20160722Addendum Comments.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF DIAMOND BAR
ESTATES WATER COMPANY'S
APPLICATION FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO.
n[:C f IVED
'Jll5 lr',,22 PH 2:26
'' ''r _ *, '- I !,^i l:J*i.J.,i ',1;,iiS-qiON
CASE NO. DIA.W.Is.OI
ADDENDUM COMMENTS OF
THE COMMISSION STAFF
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Daphne Huang, Deputy Attorney General, now submits the following addendum to comments in
response to Order No. 33547.
BACKGROUND
In December 2015, Diamond Bar Estates Water Company (Diamond Bar) filed a general
rate case Application to increase its rates and charges for water service. The Commission issued a
Notice of Application and Notice of Modified Procedure, and suspended the effective date until
July 1, 2016. Order No. 33452. Staff conducted a public workshop for customers, performed an
investigation and audit, and filed written comments to which Diamond Bar responded with a
reply. Id. at l. The Commission received more than l8 written comments and held a public
hearing at which six customers testified. /d.
In June 2016, the Commission suspended the effective date of the Company's Application
an additional 60 days, until August 30, 2016. Order No. 33547. The Commission set a deadline
STAFF COMMENTS JULY 22,2016
of July 8,2016 for Diamond Bar to provide responses to six questions regarding the AEI
engineering report, Diamond Bar's pump motor failures, and also contamination at the Company
wells. Id. The Commission also directed Staff to file an addendum, if any, by July 22,2016. Id.
The Company may file a reply by July 29,2016. Id.
DIAMOND BAR'S RESPONSES
1. KEC's requirement of a soft start on motors larger than 20 hp
The Commission asked if Diamond Bar was made aware of Kootenai Electric
Cooperative's (KEC) rule requiring a soft start on motors larger than 20 horsepower (hp), by KEC
or any pump contractors working on prior pump motor failures. The Company responded that the
rule was brought to its attention through the AEI engineering report. According to the Company,
neither Diamond Bar, nor its contractor United Crown Pump and Drilling (UCPD), was contacted
by KEC about changing to a soft start. Response to Order No. 33547.
2. Diamond Bar's understanding about needfor a soft start
The Commission next asked if Diamond Bar believed that soft start equipment would or
would not have prevented motor failure. The Company responded that the AEI report identified a
soft start as "recommended action" rather than a requirement. The Company also stated, "The
original [full voltage non-reversing starter] was approved and operational and the transformers
were sized by KEC for the intended load(s)." The Company noted that KEC's on-site testing
"confirmed that the original transformers were able to handle the load of the pumps and motors
that were operating at that time." Diamond Bar concluded that, while a soft starter would have
changed the power demand, it would not have affected the damage that occurred."
3. Did Diamond Bar inform KEC of its 2004 pump-size inuease?
The Commission asked if the Company informed KEC that it increased pump size from 50
hp to 60 hp in 2004. The Company indicated that it did not. However, Diamond Bar noted that
KEC's "monitoring report reflects the original transformers were handling the load." Diamond
Bar provided an Exhibit 1, in which KEC's Dave Kahly reports, o'Our transformer capacity is
good."
STAFF COMMENTS JULY 22,2016
4. Assessment of electrical equipment at pump by certified electrician before 201 5 AEI Report
The Commission also asked if Diamond Bar had hired a certified electrician to assess the
electrical equipment at the pump - including grounding, transformer adequacy, surge protection
and conductors - prior to the AEI Report in 2015. The Company responded that its contractor,
United Crown Pump and Drilling (UCPD), "is a fully licensed and bonded electrical contractor in
ID and WA who specializes in pump systems and controls." The Response does not address
timing or substance of UCPD's work.
5. Root cause of pumpfailures between 2002 and 2015
The Commission asked Diamond Bar what it believes was the root cause of the multiple
pump motor failures between 2002 and2015. The Company noted that AEI believes the utility
transformers were undersized but "did not pinpoint the failure reason exactly." Diamond Bar
believes that installing larger pad transforners has resolved the failures.
