com
Gary G. Allen
Kristen A. Atwood
Kelly T. Barbour
Christopher J. Beeson
William C. Cole
Michael C. Creamer
Thomas E. Dvorak
Roy Lewis figuren
Timothy P. Fearnside
Jeffrey C. Feraday
Melissa A. Finocchio
Steven J. Hippler
Karl T. Klein
Debora K. Kristensen
Anne C. Kunkel
October 21 2005
Donald L.Howell, II, Esq.
Deputy Attorney General
Idaho Public Utilities Commission
472 \V. Washington Street
Boise, Idaho 83720
Re:Col11111cnts on Stray Voltage Rules
Docket No. 31-6101-0501
Dear Don:
Jeremy G. Ladle
Franklin G. tee
David R. Lombardi
Emily A. MacMaster
John M. Marshall
Kenneth R. McClure
Kelly Greene McConnell
Cynthia A. Melillo
Christopher H. Meyer
L. Edward Miller
Patrick J. Miller
Judson B. Montgomery
Angela K. Nelson
Deborah E. Nelson
W. Hugh O'Riordan, LLM.
Kenneth l.. Pursley
Bradley V. Sneed
H. Barton Thomas, Ll..
J. Will Varin
Conley E. Ward
Robe!1 6. White
Raymond D. Givens
RETIRED
James A. McClure
RETIRED
Ucensod fn California
Thank you for distributing the COl11ments Idaho Power tiled with you concerning
the proposed stray voltage rules. We appreciate the opportunity to review and respond to
them. For your record, the only COmlllents we have seen frOll1 Idaho Power are from Paul
E. Ortn1ann, P .E. (undated) which you forwarded to interested parties on October 15,
2005. Further for the record, we have reviewed the Staffs proposed changes which were
distributed yesterday. Finally, by way ofprelitninary Inatters, this letter is submitted on
behalf of the Idaho DairYJ11CnS ' Association and the Milk Producers of Idaho.
Addressing Mr. Ortmann s con1ments first, we have no issues with the
recornmendations he has idcntitied as Recommendations 1 and 2 or vvith the suggested
rule changes associated with those recommendations. They appear to be appropriate
modifications to the proposed rules.
Reco111mendation 3 also appears to be appropriate although we believe the rule
change associated with it (Rule 071.02.e) would benefit from clarification. First, we
believe that a limited evaluation should be conducted only with the consent of the dairy.
That consent should be evidenced in writing both to avoid confusion and to clarify that
the utility will not conduct testing on the dairy premises without the prior consent of the
dairy. The language proposed by Staff for that provision incorporates the requiren1ent of
written consent in an appropriate fashion. We vv'ould also suggest that the \vriting contain
Don Ho,\'cll
October 21, 2005
Page 2
an explanation of the reasons for conducting a lilnited evaluation so the dairy n1ay be
fully infornled of the reasons the utility believes a full evaluation is not necessary. The
following language for Rule 071.03 (as nunlbered in the Staff's draft) vvould satisfactorily
address our concerns:
03 Suspended or Lhnited Testing. With the written agreelnent of both the utility
and the dairy producer, a stray voltage investigation nlay be suspended at any point in the
investigation. With the written agrcelnent of both the utility and the dairy producer, the
utility may employ a limited set of tests or Ineasurell1cnts on a dairy as part of an
intentionally limited evaluation. If the utility lllil!Joses to suspend a stray voltage
investigation or to conduct a litnited evaluation, its reasons for doing so shall be set forth
in the written agreel11eill between the utility and the dJ ry producer.
We do not agree with that portion of Recomlnendation 4 which would reduce the
primary profile test 1"ron1 three quarters to one half nlile. We believe the requirelnent for
testing within three quarters of a mile from the primary service point for the dairy is
appropriate to ensure that issues on the distribution line close to the dairy are identified
and appropriately renlcdicd. We are not sure what would lTIake it "in1practical" to Htest
starting at one end of the the distribution system and working toward the other end...
and therefore are concerned about the proposed addition to Rule 075.02.a ofthc phrase
To the extent practicaL..." Unless there is substantiation in the rulemaking record for
this modification we would suggest that it not be included.
