RE: Meter Installation - Section 2 Comments

I have the following important safety related comments regarding Section 2.

In paragraph II.1.22, the "Auto Valve" was mentioned as part of "Electrical
Hazards" which "Functional in the field the auto valve can safely be removed
from the meter installation."

I have known these devices as "Meter Protectors" when in fact they are
transformer surge arrestors.  They are indeed safety hazards.  One cannot
tell by looking at the valve that it is "Functional" therefore one would not
know if it can be safely removed.  The assessment of the auto valve requires
the assessment of the rest of the electric distribution equipment for that
service point.  The auto valve is part of the electric distribution system
and is therefore the responsibility of the UDCs.  For safety reasons, the
UDC should be the only entity servicing this device and not the MSP.  Auto
valve failures should be reported to the UDC so that the UDC can remove or
replace them.

For new installations, I would also suggest that the UDCs move this device
away from the meter.  These are pretty dangerous devices which can catch on
fire.  They could destroy the meter or be a safety hazard to the MSP if they
are in the metering compartment.

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Eugene C. Kong P.E.
PG&E Energy Services
345 California Street, 32nd Floor
San Francisco, CA  94104
Tel: 415-733-4643
Email: eugene.kong@pgees.com
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"PG&E Energy Services is not the same company as Pacific Gas and Electric
Company, the utility.  PG&E Energy Services is not regulated by the
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