6. Contamination at the wells
Finally, the Commission asked for a schedule of dates when either well was contaminated,
and the type of notice provided to customers. Diamond Bar indicated there was one contamination
issue in August 2012 (coliforrn was present). The Company stated it notified customers by
telephone that the well tested positive for coliform, and that retests were done through August into
September 2012, showing the absence of coliform.
STAFF ANALYSIS
Staff reviewed the Company's response to the Commission's requests for information in
Order No. 33547. To develop meaningful conclusions about the Company's information and to
provide additional context, Staff performed further review of technical reports and Company
responses already in the record. Based on its review, and mindful of the Commission's concems
in Order No. 33547, Staff makes four determinations, discussed in more detail below:
1. Root Cause of Pump Motor Failure - Staff concurs with the Company that the 75 kVA
transformer supplying power to the well house was undersized and was a major
contributing factor of well pump motor failures. However, Staff also believes that phase
configuration incompatibility between the transformer and the service entry was also a
STAFF COMMENTS JULY 22,2016
contributing factor. Staff believes these two items were the primary root cause of well
pump motor failures, and resolution of these items are critical for the simultaneous
operation and starting of the water system's four pumps.
Failure Mode Prevention - To reduce the possibility of future pump motor failures, Staff
believes the Company should install a circuit breaker designed to simultaneously
disconnect all three phases in the event that any one phase is disconnected.
Soft Start - Although a soft start might have prevented some of the conditions causing well
pump motor failure, Staff agrees with the Company that a soft start alone would not have
prevented all failure modes.
Contamination - Based on information provided by the Company and the Idaho
Department of Environmental Quality (IDEQ), the Company has complied with IDEQ's
customer notice and additional water sampling requirements. There have been no
contamination problems detected since November 2012.
Root Cause of Pump Motor Failure
Staff believes that the 7 5 kVA transformer (provided by KEC, not Diamond Bar)
supplying power to the well house was grossly undersized for the simultaneous operation and
starting of the water system's four pumps. This problem is made worse by incompatible phase
configurations between the pump house service entry (Delta configuration) and KEC transformer
(Wye configuration). Staff has determined that the 75 kVA transforner was barely adequate to
supply the power needed for all pumps to operate simultaneously, and that the additional load
required to start either the 60 hp well pump or the 20 hp fire pump would be sufficient to blow a
transformer circuit breaker or pump house fuse. Using Article 430 of the National Electric Code,
Staff has calculated that the transformer should be sized to supply at least 109 kVA.
To determine the root cause of the repeated pump failures between 2002 and2015, and to
understand the Company's responses to those failures, Staff again reviewed the Company's
records. Staff notes that the Company does not possess the in-house expertise necessary to
diagnose the problem without relying on advice from outside experts. Prior to consulting with
Engineering Company, AEI, in 2015, Staff believes the advice Diamond Bar received from some
of these experts may have been inadequate or incomplete.
When it was constructed in 1995, the Company's water system used a 50 hp well pump and
was provided a75 kVA transformer by KEC. Using National Electric Code Article 430, Staff
J.
4.
STAFF COMMENTS JULY 22,2016
calculated that the water system required a transformer of no less than 96 kVA. Then in 2004, the
Company decided to install a 60 hp pump making the problem worse. It is Staffs opinion that an
engineer or joumeyman electrician familiar with the National Electric Code should have
determined that the transformer was grossly undersized for simultaneous start-up loads required of
the water system's four pumps. Staff was unable to determine either why the transformer was not
originally sized correctly, or why this issue was not identified in 2004 when the pump was
upsized.
Staff notes that several parties expressed concerns about system and transformer sizing
throughout the record period. However, as late as August 2015, KEC advised the Company's
contractor, UCPD, that the transformer was adequately sized. Staff notes that KEC's analysis was
based on hourly average load data, and does not appear to have considered the brief, but large
surges needed for pump starts.