Other than the proposed lTIodification to Rule 071.03 set forth above we have no
cornments on the Staffs proposals you en1ailed yesterday other than to say that they are
satisfactory and appropriate. We thank you for the opportunity to submit these comments
to you for your consideration.
l?~~
Kenneth R. McClure
cc:Brent 0 lmstead
Bob Naerebout
:Rcx Blackburn
THE IDAHO PUBLIC UTILITIES COMMISSION--AGENCY 31
TITLE
CHAPTER
RULES FOR THE MEASUREMENT OF
STRA Y CURRENT OR VOLTAGE
(THE STRAY VOLTAGE RULES)
IDAP A 31.61.01.000
071. STRAY CURRENT OR VOLTAGE TESTS (Rule 71).
Subject to Subsection 071.02 of this rule, there are six (6) tests used to detect and measure straycurrent or voltage. (9-14-05)T
01. Order Scheduline:of Stray Voltage Tests. +he tests shall-be performed in the
order listed beiov/.Efforts shall be made to perfonn the tests under conditions substantially
similar to those conditions existing at the time(s) the dairy producer believes stray voltage to be aproblem. ( 12- 7 -05).
Test 2 - Forty-Eight (48) Hour Test;
(9-14-05)T
(9-14-05)T
Test 1 - Cow Contact Test;
Test 4 - Secondary Neutral Voltage Drop Test;
(9-14-05)T
(9-14-05)T
Test 3 - Primary Profile Test;
Test 6 - Signature Test.
(9-14-05)T
(9-14-05)T
Test 5 - Load Box Test; and
02. Testing Sequence. Tests shall be perfonned first
Tests 1 and 2 are used to detennine the presence and level of
stray voltage and shall be perfonned in all investigations, subiect to the provisions of Subsection
071.03. Tests 3, 4, 5, and 6 may be perfonned in any order and may be perfonned without first
detennining that these tests are required under Subsection 071.03. Tests 3, 4, 5, and 6 may be
perfonned prior to starting the recording for Test 2 or while Test 2 is in progress. Test 2 may be
interrupted as necessary to conduct Tests 4, 5, and 6, or for review and analysis of the data
recorded up to that point.(12- 7-051
a. If the results from Tests 1 and 2 indicate that stray voltage does not exceed the
preventive action level (PAL), the utility has no further testing or remediation obligations underthese rules during this test cycle. (9-14-05)T
b. If the PAL is exceeded, the utility shall perfonn the remaining four (4) tests except
as provided in Subsection 071.03 The utility shall also perfonn analysis to detennine whether
the portion of the stray current or voltage attributable to an off-farm source exceeds fifty percent
(50%) of the PAL. ~.c12-05)
c. If the PAL is exceeded, and the portion of the stray current or voltage attributable
to an off-fann source does not exceed fifty percent (50%) of the PAL, the utility has no further
testing or remediation obligations. (9-14-05)T
d. If the PAL is exceeded, and the portion of the stray current or voltage attributable
to an off- fann source exceeds fifty percent (50%) of the PAL, the utility shall conduct
remediation pursuant to Section 091. Under this condition, the forty-eight hour recording of
Test 2 may be reduced to no fewer than twenty-four eM) hours..c12-05)
e. For all testing conducted under these rules, the utility shall have a qualified analystprepare a report pursuant to Section 082. (9-14-05)T
03. Suspended or Limited Testing. With the written agreement of both the utility and
the dairy producer, a stray voltage investigation may be suspended at any point in the
investigation. With the written agreement of both the utility and the dairy producer, the utility
may employ a limited set of tests or measurements on a dairy as part of an intentionally limited
evaluation. If the utility proposes to suspend a stray voltage investigation or to conduct a limited
evaluation, its reasons for doing so shall be set forth in the written agreement between the utilityand the dairy producer. ,( 12 - 7 -0 5 ).I
(BREAK IN CONTINUITY OF SECTIONS)
TEST 2 - FORTY-EIGHT (48) HOUR TEST (Rule 74).074.
