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HomeMy WebLinkAbout20240401Staff 22-26 to FLS.pdf RECEt/IED Nbnday,April 1,2024 2:34:07 PM IDAHOPLHIC UTILITIES C T\/MSRON CHRIS BURDIN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 IDAHO BAR NO. 9810 Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) CASE NO. FLS-W-24-01 OF FALLS WATER CO.,INC. FOR ) APPROVAL OF A REPLACEMENT WELL ) FOR ITS MORNING VIEW SYSTEM ) SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO FALLS WATER CO., INC. Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Chris Burdin, Deputy Attorney General, requests that Falls Water Co., Inc. ("Company")provide the following documents and information as soon as possible, but no later than MONDAY, APRIL 15, 2024.1 This Production Request is to be considered as continuing, and the Company is requested to provide,by way of supplementary responses, additional documents that it, or any person acting on its behalf, may later obtain that will augment the documents or information produced. Please provide answers to each question, supporting workpapers that provide detail or are the source of information used in calculations, and the name,job title, and telephone number of 1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s attorney at(208)334-0314. SECOND PRODUCTION REQUEST TO FALLS WATER CO., INC. 1 APRIL 1, 2024 the person preparing the documents. Please also identify the name,job title, location, and telephone number of the record holder. In addition to the written copies provided as response to the requests, please provide all Excel spreadsheets and electronic files with formulas intact and enabled. REQUEST NO. 22: According to the Attachments 1, 2, and 3 in the Company's response to Production Request No. 8, the total annual water production for the Morning View system was 135.15 Acre-feet("AF") in 2023, which is a decrease from 146.14 AF in 2022 and 145.54 AF in 2021. Please explain why total annual water production decreased in 2023 from 2022 and 2021. Additionally, please explain if the Company expects the annual water production to trend down from 2023 water production levels. REQUEST NO. 23: The Company's response to Production Request No. 4 states: "The SCADA system will be set up to alternate the run time on the two wells to ensure that the wells are operational." Please provide the total estimated cost of installing the SCADA system on both Well Nos. 3 and 4. Additionally, please explain if the estimated costs of the SCADA system on Well No. 4 are included in the Project's cost estimate. REQUEST NO. 24: According to the "Morning View Water Company PER& Facility Plan" (Attachment 1 to the Application) at 22: the Company"will screen the new well, so the use of a sand separator is not anticipated." Please explain and provide evidence for the need of a new sand separator for the proposed Well No. 4, since Aspen Engineering's recommendation in the Company's Facility Plan was that the sand separator is not necessary. REQUEST NO. 25: In response to Staff s Production Request No. 19, the Company listed several significant challenges it encountered regarding repairs of the existing Well Nos. 1 and 2 due to excessive accumulation of sand, mud, and rock. In this regard, please answer the following: SECOND PRODUCTION REQUEST TO FALLS WATER CO., INC. 2 APRIL 1, 2024 a. Please explain the risk of excessive accumulation of sand,mud, and rock by drilling the proposed Well No. 4 at the same location as existing Well Nos. 1 and 2; b. If there is a risk,please explain how the Company will mitigate it; and c. If there is a risk, please explain if there are alternative locations that should be explored. REQUEST NO. 26: Please provide detailed information including but not limited to make, model, capacity, specifications, etc. for the new VFD that the Company is planning to install for the anticipated 60 hp pump of the proposed Well No. 4. DATED at Boise, Idaho, this I"day of April 2024. IUA- Chris Burdin Deputy Attorney General I:\UtiPity\U USC\PRDREQ\FLS-W-24-01 PR#2 docx SECOND PRODUCTION REQUEST TO FALLS WATER CO., INC. 3 APRIL 1, 2024 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE ON THIS DAY OF APRIL 2024, SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO FALLS WATER CO, INC., IN CASE NO. FLS-W-24-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING: PRESTON N CARTER ERIC W. NELSEN MORGAN D GOODIN SENIOR REGULATORY ATTORNEY GIVENS PURSLEY LLP NW NATURAL 250 SW TAYLOR ST. 601 W BANNOCK ST PORTLAND, OREGON 97204 BOISE ID 83702 E-MAIL: eric.nelsenaa,nwnatural.com E-MAIL: prestoncarter(aa,givenspursley.com morgangoodin(a� ivenspursley com stephaniew ,givenspursley.com K. SCOTT BRUCE FALLS WATER CO., INC. 2180 NORTH DEBORAH DRIVE IDAHO FALLS, ID 83401 E-MAIL: scottl(a,fallswater.com P TRICIA JORD ,'SECRETARY CERTIFICATE OF SERVICE