Between 201I and 2015, there were five pump failures. The notes supplied by the
Company indicate that all failures occurred during time periods when all four of the Company's
pumps were making frequent starts. Staff compared Company records to KEC's transformer
maintenance records. Staff observed a correlation between the Company's record of pump failures
and dates on which KEC noted that its substation breakers had been tripped. On at least one
occasion, KEC staff noted that this failure occurred concurrently with a pump failure, but appears
to have concluded that the pump failure caused the blown circuit breaker and not vice versa. It
was not until after the August 2015 pump failure that the Company contacted an engineering firm,
AEI, to help determine how to reduce the incidence of pump failures. In its report, AEI implied
that the service drop and the transformer have incompatible phase configurations and concluded
that the current utility transformers are undersized. As a result and as indicated in the Company's
response to Commission Order No. 33547, a new pad transforner was installed which Staff
verified was completed in late 2015, but Staff could not veriff that it is large enough to meet pump
house power requirements.
Failure Mode Prevention
Staff believes there are two improvements that should prevent most pump motor failures
like the ones seen by the Company. First, is to employ a circuit breaker designed to
simultaneously disconnect all three phases in the event that any one phase is disconnected. Each
phase of KEC's 75 kVA transformer is protected by a single circuit breaker. Additionally, each of
STAFF COMMENTS JULY 22,2016
the 60 hp well pump's three phases is protected by a single fuse. The well motor will be protected
from damage when any two of these fuses blow. However, when only a single fuse blows, the
load on the remaining phases will increase by approximately 73Yo. This condition is called single
phasing, and is a leading cause of three phase motor failure. When three fuses are used to protect
a motor, they must be properly sized so that in the event that a single fuse blows, one of the
remaining fuses blows before the pump is damaged. This arrangement, using a separate fuse for
each phase, has been permitted by the National Electric Code for many years but will not prevent
all failure modes, and is not considered a best-practice.
Second, the service entrance and the transformer should use compatible three phase
configurations - either the Wye or the Delta. Both methods work well, and have long been used
throughout the United States. However, the two methods are not completely compatible. In
particular, when a Wye transformer is connected to a Delta service entry (or vice versa), failure of
a single phase will cause the load on the remaining two phases to increase by 130% making it
possible that the pump will be damaged before the remaining fuses blow. During the 1990s, when
the well's electrical system was installed, this problem was not fully appreciated, and the National
Electric Code permitted the Company's use of a Delta service entry with KEC's Wye transformer.
This arrangement has since been prohibited in later editions of the code. According to KEC's
engineering manager, this change was also incorporated into the KEC handbook sometime
between the years 2000 and 2002. However, KEC does not require existing Delta connected
service entries to be re-wired and it is unlikely that this change was communicated to the
Company.
Soft Start
Staff does not believe that the installation of a soft start would have prevented every pump
motor failure experienced by the Company. Staff believes the majority of failures were caused by
single phase conditions. Although using a soft start could reduce the 60 hp well pump motor
starting load, it would not reduce the starting load of the other three pumps, making it possible for
any of these pumps to overtax the 75 kVA transformer sufficiently to blow a circuit breaker.
Additionally, Staff believes that a soft start would not mitigate other potential causes resulting in a
single phase condition, such as lightning.
The pump manufacturer recommends a soft start if during start-up, the torque induced by a
submersible pump on the well casing causes the pump to slip or vibrate. This can lead to pump
STAFF COMMENTS JULY 22,2016
bearing or other mechanical component failures. The Company did not report any failure mode of
this kind.
According to the KEC engineering manager, the KEC handbook was updated to include a
soft start requirement for motors larger than 20 hp sometime between the years 2000 and 2002.
This is primarily a benefit to the electric company - not Diamond Bar - by reducing surge-induced
electrical harmonics that can result from rapid starting motors. It is unlikely that this requirement
was communicated to Diamond Bar prior to 2015.
Contamination
The Company provided four Analysis Reports of water samples taken in August and
September,2012. The first two reports indicated the presence of coliform bacteria on the
distribution system (sample taken on August 6) and at Well No. I (sample taken on August 8).
The Company also provided a letter it received from the Idaho Department of Environmental
Quality (IDEQ) regarding the August 6,2012, sample, which directed the Company to provide
additional water samples for testing. IDEQ did not detect contamination at the well or at the
sampling locations on the distribution system in subsequent water samples submitted by the
Company.
Staff contacted IDEQ and obtained additional information. IDEQ sent a letter to the
Company on August 14,2012, that confirmed the presence of coliform bacteria in the system and
required that users be notified of the issue. In response, the Company provided a notice to
customers on August 20,2014. See Attachment A.