01. Purpose. The purpose of this test is to detennine whether stray current or voltage
exceeds the preventive action level (PAL) at selected location(s) over a forty-eight (48) hour
period, subiect to Subsections 071.03 and 074.. The test also demonstrates whether the
primary or secondary sides of the system have a specific impact on the recorded current orvoltage at specific times of day. (12-05)
02. Setup. digitizing data recorder with averaging capability and capable of
detecting and recording transient deviations of one-tenth (0.1) second or less in duration shall beused to record the following: (9-14-05)T
Voltage from primary neutral at the transfonner to remote reference ground, Vp.
(9-14-05)T
b. Voltage from secondary neutral in the service panel serving the area of the cow
contact to remote reference ground, V s. (9-14-05)T
c. Voltage drops (Vps) from primary neutral at the location of connection for Vp to
secondary neutral at the location of the connection for V s. (9-14-05)Td. Cow contact current through (Icc) or voltage across a five hundred (500) ohm
resistor at the high voltage point(s) found in Test 1 , Vcc. (9-14-05)T
03. Measurement Interval. The results of the forty-eight (48) hour test may be highly
indicative of the presence of stray voltage. A recording interval as high as ten (10) seconds may
be used provided that transient deviations of voltage or current of one-tenth (0.1) second or less
in duration of voltage or current are recorded to the maximum ability of the instrument.
(9-14-05)T
04. Measurement at the Cow Contact Point(s). Measurements to the earth or
concrete surface shall be to a metal plate as described in Paragraph 073.03.c. when making
measurements to metal objects, corrosion shall be removed to obtain a low resistance connection.
(9-14-05)T
05. Recording the Data. All of the data gathered by the recording equipment during
the forty-eight (48) hour test including transients shall be downloaded and retained with the
records of the investigation. In addition, the steady-state data shall be summarized in the
investigation report. The recorded data shall be made available to the dairy producer or utility
upon request. The person conducting this test shall record the location of, and measured values
, each test point. The identification of the cow contact point shall be recorded on the fonn in
Appendix 2. Transient deviations shall be recorded on the supplemental data fonn, page 3 of 3
in Appendix 2. A plot of the voltage versus time may be substituted for the recording ofmeasured values in Appendix 2. (9-14-05)T
06. Reduced Recordine Period. If a qualified analyst concludes that mitigation by
the utility is required under Subsection 071.03 prior to the completion of a forty-eight C1ID hour
recording period. the recording period may be reduced to no fewer than twenty-four C21) hours.
(12- 7-05)
075.TEST 3 - PRIMARY PROFILE TEST (Rule 75).
01. Purpose. The purpose of this test is to measure or calculate neutral-to-earth
voltage (NEV) for a multi-grounded distribution system. (9-14-05)T
02. Conducting the Test. The primary profile test requires concurrent measurement
of the ground electrode resistance and current at all primary system ground points within three
quarters (3/4) of a mile on either side of all primary service points serving the dairy, or to the end
of the line if less than three quarters (3/4) of a mile. Alternatively, the voltage between a remote
grounding rod and the primary ground point being tested may be measured. (9-14-05)T
a. This test shall be conducted starting at one end of the distribution system and
working toward the other end along the main primary distribution system
brancMines encountered-withift-the specifiethiistance . Figure 4 below illustrates the procedure.
!12- 7-05)
i. Where the dairy is served by a dedicated tap of less than one half (1/2) mile in
length from a distribution line, the neutral-to-earth voltage shall be measured at each primary
ground along the tap and along the distribution line to a distance of three quarters (3/4) of a mile
in each direction from the point of the tap; or (9-14-05)T
ii. Where a dairy is served by a dedicated tap that extends more than one half (1/2)
mile from the distribution line, the neutral-to-earth voltage shall be measured at each primary
grounding electrode along the tap and along the distribution line to a distance of one half (1/2)
mile in each direction from the point of the tap. (9-14-05)T
03. Recording the Data. The person conducting this test shall record the location of
and measured values at, each test point. Data and calculation results for these test points shall be
recorded on the form in Appendix 3. (9-14-05)T