Staff reviewed IDEQ data files for the Company's Coliform Sample Summary Results
covering the period January 1,2006 to June 24,2016. Staff discovered that coliform bacteria was
detected in the distribution system again in October and November,2ll2. In DEQ's November 6,
2016 letter, the Company was again directed to notify its customers. The letter mentions that the
agency agreed with the Company's proposed solution to the contamination problem, which was
"to chlorinate and flush the reservoir and distribution system." See Attachment B.
Staff verified that the Company complied with IDEQ's customer notification and
additional sampling requirements as provided under the Idaho Rules for Public Drinking Water
Systems. IDAPA 58.01.08. Based on Staffls review of IDEQ's records, there have been no
contamination problems detected since November 2012.
STAFF COMMENTS JULY 22,2016
RECOMMENDATIONS
Staff believes that the Company's corrective actions should stay consistent with
recommendations by the Company's engineering company, AEI, and be directed toward
decreasing the likelihood of a single phase condition. This includes that:
1. The Company ensure that KEC replaced the 75 kVA transformer with a properly-sized
transformer.
2. The Company install a device that disconnects all phases simultaneously when an
overcurrent condition occurs in any phase to protect against loss ofphase.
3. The Company replace the Delta type service drop with a Wye type service entry that
complies with KEC's current engineering guidelines.
Respecttully submitted this ??i4 Oay of July 2016.
Technical Staff: Michael Morrison
Chris Hecht
i:umisc:comments/diawl 5. ldjhmmcwh addendum comments
STAFF COMMENTS JULY 22,2016
"STATE OF IDAHO
DEPARTMENT OF
ENVIRONMENTAL QUALITY
2'l 10 lronwood Parkway, Coeur d'Alene, lD 83814 [phone]
August 14,2012
Rob Turnipseed
Diamond Bar Water, D1280268
PO Box 1870
Hayden,ID 83835
Subject: Bacteriological Contamination MCL, Diamond Bar, ID1280268
C. L. "Butch" Otter, Governor
Curt A. Fransen, Director
The purpose of this letter is to notify you that confirmation results for total coliform bacteria indicate the presence of
bacteria in the Diamond Bar water supply. The confirmed presence of total coliform bacteria during the month of August
2012 is a maximum contaminant level (MCL) violation. This MCL violation will require public notification to all users
as specified in IDAPA Section 58.01.08.150.02 of the Idaho Rules for Public Drinking Water Systems.
A public notice template that you may use to distribute this notification to your users is enclosed herein; and it is also
available online at:
http ://www. deq. idaho. eov/Applications/SDWISReports/pwsJub_notify_index. cfm
At this site, please click on the box for Tier 2. Therein, the templates to be used are identified as Template 2-l for
unresolved coliform contamination or Template2-2 for resolved coliform contamination.
This notice may be modified by adding detailed information and clariffing facts. However, the public notification issued
must contain the mandatory language for health effects as marked in italics. A copy of the public notice needs to be kept
on record with the water system and with your records. Also, a copy of the notice must be submitted to our office within
ten days of posting or delivery.
Since your bacteriological samples had only total coliform (TC) bacteria present and E coli (EC) absent, the public notice
must be issued as soon as possible, at least within 30 days. The notice should be issued by mail or hand delivery, in
addition to another method, as necessary to reach other water users. If you do not notiff your users, we may issue notice
ourselves and bill you for associated expenses.
It is the responsibility of the water system owner/operator that adequate public notification is issued to all affected
parties. Our experience has been that there is more criticism when the public has not been properly notified than due to
the notice itself. Once the problem has been corrected and you have re-sampled the water system with results of two
consecutive series of uncontaminated samples, it is acceptable to discontinue notification. Please contact DEQ before
removing public notice.
During the month following this contaminated bacteria sample (September 2012) you are required to submit five (5)
routine bacteria samples.
Sincerely,{W
Erik Ketner, R.E.H.S.
Drinking Water Analyst
[e-mail]. gov
File in TRIM: Diamond Bar,IDl280268
Attachment A
Case No. DIA-W-15-01
Addendum Staff Comments
07122/16 Page I of 2
tMpoRTANT INFORMATION.ABOUT YOUR DRINKING WATEB :
''l / tr.
Tests Showed Gotiform Bacteria in Diamond Bar Estates Water Co . "' 3 j ,.. .:.. ,,1/i
Our water system recehtly violated a drinking watgr standard. Although this incident was not an
emergency, as our customers, you have a right to know what happened and what we did to
correcJ this situation.
We routinely monitor for drinking water contaminants. We took one sample to test for the
presenc€ of coliform bacteria during August 2012. One of our samples showed the presence of
total coliform bacteria. The standard is that no more than 1 sample per month may do so.
Whatshould ldo?
o You do not need to boil your water or take other corrective actions. Howearer, if.you have
specific health concerns, consult your doctor.
. lf you have a severely compromised immune system, have an infant, are pregnant, or
are elderly, you may be at increased risk and should seek advice from your health care
providers about drinking this water. Generalguidelines on ways to lessen the risk of
infection by microbes are available from EPA's Safe Drinking Water Hotline at 1-800-
4264791.
What does this mean?
This is not an emergency. lf it had been you would have been notified within 24 hours. Total
coliform bacteria are generally not harmful themselves. *Coliforms are bacteria which are
naturally present in tie environment and are used as an indicator that othen potentially-harmful,
bacbrta may be present. Coliforms were found in more samp/es than allowed and thiswas a
wa rn i ng of pote nti al prabl e ms.*
Usually, coliforms are a sign that there could be a problem with the system's treatment or
distribution system (pipes). Whenever we detect coliform bacteria in any sample, we do follow-
up testing to see if other bacleria of greater concern, such as fecal coliform or E. coli, are
present. We did not find any of these bacteria in our subsequent testing.
What is being done?
Diamond Bar Estates Water proceeded to take 5 additional samples within the distribution
system as required by IDEQ, Further testing showed that this problem has been resolved.
For more information, please contact Office at 208-665-9200 or PO Box 1870 Hayden lD 83835.
*Pldase share this information with allthe other people who drinkthiswater, especially
those who may not have received this notice directty (for example, peopte in apartments,
nursing homes, schools, and husinesses). You can.do this by posting this notice in a public
place or distributing copies by hand or mail.*
This notice is being sent to you by Diamond Bar Estates Water Co.
Water System lD#: 1280268.
Date distrib uted: 8120 I 12.
Attachment A
Case No. DIA-W-15-01
Addendum Staff Comments
01122116 Page 2 of 2
STATE OF IDAHO
DEPARTMENT OF
ENVIRONMENTAL QUALITY
2'l 1 0 lronwood Parkway, Coeur d'Alene, lD 8381 4 (208) 769:1 422 C. L. "Butch" Otter, Governor
Curt A. Fransen, Director
November 6,2012
Robert Turnipseed, Designated Operator
Diamond Bar Estates, ID1280268
PO Box 1870
Hayden, ID 83835
avondalecon@frontier. com
Subject: Bacteriological Contamination MCL, Diamond Bar Estates, ID1280268
Dear Rob:
The purpose ofthis letter is to follow-up our conversation this afternoon regarding coliform detections in three (3) ofthe
five (5) routine total coliform bacteria samples required from the Diamond Bar Estates water system for the month of
November 2012. These results confirm the presence of total coliform bacteria within the distribution system and constitute
a maximum contaminant level (MCL) violation for November 2012.
As discussed, the Idaho Department of Environmental Quality agrees with your approach to chlorinate and flush the
reservoir and dishibution system as a means of resolving the contamination. Please ensure that after chlorinating the
system that no chlorine residual remains in the system prior to collecting future coliform samples.
This MCL violation will also require public notification to all users as specified in IDAPA Section 58.01.08.150.02 of the
Idaho Rules for Public Drinking Water Systems. A public notice template that you may use to distribute this notification to
your users is enclosed herein; and it is also available online at:
http://www.deq.idaho.eov/Applications/SDWlSReportVpws pub notif,/_index.cfm
At this site, please click on the box for Tier 2. Therein, the templates to be used are identified as Template 2-l for
nnresolved coliform contamination or Template 2-2 for resolved coliform contamination.
This notice may be modified by adding detailed information and clarifring facts. However, the public notification issued
must contain the mandatory language for health effects as marked in italics. A copy of the public notice needs to be kept on
record with the water system and with your records. Also, a copy of the notice must be submitted to our office within ten
days of posting or delivery.
Since your bacteriological samples had only totat cifiform (TC) bacteria present and E coli (EC) absent, the public notice
must be issued as soon as possible, at least within 30 days. The notice should be issued by mail or hand delivery, in
addition to another method, as necessary to reach other water users.
It is the responsibility ofthe water system owner/operatorthat adequate public notification is issued to all affected parties.
Once the problem has been corrected and you have re-sampled the water system with results of two consecutive series of
uncontaminated samples, it is acceptable to discontinue notification. Please contact DEQ before removing public notice.
During the month following this contaminated bacteria sample (December 2012) you are required to submit five (5)
routine bacteria samples.
Sincerely,
- .o(J<h-
Erik Ketner
Drinking Water Analyst
[e-mail]
cc: Cristy Tumipseed, Administrative Contact, Diamond Bar Estates [e-mail]
File in TRIM: D1280268 DiamondBar Attachment B
Case No. DIA-W-15-01
Addendum Staff Comments
O7122116 Page I of 2
dJ
IMPORTANT INFORMATION ABOUT YOUR DRINKING WATER
TestS Showed Goliform Bacteria in Diamond Bar Estates Water Co
Our water system recently violated a drinking water standard. Although this incident was not an
emergency, as our customers, you have a right to know what happened and what we did to
correct this situation.
We routinely monitor for drinking water contaminants, We took 5 samples to test for the
presence of coliforrn bacteria during October 2012. 3 out of 5 of our samples showed the
presence of total coliform bacteria. The standard is that no more than 1 sample per month may
do so.
What should I do?e You do not need to boil your water or take other ccrrective actions. However, if you have
specific health concems, consult your doctor.
. lf you have a severety compromised immune system, have an infant, are pregnant, or
are elderly, you may be at increased risk and should seek advice from your health care
providers about drinking this water. General guidelines on ways to lessen the risk of
infection by microbes are available from EPA's Safe Drinking Water Hotline at 1-800-
4264791.
What does this mean?
This is not an emergency. lf it had been you would have been notified within 24 hours. Total
coliform bacteria are generally not harmful themselves. *Coliforms are bacteria which are
naturally present in the environment and are used as an indicator that other, potentially-harmful,
bacteria may be present. Coliforms were found in more samples than allowed and this was a
warning of potential problems.*
Usually, coliforms are a sign that there could be a problem with the system's treatment or
distribution system (pipes). Whenever we detect coliform bacteria in any sample, we do follow-
up testing to see if other bacteria of greater concern, such as fecaf coliform or E. coli, are
present. We did not find any of these bacteria in our subsequent testing.
What !s belng done?
Diamond Bar Estates Water proceeded to take 5 additional samples within the distribution
system as required by IDEQ. Further testing shows that this problem has been resolved.
For more information, please contact the Office at 208-665-9200 or PO Box 1870 Hayden lD
83835.
*Please share this infonnation with allthe other peopte who dink this water, especialty
fhose who may not have received this notice directly (for example, people in apartments,
nursing homes, schools, and businesses). You can do this by posting this notice in a public
place or distributing copies by hand or mail.*
This notice is being sent to you by Diamond Bar Estates Water Co
State Water System lD#: 128A268.
Datedistributed: 11120112.
Attachment B
Case No. DIA-W-15-01
Addendum Staff Comments
O7122116 Page2 of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF JULY 2016,
SERVED THE FOREGOING ADDENDUM COMMENTS OF THE COMMISSION
STAFF, IN CASE NO. DIA-W-15-01, BY MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
ROBERT TURNIPSEED
DIAMOND BAR ESTATES
WATER CO
PO BOX 1870
HAYDEN ID 83835
E-MAIL: avondalecon(4)fi:ontier.corn
ALDEN HOLM
9446 W FAIRVIEW AVE
BOISE ID 83704
E-MAIL : alden(4)treasurevalleycpa. com
SECRETARY
CERTIFICATE OF SERVICE